An Open Letter to the Metropolitan Council

Situation Summary: The Metropolitan Airports Commission (MAC) drafted an Update to the MSP Long-Term Comprehensive Plan (LTCP) last Fall as required by State law. The document was released for comment in “pre-draft form” on August 27, 2015. The MAC announced that the purpose was to identify facility needs based on MAC-forecasted numbers of passengers and aircraft operations at MSP for 2015 to 2035. The Met Council should note that the MAC adopted a forecast in advance and did not allow questions about it. The annual passenger forecast is not consistent with State economic or demographic projections.

Millions of dollars of public investment over the next several years is proceeding at MSP without Met Council review.  MAC based its Capital Improvement Plan on the forecast. which is quite a bit different than approved in the 2010 Update. 

Since July 2015, runway use intervals have been increased (fewer operations per hour) by the Converging Runway Operations (CRO) Order suspending arrivals on Runway 35 for safety when R30L was being used for departures. After the near-mid-air collision (September 2010), the FAA MSP Air Traffic Control Tower modifiedmoperations at MSP. From a LTCP perspective, neither the econmic need for more operations per hour nor the facilities that seem to be needed have been reviewed.

 For example, the MAC delayed the construction of taxiway bridges until projected daily use of MSP would require faster trips on average from gate to runway; SMAAC noted that more flights per hour, particularly  when arrivals were scheduled on 3 runways and departures limited to 2 runways, stressed ground movements as much or more.

 

 

SMAAC considers the forecasts inappropriate for the LTCP, and perhaps illegal, because:

A.  Facilities needs and costs depend on schedules for peak hours corresponding to Delta, Southwest and Spirit arrival “banks,” not yearly origin and destination passenger use;

B.  The MAC forecasts finesse the issue of operational capacity for 2021 forward which was set as <620,000 operations in 2020 by 1996 Minnesota Law, based on 50% connecting passengers;

C.  The Met Council —through the Transportation Policy Plan —is responsible by law for air services needs forecasting, including specifically commercial aviation using MSP, for planned economic growth.

At the request of the MAC, the Met Council agreed to postpone its public hearing on, and its review of, the MSP Long-Term Comprehensive Plan (LTCP) Update. The stated purpose of the delay was (only) to collect flight-path data for at least 60 days following FAA Converging Runway Operations (CRO) procedural changes, expected to be approved and in use about mid-February 2016.  The MAC said that the changes, to runway use intervals, would be minor but more or less permanent, and corrected daiy runway-use was required for noise-exposure contour-map updates under the Consent Decree.  They were wrong.

The proposed procedural changes were not approved because of safety-risk management concerns. Details are not yet available, but it seems significant that synchronizing operations on 3 rather than 2 runways, just as SMAAC had predicted, were ordered to complete th safety-risk management plan.  The MSP capacity assumption —that up to 160 runway operations per hour peak in either NW or SE flow could be safely and affordably managed —must be revised.  Use of MSP at peak hours increased —despite the small site and asymmetrical and converging runway layout  —as flights were restored after the recession, with different airlines, routes and schedules, more noise and pollution, and higher costs.

The MAC now will either seek a further delay or reconsider its plans. The Met Council MSP LTCP review in either case will be uncertain as to hourly capacity for flight operations for possibly several years. We suggest uncertainty in several forms underlies the delay, and the unknowns include Federal policies, priorities and budgets; airline financial decisions; and how many middle-class Americans will be able to afford high fares compared to those forced to curtail air travel.

The Met Council has the opportunity and the obligation to re-direct MAC planning to a realistic transportation policy plan scenario economically and environmentally. The proposed update, based on questionable forecasting, mostly supposes large changes in annual use of MSP a decade ahead. One of the costs of this supposition is the probable impact of lower overflights on the population in the next few years unless peak-hour operations and routes are limited. 

A further delay in long-term planning is unacceptable.  Neither the Met Council, the MPCA nor the :Legislature should be deferring aviation needs planning or environmental review scheduling to the airports commission.

 

 

Background. 

A. Many aspects of the MSP 2016 to 2022 Capital Improvements Plan (CIP) and 2016 Assessment of Environmental Effects (AOEE) lack a credible basis in fact or law and do not properly report environmental impacts for lack of appropriate investigation of the causes thereof. These findings were contrary to a large number of observations of overflights, runway use and profiles.

