SMAAC's effort to illuminate the safety limitations and environmental harms of Commercial Aviation operations by the Federal government began when MSP Airport operations became much noisier per day for four reasons: jet engines, bigger airliners, more flights per day, and then more flights per hour. Airport operations that served 2 or 3 times more passengers per flight were economically beneficial, increasing capacity and distance (passenger miles traveled) at less cost per passenger mile, in part due to fewer airport operations per day.

The sequence --jets, jumbo jets, daily flights, hourly flights --varied across the USA and Internationally. Let's explore how that led to chaos, confusion, or worse at MAC and the Legislature and at FAA and the Congress.

FAA and Congress: National governments operate military aviation and some operate airlines. In the U.S. the FAA controls airport to airport routes and schedules and via the National Airspace System. FAA classifies (licenses) airports and specifies how airport owner/operator Sponsors operate them in detailed Agreements. The Department of Defense independently operates military flights, airports of all kinds, and controls large land areas where FAA cannot allow flights or approve airports. However, military aircraft often use commercial airports runways. The Congressional Committees that reauthorize and approve funding of these and related Federal agencies start with bills that wrongly assume no policy or schedule conflicts. For example, jet flight numbers and routes, a large source of GHG are classified.

MAC and the Legislature: MAC, an unelected agency, was assigned long-term comprehensive (economics, safety, noise, pollutions, etc.) commercial aviation planning in the Twin Cities by law. As the planning was supposed to implement MSP Airport policy coordinated with the Met Council's Transportation Policy Plan, both were, by law, set-up as Hearing Examinations under judicial conditions (evidence). However, the Legislature intervened every few years.

If you look back 2 or 3 decades, you will see that the four changes in paragraph 1 above motivated interventions that actually had little to do with noise and a lot to due with politics. 

The public response should also be political.  

Our position is: Too many cooks in too many kitchens. We can talk about the real dangers illuminated by ground noise complaints:

 too many flights too close to the ground in too many different aircraft with too many different communication types used by too many controllers and too many cockpit controls too seldom calibrated.

In a message to Chair King, President Jim Spensley asked that the Commission schedule time at a Full Commission meeting to discuss the MSP LTCP status. In a piece-wise way, the MAC has given attention to the not-yet-resolved conditions attached to the 2010 MSP LTCP Update after a Public Hearing before the Metropolitan Council and an agreement to address the conditions in the next Update. Chair King asserts that MAC decisions have been open and transparent, with ample consideration of public comments, including ours.

In 2014, FAA withdrew its Max Safe Operations Per Hour and issued a Safety Order limiting runway-way use intervals on three runways, or not using R30L for departures or use of visual flight rules since pilots landing on R35 could not see aircraft on the parallel runways. Eventually, FAA created an instrumented "window" controlling R35 arrivals with a priority over R30L/R operations. This Order and Rule was applied in June 2019.

Last we heard, planners were comparing an hour limit of 45 arrivals and 45 departures per hour versus a plan to allow more arrivals one hour and more departures the next hour. Both the Noise Oversight Committee and the Stakeholders Advisory Panel were briefed by the regional FAA. The MAC, however, has not yet chosen between the options. And, what State Agencies will consider the environment impacts? Both options limit flight  

While it is true that unexpected ATC and route changes were at hand in 2011, it was also expected that the ATC changes would impact FAA, airline and airport forecasted use, increase facility costs and investments, and require reviews of the noise contours. Over the next 10 years, the FAA Office of Safety and the NTSB warned FAA and MAC that certain operations at MSP were not safe due to converging runway operations, that is runway-use intervals in current use in 2010 were unsafe. Although the MSP ATCT had instituted changes they only worked with fewer than planned peak-hour operations in NW Flow. 

