This is a copy of official comments made from SMAAC to Metropolitan Airports Commission regarding the MSP 2015 AOEE
SMAAC last petitioned the Commission to review MSP safety and site limitations October 29, 2014. Various changes in flight routes increased noise and pollution near MSP. The changes were initially made by FAA to “reduce air crossings” shortly after the near-mid-air collision in September 2010. However, further changes — departure runway changes, instrumented routes, and more, rather than less, flights scheduled at or very near absolute minimum intervals — increased over-flight noise exposure and concentrated emissions of pollutants.
The original explanation for the changes (2010) was said to be safer operations. This being the case, the FAA should be able to quantify the safety risks year-to-year. In fact, FAA is developing several new technologies needed to manage flights and maintain safe separations. The implication is that current operations need to be changed, and FAA and MAC plan for PBN/RNAV, Next Gen, and A/D W deployments, hopefully but not necessarily within the next 6 years, to manage and reduce risks. How much?
The MSP FAA ATCT plans increase costs, require ongoing changes for airlines and airports as well as FAA and exceed the MSP flight capacity needed (< 620,000 operations per year) and as currently planned. Safe capacity should be considered separately by the Commission for the CIP and 2015 budgets. Increased safety risk and over-capacity are not strictly environmental issues.
That being said, we are supplementing our prior CIP comments and relating the less-than-safe peak-hour flights to the AOEE reports for 2010 - 2014 — that deny any cumulative impacts or risks to the environment or public health, but ignore convincing evidence that the impacts have been far worse than stated.
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.
An amendment of the CIP and AOEE would be a start.
The Commission should join citizens in calling for at least a temporary increase in intervals and separations to reduce dangerous noise exposure, air pollution, and the risk of accidents.
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 Metropolitan 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.
Why these actions are appropriate
1. Changes are coming.
The Federal government knows that MSP flight routes have increased noise and pollution per flight since the series of route changes made (2010-14, compared to 2009). The Federal government knows with near certainty that MSP overflights now and as planned will have grave impacts beyond those forecast by noise modeling and DNL contours.
FAA can adopt flight routes that reduce noise exposure or air pollution with or without a review. It remains to be seen if future FAA budgets will support the controller and airline systems and staff training needed, or continue to rely on “situational awareness to manage risks at congested hubs.
The Commission should insist on clarifications and consider the safety and cost outcomes publicly and rationally. The draft AOEE report based on shaky noise modeling, insufficient data, and unstated emission assumptions misrepresents the noise and pollution impacts experienced since November 2010.
2. Costs are too high and getting higher.
The Commission is planning for more peak hours, although there is no airline commitment, and planned projects will most likely increase local fees and fares.
Planning to increase hub capacity without Met Council review of economic growth needs should not drive capital investment at this time. The Commission has rightly delayed some expensive projects.
The Commission apparently agreed in 2009 to hub expansion and unrealistic Next Gen and PBN/RNAV deployment schedules. The planned early tests at MSP in 2012 -13 were not revealed in the 2010 or subsequent CIPs or AOEEs.
The small and confined MSP location and the alignment and use of MSP runways complicate operational safety and severely limit abating noise exposure or reducing emissions, which, if not abated will have nearly unbounded cost implications for local public health (noise, sub-micron particle emissions) and for the US responsibility to ease global warming (carbon monoxide, carbon dioxide and other greenhouse gases emissions).
3. Safety must be the first priority.
The 2015 - 2021 CIP is to build more gates and other facilities allowing larger hub banks, leading to more time each day with over 155+ operations per hour (or if you will, more periods with 25 or more operations in 10 consecutive minutes). Logically, increasing risk, but to an extent the Commission is unwilling to inquire about openly?
There is no plan to establish the currently defined PBN/RNAV routes or deploy Next Gen technology by mid-2015. In fact, 2021 may be optimistic. MSP operations are not now excluded from EAW/EIS review per Public Law 95-112 Title II, but may be if Next Gen is deployed..
Since 2009, the MSP FAA air traffic control tower management revised and re-revised MSP procedures. The FAA’s stated purpose was to maintain minimum safe separations as often as possible (maximize runway use per hour) rather than less risky operations.
Intervals between operations at MSP as planned are unsafe or require more extensive controller/pilot training and attention to manage. An NTSB investigation determined this, and the FAA agreed to slow operations when needed. FAA is developing aircraft systems to avoid conflicts between R35 aborted approaches and R30L/R departures.
While go-arounds are rare, they are also increasing. Most days, there are over 400 R30R/L departures and as many as 300 R35 arrivals per day at MSP, almost all at peak hours. It is likely that longer than minimum intervals between R30L/R operations (alternating arrivals and departures at peak hours) are required as a consequence. The actions are part of MSP Safety Risk Management, but audit reports are not readily available.
4. Understanding the Rules.
For the purposes of the AOEE, it is assumed that eventually most operations at MSP will be "automated" using Next Gen and PBN/RNAV technologies, and the increased noise exempted from EAW/EIS review under Public Law 112-95 and the extension thereof through early 2015. The exclusion does not apply to carbon or sub-micron particulate matter emissions, which are regulated through international treaties and agreements.
Even if the needed Air Traffic Control systems were deployed, the eventual flight routes may be based on different schedules, less needed or less costly capacity, or other reasonable alternatives that accomplish the same goals at less cost and equal or less environmental impact as required by 40 CFR 1502.14(a).
The national purposes of more concentrated operations at MSP are not tied to U. S. air transportation needs by law, but by selecting MSP, in spite of its small site in a developed urban setting, as one of 32 to 35 major hubs for connecting flight routes.
A decision to reduce accident risk by increasing intervals would be lawful as well as prudent and frugal. Peak hour schedules already exceeded safe capacity when an off-peak near-mid-air collision occurred showing some of the limitations imposed without more automation (or more controller hours).
FOR THE BOARD OF DIRECTORS
James R. Spensley, President
PO Box 19036, Minneapolis, MN 55419