Letter to MAC

Finance, Development, and Environment Committee Electronically transmitted June 7. 2005
6040 28th Avenue South
Minneapolis, MN 55450

Dear Chair McGee and Commissioners:

The Committee received a staff memorandum (Agenda Item 9) summarizing activities "complying" with two environmental stipulation agreements (enforcement actions). These matters were not reported last November for the Public Hearing regarding the Assessment of Environmental Effects (AOEE). Questions were raised for the AOEE Public Hearing by SMAAC, but our written testimony was not discussed or acknowledged until February 2005. This testimony in part said: ŒAircraft fuels and lubricants, ethylene glycol, and various other speciality chemicals are discharged and stored subject to possible accidental or terroristic spills or ignition. The concentrations of many pollutants in airport runoff are not measured, the treatment effectiveness is unknown for many of the substances, the air-water exchange factors and the capacity and effectiveness of the effluent storage and treatment facilities was not assessed.‚

We disagreed with the staff conclusion that no EAW or EIS was needed for any capital project. We felt that the glycol emissions and fuel leaks were known and reasonably related to, or exacerbated by, construction projects, and this supported a finding by the Hearing Officer, contrary to the staff recommendation, that EAWs were needed for certain projects with this risk.

NPDES. The Staff Memo, point 6, assures the Committee that measures are in place to "... prevent glycol impacted storm water runoff to the maximum extent possible." This is nonsense. We previously testified that best engineering practices for measuring glycol (ADF) emissions to the environment would be a "budget" comparing purchased amounts and recovered amounts. This is because the tests of storm water effluent do not account for ADF transported off the airport watershed as aerosols by wind or on aircraft. Staff did not address this aspect and reported no activities of this kind. If there is no measurement of glycol use, what is the virtue of a claim of reduced use? If reduced use is measured, how hard could the math be?

Fuel Leaks. The Staff Memo, point 1,does not acknowledge the amount of the fine and its justification. And, while we were pleased to learn, point 4, that a ..."report identifying capital improvement projects that have the potential (to impact) the fuel delivery system" was written by "the parties," the memo fails to list the projects. Perhaps projects undertaken in 2006 and beyond will be assessed and a more transparent EAW process worked out?

Note: We had a chuckle over the Leak Detection Prevention Plan as it was entitled in the Memo instead, we hope, as the Leak Detection and Prevention Plan.

Here again , "the parties" include MAC and various tenants and contractors at MSP. The Committee as well as the Commission should be more involved, outside experts should have been involved, and safety concerns, if taken into account, addressed. Remedies, if they exist, should be communicated in critical detail, with a review by airport workers and visitors, local governments, and the general public taken into account.

Respectfully submitted,
South Metro Airport Action Council

Note: The MAC Staff Memo (Handout) can be found as Pages 89 to 91 of the 135 page Adobe (.pdf) document at:
http://www.mspairport.com/MAC/Public_Meetings/Finance_Development_Environment/


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