The global problem is that less time traveling (higher speeds for people and cargo) is economically beneficial (even leisure travel), but the fossil-fuel energy to support air travel is proportional to the speed squared [Energy = Mass times Velocity squared]. From a climate-change perspective, twice as many tons carried the same distance or the same tonnage carried twice as far by a jet aircraft consumes more than 4 times the jet fuel and creates more than 4 times the GHG. Moreover, much of the GHG is released 5 or 6 miles up and more reaches the ozone layer and increases the reflection of heat. Science and engineering addressed fuel efficiency (miles per gallon, “clean fuel” chemistry, biomass sustainability).

The U.S. Commercial Aviation contribution to GHG production somehow (yes, we know how) increased since the EPA/FAA Finding (2015) that GHG from Commercial Aviation posed a public health hazard. The WHO had warned airport managers in 2010 that statistics showed increased health and mortality risks near busy airports, but the MAC continued to pursue more peak hour use even after runway incursions, aborted arrivals, and departure delays –signs of safety risks –increased.

Airlines try to conserve fuel per flight, but their operations are market driven and many of the costs of air transportation are sluffed off to government. That governments have had a hard time managing air transportation policy is an understatement. Today, obvious issues include that U.S. commercial airlines increased annual fuel consumption 50% 2019 over 2004 and loaded 10% more cargo and boarded about the same number of passengers (paying a higher average fare). Jet engine fuel efficiency (more thrust per fuel ton) was said to be 3% for newer aircraft introduced in 2018. The best and highly unlikely case for GHG based on moderate increases in air-travel passenger miles (6 to 10% per year) would be an GHG increase of 4.76% per annum.

Action: Other cities and groups around major hub airports are working to revive the Finding and act on it by Federal attention to national routes and schedules. Among them, the Aviation-Impacted Citizen Alliance (ACIA) which is also seeking changes in Federal policy through the FAA Reauthorization and Appropriations in Congress.

Last year, with some research help, I published a White Paper noting the history of problems in re-planning and managing the National Airspace System for security after 9/11/2001 and after the recession of 2008-09 –each modified the airline industry by reducing the corporations and alliances and jobs even after economic recovery. During (and after?) COVID-19, the Federal government shored up the entire U.S. Aviation economic sector (airlines, airports, investors, manufacturers, suppliers, and unions). SMAAC is hosting a web-based Analysis Center to collect data about air pollution from overflights. And to rebut propaganda by the airlines and others to maintain the unscientific myth that "airport noise over 65 DNL" is the only health or safety issue and under control. 

For the sake of your parents' health, your children's education, and your own well-being, please join us. If you can research, watch, and interpret science papers or legislation (bills), talk to elected officials, or write responses, volunteer to work on Center projects. If you want to protest or monitor operations or policies at MSP or volunteer or contribute to maintain the website and Forums join SMAAC. Or both.

Last month, February 2021, James Lawrence was appointed for District C [Bloomington. Edina, Golden Valley, Richfield, St. Louis Park and Minneapolis West of Lyndale Avenue] and Timothy Baylor was appointed for District D [Minneapolis East of Lyndale].

Mr. Lawrence was VP and CFO of Northwest Airlines 1996-98. Now he is Chairman of a private investment firm. Mr. Lawrence served on numerous company and non-profit boards, including currently the IAG (International Consolidated Airlines Group). 

Lawrence served as Chairman or CEO of Rothschild (Investment Bank, 2010-20), CFO of Unilever Inc. (2007-09), and  Vice Chairman and CFO of General Mills (2000-09), and was a division president at PepsiCo, serving as CEO of Pepsi-Cola Asia, Middle East, Africa from 1992 to 1996. 

Mr. Lawrence earned a Bachelor of Arts in Economics from Yale University and an M.B.A. with distinction from Harvard Business School.

