Peaceful Chiricahua Skies

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"Peaceful Chiricahua Skies is a local coalition of organizations, businesses, and individuals in the Chiricahua-Peloncillo and surrounding areas that are opposing expanded military training flights in the Tombstone MOA area.

Web Site:

Members of our coalition include the theCenter for Biodiversity,Friends of Cave Creek Canyon,Peaceful Gila Skies,Migration Taco, and others. PCS has no paid staff. It is an all volunteer effort supported by volunteers who are residents of the area affected. We are also relying on assistance from our coalition member organizations. (Because of our expedited need to get this effort going, it will be necessary to announce these partners over time. If you would like to join our coalition,please let us know.)

Here is more informationabout the U.S. Air Force proposal to prepare an Environmental Impact Statement (EIS) to assess the potential environmental consequences associated with optimizing the Special Use Airspace (SUA) to support aircrews stationed at Davis-Monthan Air Force Base, Luke AFB, and Morris Air National Guard Base in Arizona.

For more information, contact us at <> or 520-369-3503, or visit

www.peacefulchiricahuaskies.comor @PeacefulChiricahuaSkies on Facebook and Instagram.”


Thank You

We want to thank everyone who has shown interest in the recent Air Force proposal to expand military training operations in our area.

As a result of your involvement:

  • There was a strong turnout at the Animas meeting.
  • Scoping comments were submitted by well over 1,000 individuals. Sign-on letters were submitted that included over 35 organizations and businesses.
  • Some of our elected officials have begun to speak out against this proposal.
  • The media has started to report on the risks this proposal presents.

Now that scoping comments have been submitted, there will be a lull in the activity while the Air Force prepares the Draft EIS, which is planned to be released in the fall of 2023. After that there will be a public review and comment period, the Final EIS (summer 2024), and the Record of Decision (fall 2024).

We all should remain vigilant and active during this time. Here are things you can do:

  • Write yourelected officialsand thepublic agenciesthat would need to sign off on this proposal.
  • Report any military aircraft in violation of existing MOA rules with a demand for a response. To do this, contact the Air Force through theDavis-Monthan websiteor by phone at 520-228-3406. Note time and date,type of aircraft, and location of violation if available.
  • Send letters to the editor of your local newspapers.
  • Some of you have asked where you can donate to support the opposition to this proposal. CRC is nowaccepting donationsthat can be designated to support the opposition to the Air Force proposal.

Thank you for all of your positive energy. Together as a community, we believe we can successfully defeat this.


Peaceful Chiricahua Skies


PCS Action Alert

Letter #1

I have experienced F16 fighters flying low in the canyon - below my windows - and then accelerating as they travel NE out over the town of Portal. The effects were 1. to almost blow me off a ladder as I attempted to install a window and 2. flying so low over our home as to have dangerous results with our livestock, including spooking a horse which nearly flipped over backwards with my wife sitting on it. The F35 aircraft is, according to your own statistics, 10X as loud as the F16. This would definitely be a safety hazard in our canyon.

The idea of a Tombstone MAO to create a military training ground over the Chiricahua mountains with jets descending down to 100 feet, with supersonic flight at 5,000 feet, authorizing for the use of chaff, and lowering the release of flares to 2,000 feet will endanger our forest which for most of the year are dry and easily ignitable. This will affect many species of critical wildlife and rare species that are present in the area and that would negatively affect the birding and nature tour industries that are another main source of income for our area. The jet fighters actions might also endanger our livestock from the sound which could lead to livestock bolting accidents in a high-risk area.

To dramatically increases the size of the Tombstone MOA by 1/3 adding almost 1,000 square miles and “squaring" off the northern side of the MOA and in so doing encompassing both the town of Portal, the community of Cave Creek, and the critical birding habitat of Cave Creek Recreation Area is unacceptable. The military has thousands of acres and several historic mountain ranges already dedicated to use for the testing of munitions and aircraft. The Air Force’s own comments are: The Air Force has conducted faster-than-sound test flights since 1947, and today most Air Force fighter aircraft are capable of supersonic speed. Consequently, supersonic training flights that simulate actual combat conditions are necessary to ensure the success and survival of aircrews during wartime. However, Air Force procedures require that, whenever possible, flights be over open water, above 10,000 feet and no closer than 15 miles from shore. Supersonic operations over land must be conducted above 30,000 feet or, when below 30,000 feet, in specially designated areas approved by Headquarters United States Air Force, Washington, D.C., and the Federal Aviation Administration.

