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Remarks on the Part 150 Noise Compatibility Program (NCP) Update

On behalf of our Board and Membership. It is troubling that the Commission will vote to submit the Part 150 Noise Compatibility Program (NCP) Update in this form, at this time, having by other actions and pending actions invalidated the premises on which it is based. 

The contour map was drawn for thousands fewer 2007 operations than are said to be needed and used to justify further-expansion plans now before the Commission (and likely to be adopted in some form). It is unclear in the Update if the NCP will be continued after 2007, and the Commission has not corrected past noise exposure maps – as common understandings of the FAR Part 150 require. It is NOT, as the Commission and staff have so often claimed, based on the Commission’s reasonable and best projections. It is NOT based on the facts in evidence, but was, as a matter of fact, developed months before review or comment by the public or even the Noise Oversight Committee. As we said at the September 7th session, the Update is not worthy of the Certification on Page 2. 

Operations were increased over 2002 by 14.3 % for January 2003 to September 2004 (8% per year), but the for-2007 contour maps are based on 3% per year growth. These numbers were not reconciled with Metropolitan or State economic growth (need) projections. It is unknown if the numbers comport with previously projected economic growth needs, because the hubbing factor trend is unreported; and, because the percent Minnesotans, and economically significant to Minnesota visitors, are not well accounted for in the formulae anyway.

SMAAC challenged the passenger use projections and the derivation of operations projections throughout the process, but comments did not reach you until after you had voted to accept your consultant's limited-by-contract projections. We noted that significant differences in noise exposure can be computed from the same number of annual operations depending on peak rates and runway use, and we said the for-2007 map is based on an extremely unlikely case.

I met with HNTB to discuss how the contours were drawn (case details such as peak-rate and runway use, number of flight tracks). HNTB confirmed that:
1. 140 operations per hour using 3 active runways accounted for 90% of all modeled operations. 
2. The number of tracks resulting from runway operations was determined from 10 days of runway data collected in 2002, which necessarily limits the accuracy of (creates errors in) "weighting" flight noise per track in the model. Note: Weighting normalizes off-track noise using 2002 data (patterns of use). Because use of 17-35 was made up, new flight tracks for existing-in-2002 runways are introduced. No Commissioner participated directly in developing the flight tracks and no questions were asked about this aspect or the resulting runway use plan when HNTB presented to NOC, to P&E, or to the Commission.

Our engineering analysis is that the INM averages event noise. If the INM were run with the only difference being the number of flights, and at least 100 operations were assigned to each flight track, there would be no difference in the plotted contours. Contours would be smaller for 1,000 CRJ flights than for 100 DC-9 flights.

The 1996 Legislature was wary that the SIP might be limited in spite of considerably more operations. They intended, as a condition of MSP expansion, a full 5 db insulation program out to then-projected for-2005 60 DNL (or actual 2004 runway use if that was the worst case under the parallels). The two-year 17-35 delay arguably converts 2005 to 2007. In 1996, MAC committed that these neighborhoods would be treated limited only by available contractors and the SIP implementation and contracting processes.

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Neighbors and SMAAC Make Noise at MAC Hearing

After first congratulating Commissioners for actually attending the public meeting – 12 of 14 were present – SMAAC President Jim Spensley blasted them for deciding key provisions in the 2,000 page document without public input, and for not asking or answering questions in this one.

Spensley told the large assembly “If past performance is our guide, the (Part 150 Update) will be adopted whatever public comments are received. The contour map (was already) used for other actions, whatever wrong assumptions are proven or input errors discovered. We can only hope FAA or other authorities intervene. 

SMAAC wrote the Commission May 22, 2003 seeking an opportunity to testify, or at least hear airport neighbors’ issues acknowledged and discussed by NOC, by P&E, or the full Commission in public before a vote.

Mayor R.T. Rybak, Councilmembers Benson and Colvin-Roy, and Representative Frank Hornstein focused on the reduction of benefits, proposed by MAC Chair Tigwell and adopted as an amendment to MAC’s 2004 to 2009 capital budget, for the “2007 64-60 DNL areas.” 

