Spokane County Request for Supplemental EIS on Fairchild Air Force Base

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SPOIW\lE ~~--~. ~-~-~ Col}{IY OFFICE OF COUNTY COMMISSIONERS

Tooo MIELKE, lsT DISTRICT. SHELLY O'QuINN, 2ND DISTRICT. AL FRENCH, 3RD DISTRICT

March 31 , 2014

The Honorable Kevin K. Washburn Assistant Secretary - Indian Affairs U.S. Department of the Interior MS 3071 MIB 1849 C Street, N.W. Washington, D.C. 20240

Re: Request for Supplemental Environmental Impact Statement to Address Unanswered Questions Regarding Fairchild Air Force Operations

Dear Assistant Secretary Washburn:

On behalf of Spokane County, the Board of County Commissioners is writing to request that the Bureau oflndian Affairs ("BIA") prepare a supplemental environmental impact statement ("EIS") to address outstanding questions regarding the safety of the Spokane Tribe's proposed casino-resort project in Airway Heights, Washington ("STEP Project").

Based on information the County has obtained pursuant to Freedom of Information Act ("FOIA") requests filed with the U.S. Air Force and BIA, as well as reports prepared by the Spokane Tribe 's consultant that were not included in the final environmental impact statement ("FEIS"), it appears that a substantial percentage of Fairchild Air Force Base ("F AFB") operations are conducted directly over the proposed site of the Step Project. In fact, according to the Air Force, the STEP Project lies directly beneath the pattern for Visual Flight Rules ("VFR") operations, the local sortie traffic pattern- i.e., the pattern associated with training operations, including touch and goes- and the radar pattern for runway 05 .

Guidance issued by the Department of Defense ("DoD") in 2011 and Washington State both recommend that "Accident Potential Zones" ("APZs") for military installations be modified to reflect actual operations at specific air installations, both to improve safety and to minimize encroachment conflicts. The Air Force's 2007 Air Installations Compatibility Use Zone ("AICUZ") Study for F AFB, however, does not reflect the operations the Air Force has described in the course of commenting on BIA's EIS for the STEP Project. Similarly, the Joint Land Use Study ("JLUS") adopted the FAFB ' s 2007 APZs in 2011 without taking into account actual F AFB operations. Because the FEIS for the STEP Project likewise adopted the 2007 AICUZ APZs without further consideration, the impacts of the STEP Project on FAFB operations and the public safety risks of allowing a high-density facility to be built at the site are not accurately represented in the FEIS.

1116 WEST BROADWAY AVENUE SPOKANE, WASHINGTON 99260-0100 (509) 477-2265

March 31 , 2014 Page 2

The County believes that BIA should deny the Tribe's requested gaming determination without further analysis based on the overwhelming opposition to the STEP Project and the lack of any enforceable agreement with the County. If, however, the Department is considering taking the unprecedented step of approving an off-reservation gaming request despite strong County opposition and the objections of numerous political officials and the business community, a supplemental EIS is needed to address the questions that have been raised regarding the nature and scope of F AFB operations and whether the AP Zs created in 2007 are accurate in light of current operations.

DISCUSSION

A supplemental EIS is appropriate where there are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts. See 40 C.F.R. 1502.9(c). The new information provided by the Air Force, combined with comments prepared by the Tribe's own expert consultant, underscore the need to prepare a supplemental EIS in this case.

During the course ofBIA's preparation of the preliminary FEIS, Air Force and FAFB representatives met with BIA to discuss F AFB operations and various concerns F AFB has with respect to the STEP Project. Those concerns relate to noise issues, health and safety impacts related to noise, vibrations, potential accidents and emissions, the proximity of the F AFB to existing traffic patterns and the inability of F AFB to change those operations, light pollution and glare, wildlife and the potential for bird strikes and other conflicts. The County was able to obtain through FOIA some of the materials the Air Force provided to BIA, including internal comments, although most of the documents produced were heavily redacted. Two issues are clearly evident from the umedacted materials produced. First, the conflicts that F AFB has identified in its internal comments are more extensive than what is represented in the FEIS. Second, based on the information provided, it appears that the APZs in the 2007 AICUZ should have been modified to reflect actual operations at F AFB.

The attached power point presentation illustrates these points, which are discussed in more detail below. See Exhibit 1.

1. Background on AICUZ Program

In 2007, FAFB prepared an Air Installations Compatibility Use Zone ("AICUZ") report to promote compatible development within the AICUZ area of influence and to protect Air Force operational capability from the effects of land use incompatible with aircraft operations. DoD established the AICUZ Program in the early 1970s to balance the need for aircraft operations and community concerns over aircraft noise and accident potential. The goal was to encourage local planning departments to adopt AICUZ noise zones and APZs into development criteria around military installations to protect them from encroachment, or any non-Air Force action that inhibits, curtails, or possesses the potential to impede the performance of Air Force operations.

March 31, 2014 Page 3

Historically, the Air Force has focused on the noise impacts of Air Force operations. As noted in the Air Force Handbook 32-7084, 1 " [p ]roblems result when complaints over the effects of aircraft operations (e.g. noise, low overflight, etc.) lead to operational changes which negatively impact the flying mission. Incompatible encroachment has been a contributor to the cessation of flying mission and base closures." Id. 1.1.1. Generally speaking, "[m]ost complaints [regarding Air Force installations] are related to noise generated by aircraft operations." Id. 1.4.5. For this reason, most Air Force AICUZ reports devote tremendous effort to developing accurate noise contour maps of present and future operations to discourage off-base development that would result in conflicts with military operations and undermine the operational integrity of the military installation.