The Metropolitan Airports Commission (MAC) operates (sponsors) MSP International airport and six "reliever: airports. More background on MAC Commissioners is available at the MAC website.

https://metroairports.org/airport-authority

The MAC Chair and 12 (of 14) commissioners Governor-appointed. Eight Commissioners reside in districts in the metropolitan area; four. These commissioners' four-year terms are staggered. In addition, one commissioner is appointed by the mayor of the City of Minneapolis and another by the mayor of the City of St. Paul to represent those cities. These two and the Chair serve at their appointer's pleasure.

21 Dec 2020, 1 PM

Chair King, Commissioners: Planning and budgeting for next year has been a daunting task.

Staff: We understand how difficult the 2020 circumstances made day-to-day airports management. We noted that no questions, testimony, or complaints were received for the AOEE. We understand you need to start 2021 and deal with reality whatever happens. Good luck!

For many years, flights at MSP International were more expensive and less convenient for economically important local (O&D) passengers and more obtrusive and harmful overflying businesses, neighborhoods, homes, and schools than the previous year. In 2020, operations per day dropped to one-third or less of the 2019 average despite Federal interventions.

Toward the end of 2019, SMAAC met with Director Ryks and VP Rief about options for balanced flight arrivals and departures under the conditions imposed by the new FAA air traffic control procedures for R 17-35. On January 5^th, 2020 we and several Legislators took our concerns to Governor Walz. By then, the Governor’s Executive Order on reducing GHG was widely appreciated, but the Commission doubted its authority off of Commission property on environmental protection measures. These issues may seem less relevant, but they remain crucial in a economic recovery, particularly a fast “V-shaped” one.

The 2021 budget plan seems to be counting on airline revenue forecasts with no certainty or commitment. And on false assumptions about facility and operations costs modeled on 2019 use: The same passengers and trips, fewer for the next 9 to 24 months but catching up; the same airlines, fewer flights each day but the same number possible at peak-hours; the same airport services with higher average costs, including employee wages. 

Respectfully, it looks like a hub airport cookie-cutter aviation industry budget, planned for the year after 2019, not the year after the pandemic has been harnessed.

 Is there a guess about when daily operations, Delta-scheduled connections, may push hourly operations into the converging runway operations (CRO) safety corner? 

Will the next public health risk be global warming or global warming?

Did the change to virtual meetings and home offices make business travel less desirable –also considering high fares and if flight automation (remote air traffic control, B-737 MAX) reinforces fear of flying, and uncomfortable seats crowded in economy cabins reinforce fear of illness?   

Are the District Commissioners informed of residents' and businesses' air travel needs in their district? Did you plan surveys or studies to find out?  [SMAAC would help with that.]

Every recession has its own cause and effect, and every recovery has its own surprises. Did you get infallible expert advice from Staff? If not, what was learned from past mistakes? 

"Senior leadership of the MAC" as the MAC media spokesman, Pat Hogan, calls them, reversed course or never intended to discuss operational details or environmental impacts matters with SMAAC --or with other organized noise and pollution from overflights protestors.

That is the State government's and the general public's loss because truly important observations, facts, Reports and ideas are often overlooked or rejected for not coinciding with the airline-aviation industry's wants or demands. Anyway, MAC and Met Council appointments were not the first to be considered by Governor Walz, who knew of SMAAC from the House Transportation Committee and that we had rated 5CD candidates in the 2018 election.

As our concern this year is how well and how fairly will MSP restore air service in the "economic recovery." Chair King met with me just after he was elevated to MAC Chair in the context that most existing plans for MSP after the CRO/max hourly rate safety order was digested were upset by the virus. "Everyone" was concerned about pubic health workers, essential services jobs and if the economic costs expected could be controlled.MSP applied for a CRAES Act Grant and $125 million was alloted in April.

I said that there were winner and loser airports and airlines after 9/11 and after the recession and that the recent CRO Safety Order made a "V-shaped" recovery of air services passenger counts at both MSP and across the Nation was not likely based on history. And I said, public health and safety and environmental protection (continued global warming) from overflights and MSP operations is a high unknown cost and who avoids or pays for that cost is an unanswered but extremely important question affecting Metro economic recovery and future growth.