Spensley said that the draft 2007 contour map reduced those eligible, but full sound insulation was intended by the 1996 MSP expansion law by thousands of structures in both Part 150 65+ DNL areas and 64-60 areas. 

“The 1996 Legislative negotiators didn’t give a fig about the Federal compatible-use standard. They had before them the contour maps for 1995, 2000, and 2005 (and those were based on low-ball projections). The deal was full insulation or removal of 17,000 structures projected in unmitigated 69-65 DNL areas and all structures in the unmitigated 2005 64-60 DNL areas. 
He said the Commissioners “Spurred by airline lobbyists, chose 2002 as the base year for this Update, in effect crediting the tragic events of September 11, 2001 as a noise-reduction measure.” 

The prior update, submitted in late 1999, was still under review by FAA in September 2001, and use of the parallel runways in 2000 and 2001 were known to exceed MAC’s projections by half (150%) and overall use projections as well (125% approximately). 

SMAAC reported that unmitigated noise over 65 DNL frequently and continually occurred between 1996 and 2002. Even before the prior update was withdrawn, residents constantly petitioned for relief from excessive noise due to MSP expansion. 
The 1996 actual-use map revealed gross under- estimations of noise because actual use of MSP differed drastically from that modeled.

Spensley’s remark that “MAC, through the draft 2007 contour map, is telling us that airport noise in 2002 was less than it was in 1996 and greater than it will be in 2007. Be sure to let MAC know if you disagree.” was met with sustained applause from the audience.

Last year, SMAAC complained that the 2007 model was improper. MAC limited its forecast to national aviation industry data and anonymous but self-serving airline projections of MSP use and passenger demand. Spensley said tables in the update show 25,515 structures in the 64-60 DNL in the 2002 map. He remarked “Only about 215 (2.5% of single-family residences in the new 2007 map) need treatment according to MAC ‘for compatible use,’ however, about 9,000 of these structures were in 1996 unmitigated 69-65 areas.”

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Many citizens applauded Spensley’s remark about the homes left out of the first phase but told they could expect treatment in the second phase – the withdrawn 2001 update reaching the 60 DNL. Several people testified about living “just across the street” or in “left-out pockets.” A group living on between Portland and Chicago east of Pearl Park presented a petition with 83 signatures demanding the treatment MAC had told them, in 1999, to expect once the update was approved by FAA and funds were allocated.

Spensley praised Representative Wagenius and Senator Ranum for calling attention to economic provisions in the 1996 Minnesota law authorizing MSP Expansion. They said that MAC allowed Northwest Airlines to over-expand their hub, resulting in high fares here and better service in competing cities for international trade.

Minnesota Law 1996 directed MSP expansion under stringent conditions:
1. Sufficient local passenger capacity to meet projected growth and economical demand through 2020 and during the intervening years, also increasing airline competition.
2. Fully mitigate any unavoidable environmental impacts.
3. Extend the Sound Insulation Program [“SIP”] for noise mitigation during and after expansion out to the 60 DNL.

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Proposed Update to the MSP Noise Compatibility Program

The South Metropolitan Airports Action Council is a citizens’ association with a broad membership of citizens, landowners, businesses, groups, and institutions directly impacted by MSP. We are informed witnesses who monitored actions of the Metropolitan Airports Commission [“MAC”] for many years. Our comments are in three parts:

First, About This Update Itself:
1. The NCP posted for comment was not developed from the NCP approved in 1994 or within the legal proceedings required by law. It was prepared contrary to 14CFR 150.21-150.23. This so-called hearing, the Noise Oversight Committee, and untimely comments by the public at a few meetings are unworthy of the certification on Page 2.