The AICUZ Program also includes information regarding areas of heightened risk associated with aviation accidents, which are designated through identification of Clear Zones ("CZs") and APZs. The AICUZ Program developed generic CZs and APZs using studies of historic accident and operations data throughout the military to determine areas that have a higher risk of accident. Those studies showed that most aircraft mishaps occur on or near the runway or along the centerline of the runway, within certain set distances based on the type of runway involved. Land uses that concentrate large numbers of people-such as apartments, churches, malls and schools-are not recommended in CZs and APZs. In fact, within CZs, most uses are incompatible with military aircraft operations. Within APZ I and APZ II, the Air Force encourages local jurisdictions to prohibit or avoid people-intensive uses because of the greater risk in these areas.

2. Identification of APZs

The designation of AP Zs and Clear Zones for runways at military air installations is prescribed in DoD Instruction 4165.57.2 For Class B runways such as FAFB's, DoD Instruction 4165.57 establishes a generic model that includes a CZ that is 3,000 feet long by 3,000 feet wide and two APZs of diminishing but still heightened risk, the first, 5,000 feet long by 3,000 feet wide, and the second, 7,000 feet long by 3,000 feet wide. These zones are centered along the centerline of the runway. DoD Instruction 4165.57 at 15 and 9. See Figure 1 (DoD Instruction 4165.57 Appendix 1 to Enclosure 3, at 15).

1 Air Force Handbook 32-7084, AICUZ Program Manager's Guide (March 1999) available at: http://www.macdill .af.mil/shared/media/document/ AFD-070306-023 .pdf. 2 Department of Defense, Instruction 4165.57, Air Installations Compatible Use Zones (May 2, 2011) available at: http://www.dtic.mil/whs/directives/corres/pdf/4165 57p. pdf.

March 31, 2014 Page4

Figure 1

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Instruction 4165 .57, however, also states that the depiction of the CZ and APZs is a "nominal representation" and that the standard zones are "guidelines only." DoD Instruction 4165.57 at 15 and 9. The Instruction states that APZs may be modified to conform to multiple flight tracks and local conditions, including:

1) Where multiple flight tracks exist and significant numbers of aircraft operations are on multiple flight tracks, modifications may be made to create APZs that conform to the multiple flight tracks.

2) Where most aircraft do not overfly the APZs, modifications may be made to alter the straight AP Zs shown in [Figure 1] and adjust them to conform to the actual lines of flight.

3) Where other unusual conditions exist, modifications may be made to alter APZs as necessary.

DoD Instruction 4165 .57 at 9-10. The Instruction states that AP Zs "can follow major flight paths including curved flight paths." DoD Instruction 4165.57 at 15 n. 2. APZs may also extend far beyond the nominal overall dimensions (3,000' x 15,000') set forth in the Instruction. See, e.g., Exhibit 2.3

3 AICUZ Study Update for Marine Corps Air Station Miramar, California, Fig. 4-2 at 4-4 (March 2005) available at: http://www.miramar.usmc.mil/aicuz.asp.


Washington State has issued similar guidance, the Airports and Compatible Land Use Guidebook,4 relying heavily on the California Airport Land Use Planning Handbook, published in 2002 by the California Department of Transportation, Division of Aeronautics.5 The factors that Washington State uses to determine which areas around an airport need to be protected from incompatible land uses are primarily aeronautical factors, including aircraft operations, historic accident data, and flight tracks or radar tracks (if available). WSDOT Guidebook at 2-21. For land use planning purposes, Washington State identifies six safety zones, including a Runway Protection Zone, where the greatest concentration of accidents occurs, an Inner Approach/Departure Zone, an Inner Turning Zone, Outer Approach/Departure Zone, Sideline Zone and a Traffic Pattern Zone. Id. at E-10 - 11. The guidance notes that "[ e Jach airport is unique. Thus, it is essential to adjust safety zones to fit the airfield configuration, usage characteristics, and other factors associated with a specific airport." Id. at E-11 (emphasis added) . Specific adjustments include those for traffic patterns, approach type, and one-sided traffic patterns.

With respect to military runways, the California Airport Land Use Planning Handbook states that the APZs for military runways for large aircraft are based on the assumption that flight routes are predominately straight-in and straight-out flight routes, which the planner "must modify for turning routes and traffic pattern activity." CDOT Handbook at 9-40 (Fig. 9L); see also id. at 9-48.

3. The APZs for FAFB Have Not Been Modified to Reflect Current Operations

The designated AP Zs for F AFB used in the FEIS replicate the generic configurations depicted in the DoD Instruction, rather than conforming to actual operations at the Base. See Figure 2 (FEIS Fig. 3.9-4).

4 Washington Department of Transportation, Airports and Compatible Land Use Guidebook M 3074.00 (January 2011) ("WSDOT Guidebook") available at: http://www.wsdot.wa.gov/aviation/Planning/ACLUguide.htm. 5 California Department of Transportation, Division of Aeronautics, California Airport Land Use Planning Handbook (January 2002) ("CDOT Handbook") available at: http: //www.san.org/documents/aluc/California _ ALUC _ Handbook.pdf.


Figure 2

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various tracks, 7 deviations from those tracks, local prevailing winds, or aircraft accidents at F AFB. Information made available by F AFB itself, however, strongly supports the modification of the nominal AP Zs to conform to local flight patterns, especially on the northeast (downwind) end ofFAFB's main runway.

Figure 3 is a depiction of F AFB flight paths created by the Air Force from radar tracks from one week in October 2010 (when over half of Fairchild's fleet was deployed overseas). As noted in the caption, the racetrack pattern is the Visual Flight Rule ("VFR") Pattern and the straight-in tracks are the finals of the instrument approaches. The location of the STEP Project is labeled and shown as a superimposed red square. In addition, the location of the designated AP Zs and Clear Zone are discernible beneath the overlay of radar tracks. What is immediately apparent is that the location of the STEP Project is directly below FAFB's most heavily used training flight pattern. Furthermore, given the prevailing winds, the location is directly below the downwind tum, the most hazardous portion of the pattern, especially during takeoffs and landings.

