MSP Capital Improvements Program, 2015-2021

SMAAC First Comment on the MSP 2015-2021 Captial Improvements Plan and

Annual Assessment of Environmental Impacts



October 29, 2014

Metropolitan Airports Commission

6040 28th Avenue South

Minneapolis, MN 55450

Metropolitan Airports Commission

Regarding the MSP Capital Improvements Program, 2015-2021

SMAAC asked the Commission to review MSP safety and site limitations earlier this year, particularly (FAA) safety risk management  status. Since 2011, hourly use of MSP at peak hours has been modified several times by the MSP FAA Air Traffic Control Tower, supposedly for safety, resulting in increased MSP capital and operating costs.

These changes undoubtedly increased noise and pollution near MSP. An increase in the average cost per passenger served for MSP is a serious policy matter. An increased cost of airport facilities and operational capacity, environmental protection, and ground safety directly and indirectly is paid by comsumers and benefits airlines more than the Metropolitan Twin Cities economy.

The purpose of most 2014-2021 CIP projects as presented are vague, limited to titles and brief descriptions of  a project itself.  This program management style CIP presentation fails to reconcile the proposed CIP with the MSP Long Term Comprehensive Plan (LTCP), the FEIS for MSP Expansion capacity limits, and various other policies and responsibilities of the Commission. The AOEE as prepared is incomplete in this regard, and insufficient for meaningful review and approval.

The Metropolitan Council’s Transportation Policy Plan, 1996 Minnesota Law, and the FEIS for MSP Expansion (1998) apply to the needed (safe) capacity of MSP. The MSP LTCP must be updated in 2015.

The October 10, 2014 AOEE public hearing letter asserts that all needed EAW/EIS documents have been previously approved after a public hearing. That being the case, this AOEE Hearing is to review cumulative impacts, examine proposed regulatory changes,  and plan for environmental impact improvements. FAA/EPA rules require adoption of less costly alternatives that result in the same or greater reductions of noise and pollution.

A "cap” on flights per hour would be less costly, safer, more than adequate for commerce, and engender more airline competition, each a significant benefit compared to operations as they are today. As public entities, the FAA and the Commission are required by law to consider the public welfare, including economic opportunity, public health and safety. and environmental protection along with air transportation.  This consideration with respect to specific MSP CIP projects is impaired by the “rock-scissors-paper” arguments presented to the Commission before and during the AOEE and CIP approval.

Please acknowledge our intent to elaborate, and schedule time for a SMAAC spokesperson to address these concerns at the November 3, 2014 Public Hearing or its continuance.



James R. Spensley, President


Metropolitan Airports Commission

October 29, 2014  Page 2 of 2


 Supplementary Notes on MSP Safe Capacity and Public Health

In 2007, FAA started Next Gen for surveillance of en route air traffic. Next Gen depends on aircraft navigation and communications equipment not yet in regular use. FAA later began a program, later re-named Required Navigation Capability, to certify the reliability and accuracy of navigation-autopilot combinations in future use by airlines once Next Gen was deployed.

A little history here is informative. Airline and military flights have long been guided across oceans and other large areas that lacked radar coverage or other surface navigation aides using in-cockpit navigation aides. For commercial and private jet flight today, signals from the global positioning satellites (GPS) most often with  interfaces to the autopilot to follow a planned course.  A variety of communications systems are used to report  en route positions. Rigorous communications protocols and equipment are used to notify air traffic control centers upon re-entering radar surveillance.  The Required Navigation Capability performance standard for these combinations of GPS and cockpit avionics allows properly programmed and accredited Performance-Based Navigation (PBN) systems to be used in the United States for point-to-point route flight plans

As the Next Gen and PBN/RNAV programs stand today, when these technologies might extend to airport air traffic control is, at best, uncertain. The Commission staff has misrepresented a National Transportation Safety Board (NTSB) warning and has not objected to route changes.

NTSB investigations found that the corrective actions amounted to an emphasis on controller awareness and publishing advisories to pilots. Aborted approaches at MSP increased. Most parallel runway departures now involve more low-altitude maneuvers. FAA is developing (actually re-purposing) cockpit displays and applying new ATCT computer programs to avoid the aborted approach conflicts. This solution, called Approach/Departure Window automation depends on the deployment of Next Gen and PBN/RNAV at airports using runways with intersecting headings.

Embedded in the 2015-2021 MSP CIP are several costly projects needed to keep up with operations at peak-hours. This raises our two questions:

1. Are current operations at MSP safe at peak hours without the planned and very costly air traffic control and airline deployments and supporting MSP facilities?

2. Is there any need and authority to expand MSP as a busier (more congested) hub and accept the public health, environmental, and economic consequences of over-expansion and continued noise and pollution per flight?

The Commission can, and should, change its strategies and plans to provide for needed air transportation services as well as to minimize off-site impacts. There is no expressed need for facilities and systems at MSP supporting frequent operations at 155+ runway operations per hour. The direct costs are passed on to local (O&D) passengers and limit economic growth.

The Commission and the Noise Oversight Committee must not continue to ignore the health studies that prove beyond a reasonable doubt that the day-night annual average noise (DNL) fails to predict serious health risks. The FAA has asserted its general authority, upheld by the US Court of Appeals, to re-route flights to protect the population. 


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