SMAAC's suggestion to "quantify the TC Metro part of the high unknown cost" (using a small part of the 2020 CARES Act grant) seemed well received in September: Thank you emails from Chair King and OFA Chair Monaco. Director Ryks asking CFO Saeed to contact SMAAC, and mention in two news articles the next day.

As a courtesy, I copied Hogan and King on a message answering one reporters question and they messaged back; King said the CFO was too busy to keep his commitment to call us back; Hogan said I had "given incorrect information" to the reporter "as usual" including a well-established mention that new (2010-2011) routes --turning North departing MSP Runway 30R --passing over South Minneapolis now for 8 years or more and exposing residents and workers to new noise and pollution (almost exactly the conditions warned about as health risks by the 2010 WHO Warning). Hogan, I think, was misinformed by a MAC employee who may have misunderstood the question as about current operations so intent to defame was arguably missing; the "as usual" part, not so much. 

The Special Metro Airports Analysis Center is starting to track how the $billions appropriated to “tide-over” commercial aviation is being used. A Minneapolis-St. Paul Business Journal report steered us to Seth Kaplan, a well-known journalist and airline-industry expert, already known at the Center for his remark: “It’s not that an airline, after it merges… has to pick a hub to close.” The Center is trying to extend investigations of the airline routes, created during “recovery” after both 9/11 and after the recession of 2008, as increasing greenhouse gas volumes emitted (global warming, air pollution), and the cost of air travel.

Will a recovery from the economic hardships imposed to control the COVID-19 pandemic

be fair (democratic and equitable)? 

We fear it will not, given the history

and the importance of international (air) travel to both

controlling human epidemics and lubricating global economic growth.

In 2010, the World Health Organization (WHO) warned airports that many epidemiological studies correlated overflights and increased health and mortality risks within ten miles of busy airfields. Increased incidences of pulmonary and cardiovascular diseases were found,

Correlating changes at urban airports, higher pollution doses from jet operations to health risks had seemed easy enough in 2014. WHO reported that the correlation was stronger applied to persons who had lived near or worked at a busy airport. Hearings were held in the House of Representatives and bills were passed and funds appropriated to study the topic.  EPA/FAA Finding was issued in 2015, connecting commercial aviation to excessive releases of greenhouse gases. By law, the Agencies prepared to promulgate Rules.

We asked for health-outcomes studies, unsuccessfully, at Minneapolis-St. Paul International Airport, as part of the 2010-2025 Metropolitan Transportation Policy Plan. University of Southern California scientists compared the density of sub-micron particulates in lower-income neighborhoods east of Los Angeles International Airport and found an abundance of particles ear-marked chemically as produced in jet engines. That study was repeated in Seattle just last year.

The responsibility for overflight pollution rules (EAW/EIS work) was muddled by de-regulation lobbies. There were a multitude of deaf ears in city halls, airport sponsor’s hearing rooms, and State capitols. The EPA/FAA Finding was nullified in 2017 by the Trump Administration.

Last year we updated and released a White Paper and, with citizen groups in other aviation-impacted cities, hoped to extend National Airspace System (NAS) analyses with more concern for health and environment impacts.

In the COVID-19 crisis, the large airlines, some airliner manufactures and other aviation interests reacted in the same ways they had reacted to climate change in 2017, to financial audits in 2009 and to security in 2002: air operations are not solely to blame and must not be regulated. Yet we know COVID-19 was harsher for persons with lung and heart disease.

MORE …

The FAA reacted slowly after 9/11 and the Next Gen developments, funded in 2007, got in the way. FAA, airports, and airlines acted badly after the 2008 financial crisis. The Congress, too: bills were introduced to increase funding of Next Gen and privatize air traffic controller jobs. Bills were passed to enable airline mergers and reduce inspections; airline mergers were allowed that more or less passed $millions from air travelers to airline executives.