Figure 3

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7 The Noise Technical Report for the Fairchild Air Force Base Joint Land Use Study projects up to 200 arrivals, departures, and closed patterns per day. HmTis Miller Miller & Hanson, Inc., HMMH Rep01i No. 303020 at 6 (Nov. I I, 2008)(Table 6) available at: http ://westplainslives.files.wordpress.com/20 I 2/03/noisetechrpt.pdf. Under this projection, there would be up to 73,000 operations per year at FAFB.


Figure 4 illustrates that a modification of the APZs to follow actual lines of flight would completely encompass the casino location. The dashed red lines have been drawn to conform to the most heavily trafficked area of the curved flight tracks. The curved area outlined by the dashed red lines retains the nominal dimensions of 3,000' in width and 15,000' in overall length, and thus is a conservative estimate of the area appropriate for designation as an APZ. Figure 5 shows the same curved area on a different base map to more clearly show the relationship of the conforming area to the location of the proposed casino.

Figure 4

Figure 5 STEP Project: Proximity to Airport Overlay Zones .. Subjtoc1Proptrtie.

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If the existing APZs were modified per Instruction 4165.57 to conform to existing lines of flight, the location of the proposed casino would be entirely encompassed within APZ II, an area of measurably higher risk and thus unsuitable for the proposed project. This conclusion is confirmed by the history of fatal crashes at Fairchild. There have been four major accidents within two miles of the proposed location, including one mid-air collision of two bombers that rained pieces of debris weighing hundreds of pounds in the immediate vicinity of the proposed location, and resulted in one of the bombers crashing to the ground just blocks away from the proposed location. 8

In addition, serious questions are raised by the response of Madison Government Affairs, Inc. (Madison), the Spokane Tribe's own consultant on Air Force operations, installations, and basing issues, to the flight pattern and density information made available by F AFB after release of the FEIS. Madison's original rep01i, completed shortly after issuance of the FEIS, noted that FAFB had expressed concern about the potential for an aircraft accident at the proposed location, but concluded that the location must not be of high accident potential or else it would have been designated an APZ.9 Shortly after issuance of the FEIS, FAFB made public a slide presentation highlighting its concerns and presenting flight pattern information showing a high density of flight tracks over the proposed location. Exhibit 3.10 Madison's response to these slides, attached as Exhibit 4, 11 is startling: "It is our opinion that the briefing does not accurately portray flight paths, flight activity, and normal adherence to aircraft operational parameters-the very basis of flight safety regardless of whether it is military or civilian aviation." Exhibit 4 at 1-2. Yet it is indisputable that these data are the data that the F AFB produced to show actual operations at F AFB, and there is no reason to believe that the radar tracks were somehow manufactured.

The basis for Madison' s disbelief appears to be its concerns regarding the safety of the existing operations:

Overall, the briefing depicts flights over the proposed STEP property in locations and heights that are inconsistent with normal visual flight rule (VFR) operations, instrument flight (IFR) rules, and basic flight safety. Additionally, these flight paths are not consistent with Air Force publications, such as Wing Safety Officer's "Mid Air Collision Avoidance Pamphlet" (used by 92nd ARW aviators

8 Camden, J., "Witnesses Recall B-52 Collision," The Spokesman Review. September 7, 2008 . 9 Madison Government Affairs, Inc., "Spokane Tribe oflndians STEP Assessment Report" at 30 (February 2013), available at: http://www.madisongov.net/downloads/spkane-indians.pdf. 1 Figure 3 is Slide 6 of this presentation. Based on a redacted version of this presentation that was provided by the Air Force in response to the County's FOIA request, this presentation was included in the comments on the preliminary draft of the FEJS that were submitted to the BIA by the Air Force. 11 Letter from Paul J. Hirsch, President of Madison Government Affairs, Inc., to Rudy J. Peone, Chairman of the Spokane Tribal Council (February 27, 2013), available at: http://www.madisongov.net/downloads/response.pdf.

March 31 , 2014 Page 10

and published on the internet for other pilots' notification of Fairchild patterns, flight safety interests, etc.), the Air Installation Compatible Use Zone (AICUZ) of October 2007, and the Joint Land Use Study to cite three examples.

Slide #5 depicts a VFR flight pattern that is inconsistent with normal Air Force-wide operations and is questionable at best. At worst, if flown as shown, the pattern is both unsafe and blatantly dangerous. The depicted pattern, which is shown to overfly the property, would require a very 'tight' pattern with a turn to final/base leg far too close to the runway .... If the actual flight path occurred as depicted, the aircraft would be at an unsafe altitude (100-150' above the ground) and at dangerously slow airspeeds as it completes its turn to align with the runway, and with insufficient time/distance to slow to proper final approach/landing speed if maneuvering speed were maintained in the turn. This is a highly aggressive pattern that would leave no room for error or unexpected occurrences, such as a stronger crosswind than was forecast or expected.

Exhibit 4 at 1-2. Of course, what the Air Force determines is necessary for training to ensure military readiness is not an issue for BIA to consider. In fact, Madison's objections only underscore that the STEP Project is in the middle of what appears to be aggressive training maneuvers the F AFB has determined are needed and where the risk of accident is higher than what is reflected in the FEIS.

Madison ultimately makes no attempt to reconcile its analysis of the flight lines depicted in Slide 5 with the radar track evidence shown in Slide 6, which shows a high concentration of flight paths actually overflying the proposed location. Instead, Madison's response again concludes, with circular logic, that:

The potential for an aircraft mishap must be very low or non-existent in the area of STEP because ifthere was a concern the Air Force would have taken precautions in the past based on flight patterns. The only areas of concern appear to be located at the ends of Runways 23 and 5 where there are APZs. In the history of Fairchild AFB there has not been one recorded mishap in the area of STEP. [This is factually incorrect; see supra at footnote 8.] The prudent person would have to presume that ifthe Air Force ... was ever concerned about flight safety over the area where STEP is proposed that the property would have been identified as such.

