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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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MSP LTCP Update --Still Pending

FAA is stinging from (deserved) criticism about certification of the B-737 MAXs without enough sensor reliabilty stress-testing, MCAS flight testing and MCAS simulator training emphasis in Manuals.  The FAA reportedly found another software conflict of some kind according to the Seattle Times.  Groundings may not be lifted this year.
Airlines that used the MAXs have canceled hundreds of daily flights, but many passengers are finding alternative flights and routes. Delta, for example, has had an increase at MSP. At MSP,  a feedback loop --Delta is a big employer and buyer here --amplifies Delta short-term plans.   
      a] Delta does 70%+ of MSP flight operations and has by far the largest hub-connection fleet, the most income from passengers and many expenses from scheduling complexity, gate use and terminal space for baggage, cargo, counters, waiting rooms, TSA access, etc.
      b] Delta doesn't fly B-737 MAX aircraft, and SW and AA haven't used MAXs at MSP. So MSP may be experiencing a temporary increase in passengers because of the grounding.
      c] Delta bought some cheap MD-88, 90 aircraft and smaller CRJs a few years ago. Their fleet is being changed at MSP, older aircraft are being retired or sold off. New extended-range Airbus planes and slightly larger CRJs will need more tarmac and terminal space per aircraft, to be accommodated by closing some gates and expanding others.
These were smart moves for Delta because the hourly arrival capacity/hour at MSP is now 30% less than the MAC planned in 2010 because  of CRO limits. FAA will be stiffening the CRO limits at MSP, according to a statement in NOC minutes (15 May meeting, July publication, approved without comment 17 July). The Tower, with MAC's tacit approval, has been experimenting with decreasing runway use intervals at MSP for years. The announced plan apparently reduces departures further to increase arrivals, but as we already new, arrival rates were usually smaller than the Delta connection-fleet banks and many flights are now scheduled well before 6 AM.
How smart it is for the Twin Cities metro economy, MSP overflight emissions effects and the MAC CIP and long-term growth depends on how much the new safety reality affects costs per passenger. There really should have been some public and open planning done since 2014 (when the MSP LTCP Update for 2015-2025 was due. Facility planning is supposed to be based (Minnesota Law) on metro Twin Cities economic growth over time (demographics, business and industry, etc.). Operational safety risks, passenger accommodation budgets, economic forecasts and other long-term planning needs are more important than noise exposure maps. it is foolish for the 6 cities represented on the NOC to attempt negotiate runway use rates hour-by-hour with the User representatives. 
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Demanding a healthy urban environment

Any time you complain about unusual overflights in Minneapolis, unfortunate city, state and federal policies turn overflight complaints into noise complaints. Can air pollution or dangerously low or erratic flights be mollified by sound insulation? If you are complaining about an extra-loud overflight every night around 10 PM, you do not qualify for sound insulation. The disturbing noises you hear now only qualify for yhe MAC Sound Mitigation program if MAC models the exposure as 63 DNL, This usually means  by being overflown about 1,000 times a month for three years running, with the average flight's overflight noise intensity ~at 95 decibels peak and over 65 dbA for 8 seconds as typically modeled. 
Why is Minneapolis accepting this?  The same reason the City supported MSP Expansion in 1996: the people wanted something done about noise and the business interests wanted to travel easily (not really possible anymore due to TSA) and attract visitors to stadia and convention centers. 
As a bonus, the sound-insulation program provided good constuction jobs, fixed up homes and increased income tax, sales tax and propety tax revenues.
But you know, don't you, that: Quiet skies can be the "blanket" skies that increase climate change. Quiet skies are not necessarily clean skies, Quiet skies are not automatically safe skies, but the more skies are congested the less safe they are.
Skies are, however, being made noiser, more polluting and probably less safe by the FAA "eficiency" policy, a safety-risk-added, high airport cost and not-yet-ready high-tech program (Next Gen) so far badly missing  all its promised security, cost and deployment schedule goals near any urban airport, and you indirectly pay for the costs in your airfare. Also, you or your insurer or the State pay the incremental health care costs caused by pollution and climate changes due to more, lower, or less-efficient overflights.  
If you don't like it, help SMAAC. --And don't vote for candidates that support the airline-airport self-serving policies and high-profits. 
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Met Council GHG Reduction Policy

Kudoes to the Metropolitan Council for promoting clean enegy initiatives by cities and counties and public agencies (except MAC?). 

For nine years, Met Council has not reviewed MSP plans to restore some hourly flight capacity and allow airlines to further concentrate connecting fleet operations in consecutive hours because these plans remain sequestered by MAC.

MetC hasn't accepted evidence that routing flights in MSP airspace at higher operational rates steeply increases fuel burn volume and reduces fuel efficiency. An estimated 40 percent increase in carbon particulates and GHG emissions per flight is associated with lower, slower and longer flight paths around MSP --to allow less than 10 percent more operations per hour. This is because there has been no Public Hearing on MSP Long-Term planning and capital investments and the likely environmental impacts and land use restrictions since 2010.

