NOTE: SMAAC wrote the following letter to MAC on May 22nd, which was the day MAC announced its noise update assumptions and held its first and only scheduled meeting for "public input". This letter has never been acknowledged, much less considered by the Commission or the Planning and Environment Committee, although it was hand-delivered to MAC at the "public input" meeting where it was asserted by Mr. Chad Leqve that all oral and written comments received would be considered BY THE COMMISSION. At the June meeting of MAC, SMAAC inquired if this letter had been distributed to all Commissioners [yes], discussed by the P&E Committee prior to their meeting that "recommended" assumptions to the full Commission [no], or reported by MAC's Counsel or Senior staff [no].
Thank you for the opportunity to address your Noise Control Program update process. The South Metro Airport Action Council is the oldest citizen’s organization around Minneapolis/St. Paul (MSP) airport. SMAAC gives voice to MSP’s nearby neighbors and other Minnesotans who depend on air travel in their businesses or personal lives. Our members have served on MASAC, attended your meetings, and studied numerous MAC plans and reports and the law, rules, regulations, and precedents that underlie them.
Since 1996, MAC has several times announced plans to review or update the Noise Control Plan for MSP and held open meetings. SMAAC always appeared, asked questions, and expressed concerns. However, updates were always postponed. While these meetings perhaps helped to inform us about your plans, there is little evidence that information from the population most affected by your operations and proposed changes thereto was material to Commission decisions, approvals, or policies. In the case of your Noise Control Plans and Environmental Impact Statements, documentation of comments by SMAAC, other organizations, and impacted individuals has been sparse in plans and Commission mimutes.
We understand it is difficult to parse and summarize individual inputs, but therefore it is unwise for Commissioners to depend on staff digests and interpretations. We think surrogates for residents, such as city representatives on NOC, are not as free to present concerns, because their role is to meet and agree with airline members for the municipal government. We are aware that assumptions and projections are crucial to modeling airport operations and noise impacts, but heretofore the most important projections were not shared with the public and have not been questioned. This must be corrected, therefore:
SMAAC respectfully suggests that MAC’s public hearings be conducted more formally, in the manner of legislative committees, with a dialog directly between Commissioners and witnesses. A public representative should be allowed to question, or advise the Commission how to question, staff and industry witnesses during their testimony. A record of these hearings should be kept in a manner as is customarily required by Federal agencies, to be available for later review in appeals to your findings and decisions before the approving authorities.
SMAAC also recommends that cities eligible to name representatives to NOC be consulted about alternative policies or plans, finding knowledgeable witnesses, and suggesting questions.
FOR THE BOARD OF DIRECTORS
James R. Spensley, President