Furthermore, I will add, as a former VP to Portal’s Fire and Rescue organization, that your proposed expansion will conflict directly over the route (and altitude) that all our medical helicopters take to get from Trauma 1 hospitals to the Portal Rescue helipad where we do all our evacuations. We have been informed that helicopter service will turn around or not come due to hazards created by your training. This would mean that we can only send our patient off for a long journey via ambulance by way of Douglas. Timely air transport means the difference between life or death for our stroke, cardiac, and some trauma cases. We fly 30% of our calls. When we told the airmen at the Animas, NM, “meeting” that their proposed expansion completely covered this critical Medevac route, the airmen stated the Air Force had no idea we even had a helipad and seemed at a loss for a response besides “well the helicopters could listen for us on the radio.” This comment matches the level of response from the flight officer when I called to ask about the F16 flying low under my window, “Did you get the serial number?” These are unacceptable responses from a branch of the service that is suppose to protect its citizens. Also sending lawyers instead of well informed officers to our meeting in Animas left us feeling less than safe in your care.

I have no doubt and totally support that in today’s world we need to protect our country. But developing testing areas for these planes whose very sound level is a weapon needs to be well considered. We are not the enemy nor should we be treated as test subjects. Once again in the rush you have put the cart before the horse. I strongly oppose your MOA.


Letter #2

The public reaction has been swift to the U.S. Air Force’s (USAF)call for scoping commentson its latest plan to allow numerous military flights at 100 feet above ground level, and regular supersonic, sonic-boom-producing training flights at 5,000 feet over southeastern Arizona and southwestern New Mexico.

Despite the fact that the USAF published itsNotice of Intentonly 44 days before its EIS scoping comment deadline of March 4, and gave even a shorter time frame for the only public information meeting for the proposed Tombstone Military Operations Area (MOA), the response has been widespread. A website posted by a volunteer group in the Chiricahua Mountains, calling itself Peaceful Chiricahua Skies (PCS), has already received hundreds of signatures on itspetition in oppositionand attracted numerous endorsements ranging from local businesses and individuals to major conservation groups.

“It’s been amazing to see the energy opposing this threat to our livelihoods, our personal well-being and our protected wildlands and wildlife,” said Karen Fasimpaur, one of many volunteers working to elevate awareness of the proposal. She emphasized that the local effort, while centered around the Portal, Arizona/Rodeo, New Mexico area, represents a much larger landscape than that. According to refinements of generalized USAF maps, the boundaries around the Tombstone MOA portion of the proposal include much of eastern Cochise County plus the entire Bootheel of New Mexico, including Douglas, Bisbee, Portal, AZ, and Rodeo and Playas, NM.

“The Chiricahua and Peloncillo Mountains are some of North America’s most cherished historical and biologically diverse lands, drawing researchers from all over the world. Our region’s prehistoric, Native American and western histories, along with the peace and tranquility that we all came here to enjoy, make this proposal a threat to all our local traditions,” said Reed Peters, President of Friends of Cave Creek Canyon, one of the organizations endorsing the campaign.

The only public meeting scheduled by the Air Force for the proposed Tombstone MOA, held in Animas, NM—a tiny, remote community more than one hundred miles from the Cochise County population centers affected by the new plan—nevertheless drew a surprising crowd of more than 100 people from the sparsely-populated area.meeting photo

“The Air Force has allowed only six weeks for public comment on a plan which is likely to devastate life in many of our rural communities,” said Harold Farmer, a local resident helping with the effort. "We need more time, and the opportunity of more public meetings, for a responsible response to these dangerously far-reaching proposals.”

According to Peaceful Chiricahua Skies, its websitepeacefulchiricahuaskies.comprovides a wide range of background research, sample comment letters, petitions, contacts for elected representatives, and aphoto gallery for media use.