A slight increase in MSP use as a major hub probably would result in more carbon emissions than a total switch to wind and solar power for city requirements would save in, say, Minnetonka or Richfield.


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B-737 MAX 8 at MSP

        The public is stymied trying to get information on B-737 MAX's taking off at U.S. airports after the groundings.  Stranded B-737 MAX's began taking off at after it became clear that the technical issues and finger-pointing would not be quickly resolved. 
The original fix idea --a software update --could be installed anywhere. 
       Now, the public is, naturally, worried about an urban crash by a "grounded" aircraft. In Orlando, a "MAX-8" had to quickly turn back and make an emergency landing.The Orlando Sentinal matter-of-factly wrote that groundings applied to commercial passenger flights only. That missed the point: the public wasn't told --or warned --that not-yet-fixed Max's would be flying over populated areas. Storage space is limited around airports generally and B-737 MAXs were parked at airline expense. So the airlines began "ferrying" them to cheaper airfields where now it is expected thagt sensor, control panels, swirches or motors may be replaced or modified.
        That is the point: airport authorities do not consider overflight hazards their reponsibilty. 
        We uncovered more facts about the Orlando emergency landing:
1. Southwest had FAA (not airport authority) OK for ferrying B-737 MAXs to Victorville, CA, about 85 miles northeast of Los Angeles. SW and Boeing were collecting MAXs to be fixed and re-certified. Either the fix is more complcated than a software update or the grounded aircraft were in the way of airport operations.
2. The FAA is investigating the Olando incident, but Southwest said that "engine trouble" was the cause of the emergency.
3. Five B-737 MAX aircraft were grounded at Orlando International. 
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Delayed MAC Appointments

SMAAC is very concerned that millions of dollars have been spent, and many millions more planned, for operations and facilties at MSP since the last-reviewed capital improvements program was funded. Indeed the 2011-2016 programs were soon amended implying changes to the MSP LTCP last approved in early 2011 (CIP numbers for 2011-2017).

Met Council and the airports commission acted improperly, and failed the public directly, by postponing the required TPP Public Hearing and indirectly by proceeding, perhaps illegally, with capital improvements supporting a much higher annual capacity than planned in prior LTCPs. 
The situation was not improved by delaying MAC Chair and Commissioner appointments. Commissioners with expired terms are voting on budgets and not raising the issues of updating plans or transparency.
Public health and safety is theatened by oveflights at closer than needed intervals. Safety risk management (emergencies more likely ) and MSP facilities expense, if based on a high "surge capacity" will be a disservice to the Twin Cities economically.  Surely State oversight and public discussion is needed.
MAC apparently still belives the 2014 CRO safety order will be revised, after 5 years: several amendments were proposed and rejected. Why have the MSP LTCP and the Metro TPP been postponed and public hearings delayed?  Why shouldn't the public know specifically what public costs and benefits might result from restoring a few more scheduled arrivals per hour? The MAC's forecast of annual use by flights and passengers does not require additional annual capacity and Minnesota law would require, in our opinion, an amendment and an EI, since an MSP flight capacity limit was determined in 1996 law and the 1998 FEIS/ROD. 
We think the 1998 theoretical operations per hour maximum (160 operations/hour, documented as 100 arrivals and 60 departures in NW flow) was speculative. The MAC never really figured out what to do as arriving aircraft accumulated in westerly flow. So what number of scheduled arrivals for the hub peak hourss is safe and affordable? The plan and justification should be public information.
What number is sufficient for economic growth?  The approved capapcity plan indicated a 25% increase over 1995 use, or about 120 to 125 operations at peak hours. Who pays for MSP operations and infrastructure? The public. Who suffers from more GHG emissions per flight? Everyone. Who benefits? Not much discussed
We think the Governor needs these answers and getting them should be discussed with his MAC appointees. 
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Airport Emission Studies

A study in progress near Seattle-Tacoma International Airport (SEATAC) found concencrated ultra-fine particulates (UFP) timed with overflights.  That is, more paticulate density (measured in a mobile sensor array) as a jetliner passed overhead. 

The data allows aviation-produced volumes to be stated as a percent of the total volume and refine exposure (dosage) to small areas for correlation with health statistics. Mobility also allows measuring under routes used in different "flow" and runway use configurations. 

The SEATAC study also expanded the USC study around LAX, with similar results.


SMAAC Note: FAA flight recordings can count flights over a small area and use height and speed data to derive the UFP density over time. If UFP emissions by density were modeled in the International Noise Model based on the above findings, there would be a high correlation with noise exposure intensity on the ground.  Since intensity (loudness) is expressed as an expotential function and density, weight and volume for particulates are linear:

1. There would be a correlation of high-DNL (or ldn) and a much higher UFP density at modeled points.

2. Per flight, UFP density at a lower DNL contour would be proportionally higher.

3. This means that UFP densities would coincide with DNL values as mapped but are more likely the cause of increased adverse health outcomes than noise intensity.



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