Exhibit 4 at 3. Madison' s response to the Air Force's information makes clear that there are either serious questions about the accuracy of the information provided by the Air Force and relied upon by BIA, or there are serious aircraft accident risks at the proposed location. Either conclusion requires a supplemental EIS to fully analyze the true risks at the proposed location.


The need to modify the existing APZs at Fairchild has not been analyzed. Neither the 2007 Fairchild AICUZ Study nor the FEIS considered that the proposed location is within an area that should be properly designated as APZ II or took into account the questions that Madison's analysis raises. The casino-resort complex is expected to have a maximum occupancy of over l 0,000 people. The potential loss of life, should an aircraft accident occur at the proposed location, is far too great to allow this project to go forward before all the risks are understood.

Conclusion

The County remains deeply concerned that the risks the proposed casino location presents to public safety, and to the safety and viability of military operations at Fairchild, have not yet been fully assessed. The County respectfully requests that no decision be made on the Tribe' s requested gaming determination until these risks have been fully evaluated in an updated AICUZ study and a supplemental EIS . If these risks cannot be fully resolved, the gaming determination should be denied.

Very truly yours,

k7~-~vG TODD MIELKE~ice Chair

Encl.

cc :

Hon. Jay Inslee, Governor of Washington Stanley Speaks, BIA NW Regional Director Spokane Tribe of Indians Kalispel Tribe of Indians City of Spokane Greater Spokane Incorporated

Exhibit 1

Presentation

THE PROPOSED SPOKANE TRIBE'S CASINO AT AIRWAY HEIGHTS: ARE THE REAL RISKS NOT BEING PROPERLY ASSESSED? PREPARED FOR SPOKANE COUNTY, WASHINGTON PERKINS COIE LLP

The Environmental Impact Statement for the STEP Project Does Not Accurately Assess Risks to Public Safety The Accident Potential Zones used in the EIS for the STEP Project do

not reflect actual air traffic patterns at Fairchild Air Force Base (FAFB).

Based on data provided by FAFB, it appears that the site of the STEP Project falls within what should be designated APZ II or under Washington State law, Zone Ill, an area of heightened accident potential where high density uses are prohibited.

The STEP Project should be denied as detrimental to the Tribe and the surrounding community based on comments submitted.

Alternatively, a supplemental EIS should be prepared that takes into account actual flight patterns at FAFB to accurately assess risk.

What Are Accident Potential Zones {APZs)? Using military accident data collected between 1968 and 1972, an

AF study determined that 753 of aircraft accidents occur within a 3,000-foot wide corridor along a runway and extending out from the runway centerline for a distance of 15,000 feet.

Three zones were established based on the accident study to support the Department of Defense's Air Installations Compatibility Use Zone (AICUZ) Program: the Clear Zone (CZ), Accident Potential Zone I (APZ I) and Accident Potential Zone II (APZ II): The Clear Zone is measured along the extended runway centerline beginning at the

runway end, and is 3,000 feet long and wide for Class B Air Force runways like FAFB. APZ I starts at the end of the clear zone and is centered and measured on the extended

centerline, 3,000 feet wide and 5,000 feet long. APZ II starts at the end of APZ I and is centered and measured on the extended

centerline, 3,000 feet wide and 7,000 feet long.

Appropriate Land Uses of These Three Zones Are Highly Limited The clear zone, by definition, should be clear of structures to the

maximum extent practicable.

"[U]ses that concentrate people in small areas are not acceptable" in APZ I.

"High density functions such as multi-story buildings, places of assembly (theaters, churches, schools, restaurants, etc.), and high density office uses are not considered appropriate" in APZ II.

"High people densities should be limited to the maximum extent possible."

The building footprint for a shopping malls or centers will be considered as a single entity in all land use compatibility analysis .... Due to the concentrations of people associated with shoppin~ malls and centers, these land uses are considered as incompatible within all Accident Potential Zones."

Air Force Handbook 32-7084 (Mar. 1999)

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"Where multiple flight tracks exist and significant numbers of aircraft operations are on multiple flight tracks, modifications may be made to create APZs that conform to the multiple flight tracks."

Department of Defense Instruction 4165.57 (May 2, 2011)

For Local Land Use, Authorities Should Conform the Air Force's APZs to Reflect Actual Operations The depicted APZ zones used by the military assume

that flight tracks are straight-in and straight-out.

Modifications may be made to alter APZs and adjust them to conform to the line of flight if different or additional tracks are used on a regular basis.

Consideration should be given to providing safety zones lateral to the runway if these areas are not fully contained within the boundaries of the military facility.

"The safety compatibility criteria suggested in AICUZ guidelines tend to represent minimum standards {more so with respect to noise than safety)."

California Airport Land Use Planning Book (2002, 2011)

Washington Conforms Safety Zones to Actual Flight Patterns

Washington relies on the California Airport Land Use Planning Handbook (2002).

"It is essential to adjust safety zones to fit the airfield configuration, usage characteristics, and other factors associated with a specific airport."

Adjustments are made based on runway length, approach type, fleet mix, traffic pattern location.

WSDOT Airports and Compatible Land Use Guidebook M 307 4.00 (January 2011 ); COOT California Airport Land Use Planning Handbook (January 2002).

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The EIS Uses the Generic Air Force APZ, Which Assumes Straight-In/Straight Out Flight Routes

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Actual Air Traffic Patterns at FAFB Are Not Straight-In/Straight-Out

Radar Pattern, - 5000' MSL VFR Pattern - 3700' MSL Local Climb Out - 290

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Common Traffic Patterns at FAFB Pass Directly Over the STEP Project

Created by Jeff Johnson, Deputy Director FAFB Encroachment Management Team (2013)

"Fairchild aircraft must turn north (over the proposed site) to avoid Spokane International Airport approaches."