Letter #3

1 - I was asking one of their representatives about the engine noise from the jets and told him I was outside sitting on the ground one day and a jet flew over extremely low. The noise was so loud it hurt my ears and I had to put my fingers over them to close off the noise. He said they were flying much lower than they should. I said I was able to close off the noise but animals can't do that and in a short time could have their hearing diminished so badly they would not be able to hear dangers in their environment. I was very concerned about that.

2 - He said something like that could be reported to the Air Force and encouraged me to mention it in my comments, then went on to volunteer the following information. Hesaid someone in another community had expressed concern about jet noises and sonic booms, and the potential for them triggering large boulders to fall from rocky hills. The result of that was that the Air Force sent people to examine the hill and wound up not putting an MOA in that area. I told him my house had a cliff behind it with large boulders and it would be a concern for me as well. He said to mention it in my comments and that they would send someone to check it out and if it seems perilous enough they will cut this area out of the MOA. --------- I think there may be others in Portal and perhaps other areas who have a similar situation so I am hoping they can read this right away and mention it as well in their comments - if it applies to their situation. If anyone submitted comments last night I think they could still submit another idea or two as the deadline for comments is March 4th (postmarked that date if using snail mail). If there are enough of us with that problem perhaps they will establish the MOA elsewhere.


Letter #4

Noise and Sonic Booms

I have a problem with the engine noise of very low flying jets. One day three years ago I was working away from my house, but still in the area, and was sitting on the ground when a jet came flying by extremely low (maybe 2-300 feet above me - ?). The engine noise actually hurt my ears and I closed them off with my fingers until the jet was quite far off. The problem is that as a human I can close my ears off, but animals can’t do that. If they are exposed to such loud noises frequently they will have hearing loss and be unable to hear noises in their environment that should signal danger to them, and they will be unable to react to save themselves from that danger. Also if they are social animals they will not be able to hear communications from other members of their group.

Sonic booms could be another potential problem, possibly triggering large boulders to fall from the hillsides. As I mentioned, I have a cliff behind my house (PICTURE ATTACHED). This picture shows the house as it was being built. In this picture the house looks much farther from the cliff than it actually is.

If you look at the cliff face closely you can see large blocks (10 to 40 feet long) of rhyolite rock that could potentially be further fractured by sonic booms and come tumbling down toward the house. Below the cliff face you can see several large boulders that have rolled nearer the house at some point in the past. Although the fall of such huge rocks could be disastrous for my house, several species of wildlife regularly traverse the hillside below the cliff and could be killed by rockfall if they were there at the wrong time, so could human hikers. I AM SURE THERE MUST BE OTHER HOUSES IN THIS NM BOOTHEEL AREA AND COCHISE COUNTY AREA OF AZ THAT MIGHT HAVE THE SAME PROBLEM IF BOULDERS WERE LOOSENED BY SONIC BOOMS.



When I moved here 23 years ago there were mainly mesquites bushes with plenty of bare ground separating them. The majority of those years have been drought years, with a few good monsoon summers sprinkled here and there, and one more recent year with both a wet monsoon summer and a wet winter. Invasive grasses have moved in on at least 2/3rds of the property and surrounding open areas, and invasive saltbush has really taken hold mainly to the south of the house in recent years. Many mesquites have grown long branches that actually touch other mesquites over much of the property. Mesquites and saltbush are like gasoline on a stick, exploding in tall flames from the heat, or from embers just ahead of the fire. The Pelloncillos historically have not had many fires in many decades, but with the extreme drought of the last several years and the now very heavy fuel load, a large fire seems inevitable in the future. Although I keep a defensible space cleared around the buildings, we do get incredibly high winds in this area of the state and potential fire is always a major worry.

The worry is not just because of the heavy fuel load, but we have power outages frequently here, especially when there are high winds. Without power we can’t pump water from our wells to fight the fires. Also, there are less than a handful of local tanker trucks to fight fires, and it could take 20 – 40 minutes for them to get to a home, so if fires are widespread in the area most of us will have no help. Fires arising on private property have limited fire fighting resources. Fires starting on or spreading to state and government lands get more firefighting resources so homeowners have more of a chance when the BLM or Forest Service gets involved.

