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Finding of No Significant Impact:Unmanned Aircraft System Training from Fort Carson to Pinon Canon Maneuver Site,ColoradoApril 2020IntroductionThe congested airspace above Fort Carson prevents a full range of realistic training ofCombat Aviation Brigade (CAB) and other military units operating Unmanned AircraftSystem (UAS). The available training area for UAS operations needs to be expandedoutside of Fort Carson’s restricted airspace (R2601) in order to maintain an appropriatemilitary readiness posture. Fort Carson is proposing to take advantage of changes inFederal Aviation Administration (FAA) regulations to use national airspace between FortCarson and Pinon Canon Maneuver Site, and over PCMS, for operations and training ofUAS.Description of the Proposed ActionThe proposed action is that UAS training occur in the National Airspace Systembetween Fort Carson and PCMS for Gray Eagle and similar UAS. The UAS wouldtravel in any FAA approved airspace class. UAS training flights would follow all FAAand Army requirements and regulations and will occur at 13,000 feet mean sea level orhigher. Once at PCMS, the UAS would practice targeting (there would be no ordnanceonboard), surveillance, communications or other information gathering tasks inaccordance with Department of Defense Directive 5200.27 (Acquisition of InformationConcerning Persons and Organizations not Affiliated with the Department of Defense).The proposed action accounts for the activities of the UAS while in flight. There aremany other connected actions that take place in order to get the aircraft in and out ofthe National Airspace System, as well as to operate the UAS. The analysis of theEnvironmental Assessment (EA), and this Finding of No Significant Impacts (FNSI),tiers to previous environmental analysis and incorporates the documents by reference(32 CFR 651.1 (d)(3)). The Gray Eagle and other UAS, along with associated facilitiesand the stationing of personnel have been analyzed in previous environmentalassessments as is discussed in Section 1.6 of the EA.No Action AlternativeThe No Action Alternatives means that training in Fort Carson’s restricted airspacewould continue but no UAS training in National Airspace System would occur.Public ReviewPursuant to 651.14(b), Title 32 Code of Federal Regulations (Environmental Analysis ofArmy Actions), the Army made the Environmental Assessment (EA) and Draft Finding ofNo Significant Impact (FNSI) available to the public for 30 days starting on March 4,2020 prior to a final decision. A Notice of Availability (NOA) of the documents was

announced in local media for three days. The documents are available online ml#three.There were four comment letters received on the EA and FNSI. The comments wereused to identify any concerns about the effects on the environment. The commentshelped Fort Carson identify three areas that needed clarification. First, the reason for nomitigation requirements was clarified as well as reinforcing that training will follow allFAA and Army safety requirements. Second, in response to concerns over the types ofUAS that the EA analyzes for a citation was added that provides clarity about theclasses of UAS. Finally, the description of No Action alternative was edited to clarify thedifferences from the Proposed Action alternative. These changes have beenincorporated into this EA and FNSI.Summary of the Environmental ConsequencesNo significant impacts are anticipated as a result of implementing the Proposed Action.The potential impacts have been broken down into four categories: beneficial, none (orno impacts), negligible, minor, moderate but less than significant, or significant. Theseare summarized in Section 3.1 of the EA. There were several Valued EnvironmentalComponents (VEC) that were dismissed from detailed analysis. These included landuse, air quality and greenhouse gases, water resources, soil and geology, socioeconomics, traffic and transportation, airspace, facilities, utilities, and hazardousmaterials.The effects of noise on communities would be negligible. The UAS training would occurabove 13,000 feet mean sea level which is on average 8,000 feet above ground level inthe area training would occur. At this elevation, the UAS would be all but inaudible tomost people.There would be no effect to cultural resources because of the elevation of the training.There would be no audible noise or vibrations felt that could affect cultural resources orsites.There would be no effect to biological resources. Effects of aircraft flight to wildlife,including big game and migratory birds, takes place at less than 2,500 feet aboveground level. The training will occur on average at 8,000 feet above ground levelhaving no effect on biological resources.Mitigation MeasuresThere are no mitigation measures required to avoid or minimize environmental harmbecause the effects of the Proposed Action are negligible to none without mitigation.UAS training flights would follow all FAA and Army requirements and regulations. Allsafety precautions required by the Army and the FAA will be followed, including flight2

