SMAAC presented its position: operational changes that increase noise and pollution must be reviewed and alternatives evaluated that provide sufficient safe capacity and reduce noise and pollution. The presentation reiterated SMAAC's comments on the NTSB warnings about safety and the World Health Organization warnings about the inadequacy of modeling projected operations as a predictor of future health and environmental impacts.
The draft AOEE is absent any reference to operational alternatives, legal capacity, or planned deployment dates for Next Gen and PBN/RNAV. The presentation and all comments received in writing, the Chair said, ".. will be reviewed by staff and the staff recommendations considered for adopting the 2014 Assessment of Environmental Impacts at the December Commission meeting."
The Commission (or staff) have kept municipal comments on budgets and long-term plans separated from noise and pollution review. And it appears that SMAAC and other comments on the purposes of capital projects will not even be accepted for staff review or presented to the Commission. SMAAC was newly advised this year that ONLY municipalities need be invited to comment on the capital budget projects proposed for 2015 to 2021.
At the November 3rd Hearing, the Chair limited the hearing to topics in the already-drafted AOEE report. To counter this, SMAAC distributed a written presentation including the inter-relationships of noise and pollution, safety and capacity. I spoke briefly about this and invited the Commissioners to ask questions on the record -- or off-line in the next few days. If this happens, SMAAC will submit send supplementary testimony in question-answer form.
From an environmental review standpoint, operational alternatives with potentially far fewer environmental impacts are being excluded from review. The Minnesota Environmental Quality Board, the Minnesota Pollution Control Agency, the Metropolitan Council, and and the Minnesota Department of Public Health should be aware of this, and intervene.
Key technical points:
- Noise exposure and air pollution are concentrated and more harmful at peak hours or high runway use rates. The extensive departure procedure changes in 2011 and 2012 significantly increased ground noise exposure and pollutants per cubic foot per flight compared to the same operations in 2009.
- The production of noise and air pollutants is a function of the proximity and duration of operating large jet engines, defining the 'dose' per person per event-hour. The 2011-12 procedure changes increased both proximity and duration -- many more flights departing MSP turn quickly, exposing new neighborhoods and persons to higher doses per flight. The turns reduce the climb rate (increase proximity by being lower) and reduce acceleration (increase duration).
- PBN departures would maintain climb rates and progress along planned routes by constant power adjustments. The burn rate (increased power) would more than offset maintaining acceleration.