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Gov. Walz' Climate Change Order

Governor Walz has been confronted with decisions about various projects --pipelines, for example --as to ongoing risks of harm to the larger environment from leaks or spills that pollute streams or aquifers. He considered that climate change and global warming caused by GHG gas emissions was similar and issued Executive Order 19-37 directing State departments and agencies to reduce GHG emissions.

We have been asking the Metropolitan Council (MetC) and the Metropolitan Airports Commission (MAC) for decades to include environmental impacts from overflights as a topic in planning for more air traffic at Minneapolis-St. Paul International Airport (MSP). The MAC has unusual authorities under Minnesota law and rules for assessing the environmental impacts of MSP on-site projects, facilities, and operations:

1] the Commission may skip EAWs for smaller projects and, orginally assess cumulative impacts over time each year in the Assessment Of Environmental Effects or AOEE. The AOEE was originally a Hearing Examination to find the pertinent facts, such as the increased fuel used per boarded passenger using two regional jets rather than one B-727 to fly from Chicago Midway to MSP. Hint: 2 landings and two take-offs rather than one.

2] the Commision prepares Environmental Assessment Worksheets (EAWs) for larger projects and decides itself whether an Environmental Impacts Statement (EIS) is needed. 

Jet exhaust contains substances that pollute the air, including GHG emissions. GHG and solids from jet aircraft operations are proportional to fuel used, hours of operation and proximity, creating local health risk in addition to their global warming impact. The Environmental Protection Agency and the Federal Aviation Agency officially found that commercial avaition added significant GHG volumes to the atmosphere, proportional to fuel consumption. Both fewer miles flown and less fuel used (less GHG released per hour) are possible improvements.

Note: Fuel efficiency --consumption in "miles per gallon" --for commecial flights is a very misleading parameter. 

1. At cruise altitudes less fuel is burned per hour than at low alitudes: slightly less GHG is emitted traveling 500 miles at 36,000 feet altitude than traveling 120 miles per hour around airports!

2. Circling around an airport awaiting your turn to land is a net zero miles per gallon.

3. Flying from Indianapolis to Los Angeles via Dallas is shorter than flying via Minneapolis but longer than it used to when there was a hub in St. Louis. Still people fly from Indianapolis to LA via Minneapolis because it is cheaper --but uses more fuel and makes more GHG.


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FAA Today

Here's our view:
FAA departments are isolated. 
1. Next Gen has been, at best, slow and often changes course on goals, schedules, airlines do not always cooperate (e.g. ADS-B) and the deployments to airports and TRACON are much varied;
2. ATC operations --facing daily pressures and generally understaffed --focuses on realtime work at airport towers (for example, "efficiency policy") to get those suckers landed ASAP and accidents happen directly and indirectly in the mix; 
3. various inspections  issues (737 MAX, maintenance schedules stretched, multiple avionics versions, aging factors, etc.), out-sourcing inspections and airworthiness design and testing functions, and more; 
4. Management, where the airlines lobby and work together (collusion on schedules and fares) and deal with employees (pilots, unions), airports and FAA (directly or indirectly) in their own/industry interests;
5. Planning, where fifteen years after the recession, the NAS en route network is little changed, but has half or less connecting hubs exacerbating peak-hour planning issues (capapcity andschedules) fuel is wasted and polltion increased, and airport and airport airspace safety is unnecessarily complicated.
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MSP LTCP --SMAAC Announcement

What MSP Airport’s LONG-TERM COMPREHENSIVE PLAN Means for Climate Change

SMAAC today released an announcement that it was supporting changes across the U.S. and at MSP Airport to reduce GHG emissions.  Here are some excerpts.

"Citizens' groups and cities in several States connect the National Airspace System (NAS) to climate change now that the net increase in miles flown per trip since 2005 has been pointed out. The Special Metro Airports Analysis Center’s White Paper Air Traffic Control at Major Hub Airports and Metroplexes urged Congress to plan a National Airspace System for reasonable and responsible air traffic control, instead of trying to automate currently crowded routes.

"In many ways, Next Gen was a start-over at Minneapolis-St. Paul International Airport (MSP). Serious safety incidents were discounted by the Metropolitan Airports Commission (MAC); air traffic planning became entangled in the extended sound insulation litigation, and poor choices were made about new routes and environmental assessments near the airport.

"There may be no requirement in Minnesota law to complete a formal environmental study before negotiating “air rights” and capacity with the Federal government. So what? Cost and safety risk management can be agreed upon with GHG per flight an added benefit."



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LTCP Survey Response: Caucus Sample Resolution

Attention Members: The MSP LTCP Update schedule --late by several years -- parallel the 2020 Election schedule. So, let's take an endorsement/platform stand!  You can use the LINK below to access an editable Resolution to modify and share with the campaigns you support and the caucuses and conventions you attend.