Though I realize most flares burn out before they reach the ground there is always a possibility one may not, and could cause a super fire here, ESPECIALLY IF FLARES WILL BE RELEASED AT A MUCH LOWER ALTITUDE THAN PRESENTLY (180 FEET VS. 500 FEET)! We really don’t need that extra threat, especially now during this extreme and prolonged drought, and with the high winds getting more frequent and stronger, and wind seasons lasting longer than ever before - probably due to global warming.


From my research the RR188 aluminum coated type E fiberglass used in training does not seem to be a current problem in terms of chemical pollution. Research has not shown detrimental effects from it being ingested or inhaled by animals, or inhaled by people, but I could not find any long term studies, or studies done in a high desert environment similar to ours. Chaff does fall to the ground and gets caught on plants and deposited over bodies of water. It can be in the air for up to 10 hours and, depending on atmospheric conditions, can drift several miles away from the release point. The inhalation studies I came across were on small and medium sized animals, but what about larger animals with large nostrils like HORSES AND COWS?

There is a lot of wildlife in this area, and a lot of ranchers grazing cows. Over a year or two much of the chaff in certain localized areas could be broken apart when the animals walk on it, creating smaller broken particles that could get picked up by the wind and inhaled by both animals and people. INHALING FIBERGLASS PARTICLES WOULD BE LIKE INHALING VOLCANIC GLASS AFTER AN ERRUPTION!.

Chaff takes decades to break down. I would think in the arid high desert setting of this area, with very infrequent rains, it would take even longer to break down. With the lack of rain it would sit on the surface. In this area we get frequent high winds, often over 50 and 60 miles an hour. This produces immense dust storms. They are so large that the Interstate I-10 sometimes has to be closed between here and Lordsburg! Most of the soil here is in fine particles that gets picked up by the wind, and the chaff would get picked up by it as well, AND IT WOULD GET BLOWN FOR MILES!



In the studies I read there does seem to be evidence of DERMAL IRRITATION IN RESPONSE TOAIRBORNE GLASS PARTICLES! Personally I would rather not see fiberglass used at all. Perhaps research should be done to find something else to use that would not be health threatening, or detrimental to the environment.

(iNFO. ON CHAFF was obtained from a study done at Nato's Military Training Area in Goose Bay Canada.)


Letter #5

To Whom It May Concern

I am so against these planes flying over these mountains and these desert lands in the Portal area. They will be flying over our local “biologically significant “Cave Creek Canyon and what I thought was the PROTECTED CHIRICAHUA WILDERNESS AREA. The planes have been introduced to us already with flyovers rather low and extremely noisy but irregular in time/days. The sounds certainly affect my ears and are startling to our pets, horses, cattle as well as the whole forest of wild animals. For me personally your plans would make it very difficult to live here. It would reduce property values. It will hurt our few business’ Stress caused by loud sound causes a response that includes activation of the neural and endocrine systems, resulting in increased blood pressure, available glucose, and blood levels of corticosteroids in all animals OF which I am one. page 14

Now we all are breathing the the wonderful clean fresh air. It certainly won’t be good for our lungs with the flares and chaff release. Chaff is 60% glass silicate with 40% aluminum. It falls through air to the ground. And litters along with its dispensers.

The members of this community work hard to protect our homes from fire which we have had in our mountains several times in the past decades. We had to evacuate our town during one fire. So we organized with education and hard work cleaning our properties. We are now Firewise community. And you want to release flares.

This area thrives on tourists and is know nationally and internationally for its bird species and hiking trails. Our few business that are dependent on tourist trade will be affected. Why would visitors want to come here and have jets flying low over their heads. They come here for the quiet silence of a forest and canyons. A growing number of studies have shown that visiting green spaces and being exposed to natural environments can reduce psychological stress. In the birding season our roads are filled with cars and travel groups. They buy food and meals and stop at our gallery and museum. They spend a night or two in one of the many rentals. They spend money. They won’t come here to hear the jets go overhead. I don’t think you can even relate to this it is so far from your mind set. People come here for the silence away from cities. Imagine standing with your binoculars fixed on a bird and three jets come screaming by low over your head. This will happen at any time of the day. We have many wonderful hiking trails. Imagine a hike reaching some of the higher elevations to then hear the low flying jets screaming over your head. Imagine being on one of those trails and having a chance encounter with a wild animal. You get out your camera for your photo and three jets come flying over.