Environmental Assessment for theUnmanned Aircraft System Training from Fort Carson to Pinon CanonManeuver Site, ColoradoApril 2020Fort CarsonDirectorate of Public Works, Environmental Division

Contents1Introduction . 11.1 Background . 11.2 Current Conditions . 21.3 Actions Considered for Cumulative Effects . 41.4 Purpose and Need . 51.5 Scope of Analysis . 81.6 Related Environmental Documents . 81.7 Public Involvement . 91.8 Agency and Tribal Consultation . 91.9 Decision to be Made . 102 Proposed Action, No Action Alternative, and Alternative Screening Criteria. 102.1 Proposed Action . 102.2 Connected Actions . 112.3 No Action Alternative . 122.4 Screening Criteria for Alternatives. 123 Summary of Environmental Consequences and Proposed Mitigations . 123.1 Valued Environmental Components and Focusing of the Analysis . 124 Affected Environment and Environmental Consequences . 234.1 Noise . 234.2 Cultural Resources . 264.3 Biological Resources . 284.4 Environmental Consequences Summary . 294.5 Proposed Mitigation Summary . 295 Acronyms . 316 List of Preparers . 327 References . 33Appendix A: Emergency Procedures. 34iii

TablesTable 1: National Airspace System Classes. . 4Table 2: Need for analysis by VEC . 15Table 3: Summary of cumulative effects by VEC. . 29FiguresFigure 1: Diagram illustrating the multiple uses of the airspace above Fort Carson. . 3Figure 2: Analysis Area and proposed STYX route. . 7Figure 3: Average 24-hour noise level from transportation and aviation noise onal-transportation-noise-map. 24iii

1 Introduction1.1 BackgroundThe purpose of this Environmental Assessment (EA) is to document the environmentalimpacts of Unmanned Aircraft System (UAS) training off Fort Carson in the NationalAirspace System and the Pinon Canyon Maneuver Site (PCMS).The congested airspace above Fort Carson prevents a full range of realistic training ofCombat Aviation Brigade (CAB) and other military units operating UAS; therefore, theavailable training area for UAS operations needs to be expanded outside of FortCarson’s restricted airspace (R2601) in order to maintain an appropriate militaryreadiness posture. With approval from the Federal Aviation Administration (FAA) andabiding by all requirements and regulations, Fort Carson is proposing to use nationalairspace between Fort Carson and PCMS, and over PCMS, for operations and trainingof UAS. As of November 2018, only the Gray Eagle at Fort Carson is approved by theFAA to operate in Class A, E, and/or G airspace along the STYX Route to transitbetween Fort Carson and PCMS. In the future, Fort Carson may request additional oralternate routes between Fort Carson and PCMS or above PCMS for the Gray Eagle(MQ-1C) or other similar class UAS, with FAA approval. The FAA can modify the flightpath for any number of reasons or Fort Carson could request a change to increasesafety.This opportunity to improve UAS training and Soldier readiness at Fort Carson is aresult of recent regulation changes by the FAA. Training on UAS was limited torestricted airspace until the FAA issued 14 Code of Federal Regulation (CFR) Part107.41 on June 28, 2016 (effective August 29, 2016), which amended the regulation toallow the operation of UAS outside of restricted airspace. Until that time, Fort Carsoncould only perform live training for Gray Eagle within existing restricted airspace at FortCarson. The restriction has limited the training opportunities for Fort Carson Soldiersbecause the restricted airspace is heavily used by all aviation assets and has a limitedarea of operations. The Army has begun to qualify/certify their UAS pilots forInstrument Flight Rules (IFR) operations, per FAA requirements, so they can fly in thegreater National Airspace System. This, and the rule change in 2016 to allow for UASin the greater National Airspace System, are the reasons Fort Carson is proposing touse the newly available airspace for training.The only option to get a UAS to PCMS prior to the regulation change, was todisassemble it and move it by truck or rail. This method of transit will still continue as anoption for the Shadow (RQ-7B) UAS, but is not practical for the Gray Eagle, whichrequires a hardened/paved surface runway for launch and recovery, which PCMS does1