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FAA: Airlines Trump Health and Safety

The FAA chose to ignore the impact of overflight pollution according to internal USDOT/IG documents originated by FAA. The troubled Next Gen air traffic control program elevated "industry (airline) expectations" over public health and safety.

CAUTION: While we believe that the premise is correct --FAA usually designs PBN/RNAV route procedures only to increase hourly use of runways and other airport facilities --the IG study was of Metroplex implementations, multiple airports in urban areas. 

When Next Gen could not resolve air traffic congestion in "more complex" airport and large metropolises without increasing air pollution and safety risks, they doubled down on "efficiency policy."  During the last years of the George W. Bush administration, with the Next Gen program under development --and nothing else funded --FAA anticipated an expansion of routes, along the East Coast especially, and an "airline demand" for greater runway availability at many airports. Outside of the R&D departments, air traffic control management planned to "optimize runway use at minimum separations." 

This is not news at MSP. FAA tried PBN routes at MSP soon after the September 2010 near-mid-air-collision, and the MAC maintained the illusion that environmental reviews and noise mitigation would be continued. FAA publicity featured "optimized efficient use of airport facilities and airspace," and airlines characterized noise complainers as being against the efficient and optimized flight routes needed for economic growth.

"Politicians (cynically or stupidly?) adopted the above views and did not question the MAC seriously when investigations of public health and safety or environmental impacts (GHG for example) were denied." Jim Spensley, SMAAC President 




In a bombshell and likely accidental admission, the FAA revealed the truth about how the MetroPlex and NextGen flight paths were designed 
without noise, ground safety and public impact issues being considered.  The FAA was responding in writing to an audit conducted 
by the Transportation Departments Inspector General.  The audit report stated that community noise issues were problems that were causing 
delays with the FAA's implementation of the MetroPlex program across the Country.  The FAA's response to the audits findings stated that 
after noise issues became problematic, it later changed it's processes to include those concerns in future design procedures.  But in doing 
so, it admitted that the original design processes (which were used for the Sky Harbor NextGen flight paths) only considered optimization 
of paths to benefit the industry.  Here is the text of the FAA response regarding noise concerns from page 37 of the audit report:

"In order to address extensive community concerns about new noise exposure, procedures are designed and implemented that do not maximize 
efficiency benefits, but do result in less noise exposure. When the Metroplex program began in 2010, the focus was upon optimizing routes 
and airspace design. When community concerns were included in the design equation, optimization was no longer the only consideration. It 
is an extraordinarily complex balancing act to provide both efficiency benefits to industry and to minimize new noise exposure in 
communities. These are usually competing priorities."

The FAA also went on to admit that the programs only intent was to make use of all available airspace which created new noise impacts 
over areas that previously had not experienced flight path intrusions:
"The intent of the Metroplex program was to make efficient use of all available airspace, which created new noise impacts. In many 
communities, some neighborhoods experience less noise, and some more-relieved communities generally have not recognized the beneficial 
noise reductions, while impacted communities strongly oppose the new or increased exposure."

The title of the  audit report, issued on August 27th is "FAA Has Made Progress in Implementing Its Metroplex Program, But Benefits for 
Airspace Users Have Fallen Short of Expectations".  The report goes on to say the the FAA is behind schedule in implementing the programs and 
that benefits as promised are questionable.  Other statements from the report include:

"Delays have occurred largely due to increased community concerns about aircraft noise."

"Since 2014, further delays have occurred as FAA has implemented new PBN (Performance Based Navigation) procedures at more sites, largely 
due to increased community concerns. For example, in fiscal year 2018, FAA cancelled the Phoenix Metroplex project due to litigation related to a previous PBN project."


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LTCP Survey Results

Thank you for responding and particularly for submitting ideas for actions.

  1. Over 99% of the respondents had no idea that the MAC had reorganized, appointed a Long-Term Comprehensive Plan (LTCP) Stakeholders Advisory Panel, and embarked on an 18-month process. The “never heard of the panel’ including 3 Council Members in cities that assigned staff to be on the Panel.
  2. Most respondents wanted SMAAC to hold Forums (addressing GHG emissions in particular) and organize communications programs to engage the public, and through the public, elected officials. We have a few volunteers for forum arrangements, social-media networking, and caucus resolutions.
  3. Many respondents suggested alliances with Climate Change activists and environmentalists.

The South Metro Airport Action Council (SMAAC) notified the Metropolitan Airports Commission (MAC) and the Federal Aviation Agency (FAA) that the Council intends to engage the public in monitoring the development of the MSP Long-Term Comprehensive Plan for 2020-2040. The impacted travelers and the overflown populations should be more directly consulted, interviewed, studied and consulted.

