By LAURA JAMESON ljameson@lockhaven.com

LOCK HAVEN - The Clinton County Commissioners are making one final push for public input regarding the proposed Duke Military Operations Airspace change that could effect North Western Clinton County and a large portion of the PA Wilds.

The proposal came from the Maryland Air National Guard, which currently conducts training drills in the area at 8,000 to 17,000 feet above sea level. The guard is looking to conduct low-altitude drills in the area. According to the proposal, this would mean planes flying as low as 100 feet above ground level at a minimum of 170 days out of the year.

The board of commissioners held a Town Hall webinar Monday night regarding the proposal, noting that its attempts to have questions answered by the Maryland National Guard have been unsuccessful.

Commissioner Jeff Snyder directed the meeting, which included Chair Miles Kessinger, Commissioner Angela Harding and Planner/Engineer Steve Gibson.

Snyder said the commissioners asked the Maryland Air National Guard for three things:

- To hold Town Hall meetings to answer questions from residents about these training exercises that could take place four hours a day, 170 days a year, at ground levels close to 100 feet.

- To fly the jets in the areas that have been designated at these 100 feet levels, to give the public a chance to experience what could "become an almost daily event."

- To have a third party conduct a more detailed environmental impact statement "that will allow the government agencies making these decisions to make the best decision for the interest of those people that live in these areas."

"So far, all of these requests have fallen on deaf areas," Snyder said.

The webinar served as the board's last chance to encourage public comment, for or against the MOA, prior to its May 17 deadline.

Gibson spent the bulk of the hour-long meeting giving a rundown of the MOA.

According to Gibson's presention, the existing Duke MOA covers 1.4 million acres of land in North Central Pa. and is used to train military forces while avoiding comingling with commercial air space. Training may include performing air combat maneuvers that are separate from instrument flight. The current altitude is 8,000 feet above sea level to 17,000 feet.

Gibson said the Maryland Air National Guard cannot conduct training over the Atlantic Ocean because its controlled by the U.S. Navy. This limits the amount of inland airspace the guard can utilize.

It was noted later in the meeting by the board that the guard had already attempted to utilize air space in Maryland and Virginia. However, both requests were denied, but further detail as to why was not provided, Gibson said.

Within the proposed MOA, Gibson said areas that include Kettle Creek State Park and Hammersley Wild Area have proposed flight altitudes of 1,000 feet above ground level "to avoid impacts to wildlife."

Other areas such as state parks, Austin Dam, Bucktail Park, Pine Tree Trail Natural Area, Cherry Springs State Park and more, have proposed flight altitudes of 500 feet above ground level to avoid impacts to "sensitive areas."

Gibson noted that night operations would not occur below 1,000 feet above ground level.

The planes that would be part of these exercises are the A-10C Thunderbolt.

Gibson said, according to a presentation made by Retired US Air Force Col. Susan Beck noted the A-10C is being retired, with a complete retirement date expected by 2029.

The F-16 Fighting Falcon is the presumed replacement of the A-10C by 2029. Gibson said it was reported the F-16 is "a few decibels louder than the A-10C."

Gibson encouraged residents to visit the county's website, www.clintoncountypa.gov, and review Beck's presentation - which is included in its Duke MOA tab on the homepage.

In terms of the proposed MOA's environmental impact, Gibson said the county feels the current study done isn't enough.

Gibson said an Environmental Assessment was completed per the National Environmental Policy Act. He noted, from the county's understanding, no one actually came to review the area that could be impacted. The report was "completed by someone at their desk in Maryland or Washington (DC)," Gibson said.

A revised version of the EA was completed, featuring 1,000 pages of comments outlining concerns from citizens along with local and state agencies about potentially negative impacts the MOA could have to the area. Impacts of concern were the Pennsylvania Wilds, impacts on wildlife, tourism and public safety, Gibson said.

"In March of 2023, the original EA was revised and resubmitted by the MD ANG with minimal concessions to the concerns outlined in the first response to the original MOA," Gibson said.

Gibson said the county has requested an Environmental Impact Study be completed to provide a more comprehensive study of the potential impacts.

