In February, SMAAC made an Administrative Appeal of the MSP 2014 Annual Assessment of Environmental Effects (AOEE). The EQB staff did not acknowledge the Appeal. An inquiry in May revealed that the EQB staff opinion was that the Appeal was misdirected.
Last month the Minnesota Attorney General wrote SMAAC that the Administrative Appeal was properly addressed to the EQB. SMAAC attempted to contact the EQB by telephone and by email. Notwithstanding the AG opinion, an EQB staffer wrote SMAAC this week suggesting that we take both our (procedural) appeal and the substance of our contention that the procedural error, if any, had a material effect on the AOEE findings back to the MAC.
SMAAC responded that we had been seeking a discussion of noise and air pollution increases from flight operational changes, citing correspondence from FAA the changes in overflight altitude and a definitive (we thought) scientific study connecting specific submicron particulates pollution to low-flying jet aircraft. The procedural errors were, we alleged, that the above documents were not included in the Hearing Record, the absence of public deliberation (or identification of the deliberators) responsible for the Finding of No Significant Impact.
Is Flight Safety at MSP related? We noted that the MAC staff Memo Itransmitting the AOEE Report and the record of testimony and comments to the Commissioners) suggested our environmental comments were motivated by mistaken concerns (about frequent near-simultaneous use of converging runways at MSP). SMAAC indeed expressed a safety concern in solicited comments on the MSP Capital Improvements Plan and worte the Commission several times last Summer informing them that SMAAC had specific information related to MSP safety risk management in a letter from National Transportation Safety Board Chair Chrisopher Hart.
The CIP comments were separate, not intended for the AOEE Hearing, but were included in the AOEE comments by MAC staff. The letter from Chair Hart, however, was not included in the AOEE public record either.