KTA Comment Letter
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To Whom It May Concern:
Established in 1956 and representing approximately 1,000 members and 41 local trail and hiking clubs, Keystone Trails Association (KTA) is the statewide voice of Pennsylvania's hikers. The organization's mission is to provide, protect, preserve, and promote recreational hiking trails and hiking opportunities. In 1999, the Pennsylvania Department of Conservation and Natural Resources (DCNR) named the KTA “Conservation Volunteer Group of the Year” in recognition of many years of work on hiking trails. Our trail work contributes 4,000 volunteer hours annually and member clubs contribute an additional 35,000 volunteer hours each year.
The proposed Duke MOA Low would cover all or parts of the following Pennsylvania counties: Elk, Cameron, Clinton, McKean, Potter, and Tioga. Four important backcountry trails intersect the MOA Low. The Susquehannock Trail System is a remote, long-distance loop trail, passing few signs of civilization and reaching into very isolated state forest areas. The Bucktail Path is a challenging 34-mile linear trail with a northern trailhead located in Sizerville State Park. Known for outstanding vistas of the Pine Creek gorge, the West Rim trail lies on the eastern edge of the proposed MOA Low. The Donut Hole Trail is an 89-mile long-distance backpacking trail paralleling the West Branch of the Susquehanna River in the Sproul State Forest. It is one the most rugged of the state’s backpacking trails. All of these routes, proffering an abundance of wildlife and solitude, are located in an area appropriately deemed the Pennsylvania Wilds.
With 2.1 million acres of public land, the Pennsylvania Wilds is one of the largest blocks of forest between New York City and Chicago, and home to two National Wild & Scenic Rivers, the largest wild elk herd in the Northeast and some of the darkest skies in the country. Nearly a quarter of Pennsylvania’s state parks and more than half of state forestland are in the 12-county PA Wilds region. The Duke MOA Low overlays its very core, where wilderness qualities are highly manifest.
According to the draft FONSI, “during each sortie, aircraft would be down in the low altitude ranges between 500 ft to 100 ft for 2-3 minutes per activation.” Due to the intensity of noise, KTA believes that is 2-3 minutes too long.
While we greatly value the services and sacrifices of our military, the sublime natural attributes of the MOA Low area make it unique, affording hikers immersive experiences largely unavailable elsewhere in the state. Tranquility may be undervalued in the modern world, but it is an endangered quality. . . a rare and priceless experience.
In examining visitor experiences of wilderness soundscapes, Penn State University researchers found “. . . mechanized aircraft sounds were consistently some of the most annoying and unacceptable sounds evaluated by visitors.” Prior studies, cited by the authors, suggest anthropogenic noise pollution masks natural sounds and has the potential to detract from quality visitor experiences in wilderness settings.[1] Other research on the effects of aircraft on outdoor recreationalists discovered, “Those who made an effort to get to a natural setting (e.g. a multi-day walk) were more likely to have strongly held negative views about aircraft.”[2]
If the hiking experience deteriorates because of low flyovers, some hikers won’t return and others won’t bother coming at all. The stakes are high for a region promoting quality, nature-based recreation. According to the PA Wilds website, even Howard Zahniser drew inspiration from this very region to pen the Wilderness Act of 1964, protecting lands around the country to leave them “untrammeled by man.” Zahniser certainly would have viewed low-altitude sorties as trammeling the pristine attributes of the PA Wilds.
Silence means money for local communities. “Hiking and backpacking have considerable economic impact. According to the US Bureau of Economic Analysis, climbing, hiking, and tent camping accounted for more than $6 billion in economic impact in 2017, an 8.4 percent increase over 2012. Extrapolating findings from a 2011 Appalachian Trail pilot survey . . . researchers concluded that two million annual visits generated between $125 and $168 in spending.”[3]
The aforementioned Penn State research affirmed the importance of natural sounds. Natural soundscapes contribute to animal abundance, ecological functions, and a variety of psychological human benefits. They’re also important to a variety of visitor experiences (e.g. birding) in protected areas.[4]
While the draft FONSI describes avoidance and mitigation measures by limiting flight times, duration, and altitude, a substantial span of the year would be affected by training flights and the FONSI acknowledges that flights would increase overall sound levels at wilderness areas, state parks, and state forests. The assertion that “The Proposed Action would have less than significant adverse effects” seems, based on limited data, to be highly suspect.
Millions of public dollars have been invested in the PA Wilds region to foster a sustainable, nature-rich destination for visitors and a peaceful, prosperous locale for those who call the Wilds home. This progress may be compromised by the current proposal.
For all these reasons, the Keystone Trails Association opposes the Duke Low MOA as presented and requests public meetings in each of the impacted counties to allow area residents and stakeholders an opportunity to have all their questions answered. Open and transparent discourse is a must. We also believe more analysis, in the form of a rigorous environmental impact statement, should be conducted to fully ascertain the implications of the Duke MOA Low proposal.
On behalf of the individuals and organizations listed below and all our membership, thank you for the opportunity to comment. We hope our concerns and recommendations are given the utmost consideration.
Sincerely,
Brook Lenker
Executive Director
Established in 1956 and representing approximately 1,000 members and 41 local trail and hiking clubs, Keystone Trails Association (KTA) is the statewide voice of Pennsylvania's hikers. The organization's mission is to provide, protect, preserve, and promote recreational hiking trails and hiking opportunities. In 1999, the Pennsylvania Department of Conservation and Natural Resources (DCNR) named the KTA “Conservation Volunteer Group of the Year” in recognition of many years of work on hiking trails. Our trail work contributes 4,000 volunteer hours annually and member clubs contribute an additional 35,000 volunteer hours each year.