SMAAC messaged the MAC’s Planning, Development, and Environment Committee and FAA Great Lakes Regional Air Traffic Control Administrator that the public’s proper participation included questions & answers about environmental, safety and health risk changes in overflights and at MSP. The changes implemented in 2010 precipitated a ten-year delay in presenting the 2015-2025 LTCP for a Metropolitan Council Public Hearing.

The message also noted the appearance of FAA Administrator Rebecca MacPherson, who has made several visits to MSP to explain the next-to-final step in air traffic management, leaving 5-year gap. Safety changes at MSP involving landings on R-35: Runway use rates (or the interval between flight operations) are complicated by the number of runways in use and, in ‘northwest flow’ by the possibility of an aborted R-35 approach risking a collision or low altitude emergency maneuvers by entering airspace occupied by aircraft departing MSP after take-off on the parallel runways.

 Paraphrased text of the email:

MAC: Dealing with the public's questions during the planning process could make the Met C Transportation Policy Plan Hearing delay more acceptable. Public health and safety and the environment questions abound about the LTCP; economic impacts need more attention. 

The LTCP and 20 years of capital improvements will depend on EITHER the forecast daily operations being planned with balanced safe operations/hour and low safety risks OR being planned with the intent to pursue more runway-use “efficiency” and more flight capacity with whatever Next Gen systems may be deployed here and deal later with safety and too late for environmental remediation..

The two choices mentioned echo the choices considered in the dual-track studies and debated for many hours during and after legislative hearings. Those were, are: limit use and consider public health and safety, environmental impacts, and compatible zoning in the cost of flight operations before adding capacity or not. The difference is now we know the external costs are huge and the airport costs are unpredictable.

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Who are the MSP "Stakeholders?

0The Metropolitan Airports Commission (MAC) set up a Stakeholder Engagement Department and a Stakeholder's Advisory Panel on the MSP Long-Term Comprehensive Plan (LTCP). The Panel is dominated by airlines and others doing business with the MAC, a few city members --seasoned for servile cooperation by noise oversight committee routine --and a handful of government agencies and NGOs. No public or neighborhood panelists. 

Several public engagement events are planned to "inform citizens" about the LTCP progress and "listen to comments." If you've been there and done that, were your comments used in any way? The events focus on various parts of the LTCP, but are not yet scheduled.

A few years ago, to impress the Legislature and the Governor, an MSP  Vision Statement and Strategic Plan for a well-appointed and expensive destination airport --serving passengers with daily Delta flights to places Minnesotans and most destination passengers visit less than once a month.  The slickly presented Strategic Plan was apparently considered safe and healthy enough, although this wasn't mentioned.

It's clear the Converging Runway Operations (CRO) delay was used to submerge the MSP 2014 Long-Term Comprehensive Plan (LTCP) Update and at least the 2017-20 capital projects, floating long-term goals without revealing details to the public directly or to the Met Council and Legislature formally, for appropriate economic growth forecast (O&D passenger use of MSP), financial, or environmental review.

The CRO details now --stiffer safety-at-peak-hours restrictions --will:

  1. be more to Delta's competitive benefit;
  2. increase fares to pay airline fees;
  3. increase total noise;
  4. use PBN/RNAV route and limit vertical-approach technology to plan arrival rates;
  5. increase air pollution per flight with a greater GHG and overall pollution volume as passengers increase.

A MAC staff opinion is that the Minnesota Legislature intended that the MAC defer off-site public health and environmental impact statements to the FAA/EPA.  The FAA doesn’t do EAWs at specific airports. Neither MPCA or MAC is responsible for EAW/EIS or public health studies of flight operations. It appears the Evironmental Quality Board has endowed MAC with EAW authority for capital projects and immunized them against appeals.

A second assumption is that the small site will remain safe enough even if average hourly use increases to the annuaized equivalent of 800,000 to 1 million operations per year and 60 million passengers. That being the case --without a serious accident --the costs will be 3 or 4 times higher than moving to a larger site in 2001 would have been and 2 or 3 times the cost of building a second airport. now.  All of these 3 options are a risky capital investment as airline demand is fickle, not promised: airlines fail financially, real air travel demand is fare and service dependent, and the public may demand a lower public health and safety risk or more attention to GHG releases and global warming.

Aren't those assumptions worth consideration in developing the LTCP?  We think so. Drafting a plan for 18 months to be considered for 18 minutes in its only pubic hearing seems less transparent and informative than it should be considering the projected cost over 20 years.