Researchers come from all over the globe to study the flora and fauna of our lands. They become part of the world renown Southwest Research Station which is part of Museum of Natural History in New York City. They come for weeks, months or the season to do research on everything from mice to bats, bears, and hummingbirds to birds of prey. Their science is published. They are required to follow rules to protect the habitat. Did you know that sonic booms can rupture brains of small mammals?

I am so against your plans and I will join my community to aggressively fight this plan.


Letter #6

We, as residents and property owners of Aravaipa Canyon, and living in or closely adjacent to either Outlaw MOA/ATCAA, Jackal MOA/ATCAA, or Jackal Low MOA discussed in the “Notice of Intent”, strongly oppose changing the overflight regulations in these areas for military aircraft. We therefore support Alternative 1 – No action, Existing Airspace.

In general, Alternatives 2, 3, and 4 propose in the Outlaw and Jackal MOAs that overflights be lowered from 3,000 feet Above Ground Level (AGL) to only 500 feet AGL (or in some areas to only 100 feet AGL), allow dropping of flares to be lowered from 3,000 feet AGL to 2,000 feet AGL, and lower authorization of supersonic flights from 30,000 feet AGL to 5,000 (or 10,000 feet) AGL. Below are the specific reasons that we oppose changing overflight regulations for military aircraft in the Outlaw and Jackal MOAs.

  1. These lower overflight proposals increase the risk of wildfires caused by dropping flares from lower elevations. In 2021, both the nearby Pinnacle Fire (south of the Santa Teresa Mountains) and the nearby Telegraph Fire (south of Superior) occurred before the dry lightning season, were thought to be human-caused, and military overflights dropping flares were known to have occurred in these areas. As a result, flares are thought to be the cause of these wildfires making releasing flares from a lower elevation over the Outlaw and Jackal MOAs cause more harm and a big mistake. At this point the drought in these areas, which includes wilderness forested areas, is as extreme now as it was in 2021 making wildfires a great risk.

  1. We have had times here in Aravaipa Canyon when there were many low overflights resulting in harm and very great and potentially debilitating noise well over 100 decibels and these proposals would increase this risk. We live in a narrow canyon and the proposal would allow even lower overflights. Our BLM ranger suffered harm and lost most of her hearing for several months because of low overflights in the canyon. There is no reason for low overflights over wilderness areas, and areas adjacent to wilderness areas, where recreation for hikers and protection of the environment for wildlife should be the highest priority. The Wilderness Act of 1964 was explicitly developed to preserve federally designated Wilderness Areas, such as this one, in their natural condition and free from mechanized intrusion.

  1. Aravaipa Canyon has important populations of birds and wildlife and an invaluable population of bighorn sheep that were reintroduced at significant expense and effort by Arizona Game and Fish Department in the 1960s and again more recently (this effort is also financially supported by the Desert Bighorn Sheep Society). Bighorn sheep are part of the wilderness environment and hunted in a limited way along the Aravaipa Canyon rims. Lowering overflights would increase the disturbance to bighorn sheep behavior and negatively affect their mating and reproduction.

  1. Lowering the level of supersonic flights, many at night, would result in harm and increase the impact of sonic booms on our residents and damage buildings. Additionally, sonic booms would cause harm for hikers in the Aravaipa Canyon Wilderness and birds and wildlife including bighorn sheep. Sonic booms could cause danger for the many people who ride horseback (horses could throw their riders) and greatly disturb livestock (could cause cattle to stampede endangering both the cattle and people working them) maintained by ranchers and residents.

Thanks for consideration of our concerns. We again urge you to support Alternative 1- No Action, Existing Airspace


Letter #7

The Chiricahua Mountains are a biodiversity hotspot, recognized worldwide for their incredible plant and animal diversity and high numbers of endemic species. One of the largest biological research stations in the country, the Southwestern Research Station of the American Museum of Natural History, is located in the heart of these mountains and hosts hundreds of scientists from countries all over the world each year that come to study the remarkable biological diversity present in these mountains. Many long-term, cutting edge, and taxpayer-funded research studies are being conducted in this area and will be severely impacted by the proposed changes.

We scientists are extremely concerned about the damaging impact of the proposed project on the many threatened, endangered and sensitive species in the area.