not have. Also, UAS operating at PCMS are currently limited to flying within therestricted airspace (R2603) which currently has a ceiling of 9,999 feet mean sea level(MSL), or about 5,000 feet above the average terrain. The most effective way to useGray Eagle UAS to meet mission and training requirements is at elevations normallyhigher than that, which further restricts the training opportunities at PCMS if trying toremain within the maximum ceiling of R2603.1.2 Current Conditions1.2.1 UAS Use and InfrastructureThere are several types of UAS stationed at Fort Carson, with the Gray Eagle currentlybeing the largest platform on inventory. It is a diesel powered aircraft and can weigh asmuch as 3,600 pounds with fuel and payload. The Gray Eagle is considered a Divisionlevel asset and enhances the CAB training by integrating a key combat enabler withinthe modern battle space. The Gray Eagle has multiple uses including surveillance,target acquisition, command, control, communications and intelligence collection.Although weapons capable, the Gray Eagle is not armed with live ordinances duringtraining exercises in flight at Fort Carson. Units may only install “dummy” ordnancepayloads to replicate the drag experienced on the aircraft and allow units to imitate thedegraded aerodynamics and performance of an armed aircraft.Fort Carson has four runways where UAS are launched and recovered. However, ButtsArmy Airfield (BAAF) is the only facility capable for launch and recover operations forthe Gray Eagle UAS. The airfield has a UAS hangar complex for a Gray EagleCompany. The complex includes operations and maintenance hangar with shops,storage and supply, and company administration areas. The three other airfields areused for Shadow UAS operations and lack appropriate infrastructure for Gray Eagle.Agony Airfield North is a complex with hard surface runway (too short for Gray Eagle),hangar, towers and other associated support infrastructure. The other three airfieldsare more austere and are used for the other types of UAS at Fort Carson.Specifications of the UAS currently stationed at Fort Carson can be found in the 2012Combat Aviation Brigade Environment Assessment, the 2015 MQ-1C Gray Eagle UASEA, and the 2015 Piñon Canyon Maneuver Site (PCMS) Training and Operations FinalEnvironmental Impact Statement on the Fort Carson NEPA webpage ml#three.PCMS has an airfield located near the Cantonment Area. The runway is surfaced withgravel and there are two clam shell temporary support buildings and concrete parkingapron. This airfield is not suitable for Gray Eagle because the runway is not a pavedsurface, nor does it meet the required dimensions.2

1.2.2 Airspace UseFort Carson’s restricted airspace (R2601) is congested, not just with aircraft but withartillery training and other live fire training (Figure 1). The Fort Carson restrictedairspace sees about 160,000 movements a year.Figure 1: Diagram illustrating the multiple uses of the airspace above Fort Carson.Army UAS currently operating from Fort Carson do not have unencumbered access tothe National Airspace System, unlike manned aircraft. In order for a UAS to operateunder complete Army control, the Army is required to fly within one of the special userestricted airspace designated areas above Fort Carson or PCMS, R2601 or R2603respectively. For UAS flight outside of these areas a Certificate of Waiver orAuthorization (COA) from the FAA is required. A COA allows Army UAS to fly precoordinated flight routes.Operation of UAS (such as the Gray Eagle and Shadow) are conducted at Fort Carsonwithin the existing restricted airspace (R2601). When they are launched from theadjacent BAAF (which is adjacent to R2601) an approved COA is required, and then theaircraft transits into the restricted airspace to conduct training. Fort Carson currentlyhas a COA for Gray Eagle (2018-WSA-1865 COA) to fly a path known as Route STYX3