"Aircraft flights below l 000 ft over the Project Site"

"Under the VFR Final Turn to RWY 23 ( 600-650' AGL)"

"Under Ground Track for Departures for Rwy 05 (700-850' AGL)"

"Under the Circling Approach Track for RWY 23 (558' AGL)"

Radar Tracks from October 2010 Produced by FAFB to BIA

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The STEP Project Is Located in APZ II, If APZs Are Conformed to Actual Operations

STEP Project: Proximity to Airport Overlay Zones - Subject Properties o iim:::o.i2siic:::oiii.s---1c====1.iiis ___ llii2MUos

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The Navy Conforms APZs to Actual Flight Patterns Where the flight track departs the centerline prior to

crossing the clear zone, APZ-1 will be 5,000 feet in length and APZ-11 will be 10,000 feet in length, measured from the point the flight path leaves the runway centerline.

Where the flight track passes through the side of the clear zone, APZ-1 will be 5,000 feet in length and the length of APZ-11 will be the difference between the total length of the clear zone and APZ-1 and II ( 15,000 feet) less APZ-1 and the distance the flight track traverses the clear zone.

Op Nov Instruction 11010.36 (Oct. 9, 2008)

Why Don't FAFB's APZs Match Actual Flight Patterns?

The 2007 Fairchild AICUZ follows the 1999 Air Force Handbook 32-7084 and does not include a Flight Tracks Map or a Separate Accident Potential Zones Map.

The Air Force AICUZ program focuses on avoiding conflicts from noise complaints and leaves risk assessments largely to local planning processes.

The Air Force not as aggressive about land use as Navy, due to siting in more remote locations.

AF Statements on the Preliminary Final EIS Confirm that the STEP Project Is Within Current Flight Tracks "Due to air traffic from neighboring Spokane

International Airport to the south, Fairchild AFB is limited to conducting flying operations to the north of its runways, leaving only 503 of the airspace normally available for closed pattern flight activity in the proximity of the airfield."

"The project site is located adjacent to and directly below established flight patterns for Fairchild AFB."

The AF's Comments Indicate That There Are Serious Risks, Which Current APZs Do Not Reflect

~J Spokane Tribe Economic Project .,.f (STEP)

AF Position = Neutral AF Concerns vetted through EIS Process

Aircraft flights below 1000 ft over the Project Site Noise Complaints

Light Pollution from the Site {Pilot's Night Vision) Proximity to FAFB Aircraft Traffic Patterns

Under the VFR Final Turn to Rwy 23 (600-650' AGL) Under Ground Track for Departures for Rwy 05 (700-850' AGL) Under the Circling Approach Track for Rwy 23 (558' AGL)

Large Concentration of People in Proposed Buildings Potential for Aircraft Crash/Mishap

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Reading Between the Lines: FAFB Operations Are Constrained and the STEP Project Creates Additional Problems "Air Force reaffirms its position that Interior consider the entirety of the record

before it to include the JLUS recommendations as part of its decision-making."

"Request ... clarification of the Fairchild flight pattern limitations, and inability to modify operations to avoid the proposed site."

"[DJ ue to the current airspace and flight track limitations, [the AF] will need to continue to fly existing patterns, which will generate high noise levels as pilots fly the closed patterns and conduct approach and departure flight operations."

"Recognizing that communities are often left with little control over what is built on tribal lands, it is well within Interior's scope of authority to take these types of issues (aka, "strategies") (e.g., land use planning and encroachment) into consideration in its decision making as a predicate to what may eventually take place or may be permitted on referenced triba l lands."

Conclusion Project Denial on the Basis of the Existing Record:

The STEP Project will be detrimental to the surrounding community and the Tribe by further constraining FAFB operations, siting high-density uses in an area where there is a heightened risk of accident, and generating light impacts that cannot be mitigated in all conditions.

Prepare a Supplemental EIS to Address Actual FAFB Operations: A supplemental EIS is needed, if the STEP Project is not immediately denied, to address the information the Air Force has provided about actual flight operations after the FEIS was complete.

Exhibit 2

MCAS Miramar MCAS APZs

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SANTEE

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MCAS MIRAMAR

Figure 4-1 MCAS Miramar APZs and Aircraft Mishap History

/\./ MCAS Boundary

D Accident Potential Zone II D Accident Potential Zone I E c1earZone

Primary Surface

D Helipad APZ I O c1earZone Primary Surface

Crash Sites

Note: This map was generated by developing APZs based on OPNAVINST 11010.368. They were based on proposed flight tracks obtained from the 1995 Wyle Noise Study. In several cases, the APZs were extended based on historic accident data , airspace constraints and operational conditions from 19722004. APZs were created based on the following flight tracks which have over 5.000 annual operations. 4RS1, 4RS2, 4RJ2, LF1, LT2 and E20H.

1.5 0 1.5 E--3 I I

Scale in Miles

Exhibit 3

F AFB APZ Slides

92d Air Refueling Wing

Environmental Impact & Community Relationships

Mr. Jeff Johnson Deputy, 92 Mission Support Group

Director, FAFB Encroachment Management Team

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Environmental Impact & Community Relationships

Fairchild AFB has positive working relationship with planning elements of:

Spokane County City of Spokane City of Airway Heights Spokane International Airport {SIA)

2009 Joint Land Use Study Cooperation balanced zoning heights adjacent to base

between Fairchild mission and community dev. Base involvement in SIA proposed second runway USAF Cooperating Agency participation with Spokane

Tribe Casino Environmental Impact Statement 2

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Fairchild AFB/Spokane International Class C Airspace

~2~ Excludes Spokane ? P-2\ I sPO~ International Airport

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~\ ,i . ... ~, b~ \,.J Fairchild Tower & Spokane Tower Airspace

... / "~2"'.. Fairchild aircraft must turn north (over the proposed site) to avoid Spokane International Airport approaches

5 NM Radius

4500 Surface

1/2 NM

1GEG

3500 Surface

.9 NM

Note: Runway 23 is the designated calm wind Runway (

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f(adar,Pattern :. , (S,000' .MSL) .

