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:
- be more to Delta's competitive benefit;
- increase fares to pay airline fees;
- increase total noise;
- use PBN/RNAV route and limit vertical-approach technology to plan arrival rates;
- 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.
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.Read more
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.
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).
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.