(Figure 2) to or from PCMS at an elevation of 13,000 up to 22,000 feet MSL. Thecurrent Route STYX leaves Fort Carson at the most southeast corner heading east intoPueblo County, then continues north and east of the City of Pueblo, then continuessoutheast towards PCMS crossing above Las Animas County, then Otero County, thenback to Las Animas County arriving at PCMS. The route is approximately 82 miles.Once above PCMS, the FAA through the authority of the Denver Air Route TrafficControl Center (ARTCC), can allow the UAS to loiter in Class A airspace (18,000 feetMSL and above) above PCMS. The current COA expires in November 2020, howeverefforts are underway to renew and keep the COA active for UAS operations to continueto have access to off installation flight, as needed. The physical route will continually beassessed and adjusted based on population growth/density to ensure risk is continuallymitigated as much as possible. This EA analyses the environmental effects ofexercising the COA for the STYX route and future modifications.1.3 Actions Considered for Cumulative EffectsReasonably Foreseeable Actions in the National Airspace System are difficult to define.The actions that may have cumulative effects with the proposed action are bestdescribed using on-going activities in each airspace class.The National Airspace System has six airspace classes with different on-going activitiesassociated with each class. The classes and their uses are described in Table 1.Table 1: National Airspace System Classes.Class AAirspace System ClassOn-going ActivitiesAn en route, high-altitude space usedmainly by aircraft traveling from one areaof the country to another. All aircraft inClass A airspace must be able to operateusing Instrument Flight Rules (IFR).Airspace surrounding 29 high use airportsin the United States. It is intended to helpwith the management of air trafficactivities around airports.Airspace around any airports with controltowers and radar approaches (ColoradoSprings Airport).Areas around 120 designated airportsthat are under the jurisdiction of the localair traffic control tower to help manage airtraffic activities (BAAF Fort Carson).Class BClass CClass D4

Class EA general category of airspace intendedto provide adequate separation betweenaircraft using IFR and aircraft using VisualFlight Rules (VFR).Any airspace not designated as A, B, C,D or E airspace. Air traffic control doesnot have authority in this airspace.Class G1.4 Purpose and NeedUAS have several components which include the aircraft, payload, human operator,computer systems, communication platforms, and information displays. UAS are notactually “unmanned”, this is a misnomer. Trained professional Soldiers operate andmaintain Army UAS at all times; therefore, an Army UAS is never “unmanned”.UAS are the “eyes of the Army” and are used to quickly collect, process anddisseminate relevant intelligence and information. The Army employs UAS for many ofthe tactical, operational and strategic operations it undertakes to support Soldiers andthe mission. UAS are used for surveillance, security, command and control support,communications support, combat support and sustainment. The use of UAS reducesthe Soldiers workload, thus improving their agility, flexibility, and safety (UAS CoE,2010, Section 2.6). UAS employment also allows the United States military to reducethe risk to our military personnel during combat operations, resulting in highersurvivability rates for personnel deployed fighting for and on behalf of the nation.Technologies are changing rapidly, making UAS more and more indispensable to ourarmed forces with each improvement and technology integration. Having well-trainedoperators allows the Army to take full advantage of the upgrades during both war andpeace operations. One of the keys to well-trained personnel is the ability to performboth live and virtual training, as well as integrated training exercises (UAS CoE, 2010,Section 7.2).It is becoming more and more difficult to deconflict the restricted airspace use (R2601)over Fort Carson because of the multiple use and high demand. The restricted airspaceat Fort Carson is not large enough to support the full range of battlefield tasks ourSoldiers require to support the modern warfare. The change to the FAA regulation hasopened up new training opportunities such as flying off the installation to PCMS andover PCMS, above the restricted airspace. Expanding the training to the greaterNational Airspace System will help to alleviate this for UAS training.In order to be successful, Soldiers need to train as they fight. This includes using thefull sensor capabilities on board for navigation and to be fully trained on IFR flight. Thefull capabilities of the UAS for training in the Fort Carson restricted airspace is5

