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.

Noise Matters. It is elementary that closely spaced arrivals and departures will involve air traffic control enhancements, including, eventually, secure communications and immediately PBN/RNAV routes. "Sharing noise exposure" means sharing air pollution as increased per flight at busier hours. Public health and safety risks are increased by more routes and operations/hour. MSP has a runway geometry that creates a risk of collision (or dangerous  emergency manuevers to avoid one) due to Converging Runway headings

Excerpts from Converging Runway Operations At Minneapolis St. Paul International Airport  [Received by email from Patrick Hogan, MAC's Director of Corporate Communications and Creative Services, said to be the Summary of FAA Great Lakes Regional Administrator, Rebecca MacPherson's 'presentation' to NOC, 15 May 2019.]Background [Omitted, refers to a 2006 Las Vegas emergency caused by Converging Runways Operations (CRO), not the September 2010 MSP incident.]

"CRO at Minneapolis St. Paul International Airport. (MSP) ...The airport has a runway geometry that creates a risk of collision [or dangerous  emergency manuevers to avoid one. jrs] due to Converging Runway headings. Under certain conditions, favoring takeoffs and landings on runway 30 Right (30R) and/or runway 30 Left (30L), and landings on runway 35 into the wind achieve a higher altitude in less time on take-off and landings with shorter stopping distances [and reduced ground speeds-jrs]. ...

"Aircraft departing runway 30R and/or runway 30L could conflict with an airplane needing to go around from an aborted approach [to] runway 35. ...the ATC rulebook when there is a risk of a CRO-related collision [requires] use of the Arrival/Departure Window (ADW). This tool uses radar to show an aircraft’s position relative to [the ADW] displayed on the air traffic control screen ... At MSP, ...controllers use the ADW displayed for runway 35 to determine when a departing aircraft can start its takeoff roll from runway 30L and/or runway 30R. An aircraft cannot start its takeoff roll on runway 30L and/or 30R when an aircraft is inside the runway 35 ADW. A takeoff roll can begin after the aircraft landing on runway 35 has exited the ADW [??? I think ...completed the landing unless another aircraft approaching R35 has entered the ADW-jrs] 

"While the [ADW] CRO process has worked well from a safety perspective, it has adversely effected efficiency of the MSP runways 30L, 30R and 35 configuration at the higher traffic levels. [See arrival rates below.]  ...when the winds were from the North ... the FAA was able to achieve landing rates of 75-90 aircraft per hour [and departure rates of 68 to 83-jrs]. Since implementation of CRO requirements in 2014, the efficiency of the runway landings using the runways 30L, 30R and 35 configuration at MSP has decreased to 75-84 aircraft per hour ...because of the increased spacing between aircraft required to meet the constraints of the ADW. This increased separation has also led to ATC distributing additional arrival traffic that would have landed on runway 35 prior to the CRO mitigations to runway 30L and runway 30R [and reducing the deaparture rate-jrs]

"The FAA has worked [in the background, since 2011. jrs] with the MAC to identify [safe and efficient options]. The results of the 180-day test [January-March] have been incorporated into Standard Operating Procedure (SOP) in ...the MSP District ATC facilities ... that control air traffic into and out of the MSP airport. Because the criteria for implementing CRO is demand-based, the times that CRO may be implemented under the SOP can shift as arrival/departure banks shift [that is, airline scheduling trades off more arrivals for fewer departures per hour, impacting routes and facilities-jrs]. Likewise, new periods of CRO may be implemented as [airline schedule] demand requires. Many internal processes and controls are in place to ensure that the new CRO mitigation process supports safety, real demand, and arrival and departure efficiency. [This is oxymoronic; safe rates are always less efficient than unsafe rates and 'demand' as scheduled every day at peak regardless of wind direction is an airport capacity and safety-risk management planning issue as well as a National Airspace System planning issue-jrs]

"The FAA is in the process of evaluating the appropriate level of environmental review to assess and disclose potential adverse impacts of changes in runway use because of the implementation of CRO procedures at MSP. [There is no environmental baseline for GHG and particulate emissions associated with the routes and runway use changes set in 2011 to 2018-jrs] ...

"The agency hopes to provide the MSP Noise Oversight Committee (NOC) with an update at the September 2019 NOC meeting.  [But what if the FAA determines there will be no additional impacts?-jrs]" 

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