2. Spurred by airline lobbyists and back-room discussions, MAC chose 2002 as the base year for this Update, in effect crediting the tragic events of September 11, 2001 (which temporarily reduced use of MSP) as a noise-reduction measure. 
This Update, target year 2007, reversed a previous decision, in October 2001, to keep the prior update intact (not withdraw it) because, the Commission stated, use of MSP had exceeded projected levels for 2005 and recovery at least to that level was considered certain. This proved to be accurate through 2004. 
You will recall that a year before, Halloween, 2000, airline representatives on MASAC withdrew. MASAC was disbanded, in spite of its designation as MSP Noise Abatement action #1. The only recourse for citizen input, other than frequent – and mostly unwelcome – conversations with Commissioners was monitoring commission and committee meetings..
The prior update, submitted in late 1999, was still under review by FAA in September 2001, and use of the parallel runways in 2000 and 2001 were known to exceed MAC’s projections by half (150%) and overall use projections as well (125% approximately). That Update specified NCP projects for 1996 to 2001.

3. Even before the prior update was withdrawn, MAC was constantly petitioned for relief from excessive noise arising from expansion. We argued that justice delayed is justice denied. Unmitigated noise over 65 DNL frequently and continually occurred between 1996 and 2002. This is as “measured” by contour maps published for Part 150, EIS/EAW, and Dual-Track uses, including both actual and projected flight data. Just as the 1996 base year noise exposure map revealed gross under-estimation of airport noise because actual operational use of MSP differed drastically from that modeled, the (NCP Update and the) 2007 mitigated noise exposure map is based on unlikely and potentially infeasible assumptions (centered on peak-rates required for continued hub operations), flawed methods for projections, and, it appears, favors granted to Northwest Airlines.

4. MAC limited the scope of development of the assumptions and use forecasts to national aviation industry data and anonymous but self-serving airline projections of MSP use and passenger demand.
HNTB’s contract with MAC was limited to these sources although they proposed using wider economic data and forecasts as usual in Part 150 Updates. MSP use since the 2007 passenger forecast was recommended by NOC, endorsed by Commissioners, and submitted for this review has been far above the forecast trend. The percent local passengers, which determines the PFC revenue underlying NCP projects, has not been reported even though it was a primary concern of the public and the legislature in the dual-track study and made a condition of MSP expansion in the 1996 Law and the FEIS/ROD.
Second, About Treatment of Excessive Noise in the 64-60 DNL areas. Page 2 of 2.
Many citizens are here tonight because they are outraged by changes1 already adopted by MAC in a capital improvement project. The contour map now proposed for 2007 in this Part 150 Update was already incorporated as a draft. in the revised MAC plan for 64-60 areas (part of the 2004-2009 CIP).
Originally, the public was told the full SIP was going to be extended to residences, schools, and hospitals in 64-60 DNL areas as a condition of expansion. SMAAC believes this is an enforceable condition of the 1996 law, subject only to the limitations of forecasts and projections and details of construction and schedule. Now MAC is telling us this tale: noise in the new 64 - 60 DNL areas in 2002 was less than it was in 1996. Be sure to let MAC know if you disagree. 
The connection with the Part 150 Update can be seen in Tables 5.2 [page 5-7 or sheet 138] and 5.4, [page 5-15 or sheet 146]. The Federal standards are: residences including nursing homes with the usual insulation and any School, Church or Hospital are considered a compatible use in the 64-60 DNL area. The consultant finds 25,515 structures in the 64-60 DNL in the 2002 map. 
MAC says about 215 (2.5% of single-family residences in the new 2007 map) lack the “usual (15 db) insulation” However, about 9,000 of these same 25,000 structures were in 1996 unmitigated 69-65 areas.

Minnesota Law 1996 directed MSP expansion under stringent conditions:
1. Sufficient local passenger capacity to meet projected growth and economical demand through 2020 and during the intervening years, also increasing airline competition.

2. Fully mitigate any unavoidable environmental impacts.

3. Extend the Sound Insulation Program [“SIP”] for noise mitigation during and after expansion out to the 60 DNL.
The 1996 Legislative negotiators didn’t give a fig about the Federal compatible-use standard. They had before them the contour maps based on low-ball projections for 1995, 2000, and 2005. The deal was full insulation or removal of 17,000 structures projected in unmitigated 69-65 DNL areas and all structures in the unmitigated 2005 64-60 DNL areas. In those days, diverting noise as compared to abating noise was better understood. The FEIS and ROD, 1998, imposed noise abatement conditions beyond Part 150 rules.