(2,539' f)bove R/W)

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Fairchild AFB flight paths (radar tracks) from October 2010. The race track pattern is the Visual (VFR) Pattern and the straight in tracks are the finals of the instrument approaches.

6

~J Spokane Tribe Economic Project {STEP)



Light Pollution from the Site (Pilot's Night Vision) Proximity to FAFB Aircraft Traffic Patterns



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Exhibit 4

Madison Response

Madison Government Affairs Inc. 444 North Capitol Street, N.W., Suite 601

Washington DC 20001

Spokane Tribe of Indians Mr. Rudy J. Peone, Chairman Spokane Tribal Council 6195 Ford-Wellpinit Road Wellpinit, Washington 99040

Dear Chairman Peone:

Phone 202.347.1223 Fax 202.347.1225

February 27, 2013

On Monday, February 4, 2013 I received an email from Mr. Jeff Johnson, Director of Fairchild AFB Encroachment Management Office, 9211d Air Refueling Wing (ARW). Attached to the email were 8 slides, titled Environmental Impact & Community Relations. These slides are similar to the slides that Mr. Johnson and Colonel Newberry, 9211d ARW /CC, briefed to Madison Government Affairs (MCA) on our visit to Fairchild AFB in October 2012 and which we had requested at tl1at time. I cannot attest that they are the exact same slides briefed to us on October 1Qth. But it did take four months for the 9211d ARW to gain permission to release the slides.

It is my understanding that Mr. Johnson presented these slides to you at your offices on Wednesday February 6, 2013. The referenced slides are enclosed. In discussions following the receipt of the 9211d ARW slides, you asked MCA to prepare our reaction to the information contained therein. While this is not part of our original agreement to accomplish a STEP Assessment Report, MCA agreed to your change order request. Below is the Madison Government Affairs (MCA) response to the 9211d Air Refueling Wing (ARW) slides sent to me by Mr. Jeff Johnson.

It is our opinion that the briefing does not accurately portray flight paths, flight activity, and normal adherence to aircraft operational parameters - the very basis of flight safety regardless of whetl1er it is milita1y or civilian aviation. Overall, the briefing depicts flights over the proposed STEP property in locations and at heights that are inconsistent with normal visual flight rule (VFR) operations, instrument flight (IFR) rules, and basic flight safety. Additionally, these flight patl1s are not consistent with Air Force publications, such as tl1e Wing Safety Office's "Mid Air Collision Avoidance Pamphlet" (used by 9211d ARW aviators and published on the internet for other pilots' notification of Fairchild patterns, flight safety interests, etc.), the Air Installation Compatible Use Zone (AICUZ) of October 2007, and the Joint Land Use Study to cite three examples.

Prior to the release of the briefing slides, the 9211d Air Refueling Wing had taken a fairly benign position on STEP and t11e impacts to Fairchild AFB. The impacts such as lights and

Madison Government Affairs Inc. Page 1


Washington DC 20001 Phone 202.347.1223

Fax 202.347.1225 glare as well as noise are documented and addressed. In fact, the Wing has consistently stated they are 'neutral' to STEP. Also, Air Force civilian leadership in t11e Pentagon is on record with the Tribe as being 'neutral' on STEP. Our review of briefing slides 5, 6, and 7 follows:

Madison Government Affairs Comments in Response to Slides 5, 6, and 7

Slides #5, 6, & 7 - Flight Patterns, Density Slide, & Proximity to FAFB Patterns

Slide #5 depicts a VFR flight pattern that is inconsistent with normal Air Force-wide operations and is questionable at best. At worst, if flown as shown, the pattern is botl1 unsafe and blatantly dangerous. The depicted pattern, which is shown to overfly the property, would require a very 'tight' pattern with a turn to final/base leg far too close to the runway. The aggressive pattern depicts beginning the turn to the base leg/ final tum at a point on tl1e 'downwind' even with the landing zone (adjacent to base housing) with the aircraft 'rolling wings level' on final inside 1/2 mile from the end of the runway. If the actual flight path occurred as depicted, the aircraft would be at an unsafe altitude (100-150' above the ground) and at dangerously slow airspeeds as it completes its tum to align with the runway, and with insufficient time/ distance to slow to proper final approach/landing speed if maneuvering speed were maintained in the tum. This is a highly aggressive pattern tl1at would leave no room for error or unexpected occurrences, such as a stronger crosswind than was forecast or expected.

It is inconceivable that a Wing Standardization Evaluation function would condone this type pattern. Aviators who fly, and who have flown the KC-135, indicate that a normal final turn is far less aggressive. The standard VFR pattern 'turn to final' would start at a point on the downwind approximately 1/2 mile further t11an depicted and would be flown in such a manner to intercept the instrument glide path at or above 300 feet above the ground at or beyond one nautical mile from the end of the runway. This normal pattern would not overfly STEP; however, even if it did, aircraft would be well above required obstacle clearance height requirements.

Similarly on t11e same slide, the Circling Approach flight path has been altered from the previously published 'Fairchild Mid-Air Collision Avoidance' pamphlet to depict a sharper turn from the final approach heading so as to unnaturally overfly the property. In normal practice and actual low weather conditions, tl1e pilot would fly to within 1-11/2 miles of the touchdown point before turning off the final approach course to maneuver for landing on another runway. The whole concept is to maneuver so as to stay close to the airfield keeping the runway environment in sight during low ceiling and visibility conditions. The depicted pattern shows the aircraft starting the turn away from the final approach at 2 1/2 miles and turning sharply (approximately 45 degrees) so as to depict a flight pattern over STEP.