B. Most noise, air pollution and other health and environmental impacts are a result  of overflights, and current and reliable assessments of these impacts are needed, but missing.

C. References in the 2015 Draft AOEE Report to prior environmental reviews that resulted in a Finding of No Significant Impacts are misleading. Several prior noise assessments were based on models that did not include flight profiles and applied to annual operations per runway during years with  frequent significant changes in runway use, routes and rates of ascent and descent during the year.

D. The extension of this modeling to 2015 over 2014 is the stated plan of the MAC for noise impacts; The best engineering practice would be base year 2009, target-year, 2016..

E. Previous AOEEs reported no accumulations of pollutants on land or affecting water quality, but no  investigative effort was reported or scheduled in MAC budgets since 1995.  MAC staff claimed to monitor air and water quality studies in 2011, 2012, 2013 and 2014. The monitoring was an annual Memo to the Noise Oversight Committee, whose Co-Chair denies NOCs aurthority or interest in air pollution. In the absence of local studies,  the best engineering practice would be comparison with similar airports where studies were completed.*

F. The Draft 2015 AOEE is incomplete, uninformative and draws unjustified conclusions'

.

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* MAC staff subsitutes “comparable” aircraft noise intensity parameters when forecast new aircraft values are not available from FAA tests, so a claim of zero air pollution or zero changes year-to-year does not NOT comply with Minnesota or Federal air pollution regulations.s changes in Converging Runway Operations — is unlikely to have any meaningful interpretation of he validity or predictive shortcomings of the DNL standards, and most certainly will not confirm anything regarding the absence of air and water pollution.

 

 


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  • Forum Manager
    commented 2016-04-02 15:25:23 -0500
    A recent message to the MAC Chair, Dan Boivin:
    QUOTE: MAC finds it troublesome to connect air operations at MSP to global warming and air pollution. For the time being, MAC claims that MSP meets all applicable EPA and MPCA air quality regulations. We find this a little disingenius for
    future planning.

    First of all, MAC cedes aircraft and flight operations control to airlines and FAA/EPA and excluded both on-airport and near-airport emissions in the AOEE and EAs.. Second, MAC environmental reviews exclude how or if MSP operations increase
    emissions (and noise) exposure) per operation —and how capital improvements may change emissions volume per flight (more or less fuel use) as well as per day (more flights).

    As the MSP ATCT deals with the CRO to slightly increase arrival acceptances and peak-hour runway use at MSP, a counter consideration is FAA Washington policy at

    Isn’t it possible, even likely, that plans to increase per-hour capacity will conflict with reducing GHG emissions? Such as by fewer opportunities to gradual approaches, more fuel consumption and GHG emissions per departure due
    to low-altitude manuevers and longer, faster taxiing?

    What if costly MSP facility additions and improvements, as planned to accommodate increased passenger arrivals more often were built, but operations per hour are later restricted by ATC delays or costs, environmental rules, or airlines?" UNQUOTE
    Jim Spensley,

    Unfortunately, the public has very little traction dealing with MAC about operational noise and pollution. However, citizens, through Met Council and the Legislature, can offer input about MSP plans for funding needed (not excessive) flight capacity. MAC however has postponed review of its 2017-2022 capital expenditures plans and its update of the the MSP LTCP. The
    postponement includes the Met Council’s MSP LTCP Public Hearing, required every 5 years by MN Law.

    Several people asked me how “privatizing” Air Traffic Control would affect cost, safety, noise and pollution at MSP. HR4441 passed but neither Senate or White House support will be forthcoming, and the FAA Continuing Resoution was extended to September 30 this year. FYI, I attached an article.

    This Post addressed the air pollution issue separately. Federal Rules and Regulations are being drafted requiring that airport and airline operations be managed to reduce US Green-House Gases (GHG) emissions. The goal of a substantial GHG reduction requires either burning less fuel per flight hour per plane or flying fewer miles or both. GHG emissions and noise will ncrease if MSP peak-hour operations continue as they are, slightly more if the converging runway operations restoration (arrivals per hour) is done, and far more if MAC operations per year forecasts are realized as planned. In turn, warnings of
    increased mortality and healh risks near airports would incease.

    These prices are too high to pay for the convenienece of connecting passengers or airline profits.