To the Editor:
On behalf of the Board of Selectmen, I recently sent the following letter to the Federal Aviation Administration to register our unanimous opposition to the aquaculture farm in Thomas Bay.
Our basis for this opposition is our concern for the safety of Trenton residents, which will be jeopardized if this permit is granted. According to the FAA’s own Advisory Circular 150/5200-33B, this is too close to the Hancock County-Bar Harbor Airport. Increased bird strikes with aircraft will be a likely result. The AC discourages aquaculture because of this risk. OysterGro cages, related equipment and waste materials are known bird attractants.
I know that this public meeting is about the application in Thomas Bay; not the already granted permit in Goose Cove. But, the Goose Cove permit and its potential 5,000 oyster cages covering 50 acres beneath the airport approach cannot be ignored. If this new permit is granted to the Bar Harbor Oyster Co., which could place oyster cages over 22 more acres beneath an approach to the airport, the increased risk will be immeasurable.
We are frustrated by the casual attitude of the DMR, Army Corps and FAA toward our lives and property, and we see the commercial profit of two local businesses as being considered more important than human life. The two main players, the FAA and Army Corps each have made excuses: the FAA says it cannot pass judgment on activities off airport property; the Army Corps says it cannot pass judgment regarding airport safety. Neither has made an effort to remedy the problem.
We cannot understand why a compromise to areas away from the airport will not be sought. And we can’t understand how profit can outweigh public safety when everything in print within government channels points to the danger in this situation.
The Trenton Select Board has learned a great deal since our debate about oyster aquaculture began in 2010. We have reviewed over 1,000 pages of documents obtained from state and federal agencies. We have researched laws, directives and guidelines, and there are many that deal with aviation and wildlife strikes. Several are significant.
In 2003, the FAA signed a memorandum of agreement with five other federal agencies, the Air Force, Army, Environmental Protection Agency, Fish and Wildlife Service, and Department of Agriculture, all agreeing to cooperate with the others in dealing with aircraft and wildlife strikes. They all signed because these six agencies know the risks that aircraft-wildlife strikes pose to aviation.
In this document, they agreed that 90 percent of wildlife strikes occur when aircraft are below 2,000 feet. They agreed that these strikes at lower elevations are especially dangerous because of high aircraft speed and low altitude. They agreed that aquaculture facilities attract hazardous wildlife and are incompatible with airports. They agreed to advise owners of non-airport facilities that are known hazardous wildlife attractants to find alternate sites. They agreed to cooperate with the airports to develop wildlife hazard management plans when potential hazards are identified. They agreed that when wildlife strike potential is identified, each agency may help the others to develop solutions to reduce the probability of strikes. And finally, they agreed that analyses relating to mitigation that could contribute to strikes should be provided to satisfy the National Environmental Policy Act (NEPA).
The FAA is required to obtain a wildlife hazard assessment when wildlife of a size, or in numbers capable of causing a strike, have access to a flight pattern. The wildlife hazard assessment for our airport, accomplished in 2010/2011, does not address oyster aquaculture. It is outdated.
A USDA manual entitled “Wildlife Hazard Management at Airports” states that “Aquaculture within the separations listed in the AC should be opposed!”
A USDA directive gives Wildlife Services responsibility to assist airports to identify and reduce hazards. It gives Wildlife Services a mission to conduct research, visit sites, monitor, make assessments, train and manage activities to minimize hazards.
The list of federal directives goes on and on regarding aircraft vs. wildlife. None of the discovery documents indicated that interagency assistance was requested by FAA or Army Corps. We were surprised at how little was done to truly examine the risk in this controversial issue.
Let’s set aside air safety. When will the EPA be asked its opinion of what 72 acres of oyster cages will do to our coastline? Has an environmental assessment ever been requested? How will the livelihood of other fishermen be protected?
We have learned a lot since 2010. We find this history appalling and ask that this time, the Army Corps be our advocate. We ask that you insist that coordination be accomplished with the other signatories of the MOA, and that you only accept a well-documented, legitimate and logical response from the FAA with regard to the Bar Harbor Oyster Co. application.
We know our government cannot guarantee our safety, but it should not fail us by deliberately making us less safe. If this permit is issued, our airport will be nearly surrounded by significant aquaculture farms, attracting enough birds to make flight a serious gamble. As you pass judgment on this application, please do not disregard public safety, and please do not abdicate your responsibility for it.
Susan A. Starr
For the Board of Selectmen