Madison Government Affairs Inc. Page 2


Washington DC 20001 Phone 202.347.1223

Fax 202.347.1225 Slide 6 leaves the impression that there is typically a high density of traffic over the property. The depicted tracks represent flight traffic during a full one-week period in 2010, not daily as the slide would lead one to believe. This period comprised some 148 takeoffs (including initial and 'touch and goes') and a somewhat lower number of landings. Averaged out over the seven day period, that equates to 22 patterns per day or 1.4 per hour, when spread over a 16 hour flying window, which is a comparatively low traffic density.

Slide 7 notes that Air Force participated in the EIS process. Specifically, the 92nd ARW represented the Air Force as a Cooperating Agency in the Environmental Impact Analysis Process (EIAP) and in that capacity provided input and comments. Among their comments were issues relating to the amount of noise generated by the 92nd ARW aircraft and the potential adverse impact on STEP. The 92nd ARW also commented about the glare from STEP activities and parking areas and the impact on aircrews. The Final Environmental Impact Statements addresses those issues and concerns and incorporates the 9211d ARW' s proposed mitigation measures.

Finally, the "bullet" on Slide 7 - Potential for Aircraft Crash/Mishap - is misleading. One thing has nothing to do with the other. The potential for an aircraft mishap must be very low or non-existent in the area of STEP because if there was a concern the Air Force would have taken precautions in the past based on flight patterns. The only areas of concern appear to be located at the ends of Runways 23 and 5 where there are APZs. In the history of Fairchild AFB there has not been a recorded mishap in the area of STEP. The prudent person would have to presume that if the Air Force (9211d ARW, Air Mobility Command, and HQ USAF) was ever concerned with flight safety over the area where STEP is proposed that the property would have been identified as such. Also, the same assertion made by this "bullet" could be made about Airway Heights' location. If an aircraft was to fall from the sky or drop an engine over Airway Heights the potential for disaster is great as well.

As set forth in our Assessment Report, STEP' s location, while under some of the base's flight patterns, is not in a high accident potential location and flight is well above the minimums established by the FAA and the Air Force. Additionally, it is well outside the APZ, and its location has never been in conflict with the long accepted Air Installation Compatible Use Zone program. After review of the Johnson slides, Madison Government Affairs stands by the conclusions reported in our STEP Assessment Report of February 2013.

Enclosure: Slides Prepared by Mr. Jeff Johnson

Madison Government Affairs Inc.

Sincerely,

Paul J. Hirsch President

Page 3

THE PROPOSED SPOKANE TRIBE'S CASINO AT AIRWAY HEIGHTS: ARE THE REAL RISKS NOT BEING PROPERLY ASSESSED? PREPARED FOR SPOKANE COUNTY, WASHINGTON PERKINS COIE LLP

The Environmental Impact Statement for the STEP Project Does Not Accurately Assess Risks to Public Safety The Accident Potential Zones used in the EIS for the STEP Project do

not reflect actual air traffic patterns at Fairchild Air Force Base (FAFB).

Based on data provided by FAFB, it appears that the site of the STEP Project falls within what should be designated APZ II or under Washington State law, Zone Ill, an area of heightened accident potential where high density uses are prohibited.

The STEP Project should be denied as detrimental to the Tribe and the surrounding community based on comments submitted.

Alternatively, a supplemental EIS should be prepared that takes into account actual flight patterns at FAFB to accurately assess risk.

What Are Accident Potential Zones (APZs)? Using military accident data collected between 1968 and 1972, an

AF study determined that 753 of aircraft accidents occur within a 3,000-foot wide corridor along a runway and extending out from the runway centerline for a distance of 15,000 feet.

Three zones were established based on the accident study to support the Department of Defense's Air Installations Compatibility Use Zone (AICUZ) Program: the Clear Zone (CZ), Accident Potential Zone I (APZ I) and Accident Potential Zone II (APZ II): The Clear Zone is measured along the extended runway centerline beginning at the

runway end, and is 3,000 feet long and wide for Class B Air Force runways like FAFB. APZ I starts at the end of the clear zone and is centered and measured on the extended

centerline, 3,000 feet wide and 5,000 feet long. APZ II starts at the end of APZ I and is centered and measured on the extended

centerline, 3,000 feet wide and 7,000 feet long.

I

Appropriate Land Uses of These Three Zones Are Highly Limited The clear zone, by definition, should be clear of structures to the

maximum extent practicable.

"[U]ses that concentrate people in small areas are not acceptable" in APZ I.

"High density functions such as multi-story buildings, places of assembly (theaters, churches, schools, restaurants, etc.), and high density office uses are not considered appropriate" in APZ II.

"High people densities should be limited to the maximum extent possible."

The building footprint for a shopping malls or centers will be considered as a single entity in all land use compatibility analysis .... Due to the concentrations of people associated with shopping malls and centers, these land uses are considered as incompatible within all Accident Potential Zones."

Air Force Handbook 32-7084 (Mar. 1999)

To Maximize Safety, APZs Should Follow Major Flight Paths: C :JSS ?Li '"''' ' ''""'" , : ' t I "" J

(SOO N

For Local Land Use, Authorities Should Conform the Air Force's APZs to Reflect Actual Operations The depicted APZ zones used by the military assume

that flight tracks are straight-in and straight-out.

Modifications may be made to alter APZs and adjust them to conform to the line of flight if different or additional tracks are used on a regular basis.

Consideration should be given to providing safety zones lateral to the runway if these areas are not fully contained within the boundaries of the military facility.