Federal statistics (USDOT) show that jet fuel burned by commercial flight operations in 2011 was 20 to 25% greater than in 2005 --when millions more travelers flew. The difference was noted at hub airport as routes were changed for safety reasons. Four findings were documented:

1. U.S. passengers-boarded in 2010 were less, but 2010 fuel consumption was greater (each compared to 2005). The average trip was apparently quite a bit longer, because the average aircraft in 2010 had fewer seats and a lot more cargo weight was carried in passenger flights in 2005.
2. In 2011, a majority of passengers boarded at fewer airports than in 2005; shown by sorting airports by departing passengers, highest to lowest, and a running total.
3. There were significant differences in airport rank, sorted by runway operations per day.
4. At the busiest airports, flight operations per day were higher, and more concentrated at peak hours, in 2011 than in 2005.

We conclude that city-hub-city passengers traveled fewer miles each in 2005.

There were fewer seats available per departure in 2011, and

airlines prospered by higher load-factors and much higher average fares.

Health and safety risks increased as a result at MSP and similar hub airports.

We thought this had to be addressed by Federal policy. The DOT and FAA operational statistics had become less available and epidemiological research more prevalent.

In 2014, the MAC and the Met C were to update the Metropolitan Transportation Policy Plan for 2015 to 2035. The MSP CIP plan for 2010 to 2017 was to be approved. Facilities needed were postponed: said to be because the peak runway use rates were reduced (CRO safety) and amendments to the Consent Decree on Noise Mitigation.

SMAAC and similar groups around the country connected with EPA and FAA in 2013 (soon after President Obama recommended attention to the relationship of high-rate airport flight operations to air pollution, the 2010 WHO Warning. The result was the Official Finding in 2015 that, by law, resulted in drafting Rules for approach and departure routes and rates in GFY 2016 that did not happen.

In 2002 and 2008, the airline business had dropped like a stone,

but recovered financially after bailouts, with higher profits,

fewer airlines, less service, less safety, and less oversight.

Also, more pollution including GHG and particulates (carbon footprints).

Opinion by Jim Spensley, Co-Founder, Special Metro Airports Analysis Center

© Copyright 2020

SMAAC, Minneapolis, MN

      The safety disjoint between peak-hour capacity and airline forecasts continues without documentation. The MAC began several capacity-related projects reviewed by Met Council for funding or economic impact in capital improvement plan (CIP) projects 2010-2019. Due to changes in air traffic use and a series of FAA Safety Orders restricting runway-use MAC first undertook to "share" approach and departure overflight disturbances among neighborhoods by continuing the real-time Air Traffic Control Tower (voice, radio telephone) manual departure control 

MAC and FAA, years ago, estimated the maximum safe operations per hour at about 160, unbalanced: either 100 arrivals and 60 departures, NW flow, or 60 arrivals and 100 departures, SE flow. To interpret this plan as possible, other critical assumptions were made: the temporary response by the Tower Manager. 

1. Ground traffic management (open gates or parking space for aircraft, runway transit time or speed, time lost in switching flow and average weather and wind conditions).

2. How many days per year would weather, maintenance and emergencies decrease possible runway-use hours?

3. Cost and schedule details based on airlines forecasted numbers for airfield facilities and aircraft changes.

4. Cost and schedule details for airport facilities based on passengers and passenger services.

However, use of MSP airport during and recovering from COVID-19, varied demand, and affected flight planning.

      What the 2019 Rules Allow. Either A. Less than 136 operations per hour with "nearly equal arrivals and departures" or B. balancing arrivals and departures over a longer period than an hour. That is, in comprehensive plan assumptions, the 25% peak hour difference and the two options are very significant and quite different.

