i '

SPOIW\lE
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
(Seo Notes Below)
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Sec Note on Navy Clear Zona Shape
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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.
March 31, 2014
Page 5
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.
March 31, 2014
Page 6
Figure 2
OeP41r1men1 d OfOl'\U APZI
t:::"j APZI
EJ APZ ll
llllffiJ CZ
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F1lrchi:d Air Forco &so
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This decision is highly significant and ultimately downplays or obscures that actual risks
associated with allowing the STEP Project to proceed. In fact, the FEIS concludes that, with
respect to aircraft accident potential and public safety, the project is compatible with F AFB
operations because it is not located in a designated APZ, and "[t]herefore, the Proposed Project
would not locate people within an area that is considered to have a level of risk associated with
accident potential that warrants land use and density restrictions in accordance with DoD
recommendations." FEIS 3.6.1at3-15; see also 4.9.1at4.9-2 and Fig. 3.9-4. Although the
County disagrees with this conclusion because local zoning prohibits high density uses in
Military Influence Areas 3 and 4, where the STEP Project would be located, the problems with
the FEIS analysis and the questions raised by the Air Force's data and the Tribe's consultant are
actually far more critical.
The FEIS relies on the 2007 AICUZ Study for F AFB. This study predates the recent revision of
DoD Instruction 4165.57 in 2011; the previous version, which dates back to 1977, did not
emphasize the modification of nominal APZs to account for curved flight paths.
6
The 2007
F AFB AICUZ Study thus contains no analysis of whether the nominal AP Zs adopted should be
modified to conform to actual flight patterns and local conditions specific to F AFB. Other than
including representations of official flight tracks, there is no analysis of the intensity of use of the
6
The 1977 version ofDoD Instruction 4165.57 is available at:
http: //biotech.law.lsu.edu/blaw/dodd/corres/pdfli4l6557_ 110877 /i4 l 6557p.pdf.
March 31, 2014
Page 7
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
Spokane Tribe Casino
T1'o r:1utra;:lr.r. .... ,s!ll1
... 1!'l.""- ... 'lJv.kln
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.
March 31, 2014
Page 8
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.
Fairchild
Air Force
Base
'
....
March 31, 2014
Page 9
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.
March 31, 2014
Page 11
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,

TODD 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 s o p p i n ~ 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:

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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
Departmnt of Defense APZ j__J City Limits
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Fairchild Air Face Base
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Actual Air Traffic Patterns at FAFB Are Not
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Radar Pattern, - 5000'
MSL
VFR Pattern - 3700' MSL
Local Climb Out - 290

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Fairchil d Air Force Base Mid-Air Collision Avoidance Brochure
',
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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Spokane Tribe Casino
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vm.nt ' Ill' '"' u.:t:b 11t rit l11ds e'.! the amnrnrn'I
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.iii s ___ llii 2MUos
...-,1.v....\ ,,1,,-..ml
Fairchild
Air Force
Base
';,, ''q, " '\.
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
.,.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
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ - - -
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 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.
Exhibit 2
MCAS Miramar MCAS APZs
La Jolla
Sorrento
Valley
r
!
!
j
!
i
i
. '
..
------.i
Rancho Penasquitos
Rancho
Bernardo
POWAY
r--j---
i
i
i
____ .. _ ..
L - ,/ tJ
--' -- _, ......... \
., .. _,_. __ .,
!
i
East Elli ot
I
I
I
fl.
i ';\
!
t,..-.. .J
i
SAN DIEGO
COUNTY
SANTEE
Sa11ree I.des
i ..--1
r----[ --
I
.?-..... j" l ,J"
'..... \- t .. ':i
' -- 'f! r.1 I
',\ ('J ;,]:
. .
... ,r
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
~ 4

. ,
~
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
... , ..
- ' ti'
. rir.
... 4'.

Fairchild AFB/Spokane
International Class C Airspace
Excludes Spokane
?P-2\ I International Airport
.f /. "\. -=iL 1_',""' .. - . _ _ _
tJ; -4" . . "=T .
3
,i .
...
\,.J Fairchild Tower & Spokane Tower Airspace
... /

..
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 (<5 kts)
4
-
! .,
f(adar,Pattern
:. , (S,000' .MSL) .
(2,539' f)bove R/W)
\
I ~ _, __ .\
"
.' J' "

'
~
Spokane Tribe Casino
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
~ Spokane Tribe Economic Project
{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
--
7
c
0
-
tn
tn
:::J
CJ
tn
-
c

tn
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0
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a
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, 92
11
d 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, 92
11
d
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 92
11
d
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 92
11
d 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 92
11
d 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 92
11
d 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 92
11
d 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
Madison Government Affairs Inc.
444 North Capitol Street, N.W., Suite 601
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
Madison Government Affairs Inc.
444 North Capitol Street, N.W., Suite 601
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 92
11
d 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 (92
11
d 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<Xes Belowj
.. "'
,.._. See Hore on Navy CJNr Zl:>ne Shape
____ .::.____,,,---------.--------------,-.-
"
\
'
r
--- ~ _:1'
' ,
i . ~
I ) ' '"
c:.:.-:.:\R ZCN .. r ~ ! A?Z !:
'
----
'
.... .. ~
"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).
"1 00()1
I - 1
Ill
4

(APZ II)
....:
I
2
(APZ I)
,.;
1
(Cfoor
zono)

-
- 2.000'
Runway for Large AJrcrJf1:
Assumptions:
Mlll r.1ry Jlrport
Predomin.nely uralght in and
straigh1-0Ut flight routes
..-. (mu!lt modify 4ar turning
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: Sho
E3 A?Z ll
Jlilll] CZ
Fairchild Ai:' Fo.-cc Base
.
l't : . ; fn:I Propcsac Runway
r-i I ... ..
(I JJXXJ
Actual Air Traffic Patterns at FAFB Are Not
Straight-In/Straight-Out
Radar Pattern - 5000'
MSL
VFR Pattern - 3700' MSL
Local Oimb Out - 290

fiir,, '(>-$.



"'?l>
(;)':>
_____ ,,,,,...-
"'-vf'."i.
t
N

- "
i"!:> r1:1yr<i:d
"'-v'('i. ""' "'? lJJO.:

(
" "J>'i>
t;i...e"wr>"'
1-=Uc

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
A'

...
Spokane Tribe Casino
(1.ld 1rxks)ftOl'IOctebc!t 1010 Tit r.xU>et\
(VfRJ P.-ttt'MMtd ir. llach the bnals dlhe
The STEP Project Is Located in APZ II, If APZs
Are Conformed to Actual Operations
STEP Project:
Proximity to Airport Overlay Zones
- Subject Properties
..... 1i::::=====1
3
.s.,. ..... 2Mil cs
1t1,,,t."N\',''r'''\"1
Fairchild
Air Force
Base
" Iii
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)
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
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.