"The safety compatibility criteria suggested in AICUZ guidelines tend to represent minimum standards (more so with respect to noise than safety)."

California Airport Land Use Planning Book (2002, 2011)

Washington Conforms Safety Zones to Actual Flight Patterns

Washington relies on the California Airport Land Use Planning Handbook (2002).

"It is essential to adjust safety zones to fit the airfield configuration, usage characteristics, and other factors associated with a specific airport. "

Adjustments are made based on runway length, approach type, fleet mix, traffic pattern location.

WSDOT Airports and Compatible Land Use Guidebook M 307 4.00 (January 2011 ); COOT California Airport Land Use Planning Handbook (January 2002).

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Ill 4

(APZ II) ....:

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2 (APZ I) ,.;

1 (Cfoor zono) ~1

-- 2.000'

Mlllt~ry Runway for Large AJrcrJf1:

Assumptions: Mlllr.1ry Jlrport Predomin.nely uralght in and straigh1-0U t flight routes

..-. (mu!lt modify 4ar turning routt~ and traffic pattern activity}

The EIS Uses the Generic Air Force APZ, Which Assumes Straight-In/Straight Out Flight Routes

.- .., Oopar1 mcnt at Defense APZa 1_ _: Cy Limits

- Af'Z I C.:] Pro)oc: S ho E3 A?Z ll Jlilll] CZ

Fairchild Ai:' Fo.-cc Base

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Actual Air Traffic Patterns at FAFB Are Not Straight-In/Straight-Out

Radar Pattern - 5000' MSL VFR Pattern - 3700' MSL Local Oimb Out - 290

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Fairchild Air Force Base Mid-Air Collision Avoidance Brochure

C1I

Common Traffic Patterns at FAFB Pass Directly Over the STEP Project

Created by Jeff Johnson, Deputy Director FAFB Encroachment Management Team (2013)

"Fairchild aircraft must turn north (over the proposed site) to avoid Spokane International Airport approaches."

"Aircraft flights below 1000 ft over the Project Site"

"Under the VFR Final Turn to RWY 23 (600-650' AGL)"

"Under Ground Track for Departures for Rwy 05 (700-850' AGL)"

"Under the Circling Approach Track for RWY 23 (558 ' AGL)"

Radar Tracks from October 2010 Produced by FAFB to BIA

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Spokane Tribe Casino

f:wd111dAFO~ ~la (1.ld 1rxks)ftOl'IOctebc!t 1010 Tit r.xU>et\ l)r.trn~tM V~ua: (VfRJ P.-ttt'MMtd lit~ stJ~ ir. llach at~ the bnals dlhe ins!nnnenl-WO~s

The STEP Project Is Located in APZ II, If APZs Are Conformed to Actual Operations

STEP Project: Proximity to Airport Overlay Zones - Subject Properties

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Airway Heights

The Navy Conforms APZs to Actual Flight Patterns

Where the flight track departs the centerline prior to crossing the clear zone, APZ-1 will be 5,000 feet in length and APZ-11 will be 10,000 feet in length, measured from the point the flight path leaves the runway centerline.

Where the flight track passes through the side of the clear zone, APZ-1 will be 5,000 feet in length and the length of APZ-11 will be the difference between the total length of the clear zone and APZ-1 and II ( 15,000 feet) less APZ-1 and the distance the flight track traverses the clear zone.

Op Nov Instruction 11010.36 (Oct. 9, 2008)

Why Don't FAFB's APZs Match Actual Flight Patterns?

The 2007 Fairchild AICUZ follows the 1999 Air Force Handbook 32-7084 and does not include a Flight Tracks Map or a Separate Accident Potential Zones Map.

The Air Force AICUZ program focuses on avoiding conflicts from noise complaints and leaves risk assessments largely to local planning processes.

The Air Force not as aggressive about land use as Navy, due to siting in more remote locations.

AF Statements on the Preliminary Final EIS Confirm that the STEP Project Is Within Current Flight Tracks "Due to air traffic from neighboring Spokane

International Airport to the south, Fairchild AFB is limited to conducting flying operations to the north of its runways, leaving only 503 of the airspace normally available for closed pattern flight activity in the proximity of the airfield."

"The project site is located adjacent to and directly below established flight patterns for Fairchild AFB."

The AF's Comments Indicate That There Are Serious Risks, Which Current APZs Do Not Reflect

\;,/Spokane Tribe Economic Project ... (STEP)



Light Pollution from the Site {Pilot's Night Vision} Proximity to FAFB Aircraft Traffic Patterns



Reading Between the Lines: FAFB Operations Are Constrained and the STEP Project Creates Additional Problems "Air Force reaffirms its position that Interior consider the entirety of the record

before it to include the JLUS recommendations as part of its decision-making."

"Request ... clarification of the Fairchild flight pattern limitations, and inability to modify operations to avoid the proposed site."

"[D] ue to the current airspace and flight track limitations, [the AF] will need to continue to fly existing patterns, which will generate high noise levels as pilots fly the closed patterns and conduct approach and departure flight operations."

"Recognizing that communities are often left with little control over what is built on tribal lands, it is well within Interior's scope of authority to take these types of issues (aka, "strategies") (e.g., land use planning and encroachment) into consideration in its decision making as a predicate to what may eventually take place or may be permitted on referenced tribal lands."

Conclusion Project Denial on the Basis of the Existing Record:

The STEP Project will be detrimental to the surrounding community and the Tribe by further constraining FAFB operations, siting high-density uses in an area where there is a heightened risk of accident, and generating light impacts that cannot be mitigated in all conditions.

Prepare a Supplemental EIS to Address Actual FAFB Operations: A supplemental EIS is needed, if the STEP Project is not immediately denied, to address the information the Air Force has provided about actual flight operations after the FEIS was complete.

Documents

Spokane County Request for Supplemental EIS on Fairchild Air Force Base