MSP will lack the space to safely move and hold aircraft (park at gates or elsewhere) in either flow between 4 PM and 8 PM. At 7 AM in NW flow, a large departure bank will limit arrivals. If as many as 75 aircraft land before 7 AM  or between 8 and 9 AM in either flow, MSP will lack the space to safely move and hold the aircraft. In SE flow, MSP could allow perhaps 60 take-offs and 80 take-offs if 60 or 70 aircraft were available and the turn-around of arrivals was swift. It will be interesting to see what changes will be made and when. The NOC has slept as two policies were accepted: allowing more noise exposure per location per flight and reducing daily flights per route by using more routes; now there is nothing left for the Noise Oversight Committee to oversee except how the contour maps are prepared, but it doesn't.

Safe and affordable (costs financed by airfares do not hobble Twin Cities economic growth capacity) MSP facilities and operating costs, an annual O&D passenger goal, and increases in GHG, carbon sub-micron particulates or other overflight emissions limits, and the issue of land use or land acquisition are beyond the sole authority of MAC. 

The FAA chose to ignore the impact of overflight pollution according to internal USDOT/IG documents originated by FAA. The troubled Next Gen air traffic control program elevated "industry (airline) expectations" over public health and safety.

CAUTION: While we believe that the premise is correct --FAA usually designs PBN/RNAV route procedures only to increase hourly use of runways and other airport facilities --the IG study was of Metroplex implementations, multiple airports in urban areas. 

When Next Gen could not resolve air traffic congestion in "more complex" airport and large metropolises without increasing air pollution and safety risks, they doubled down on "efficiency policy."  During the last years of the George W. Bush administration, with the Next Gen program under development --and nothing else funded --FAA anticipated an expansion of routes, along the East Coast especially, and an "airline demand" for greater runway availability at many airports. Outside of the R&D departments, air traffic control management planned to "optimize runway use at minimum separations." 

This is not news at MSP. FAA tried PBN routes at MSP soon after the September 2010 near-mid-air-collision, and the MAC maintained the illusion that environmental reviews and noise mitigation would be continued. FAA publicity featured "optimized efficient use of airport facilities and airspace," and airlines characterized noise complainers as being against the efficient and optimized flight routes needed for economic growth.

"Politicians (cynically or stupidly?) adopted the above views and did not question the MAC seriously when investigations of public health and safety or environmental impacts (GHG for example) were denied." Jim Spensley, SMAAC President 

__________________________________________________

FAA ADMITS PUBLIC HEALTH AND SAFETY WERE NOT CONSIDERED IN IMPLEMENTING OVERFLIGHT ROUTES NEAR AIRPORTS:  "......THE FOCUS WAS UPON OPTIMIZING ROUTES AND AIRSPACE DESIGN"  RUNWAY-USE EFFICIENCY WAS "THE ONLY CONSIDERATION."

U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF INSPECTOR GENERAL FINDINGS ON THE FAA'S METROPLEX AND NEXTGEN IMPLEMENTATIONS OF GPS-PLANNED AND FLOWN ROUTES (PBN/RNAV ROUTES).

In a bombshell and likely accidental admission, the FAA revealed the truth about how the MetroPlex and NextGen flight paths were designed 
without noise, ground safety and public impact issues being considered.  The FAA was responding in writing to an audit conducted 
by the Transportation Departments Inspector General.  The audit report stated that community noise issues were problems that were causing 
delays with the FAA's implementation of the MetroPlex program across the Country.  The FAA's response to the audits findings stated that 
after noise issues became problematic, it later changed it's processes to include those concerns in future design procedures.  But in doing 
so, it admitted that the original design processes (which were used for the Sky Harbor NextGen flight paths) only considered optimization 
of paths to benefit the industry.  Here is the text of the FAA response regarding noise concerns from page 37 of the audit report:

"In order to address extensive community concerns about new noise exposure, procedures are designed and implemented that do not maximize efficiency benefits, but do result in less noise exposure. When the Metroplex program began in 2010, the focus was upon optimizing routes and airspace design. When community concerns were included in the design equation, optimization was no longer the only consideration. It is an extraordinarily complex balancing act to provide both efficiency benefits to industry and to minimize new noise exposure in 
communities. These are usually competing priorities."

