Remarks to the Metropolitan Airports Commission

We are here because we believe the Commission takes its duties as a public agency seriously. We have for many years addressed the MSP Part 150 Noise Control Plan and noise mitigation program. SMAAC has not addressed its concerns over your heads to the Legislature, to the FAA, or to the US Senate. Ever since 1996, SMAAC has asked the Commission to do an update. In this instance, we attempted to comment, beginning on March 22, on your update process as announced. The process raced ahead, until your June meeting, when Commissioner Boivin moved deferring approval of the use assumptions to today. SMAAC appeared at the July 17 NOC meeting, but was not recognized. We believe MAC intended that NOC meet July 23, as suggested to NOC by MAC staff, the day after the quarterly public meeting.

Commissioner Boivin said he intended to ask HNTB questions posed by SMAAC and asked that we be present at the August 6 P&E Committee meeting. HNTB was not in attendance, and Chair Houle, unaware that NOC had acted before the public meeting, did not call on Commissioner Boivin or SMAAC. Her gracious apology for that oversight was gratefully accepted. So here I am today. About SMAAC. The South Metro Airport Action Council, SMAAC, represents MSP's neighbors and passengers in 3 counties and 11 municipalities. MSP's neighbors directly impacted by airport noise &Mac246; residents and institutions &Mac246; should have as much policy access to MAC and its committees as the noise-makers &Mac246; the business and commercial airline users. What about noise between 1996 and 2006? With respect to the current Part 150 Update, we wrote you on May 22 that your limited approach to hearing public concerns is less than the standard required by FAR Part 150, Subpart B 150.21(c) and Appendix A 150.105 (a) and also not in keeping with other applicable law. The airlines, Northwest in particular, present (testify) directly, often in private. While neighbors were pleased that some changes in the existing Part 150 SIP were re-considered and that additional changes were rejected last year, we were not pleased that Chair Grunseth sought Northwest Airlines' "agreement" for spending $10 million for the SIP in 2003 or that the Commission tacitly agreed Northwest's approval was important. Northwest unduly influenced a $40 million reduction in SIP spending the year before, and MAC held no public hearing on revising its capital improvement s plan or its sound insulation plan.


Public Hearings. We respectfully suggested the public should have had an opportunity to comment on key aspects of the MSP Noise Control Program before the update process was modified by the Commission in a material way earlier this year. MAC held its first "public-input" meeting on the Part 150 Update May 22. Questions and comments were allowed, but not answered. SMAAC wanted to testify as to the burdens placed on MSP neighbors by delaying the Part 150 Updates 5 times since 1995, by never taking into account errors in the for-1996 noise exposure map, by never taking into account under-projected noise exposure, by never correcting fleet-mix and daily operations to actuals (choosing an appropriate base year for the update); and by never reviewing the more reasonable noise exposure maps approved in 1998 during the EIS process.

SMAAC wanted to ask about using limited data sources, just as State Representat ive Jean Wagenius asked on July 22: "Why weren't passenger use/demand forecast methods used that had been used to project economic growth justifying expansion in 1996?" She referred to the House Research Critique of the MAC's Forecast and Policy ... dated June 26, 2000 which was part of the testimony provided MAC during the then-planned Part 150 Update for base year 1996, target year 2001 and base year 2001 target year 2005 announced updates, never completed. SMAAC wanted to ask, as we did in 1999 and 2000, "What year was excessive noise exposure the worst case overall? The worst case due to use of the parallels (1998 to 2007 as discussed in the FEIS)?"

SMAAC notes, as we did in our letter of May 22, that these concerns are not comments on the assumptions per se, but upon the Update process itself. Proceeding with the update under current conditions is at least unreasonable and unfair. Likely the process is legally insufficient considering not only FAR 150 but also the 1996 legislation, the agreement with the City of Minneapolis, and the FEIS, all of which bind MAC to noise abatement and noise mitigation measures effective between 1996 and 2006 as well as the years beyond.

The Use Assumptions. By May 7, MAC's consultant, HNTB, had already prepared its Presentation of Assumptions in five tasks. The report stated the base year and target year to be used and outlined the schedule and remaining tasks. The first task, Collect Data, listed their sources: airline-industry, airport, or FAA only. HNTB already included use forecasts based on meetings with Northwest and other airlines currently leasing gates at MSP. The airlines forecasted what aircraft would be using MSP in 2007 and how often. So many important givens or policy directions were already complete before the first public meeting with your Consultant, HNTB, and they had not been openly discussed by the Commissioners or necessarily implied by MAC resolutions. SMAAC wanted to ask "Why would MAC direct HNTB to use the airlines' forecasts without public or MAC review of their past reliability? Without considering the implications on related peak-hour capacity and other expansion projects and on MAC's policy goal of increasing airline competition at MSP?


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