Third, What is Next?
If you’re hoping MAC will re-instate the Extended SIP, revise this Update, and adopt a reasonably fair noise compatibility program as a result of public pressure, you are about 500 meetings and two failed Committees behind the times. 
If past performance is our guide, the NCP will be adopted by MAC without significant change, whatever public comments are received. The Noise Exposure Map [“NEM”], contour map, has been used as a basis for other actions, and will be unmodified, whatever wrong assumptions are proven or input errors discovered. The impacted citizens can only hope FAA or other authorities intervene. You are all invited to join in SMAAC’s efforts to secure the intervention of other authorities.

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The Metropolitan Airports Commission has political direction to favor Northwest Airlines

At the State level, Northwest Airlines was shored up by huge loans. In return, Northwest was to extend its Minnesota operations, reservations centers and maintenance facilities, into economically stressed areas. In 1996, Northwest hired dozens of lobbyists to stop the dual-track process before all the facts were reported. Northwest said then they could not afford to move their maintenance base or passenger service away from Minneapolis-St. Paul International Airport. And, they said it would be unfair because competing airlines could add flights, gates, and services at a new airport easily, while Northwest had large capital investments at MSP. 

The dual-track studies, however, showed that an increase in air transportation services was essential to economic growth, job development, and participation in emerging global markets. The Legislature assigned a number to this need: the number was widely reported as annual flight operations, capacity or use, charted at five-year intervals, from 2000 to 2020. Actually, the number was local (starting or ending a trip in the Twin Cities) passengers. Minnesotans flying to visit customers, attend trade shows, check on suppliers, or buy parts and services for their businesses; buyers or tourists or convention attenders flying to Minnesota. 

Because Northwest operated a major hub at MSP, over half of the airport's passenger capacity was used by connecting passengers. Services purchased, and taxes paid, by airlines serving MSP are a small part of the airport's economic impact, but still significant. 
Northwest lobbyists lied to the Minnesota Legislature: they said larger aircraft and a higher ratio of local to connecting passengers would reduce the needed flight capacity for the same number of local passengers. 

They lied again when they said MSP expansion would allow more airline competition. 

They lied again when they said a new runway was essential for needed capacity. 

They lied again when they said that comparable capacity at a new airport would cost $1.4 billion more than at MSP. (The $4.2 billion new airport price tag was for just over double the flight and passenger capacity of MSP expanded.) 

They lied again when they said closing MSP would not lead to re-development of the site and support economic growth. (See Denver’s experience re-developing Stapleton Field.)

They lied again when they said environmental compliance could not possibly exceed a few million dollars and that noise abatement would be funded from increased passenger-fee revenues and reduced by using larger, less-noisy aircraft. 

The Legislature, skeptical of these assertions, incorporated many of them into the law, but ...

Northwest, as a matter of fact, never planned anything like this. Northwest planned to further fortify their hub. They asked MAC to add gates first, to lease them the gates at reduced rates, and to enlarge the terminal. MAC complied. Whereupon, Northwest expanded its hub, replaced many aircraft with smaller ones, and increased their hub operations by about 40%. To do this, they "dispersed" peak-hour take-offs, spreading noise and pollution over a larger area; they increased daily use of the noisiest aircraft (727s, DC-9s, and DC-10s) beginning in 1997 and continuing though 2000. Fully-loaded Northwest 747s were accommodated by runway extension.

MAC buckled under, pretending the law allowed it. Commissioners said they feared that otherwise Northwest would re-locate hub operations to Detroit or Memphis. (Oh sure, NOW they could afford to move away?) 

So, thanks to this level of cooperation with Northwest, how has the public benefitted? A few added NWA jobs, with salary concessions and other economic activity reductions for thousands of old jobs. But local business seats are still monoply priced at 130% to 140% of comparable fares in cities that compete with us for economic development. Where are all thestart-up businesses? 