The proposed Duke MOA Low would cover all or parts of the following Pennsylvania counties: Elk, Cameron, Clinton, McKean, Potter, and Tioga. Four important backcountry trails intersect the MOA Low. The Susquehannock Trail System is a remote, long-distance loop trail, passing few signs of civilization and reaching into very isolated state forest areas. The Bucktail Path is a challenging 34-mile linear trail with a northern trailhead located in Sizerville State Park. Known for outstanding vistas of the Pine Creek gorge, the West Rim trail lies on the eastern edge of the proposed MOA Low. The Donut Hole Trail is an 89-mile long-distance backpacking trail paralleling the West Branch of the Susquehanna River in the Sproul State Forest. It is one the most rugged of the state’s backpacking trails. All of these routes, proffering an abundance of wildlife and solitude, are located in an area appropriately deemed the Pennsylvania Wilds.
With 2.1 million acres of public land, the Pennsylvania Wilds is one of the largest blocks of forest between New York City and Chicago, and home to two National Wild & Scenic Rivers, the largest wild elk herd in the Northeast and some of the darkest skies in the country. Nearly a quarter of Pennsylvania’s state parks and more than half of state forestland are in the 12-county PA Wilds region. The Duke MOA Low overlays its very core, where wilderness qualities are highly manifest.
According to the draft FONSI, “during each sortie, aircraft would be down in the low altitude ranges between 500 ft to 100 ft for 2-3 minutes per activation.” Due to the intensity of noise, KTA believes that is 2-3 minutes too long.
While we greatly value the services and sacrifices of our military, the sublime natural attributes of the MOA Low area make it unique, affording hikers immersive experiences largely unavailable elsewhere in the state. Tranquility may be undervalued in the modern world, but it is an endangered quality. . . a rare and priceless experience.
In examining visitor experiences of wilderness soundscapes, Penn State University researchers found “. . . mechanized aircraft sounds were consistently some of the most annoying and unacceptable sounds evaluated by visitors.” Prior studies, cited by the authors, suggest anthropogenic noise pollution masks natural sounds and has the potential to detract from quality visitor experiences in wilderness settings.[1] Other research on the effects of aircraft on outdoor recreationalists discovered, “Those who made an effort to get to a natural setting (e.g. a multi-day walk) were more likely to have strongly held negative views about aircraft.”[2]
If the hiking experience deteriorates because of low flyovers, some hikers won’t return and others won’t bother coming at all. The stakes are high for a region promoting quality, nature-based recreation. According to the PA Wilds website, even Howard Zahniser drew inspiration from this very region to pen the Wilderness Act of 1964, protecting lands around the country to leave them “untrammeled by man.” Zahniser certainly would have viewed low-altitude sorties as trammeling the pristine attributes of the PA Wilds.
Silence means money for local communities. “Hiking and backpacking have considerable economic impact. According to the US Bureau of Economic Analysis, climbing, hiking, and tent camping accounted for more than $6 billion in economic impact in 2017, an 8.4 percent increase over 2012. Extrapolating findings from a 2011 Appalachian Trail pilot survey . . . researchers concluded that two million annual visits generated between $125 and $168 in spending.”[3]
The aforementioned Penn State research affirmed the importance of natural sounds. Natural soundscapes contribute to animal abundance, ecological functions, and a variety of psychological human benefits. They’re also important to a variety of visitor experiences (e.g. birding) in protected areas.[4]
While the draft FONSI describes avoidance and mitigation measures by limiting flight times, duration, and altitude, a substantial span of the year would be affected by training flights and the FONSI acknowledges that flights would increase overall sound levels at wilderness areas, state parks, and state forests. The assertion that “The Proposed Action would have less than significant adverse effects” seems, based on limited data, to be highly suspect.
Millions of public dollars have been invested in the PA Wilds region to foster a sustainable, nature-rich destination for visitors and a peaceful, prosperous locale for those who call the Wilds home. This progress may be compromised by the current proposal.
For all these reasons, the Keystone Trails Association opposes the Duke Low MOA as presented and requests public meetings in each of the impacted counties to allow area residents and stakeholders an opportunity to have all their questions answered. Open and transparent discourse is a must. We also believe more analysis, in the form of a rigorous environmental impact statement, should be conducted to fully ascertain the implications of the Duke MOA Low proposal.
On behalf of the individuals and organizations listed below and all our membership, thank you for the opportunity to comment. We hope our concerns and recommendations are given the utmost consideration.
Sincerely,
Brook Lenker
Executive Director
[1] Miller et al.Visitor Experiences of Wilderness Soundscapes in Denali National Park and Preserve. International Journal of Wilderness, August 2018, Volume 24, Number 2.
[2] Booth et al. Measuring the effects of aircraft overflights on recreationists in natural settings. Wellington, N.Z.: Dept. of Conservation, 1999. P. 25.
[3] https://thetrek.co/heres-trails-become-important-boosters-local-economies/
[4] Miller et al.Visitor Experiences of Wilderness Soundscapes in Denali National Park and Preserve. International Journal of Wilderness, August 2018, Volume 24, Number 2.
[2] Booth et al. Measuring the effects of aircraft overflights on recreationists in natural settings. Wellington, N.Z.: Dept. of Conservation, 1999. P. 25.
[3] https://thetrek.co/heres-trails-become-important-boosters-local-economies/
[4] Miller et al.Visitor Experiences of Wilderness Soundscapes in Denali National Park and Preserve. International Journal of Wilderness, August 2018, Volume 24, Number 2.