Letter #8

I am strongly opposed to the Chiracahua Mountains area being included in an Air Force MOA.

Cave Creek Canyon is not a desolate area where planes could zoom around practicing war maneuvers and issue sonic booms without affect. It is a vibrant community encompassing a number of world famous features, which I suspect the Air Force planners were not even aware of:

1) Portal, Rodeo, and the entire Cave Creek Canyon/Chiracahua Mountain Sky Island area is a booming tourist area, where volunteers staff the Visitors Center of the Coronado National Forest 365 days a year because people come from all over the world come to camp, hike, bird watch and enjoy the scenery and unique animals, plants, insects and birds. Tourism is a large part of our local economy, and it is hard to imagine low flying jets, sonic booms, flares and chaff where people are living in tents and campers and where they have travelled, often from far away, for the peace and quiet of our local forest. Imagine being on a hike in the wilderness when a jet strafes low or there is a dogfight between two jets and one emits a sonic boom. This has been outlawed for many decades over communities and must not be allowed over ours.

2) Scientists from all over the globe come to the distinguished Southwestern Research Station, located right here in Cave Creek Canyon, and owned by the world famous American Museum of Natural History in New York City to conduct research on different aspects of the unique geology, flora and fauna, some of which are not present anywhere else in the US. In addition, the Research Station hosts many educational classes throughout the seasons for universities as well as the general public. The research depends on a healthy ecosystem which currently supports the enormous diversity of animals, plants, insects and birds. The proposed jet activity would destroy this ecosystem.

3) There are at least three astronomy villages in close proximity; in Portal, in Animas, NM, and near Granite Gap, where astronomers have private observatories housing extremely expensive equipment. They were drawn here because the area is pristine, with dark skies and good air quality. How will low flying jets and sonic booms affect their equipment and the air quality?

4) We are experiencing a severe drought, and fire is always of huge concern. There have been a number of bad fires here in the last 15 years. The flares you propose could set off a fire. And low level jet tactics are dangerous especially in such a hazardous area with canyons and rocky outcrops everywhere. I shudder to imagine the fire that would result from such a crash.

5) One of the hazards we face here daily is the distance to a hospital in case of emergency such as snake bites, heart attacks etc. We have three helicopter companies that service the area, and in fact just built a new heliport. Your jets would endanger the citizens and tourists here who often rely on reaching a major hospital quickly by making it too risky for them to fly here. I can imagine that they might decide not to service this area due to risk to their helicopters and pilots if your MOA expands to this area.

6) This is not an open, empty area. Many people live here, including my husband and I. The amount of new homes being built right now is unprecedented. We do not want to be subjected to strafing jets, sonic booms, and the degradation to our air quality from the jet fuel exhaust, flares and chaff. Would it be appropriate for jets to be performing low level tactical maneuvers and sonic booms over your house and deck while you host a BBQ? Of course not.

According to an article by Lockheed Martin, "in the 1950s and ‘60s, Americans filed some 40,000 claims against the Air Force, whose supersonic jets were making a ruckus over land. Then in 1973, the FAA banned overland supersonic commercial flights because of sonic booms—a prohibition that remains in effect speeds greater than Mach 1, air pressure disturbances around airplanes merge to form shock waves that create sonic booms, heard and felt 30 miles away."

6) This is a designated wilderness area, and shame on you for daring to disturb and destroy it. In short, you have greatly underestimated the vibrancy of our rapidly expanding community, the important international scientific research conducted here, and the amount of year round tourist/recreational activity here. Your proposed expansion of an MOA into this area would destroy all that our community encompasses and must be stopped.


Letter #9

I am writing to register strong objection to expansion of the Air Force Tombstone MOA over eastern Cochise County, the Chiricahua Mountains, and the New Mexico boot-heel Peloncillos.

The Cave Creek Canyon portion of Portal AZ area on the eastern side of the Chiricahuas has amazing biodiversity unmatched anywhere else in the western United States. This is why the American Museum of Natural History established the year-round Southwestern Research Station (SWRS) in that very unique location. The SWRS “serves scientists, students and groups that strive to conserve the World’s biodiversity and add to knowledge of the natural world” (see Since 1955 the SWRS has served biologists, geologists, anthropologists, graduate and undergraduate students. Scientists from the American Museum of Natural History and institutions from around the world conduct research at the SWRS, some of their studies have been ongoing for decades.

