Thursday, July 4, 2013


The South Burlington and Winooski City Councils are to be commended for arranging public forums on the proposed F-35 basing.  The opportunity for public process and the Council’s willingness to listen to resident concerns and opinions on the basing is most welcome.

The Air Force recently released a revised Draft Environmental Impact Statement, relating to proposed basing. After reviewing the revised DEIS, and other relevant information, I want state my strong and complete opposition to the basing of the F-35 jets at the Burlington Air Guard base, because of the damaging impact it will have on our communities. The reasons for my opposition are as follows:
Reliability of the Data 

The revised DEIS includes estimates of housing and population impact based on 2010 Census data. The estimates are significantly higher than the figures presented in the initial Draft EIS. However, the estimates are still incorrect and significantly understate the number of housing units and people that are located in the high noise zone. Using the reliable data source of municipal assessments / tax parcel data, the properties have been identified by property owner, address and indicate the number of housing units affected is substantially greater than reported in the revised DIES. This irrefutable data indicates that the Revised DEIS understates the number of housing units, located within the 65 db DNL zone (Scenario 2), by 505 units and understates the population affected by approximately 900. The EIS must be revised to accurately reflect the impact of the high noise on our homes and residents.  


A huge land area, encompassing thousands of homes and families is located within the designated accident potential zone area. The DEIS states that the F-35's will have a significantly higher risk of crash, as compared with the F-16's.  The very recent crash of an F-16 in Arizona at Luke AFB illustrates the risk.  Fortunately, this crash was in a rural area and not a populated area, and there were no casualties. The high crash zone near the Burlington Air Guard space is the most densely populated region of our entire state.  In other communities, the Air Force has gone to court to prevent residential development from occurring in Accident Potential Zones. This same standard of safety should be applied in this case.


There is credible evidence that children are at much higher risk of negative health impacts due to high noise levels. The DEIS does not adequately address the impact on the health of children and should be amended to include recent studies, including the study completed by the World Health Organization. Over one thousand children will be impacted.

Several schools are located within the 65 db DNL zone and would be negatively impacted by high noise levels. The South Burlington and Winooski school boards both oppose the basing because of the negative impact on their hundreds of students. The DEIS did not even consider the presence of the recently developed Community College of Vermont, located in downtown Winooski. This multi million dollar facility, serving hundreds of students, would also be impacted by the high noise. 
Property Values 

There is an abundance of evidence confirming that airport noise has a detrimental / negative impact on property values. The DEIS only briefly examined this issue; on one hand, recognizing the impact on property values, but neglecting to quantity the impact. There are many academic studies, as well as local market evidence, that should be reviewed in order to assess the impact of the basing on property values. There are thousands of housing units in the proposed 65 db DNL zone. The loss of equity for these mostly modestly priced homes could be financially devastating for the owners. The potential loss in home values must be considered as a cost of this basing and examined more closely in the EIS. The analysis should identify the value of the residential property which is located within the high noise zone, and estimate the potential loss in value of this property, as well as the potential cost to mitigate the noise damages, if mitigation is possible. 

Municipal and State Tax Revenues

Related to potential property value loss, is the potential loss of municipal tax revenues. The DEIS did not address this issue.  The EIS should quantify the potential loss of state and municipal tax revenues as a significant impact of the proposed basing. 
Quality of Life  

Because of the high noise levels, the quality of life will be significantly diminished for over 8,000 residents, including many disadvantaged families, elderly residents and children. The repeated exposure to excessive jet noise, up to 28 times a day, will greatly diminish the quality of living for these communities.


If the F-35's are based in Vermont, the 65 db DNL noise zone in Winooski will be expanded to include nearly 80% of all housing units in the City.  Large sections of South Burlington, Burlington and Williston are also impacted.  Aside from the very real negative impacts of high noise on property values, health and quality of life, the high noise levels will also bring the collateral Federal label to our communities and homes as being “incompatible with residential use” and “incompatible with educational use”. The FAA and Department of Defense both have policies which explicitly define this.  I believe that this will stigmatize these communities and homes through the perception that they are a less attractive and safe place to live. The affected neighborhoods and communities will be burdened by the negative reputation imposed by this Federal “label”.  Who would want to live in a community or home which has been labeled as “incompatible with residential use”?  Who would want to send their children to school in a community which carries this label?

Available Alternatives

As the DEIS informs us, there are several potential sites that are better suited to the F-35 basing. I fear that the decision is being controlled by politics.  I understand that “mission” is a controlling element in the basing decision and I am afraid that this somewhat vague term will be used to make Burlington the top choice, despite it being the worst choice from an environmental standpoint. If the Air Force and Air Guard are serious about transparency, there should be an investigation in the selection process, specifically focusing on the glaring “mistakes” in the application, which led to Burlington being erroneously selected as the preliminary top choice for the basing.

Support for Guard 

The Air National Guard has a commendable record of service to our country and state. As a community, we can support the Air Guard without supporting the F-35's. The DEIS indicates that only a small number of jobs will result from the basing, even under the most expansive plan. Air Guard leadership has publicly stated that it is unlikely that the base would ever close, while recognizing that the mission could change. The host of economic benefits associated with the ANG will continue, even if the mission is changed.  Most importantly, the marginal benefits of the F-35 basing should be weighed against the costs. For the affected communities, the costs are enormous and the benefits are minimal.

Steve Allen
87 East Spring Street

Winooski, VT  

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