hampered due to its limited size. There is a need for more non-simulated trainingopportunities for Gray Eagle pilots, and the ability to make long distance flights usingIFR, which is often required during military and humanitarian missions, currently doesnot exist on Fort Carson.The use of the greater National Airspace System to train UAS operators will increaseSoldier skills on essential UAS tasks, improve leader decision making and increaseSoldier safety while in theater. The expanded area will also allow for additional trainingto analyze a wider variety of reconnaissance and surveillance data from PCMS andtesting of techniques and tactics not possible within the small amount of airspace at FortCarson only. Route STYX will provide opportunities for more realistic UAS operatortraining, integrating long distance flight into other battlefield tasks, and while operatingvia Satellite Communications (SATCOM), a task critical for future combat operations.6

Figure 2: Analysis Area and proposed STYX route.7

1.5 Scope of AnalysisThis EA has been developed in accordance with the National Environmental Policy Act(NEPA), regulations issued by the Council on Environmental Quality (CEQ) published in40 Code of Federal Regulations (CFR) Parts 1500-1508, and the Army’s NEPAimplementing procedures published in 32 CFR Part 651, Environmental Analysis ofArmy Actions (Army Regulation 200-2). This EA facilitates the planning and decisionmaking by the Garrison Commander. It helps the Army, stakeholders, and the publicunderstand the potential extent of environmental impacts of the Proposed Action andalternatives, and whether those impacts (direct, indirect, and cumulative) are significant.This EA analyzes the effects of the proposed action, including flying in the greaterNational Airspace System and above PCMS only. Connected actions such asmaintenance, launch and landing are analyzed in previous environmental documents(Section 2.2) and are included in the cumulative effects analysis as on-going actions.1.6 Related Environmental DocumentsFort Carson and the Army have completed several Environmental Assessments andfound no significant impacts from the use of UAS, particularly the Gray Eagle, Shadowand Raven. These are the most common platforms in use by the Army today. Astechnologies change the names and capabilities of the UAS used by the Army maychange, but the use and effects are expected to be similar to the current UAS.The 2012 Fort Carson Combat Aviation Brigade Station Implementation EA wasdesigned to implement effectively and efficiently the stationing decision, to includeensuring adequate facilities requirements were met. The Installation had to provide forthe training readiness, deployment, administrative functions, and Soldier and FamilyQuality of Life elements for those assigned to and supporting the incoming CAB thatwas to be home-stationed at Fort Carson. The analysis included flight operations andtraining of UAS (Shadow) at Fort Carson, but specifically did not include the Gray EagleUAS. In 2012, there were no extended range multi-purpose (ERMP) UAS expected tobe stationed at Fort Carson at that time.The EA for the MQ-1C Gray Eagle UAS was signed in April 2015 which evaluatedpotential environmental impacts of the Army’s proposal to construct a UAS trainingcomplex and operate the MQ-1C Gray Eagle, at Fort Carson, CO. The purpose of theProposed Action was to implement the UAS equipment, assignment and stationingdecision described in the 2014 Aviation Force Structure Realignment Record ofEnvironmental Consideration by the Department of the Army for the stationing of anAviation Regiment Gray Eagle Unit at Fort Carson, CO in 2017. The need for theProposed Action was to provide adequate facilities, training and flight operations8