There are fewer scheduled airlines, not more, serving MSP than in 1996. It is just wondrous, isn't it, what cooperation can be developed between a large, financially troubled corporation and a "public" agency like MAC. Who appointed these guys?

SMAAC maintains, with ROAR -- Residents Outraged About (Airport) Racket --and with a national organization.

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SMAAC Proved Right

Yesterday, airport Commissioners listened to various elected officials and dozens of ordinary citizens and ignored everything they heard. SMAAC listened while Commissioners explained their positions, leading SMAAC President Jim Spensley to comment. "You (the Commissioners) would not recognize the September 9 as a 'public hearing' if you attended. MAC has never held a real “public hearing” on noise; yet you claim the 'legislative' power to change your previous resolutions."

He said during brief remarks allowed after Commissioners had stated their positions: "Major changes in expansion of MSP, as you were told here today, must be based on facts and deliberation. 

“Commissioner Long said he was concerned about security costs (to Northwest), ignoring the fact that TSA has relieved Northwest and MAC of major security costs, shifting the burden to US taxpayers.. He seemed to have no idea that security cost increases are strongly associated with hub use of MSP, periods of far-above-average use." 

SMAAC also sees that other Commissioners lack facts. Spensley addressed Commissioner Landy's comment that he wanted a "needs test" for sound insulation eligibility. "The Commission spent millions of dollars on ANOMS and staff studies to test the computer-model projections." Spensley said. "The stations almost all show an increase in the number of loud (over 95 db intensity nearest the station) flights. This proves that overflight noise in the 'new' 64 and 63 DNL areas is greater than it was in many of the already insulated houses." 

He told the MAC that ample facts about this, and about the difference between overflights (events) and the modeled contours were presented in writing to NOC and the MAC, and are (supposedly) part of the public record and evidence. "Thanks for announcing that your deliberations have not yet included most of the facts in evidence." Spensley remarked."The Commission does not know what it is doing. You do not know the facts!"

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SMAAC Rebukes Airport Commissioners on Political Influence

The South Metro Airport Action Council was advised by a Metropolitan Airports Commissioner that Chair Vicki (Grunseth) Tigwell was orchestrating a negative vote on the Extended Sound Insulation Program at the behest of Governor Pawlenty, following a private meeting between Pawlenty and Northwest Airlines' President Richard Anderson. SMAAC President Jim Spensley noted that “No dialogue with the public, State legislators, or municipalities surrounding MSP is planned: just a simple motion to be sprung at today's P&E meeting to budget a token amount for the Extended Sound Insulation Program and to ignore Minnesota law, existing MAC policies, and assurances given by MAC to neighborhoods impacted by airport expansion."

"We received a copy of a message alleging that Pawlenty or his staff have been, and are continuing to, condition appointments to MAC on a Commissioner's pledge to go along with leadership and Northwest in most matters, because Northwest is friendly to the campaigns and goals of the IR Party as well as a major employer important to the State economy " Spensley said. "Indeed, this comes as no surprise to SMAAC. We have been aware of undue influence, as well as totally-BS noise statements by Northwest, for some time."

SMAAC says the "cover" -- that a few jobs are generated by hub expansion -- is eye-wash. "Expanding the hub disadvantages the small businesses in this area that can truly create good and enduring jobs." Spensley remarked. "Northwest requires a virtual MSP monopoly (and high fares), billions in Federal subsidies, hundreds of millions in State loans, and MAC allowing operations that are polluting and less safe to be an asset?" he asked. "Don't the Commisioners take an oath mentioning upholding the State law and Constitution?" Spensley said that the Pawlenty administration claims aviation job creation because airline employees were replaced by more US Transportation Security Administration employees and contractors, and that Pawlenty takes a pro-Northwest management position on out-sourcing airliner maintenance jobs internationally. Northwest's recent purchases of aircraft manufactured in Canada and Europe adversely affected the Minnesota companies making part s for Boeing. "Something is going on" Spensley said "but it isn't economic development."

