Madison mayor requests issues to be addressed in final EIS for F-35s

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MADISON, Wis. (WMTV) -- Madison’s mayor is requesting the United States Air Force to address several issues in order for her to support the potential placement of a squadron of F-35 jets at Truax Field Air National Guard Base.

Mayor Satya Rhodes-Conway released her official comments and questions for the draft environmental impact statement (EIS) on Friday, Nov. 1. Friday was the deadline to submit comments to the USAF on the draft EIS.

The Air Force will release a final EIS in February 2020.

According to the draft EIS, the jets would increase noise for those living near Truax Field. During take-off, the jets can reach 110 decibels or more which is the equivalent of standing next to a car horn. According to the report, the noise would render more than 1,000 homes incompatible for residential use.

Critics say the noise produced from the jets will be a nuisance for east side residents. Proponents cite the jobs and other economic benefits the jets will bring to Madison.

Rhodes-Conway said the Common Council wished the following concerns to be addressed in the final EIS.

  1. Neighborhood characteristics
  2. Noise issues
  3. Cultural issues
  4. Water issues
  5. Hazardous materials

Rhodes-Conway stated she “submits the following substantive comments with expectations that they will be addressed in the Final EIS, and the Secretary of the Air Force will reconsider listing Truax Field as a preferred location before making a final decision on where to bed-down the F-35 fighter jets.”

Process Concerns
Rhodes-Conway said there were flaws in the EIS process. She said the Air Force and Air National Guard held its only public meeting far from where most residents will be negatively impacted. She also said there was no document translation or interpreters for non-English speaking residents.

The meeting was held at the Alliant Energy Center on Sept. 12. Hundreds of Dane County shared feedback on the draft EIS and the meeting lasted five hours. It consisted of an informational open house and three hours of oral testimony.

The meeting came after a city staff analysis was released Sept. 10. The analysis stated the impacted neighborhoods on Madison’s North Side have high concentrations of minorities, poverty issues, and low-income housing.


Rhodes-Conway requested the Air Force to further evaluate the impacts of F-35s on children in daycare centers, schools, and special needs programs in the area. She said city staff feel that the EIS examines low-income residents and minorities, but understated their significance.

“While the 50 percent minority rate may be a national standard for environmental impact statements, it appears to be a very high bar for measuring impacts on communities of color particularly in Madison and Dane County, where persons of color make up 26 percent and 20 percent of the population respectively,” said Rhodes-Conway.

She asked the Air Force to use a different definition to examine the impact of F-35s.

Impact on Public Housing Investments

Rhodes-Conway cited the various investments into affordable housing in the neighborhoods near Truax Field. She requested the final EIS to take into the account of the investments and the potential impact of the beddown on them.


The mayor also raised concerns about per- and polyfluoroalkyl substances (PFAS). She requested existing contamination to be investigated and documented as well as developing a management plan before any construction is done at Truax Field.

Rhodes-Conway wants the Air Force and Air National Guard to cooperate with the Wisconsin Department of Natural Resources to complete the steps and comply with regulations.

PFAS are a widely used class of chemical compounds found in firefighting foams, nonstick cookware, water-resistant clothing, food packaging, carpet and upholstery. Madison Water Utility said the compounds are extremely difficult to break down and are now showing up in dust, air, groundwater, lakes, rivers and streams.

In a July 2018 letter to the WDNR, the 115 Fighter Wing accepted responsibility for conducting investigations into potential PFAS contamination on two former fire training burn pits located at International Lane and Darwin Road and another on Person Street. The mayor said no additional work has been done on either site.

Rhodes-Conway said the city has five requests:

  • The environmental site investigation into PFAS contamination to be completed under Wisconsin Department of Natural Resource.
  • The 115 FW shall obtain WDNR approval of a Material Management Plan (MMP) prior to the start of any construction.
  • the City of Madison wants PFAS contamination resulting from actions on the 115 FW to be fully remediated under WDNR supervision
  • The City requests that the 115 FW honor its commitment to conduct these historic burn pit site investigations no later than FY2020.
  • the EIS specifically outline how the 115 FW will cooperate with the WDNR to: complete the PFAS site investigation, safely manage materials during construction, and remediate the remaining PFAS contamination.

Rhodes-Conway stated additional construction at Truax Field would lead to flooding in the Starkweather Creek Watershed. She asks for compliance to the city’s stormwater regulations and requirements. She inquired about the Air Force’s stormwater management standards

She also asked for the financial and environmental impacts of remediating PFAS at the site to be included in the final EIS.


The mayor said the sound modeling in the EIS is confusing and raised huge concerns in the community. She requested more specific information on the proposed F-35 operations at Truax Field, including number of flights, sound contours, the use of afterburners, and on sound mitigation for mobile home parks.

Environmental Concerns

Rhodes-Conway was concerned the Cherokee Marsh Conservation Park and Cherokee Marsh State Natural Area was in the impacted area, but it was not considered in the draft EIS.

She raised concerns about potential impacts to federally- and state-protected species and wants it to be considered in the final EIS.

“Once the true potential environmental impacts of an F-35 bed-down at Truax Field are known, it is incumbent on the USAF/ANG to consider carefully its choice of preferred location,” said Rhodes-Conway. “If there are options that represent less harm to communities and the environment, as it appears in the draft EIS, those options should be preferred. If preferred locations, such as Madison, are known to have significant negative impacts as shown in the final EIS, the USAF must be prepared to prevent and/or fully mitigate those impacts. Absent that, it will not be possible for me to support the selection of Madison for this beddown.”