Regarding the MSP Capital Improvements Program

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 consumers 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.

Sincerely,
For The Board of Directors
James R. Spensley, President


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