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SMAAC Says MAC is Acting Illegally on Noise

Why not measure excess noise and treat it out to the 60 DNL contour as originally proposed? How can either of the two limited choices before you be in the public interest? If you lived under the parallel runways 50 yards outside the old and proven wrong 1996 contour, would you agree to choose between delay with a series of uncertain budget approvals or being ignored? Promises delayed now, maybe denied later? Or commitments now denied, after being acknowledged, but postponed, for years? Do you hold us ˆ and the Legislature -- simple for believing your testimony that the NCP was self-funding because PFC's increased with airport use? Do you not understand that this "compromise" is a compromise of your honor?

We agree with one part of the proposal before you: eligibility for any residential sound insulation program should not be based on projected noise exposure but on actual noise exposure. You are making phony projections of fleet mix, runway use, and number of daily operations (as manipulated and politically influenced by Northwest Airlines) your standard of fairness, and only a few of you seem embarrassed. We thank those few for their integrity, while we hope for an awakening of conscience and the emergence of a more responsible majority.

In the 1996 Minnesota Law, the Extended SIP, separate from Part 150, was to be implemented during and after construction of the new runway (1998 to 2004), as a condition of MSP expansion. The Commission made this three times negotiable with Northwest Airlines. First, the Commission dissolved MASAC at the behest of the airline. In spite of clear evidence that airport noise far exceeded that projected for 1996, your Part 150 NCP was never amended and you did less than nothing about actual noise beyond the wrongly projected for-1996 noise exposure map. We believe dissolution of MASAC, and the spending of AIP/PFC funds for staff support since, are each inconsisten t with FAR 150. Second, MAC staff, without any public notice or public input at all, agreed to reduce the planned budget for, and to delay implementation of, the Extended SIP. This was more than a year before the terrorist attacks, at a time when MSP use by Northwest was being expanded (and use by competing airlines limited), whether use were measured by passenger market share, gates leased, or percent of operations per day. We doubt the negotiation was within the lawful authority of the Commission. No one represented the public interest in these negotiations, so that was your duty. You ducked.

Third, you now entertain a recommendation by Northwest to just skip the Extended SIP. A desperate group of cities, thinking you will cave in to Northwest again, proposes to further delay the Extended SIP, with need based on a preliminary noise exposure map. The map was made from biased premises already conceded to Northwest Airlines in prior NOC meetings. We also doubt that these delays and limitations are within the lawful authority of the Commission. We believe you know representations were made by the Commission (as constituted in 1996) that MSP neighbors would be shielded from excessive noise when a trade-off was made to subject thousands of us to increased noise rather than re-locate the airport to a less-developed site. In testimony before the legislature, the Commission said if airport use continues to grow at the current rate, total noise exposure around the airport during constructio n will far exceed 1995 levels. The Commission stated publically and testified before the Legislature that MAC would continue noise abatement and noise mitigation programs specifically recognizing that more traffic would necessarily use the parallel runways until the North-South runway was completed. In effect, you proposed the Extended SIP. We see that it was adopted in Minnesota law and incorporated by reference in the ROD.

There were over 4,000 residential housing units in the 64-60 DNL using the dual-track noise map based on actual 1996 use, and more in maps prepared for the EIS in 1998. Another 2,000+ were in the 65+ DNL area under the parallel runways compared to the "Official" map. These are the maps referenced in the Record of Decision. A 5db SIP treatment, in 1998 dollars, was estimated at $42,000 per unit. MASAC noted in 1998 that there were more flights using MSP that year than had been projected after 17-35 was completed; in fact, no new runway was even needed to attain 2020 projections in annual operations . MAC ought to have updated its NCP and asked for at least $100 million in additional PFC funds (in addition to funding for noise mitigation under the new runway) and budgeted close to $250 million for the Extended SIP.

