Wisconsin environmental regulators say the Air Force has not accounted for all the environmental impacts of stationing a squadron of F-35 jets in Madison, which they contend will require a yet-unfunded investigation of existing pollution.
In a letter Wednesday, the Department of Natural Resources said the military’s draft environmental impact statement fails to address contamination of hazardous chemicals known as PFAS, which are used in firefighting foam and have been found at high levels throughout Truax Field.
The DNR also raises concerns about the impact of noise on wildlife and public lands, specifically the 2,000-acre Cherokee Marsh, nearly half of which would be subject to higher noise levels, according to the Air Force’s models.
While it mentions three construction projects near sites where PFAS have likely been spilled, the 1,099-page environmental study does not discuss the probability of widespread PFAS contamination or the need for a complete site investigation, which the DNR ordered in 2018.
The DNR said a 2018 preliminary investigation does not meet state requirements and said the extent and nature of PFAS contamination has not been determined, although results of the preliminary study indicate there is a likelihood of contamination “across much of the installation.”
The Pentagon has identified Madison and Montgomery, Alabama, as the preferred sites for two squadrons of F-35s as soon as 2023.
If selected, Truax would require up to $120 million in construction to prepare for the new planes. Planning is already underway for $34 million worth of projects that could start next year if the mission is granted.
The DNR said all planned construction projects will require a site investigation, and the National Guard may need permits for any contaminated soil or water.
The agency’s comments echo those of the city, which argues the Guard can’t “safely and legally” begin construction without a complete site investigation.
PFAS are a group of chemicals found in numerous products. Studies have shown two of these compounds may increase people’s risk of cancer and affect cholesterol levels, childhood behavior, the immune system and the ability to get pregnant.
The DNR in 2018 informed the 115th Fighter Wing, along with the Dane County Regional Airport and the city of Madison, that they were responsible for possible PFAS contamination at former firefighter training sites — known as burn pits — near the base.
The 115th agreed to take the lead on the required investigation, which it said would be done as part of a nationwide study of bases expected to be completed by September, but Capt. Joe Trovato said the Pentagon has not provided funding or authorization for the Wisconsin National Guard to conduct that investigation.
Trovato said PFAS testing would be done in connection with any individual construction project and remediation plans developed if necessary independent of a comprehensive site investigation.
“The Wisconsin National Guard appreciates the Wisconsin DNR’s comments on the draft EIS for the F-35 along with all comments from the community, legislators and other stakeholders,” Trovato said, “so that the best decision can be made not only for the Air Force, but for the surrounding communities as well.”
Friday is the deadline to submit comments on the 1,099-page EIS. A final decision by the secretary of the Air Force is expected in February, 30 days after the final EIS is released.