capability, and support for the new equipment and for assigned Soldiers and theirFamilies.The 2015 Piñon Canyon Maneuver Site (PCMS) Training and Operations FinalEnvironmental Impact Statement (2015 PCMS EIS) evaluated the environmentalimpacts associated with training Fort Carson Brigade Combat Teams (BCTs) in fullbrigade-size exercises at PCMS, and allow additional training opportunities using newtactics and equipment. The Army purpose and need of the Proposed Action is theability to conduct realistic and coordinated large-scale training that integrates the groundand air resources of assigned and visiting units, including mechanized, infantry, support,and combat aviation assets. To accomplish this, the Army must maintain largemaneuver and training areas of varying characteristics with complex terrain. Advancesand changes in equipment and weapons systems and in their coordinated use requirechanges to the manner in which PCMS is internally configured and utilized.1.7 Public InvolvementPursuant to 651.14(b), Title 32 Code of Federal Regulations (Environmental Analysis ofArmy Actions), the Army made the Environmental Assessment (EA) and Draft Finding ofNo Significant Impact (FNSI) available to the public for 30 days starting on March 4,2020 prior to a final decision. A Notice of Availability (NOA) of the documents wasannounced in local media for three days. The documents are available online ml#three.There were four comment letters received on the EA and FNSI. The comments wereused to identify any concerns about the effects on the environment. The commentshelped Fort Carson identify three areas that needed clarification. First, the reason for nomitigation requirements was clarified as well as reinforcing that training will follow allFAA and Army safety requirements in Section 4.5. Second, in response to concernsover the types of UAS that the EA analyzes for a citation was added that provides clarityabout the classes of UAS to Section 2.1. Finally, the description of No Action alternativein Section 2.3 was edited to clarify the differences from the Proposed Action alternative.These changes have been incorporated into this EA.1.8 Agency and Tribal ConsultationIn accordance with 32 CFR 651.36 regarding other agency and organizationsinvolvement, USAG Fort Carson has provided a copy of these documents to appropriatelocal, state, and federal government agencies and Native American tribes for theirreview and comment.9

1.9 Decision to be MadeA decision will be made on whether the Proposed Action will have significant impacts.As part of the decision-making process, the Garrison Commander will consider allrelevant environmental information and stakeholder and public issues of concern raisedas part of the NEPA process. If the process results in a FNSI, the Garrison Commanderwill document his or her decision on which alternative to implement, which would besigned no earlier than 30 days from the publication of the NOA of the Final EA/DraftFNSI (see Section 1.7 above for information on the NOA publications). Upon adetermination that there are no significant impacts, the Army would sign the FNSI andcarry out the decision.2 Proposed Action, No Action Alternative, and AlternativeScreening Criteria2.1 Proposed ActionFort Carson is proposing that UAS training take place in the National Airspace Systembetween Fort Carson and PCMS, and above PCMS for the Gray Eagle (MQ-1C) orother similar class UAS (Class 4), with FAA approval. Classes of UAS are described inEyes of the Army: U.S. Army Roadmap for Unmanned Aerial Systems, 2010-2035(Army UAS Center of Excellence, 437.pdf).The current COA from the FAA allows the Gray Eagle to travel along Route STYX inClass A, E and/or G airspace. However, the analysis in this EA will cover a wider areafor potential flight paths to account for any future adjustments to the routes or additionalroutes that may be authorized by the FAA in the future (Figure 2). The FAA can modifythe flight path for any number of reasons or Fort Carson could request a change toincrease safety.The UAS would travel in any FAA approved airspace class. UAS training flights wouldfollow all FAA and Army requirements and regulations and will occur at 13,000 feet MSLor higher. When flying in Class A airspace (18,000 feet MSL or above) the aircraftwould operate using IFR flight plans and only in visual meteorological conditions, but ifrequired to fly between 13,000 feet and 17,999 feet MSL visual flight rules (VFR) wouldapply and a chase aircraft would be required. Once arriving at PCMS the UAS will flywithin the boundary of PCMS in Class A airspace above the restricted airspace R2603.Once at PCMS, the UAS would practice targeting (there would be no ordnanceonboard), surveillance, communications or other information gathering tasks.Surveillance and information gathering and analysis training will only occur on data10

gathered from PCMS or Fort Carson properties. Department of Defense Directive5200.27 (Acquisition of Information Concerning Persons and Organizations not Affiliatedwith the Department of Defense) restricts the collection of data on the civilian populationunless there is a national defense reason and the Secretary of Defense is the approvalauthority.2.2 Connected ActionsConnected actions are those that are closely related [to the proposed action] and shouldbe discussed in the same environmental document (32 CFR 651.51 (a)(1)). Theproposed action

The UAS training would occur above 13,000 feet mean sea level which is on average 8,000 feet above ground level in the area training would occur. At this elevation, the UAS would be all but inaudible to most people. Th