1. Excess noise is additional or unabated noise compared to projected (modeled) noise. If abatement measures succeed, or operations are reduced, both 65 and 60 DNL contours will include fewer buildings and mitigation (insulation) costs would be reduced. Reduced SIP costs are an incentive (carrot) to be earned by the airlines, and the more higher PFC's stimulate airline/airport competition, the greater the motivation (stick) for airline efficiency.

2. As well as the Part 150 NCP and various other, in fact most, environmental compliance projects.

3. The Official NCP created MASAC to ensure participation by the impacted citizens and FAA recognized the value by approving MASAC as a needed action.

4. In a widely publicized table, actual flights using MSP and the parallel runways exceeded 125% of operations as projected bt MAC, proving that more operations, not fewer, would use the parallel runways after 17-35 was opened than used them in 1996. Moreover, projected retirements of the noisiest aircraft were unrealized in 1998-99, as SMAAC noted at the time, making 1999 the worst year-case noise exposure year for Minneapolis, Richfield, Mendota Heights, and Eagan (unless 17-35 were delayed or unable to support 25% of all operations due to time-of-dayor rate demand and safety rules).

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Listening to the Neighbors

Dan Wascoe's article [Jet Noise debate ready to takeoff, Metro section, Mar 22] has the revealing quote from MAC Chair Vicki Grunseth: Commissioners "need to listen to the airlines" meaning of course, agree with Northwest. What the Commissioners need to do is listen to the airport's neighbors and follow the Minnesota law incorporating what anonymous Commissioners called a trade-off for expanding MSP (for increased hub use by Northwest Airlines) instead of building a new airport where far fewer people would be harmed by noise and other airport pollution. Commissioner Houle is right that "What this area has done clearly exceeds [federal] guidelines." In approving the Environmental Impact Statement for MSP Expansion, the Feds said, in effect: Minnesota chose a course of action that, without necessarily meeting future air transportation needs, will likely require noise mitigation for 17,000 rather than less than 1,000. Commissioner Houle is technically correct: Federal guidelines are to minimize environmental impacts.

MSP expansion costs are over $3.1 billion. A pretty high price, not including the bulk of the extra noise mitigation trade-off, mostly for Northwest Airlines' benefit. The $214 million sound insulation program to date may have "bought" negative "without delay" capacity, and local MSP users will pay higher fares (to offset cost increases). The media doesn't report that actual airline use of MSP in 2000 (524,000 operations) exceeds the capacity that Northwest and MAC claimed, in 1996, could not be attained without a new runway, or that this level of use was never mapped without assuming substantial use of a new runway. In other words, the trade-off, and the "commitment" was for a combination of noise abatement and sound insulation for long-suffering neighbors under the main runways. The issue at hand is not whether "houses in the 64-60 DNL areas as mapped for 2007 operations" deserve treatment, but that MAC chooses to ignore the facts:

There is considerable doubt that the 2007 map is reasonable. Thousands of untreated homes, apartments, schools, churches, hospitals, nursing homes, and businesses were exposed to more than 65 DNL noise, according to maps made by MAC between 1995 and 2002, and more homes and schools should have been removed or converted to more compatible use because of 70+ DNL exposures. MAC and Northwest Airlines conspired, in 2000, to both reduce Northwest's lease rates and accelerate aspects of MSP expansion that allowed increased use of the main runways. Between 1996 and 2001, Northwest was permitted to expand its control of Lindbergh Terminal gates and increase its use of the main runways at peak (hub connection) hours. The 1996 noise compatibilit y plan did not forecast this level of use; MAC said use would be less because of the limited capacity of MSP without a new runway. Another reason Northwest was able to extend its hub operations was the Commission's investment in improving the reliever airports. The name "reliever airport" refers to directing slower and smaller aircraft away from MSP so that peak use rates could be increased. Small private planes and some turboprop airliners could not "keep up" with approach traffic flow or take-off as soon after a large jetliner. By these policies, MAC steeply increased noise compared to projections and disadvantaged Sun Country (trying at the time to operate scheduled flights) and limited the facilities available for new, competing airlines such as Southwest or Jet Blue. 

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