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Feds to Stiffen CRO Rules

      Members may recall that FAA added new departure routes and planned PBN/RNAV routes in late 2010 when the theoretical peak hour  was 160 operations per hour --100 arrivals and 60 departures. This was a serious flaw in the 2010-2030 MSP LTCP. As predicted by SMAAC,this plan depended for safety on Next Gen features still under development and was less than safe or practical long-term considering that 40 or more aircraft would be parked waiting for a gate and congesting ground traffic. Evidently the disjoint between peak-hour capacity and forecast passengers, as SMAAC commented on the MSP LTCP and CIP and testified to in 2010-11 before Met Council, continues.

      It was reported on-line by the MAC Noise Department and in draft minutes released before the July NOC meeting that Federal Aviation Administration (FAA) Great Lakes Regional Administrator, Rebecca MacPherson, attended the May 15 NOC meeting and foretold a change at MSP reducing peak hour runway use in ‘northerly’ flow by 25% or more. We have not discovered when and how NOC came to be the locale, but the reported discussion was not restricted to noise exposure.

      The May 15 Noise Oversight Committee minutes suggest that FAA committed to work on finalizing the change "through the NOC." Responding to a Eagan request, Rep. Angie Craig wrote FAA's Rebeccas MacPherson requesting coordination with the NOC on noise mitigation and environmental reviews. SMAAC has made Rep. Craig aware of the 9+ year delay in assessing the cost, safety and environmental impacts of hourly and daily operation rates, PBN/RNAV routes, and MSP facilities related to capacity, airline demand forecasts and Metro economic growth needs.

      President Spensley asked MAC PR Manager Pat Hogan to clarify a few differences in the article and the minutes, and SMAAC was sent a paper "from Ms. MacPherson," with no letterhead or signature (see exrcted text below). President Spensley also had a short telephone converstion with MAC Executive Director Ryks about the above, and Ryks said that NOC was a small part of MSP planning, He also said that a "Stakeholder Advisory Committee" had been set up.

      Spensley later emailed Chair King and Ryks that "SMAAC is strongly opposed to CRO, max ops per hour, and PBN routes being discussed with FAA by the NOC in advance of the LTCP and CIP drafts."  Not NOC's job at all.

History. The MAC began projects last year to decrease the number of gates at Lindbergh Terminal to accommodate larger aircraft. Evidently the disjoint between peak-hour capacity and forecast passengers, as SMAAC commented on the MSP LTCP and CIP and testified to in 2010-11 before Met Council, continues.

In 2013, the National Transportation Safety Board warned MSP (the MAC and the ATC Tower and TRACON) that using R30L/R and R35 independently was inherently unsafe. MAC ignored the warning, publically accusing SMAAC of fear-mongering by "saying MSP was inherently unsafe" --as if we had not quoted NTSB in speech and written comments to the PDE Committee and the full commission.

In 2014, FAA suspended operations on R35 when R30L/R were active, and removed the maximum hourly operations rate oending a study. The new maximum has not been determined. Daily use of MSP in 2014-15 was such that departure delays were relieved by lack of arrival demand before or after a large arrival bank was accommodated.  The MAC began projects last year to decrease the number of gates at Lindbergh Terminal to accommodate larger aircraft.

This May, FAA revised the air traffic control Standard Operating Procedures for MSP, changing how arrivals are accepted, giving prioity to R35 arrivals (on demand) and limiting operations on the main parallel runways in NW flow. FAA says it is theoretically possible but impractical (because of limited departures) to accept 90 arrivals in 60 minutes. 75 arrivals per hour has been mentioned for the 7 AM and 4 and 6 PM arrival schedule peaks at MSP. "Demand" at those hours is from Delta Airlines and the Delta NOC Co-Chair should recuse himself from discussions of arrival rates and routes used to time them as an ethical conflict of interest, even as a noise mitigation consideration, since how flights are scheduled is a cost of capacity driver and airport capacity is an agreement between an airport and the FAA, a scheduling given.

What the Rules Allow. Our analysis is that MSP will lack the space to safely move and hold aircraft (park at gates or elsewhere) between 4 PM and 8 PM and likely between 7 and 9 AM if as many as 75 aircraft land in an hour in either flow. In SE flow, MSP could allow perhaps 60 take-offs and 80 take-offs if 60 or 70 aircraft were available and the turn-around of arrivals was swift.

Safe and affordable (costs financed by airfares do not hobble Twin Cities economic growth capacity) MSP facilities and operating costs, an annual O&D passenger goal, and increases in GHG, carbon sub-micron particulates or other overflight emissions limits, and the issue of land use or land acquisition are beyond the sole authority of MAC. 

Please complete the survey of members on actions the Board should consider to the raise public and government awareness of the stakes involved in the MSP CIP and LTCP plan updates.

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