Several years ago, I attended a presentation by the resident biologist at the SWRS, Dr. Lanan. She highlighted the following astonishing richness of species in this area:

90 mammal species

370 bird species

75 reptile & amphibian species

20 bat species

1200+ plant species

60 species of butterflies

(not yet possible to estimate the huge number of other insect species)

Low level massively loud flyovers, sonic booms & jet air pollution will harm human residents as well as many of the species included in the list above; homes, properties and businesses are also likely to sustain damages. The Chiricahua area is extremely remote and is currently suffering from prolonged drought. Flares have potential to ignite massive uncontrollable burns with spread to inaccessible mountains & canyons. In 2019 at a Portal AZ/Rodeo NM community meeting, National Forest Service (NFS) leaders estimated a 2hour emergency arrival time from their headquarters to Portal. Residents were advised that lives of NFS firefighting teams would not be risked to save homes or businesses in this area (**this includes the American Museum of Natural History SWRS extensive facilities). Even a small accident could easily cause devastating irreparable damage.

While concerns listed above specify the Portal AZ Chiricahua area, the Tombstone MOA also includes critical areas in the Peloncillo Mountains, Baker Canyon Wildlife Refuge & Wilderness Study Area, San Bernadino Wildlife Refuge, and Animas Peaks.

I respectfully argue that in view of the (daily) likelihood for extreme damages to all life forms in the aforementioned locations, there should be no expansion to the MOA’s over eastern Cochise County, the Chiricahua Mountains, and the New Mexico boot-heel.


Letter #10

I am writing a second letter to express a specific concern if the U.S. Air Force expands the Tombstone MOA. Among other important issues, expansion would negatively affect both human residents and native wildlife due to loud noise exposure impact.

I worked as a Nurse Practitioner for 8 years conducting Department of Defense Post Deployment Health Reassessments. The PDHRA is a “health screen designed to protect and evaluate the health of those returning from combat & provides education, screening, assessment, and access to care for a wide variety of questions and concerns that Service members may have about their health” (

Service members from every active duty branch as well as National Guard & Reserves are required to have the PDHRA screen with a Nurse Practitioner (NP) or Physician Assistant (PA) 3-6 months after every deployment (the frequency pf the PDHRA requirement for each deployment increased during the duration of my time with the project). The Service Member (SM) completes his/her portion of an extensive questionnaire which is reviewed with a NP/PA who then refers the SM for treatment or further evaluation if necessary. I performed thousands of these interviews & recall many of the issues that impacted military members who served our country but note the most common:

Tinnitus (ringing of the ears) and Hearing Loss are the #1 and #2 service related disabilities. These injuries are usually a result of loud noise exposures

“Excessive exposure to noises that are too loud, too close, or experienced for too long can cause irreversible & permanent damage to hearing” ( Exposure to sounds 85 dB and above damages hearing, noise above 120dB (like a commercial jet taking off) can cause immediate pain and ear injury ( Fighter jets have been measured at 140dB (

The Department of Defense has been so concerned about Noise Induced Hearing Loss (NIHL) that some years back the Hearing Center of Excellence was established & legislated by Congress (National Defense Authorization Act) to focus on prevention, diagnosis, treatment & rehabilitation (Hearing Center of Excellence, 2200 Bergquist Dr., Suite 1, Lackland AFB, Texas 78236)

Service members are instructed to wear ear protection at all times when warned that they might be subjected to loud noise exposures (predictable or not), yet a very large number continue to suffer injury & permanent disability. Rehabilitation services and expenses for what seem like “minor” health issues are astronomical. Many of those injured suffer greatly as they have no choice but to endure life-long communication struggles because normal hearing cannot ever be restored.

It seems impossible for Arizona & New Mexico residents to be protected from Tombstone MOA expansion involving higher impact loud noise exposure when protecting Military Service members remains a tragically complex & unresolved challenge.

While residents support the military role in protecting our country, in view of the dangers referenced here and in a variety of comments submitted by many others, it seems logical to adopt Alternative 1, No action for the Tombstone MOA proposal.

Howard Topoff 2011