SMAAC Says MAC is Acting Illegally on Noise

Why not measure excess noise and treat it out to the 60 DNL contour as originally proposed? How can either of the two limited choices before you be in the public interest? If you lived under the parallel runways 50 yards outside the old and proven wrong 1996 contour, would you agree to choose between delay with a series of uncertain budget approvals or being ignored? Promises delayed now, maybe denied later? Or commitments now denied, after being acknowledged, but postponed, for years? Do you hold us ˆ and the Legislature -- simple for believing your testimony that the NCP was self-funding because PFC's increased with airport use? Do you not understand that this "compromise" is a compromise of your honor?

We agree with one part of the proposal before you: eligibility for any residential sound insulation program should not be based on projected noise exposure but on actual noise exposure. You are making phony projections of fleet mix, runway use, and number of daily operations (as manipulated and politically influenced by Northwest Airlines) your standard of fairness, and only a few of you seem embarrassed. We thank those few for their integrity, while we hope for an awakening of conscience and the emergence of a more responsible majority.

In the 1996 Minnesota Law, the Extended SIP, separate from Part 150, was to be implemented during and after construction of the new runway (1998 to 2004), as a condition of MSP expansion. The Commission made this three times negotiable with Northwest Airlines. First, the Commission dissolved MASAC at the behest of the airline. In spite of clear evidence that airport noise far exceeded that projected for 1996, your Part 150 NCP was never amended and you did less than nothing about actual noise beyond the wrongly projected for-1996 noise exposure map. We believe dissolution of MASAC, and the spending of AIP/PFC funds for staff support since, are each inconsisten t with FAR 150. Second, MAC staff, without any public notice or public input at all, agreed to reduce the planned budget for, and to delay implementation of, the Extended SIP. This was more than a year before the terrorist attacks, at a time when MSP use by Northwest was being expanded (and use by competing airlines limited), whether use were measured by passenger market share, gates leased, or percent of operations per day. We doubt the negotiation was within the lawful authority of the Commission. No one represented the public interest in these negotiations, so that was your duty. You ducked.

Third, you now entertain a recommendation by Northwest to just skip the Extended SIP. A desperate group of cities, thinking you will cave in to Northwest again, proposes to further delay the Extended SIP, with need based on a preliminary noise exposure map. The map was made from biased premises already conceded to Northwest Airlines in prior NOC meetings. We also doubt that these delays and limitations are within the lawful authority of the Commission. We believe you know representations were made by the Commission (as constituted in 1996) that MSP neighbors would be shielded from excessive noise when a trade-off was made to subject thousands of us to increased noise rather than re-locate the airport to a less-developed site. In testimony before the legislature, the Commission said if airport use continues to grow at the current rate, total noise exposure around the airport during constructio n will far exceed 1995 levels. The Commission stated publically and testified before the Legislature that MAC would continue noise abatement and noise mitigation programs specifically recognizing that more traffic would necessarily use the parallel runways until the North-South runway was completed. In effect, you proposed the Extended SIP. We see that it was adopted in Minnesota law and incorporated by reference in the ROD.

There were over 4,000 residential housing units in the 64-60 DNL using the dual-track noise map based on actual 1996 use, and more in maps prepared for the EIS in 1998. Another 2,000+ were in the 65+ DNL area under the parallel runways compared to the "Official" map. These are the maps referenced in the Record of Decision. A 5db SIP treatment, in 1998 dollars, was estimated at $42,000 per unit. MASAC noted in 1998 that there were more flights using MSP that year than had been projected after 17-35 was completed; in fact, no new runway was even needed to attain 2020 projections in annual operations . MAC ought to have updated its NCP and asked for at least $100 million in additional PFC funds (in addition to funding for noise mitigation under the new runway) and budgeted close to $250 million for the Extended SIP.

1. Excess noise is additional or unabated noise compared to projected (modeled) noise. If abatement measures succeed, or operations are reduced, both 65 and 60 DNL contours will include fewer buildings and mitigation (insulation) costs would be reduced. Reduced SIP costs are an incentive (carrot) to be earned by the airlines, and the more higher PFC's stimulate airline/airport competition, the greater the motivation (stick) for airline efficiency.

2. As well as the Part 150 NCP and various other, in fact most, environmental compliance projects.

3. The Official NCP created MASAC to ensure participation by the impacted citizens and FAA recognized the value by approving MASAC as a needed action.

4. In a widely publicized table, actual flights using MSP and the parallel runways exceeded 125% of operations as projected bt MAC, proving that more operations, not fewer, would use the parallel runways after 17-35 was opened than used them in 1996. Moreover, projected retirements of the noisiest aircraft were unrealized in 1998-99, as SMAAC noted at the time, making 1999 the worst year-case noise exposure year for Minneapolis, Richfield, Mendota Heights, and Eagan (unless 17-35 were delayed or unable to support 25% of all operations due to time-of-dayor rate demand and safety rules).


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