Included in Gibson's presentation was the Maryland Air National Guards proposed final action and mitigation efforts. They included:

1. The vertical limits would be defined as 100 feet above ground level (AGL) to7,999 feet MSL.

2. The Duke Low MOA may be activated separately from the Duke MOA or concurrently as needed to facilitate low-level training requirements.

3. Activation times would be intermittent by Notice to Air Missions (NOTAM).

4. Expected usage would be two hours per day, twice per day, one hour at a time, with no more than six total aircraft, approximately 170 days per year.

5. Weekend operations would be limited mostly to Saturdays. Sundays would be non-typical.

6. The Maryland ANG is a federal entity that would not typically, outside of wartime, fly on federal holidays.

7. Nighttime operations (defined as sunset until 10 p.m.) at low altitude would be limited to above 1,000 feet AGL.

8. A surface to 6,000 feet MSL exclusion area would avoid Wellsboro Airport Class E airspace within the eastern side of the Duke Low MOA. No supersonic operations, release of chaff and flares, ordnance deployment, weapons firing, infrastructure changes or ground disturbance would be conducted in the Duke Low MOA.

9. A 1,000 foot AGL floor would be implemented over sensitive areas of concern in the southern portions of the Duke Low MOA, specifically over the Hammersley Wild Area, Forrest H. Dutlinger Natural Area and the Kettle Creek State Park.

10. A 1,000 foot over flight buffer and a 0.5 nautical mile (NM) lateral buffer around Bald and Golden Eagle nests would be incorporated per Air Force direction.

11. A 500 foot AGL floor would be implemented over sensitive areas of concern in the remaining portions of the Duke Low MOA, such as over the State Parks, Sinnemahoning Creek and the historical Austin Dam ruins.

12.A 500 foot over flight buffer would be maintained over obstacles such as radio towers, windmills and oil drilling rigs per Air Force Manual (AFMAN11-202v3).

According to Gibson, the proposal doesn't deeply address five key areas of concern the county has expressed:

- Noise and its impact on quality of life. "Low level flights produce noise levels of 110 to 120 decibels," Gibson said, according to reports in the Environmental Assessment. "Sudden onset of noise is not addressed in the EA."

- Wildlife. "Sudden onset of noise and vibration can impact predatory birds, startle mammals and impact spawning of aquatic life," Gibson said.

- Toursim and Recreation. "The Pennsylvania Wilds, DCNR, the PA Game Commission and PA Fish and Boat have collectively worked for decades establishing eco-toursim, hunting and fishing below the Duke MOA, generating $1.68 billion in 2021," Gibson said.

- Public safety. "The EA does not address public safety or training of emergency services" in the event of a plane crash or other disaster, Gibson said.

- Public outreach. "The Maryland Air National Guard has not responded to county requests to attend public meetings to personally outline the proposal," he said.

Another point of concern by county officials is energy infrastructure within the MOA, including the Leidy Natural Storage Facility.

According to Gibson, the current Environmental Assessment doesn't address the natural gas infrastructure that exists within the MOA.

"The Leidy Natural Gas Storage Facility takes Federal Energy Regulatory Commission (FERC) pipelines from across the United States and stores excess gas until demand reaches an annual peak for the release of the stored gas," Gibson explained.

Gibson said pipeline operators indicated they use remote sound detection devises to alert operations of pressure relief valve malfunctions. These devices can be impacted by loud noises, he said.

"Low level aircraft noise may inadvertently cause a Pressure Valve alarm, which could shut down the pipeline, affecting the fuel source to major customers, such as power plants," Gibson said.

These false alarms could also potentially trigger a 9-1-1 emergency response as well, he said.

At the conclusion of Gibson's presentation, he encouraged those watching at home to consider expressing their concerns - or support - of the MOA. The county is collecting comments and questions about the proposal until May 17.

Comments and questions may be emailed to Gibson at sgibson@clintoncountypa.gov.

More detailed information regarding the MOA proposal, along with various presentations and more, are available on the county's website, www.clintoncountypa.gov, under the "Duke MOA" tab on its homepage. The information also includes a short survey, Gibson said.

Over two dozen members of the community attended Monday's webinar. According to county officials, a recording of the webinar will be uploaded to the county's website and social media.

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