The FAA also went on to admit that the programs only intent was to make use of all available airspace which created new noise impacts 
over areas that previously had not experienced flight path intrusions:
"The intent of the Metroplex program was to make efficient use of all available airspace, which created new noise impacts. In many 
communities, some neighborhoods experience less noise, and some more-relieved communities generally have not recognized the beneficial 
noise reductions, while impacted communities strongly oppose the new or increased exposure."

The title of the  audit report, issued on August 27th is "FAA Has Made Progress in Implementing Its Metroplex Program, But Benefits for 
Airspace Users Have Fallen Short of Expectations".  The report goes on to say the the FAA is behind schedule in implementing the programs and 
that benefits as promised are questionable.  Other statements from the report include:

"Delays have occurred largely due to increased community concerns about aircraft noise."

"Since 2014, further delays have occurred as FAA has implemented new PBN (Performance Based Navigation) procedures at more sites, largely 
due to increased community concerns. For example, in fiscal year 2018, FAA cancelled the Phoenix Metroplex project due to litigation related to a previous PBN project."

0The Metropolitan Airports Commission (MAC) set up a Stakeholder Engagement Department and a Stakeholder's Advisory Panel on the MSP Long-Term Comprehensive Plan (LTCP). The Panel is dominated by airlines and others doing business with the MAC, a few city members --seasoned for servile cooperation by noise oversight committee routine --and a handful of government agencies and NGOs. No public or neighborhood panelists. 

Several public engagement events are planned to "inform citizens" about the LTCP progress and "listen to comments." If you've been there and done that, were your comments used in any way? The events focus on various parts of the LTCP, but are not yet scheduled.

A few years ago, to impress the Legislature and the Governor, an MSP  Vision Statement and Strategic Plan for a well-appointed and expensive destination airport --serving passengers with daily Delta flights to places Minnesotans and most destination passengers visit less than once a month.  The slickly presented Strategic Plan was apparently considered safe and healthy enough, although this wasn't mentioned.

It's clear the Converging Runway Operations (CRO) delay was used to submerge the MSP 2014 Long-Term Comprehensive Plan (LTCP) Update and at least the 2017-20 capital projects, floating long-term goals without revealing details to the public directly or to the Met Council and Legislature formally, for appropriate economic growth forecast (O&D passenger use of MSP), financial, or environmental review.

The CRO details now --stiffer safety-at-peak-hours restrictions --will:

1. be more to Delta's competitive benefit;
2. increase fares to pay airline fees;
3. increase total noise;
4. use PBN/RNAV route and limit vertical-approach technology to plan arrival rates;
5. increase air pollution per flight with a greater GHG and overall pollution volume as passengers increase.

A MAC staff opinion is that the Minnesota Legislature intended that the MAC defer off-site public health and environmental impact statements to the FAA/EPA.  The FAA doesn’t do EAWs at specific airports. Neither MPCA or MAC is responsible for EAW/EIS or public health studies of flight operations. It appears the Evironmental Quality Board has endowed MAC with EAW authority for capital projects and immunized them against appeals.

A second assumption is that the small site will remain safe enough even if average hourly use increases to the annuaized equivalent of 800,000 to 1 million operations per year and 60 million passengers. That being the case --without a serious accident --the costs will be 3 or 4 times higher than moving to a larger site in 2001 would have been and 2 or 3 times the cost of building a second airport. now.  All of these 3 options are a risky capital investment as airline demand is fickle, not promised: airlines fail financially, real air travel demand is fare and service dependent, and the public may demand a lower public health and safety risk or more attention to GHG releases and global warming.

Aren't those assumptions worth consideration in developing the LTCP?  We think so. Drafting a plan for 18 months to be considered for 18 minutes in its only pubic hearing seems less transparent and informative than it should be considering the projected cost over 20 years.

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