SMAAC told MAC its plan for a proposed noise plan update was way too hasty. "MAC's so-called public review process," President Jim Spensley said, "only provides for announcement of back-room projections and consequences after they were prepared by staff and recommended by the Planning and Environment Committee of the Commission with little discussion , or, for that matter, understanding. They are an unfit basis for a legal Finding of the Commission." MAC's P&E Committee was apparently not appraised of SMAAC's request, made in a May 22nd letter to the Commission, for hearings and an opportunity for knowledgeable public advocates to testify and to question how assumptions and forecasts were prepared. During its June 5th meeting, the Committee moved the staff report along to the full commission, although P&E Chair Carol Houle suggested action there might be "tabled to allow more public discussions".
"Now," Spensley explained, "the impacted public cannot really question how a new noise exposure map was drawn. Expert assistance and prior access to the voluminous data tables used in the Integrated Noise Model and graphical rendering program are needed to spot issues."
Conflicts of interest feared. It is becoming apparent that conflicts of interest taint the MAC update process," Spensley said. "It unfolds before us as a pro-industry exercise with political overtones." Spensley informally asked MAC Executive Director Jeff Hamiel and Deputy Director Nigel Finney about a large project management contract held by HNTB, MAC's Part 150 Plan consultant, with Northwest Airlines in Detroit. They denied such a contract existed. When sent proof of the Northwest contract, Hamiel messaged "I am very surprised. I'll call my contact at HNTB for a full explanation. I clearly recall discussions (with HNTB) on several occasions stating that HNTB and NWA did not have and never did have a (business) relationship."
Northwest at the MAC Helm? SMAAC notes that MAC has been repeatedly asked by Northwest to cut its Capital Improvements Plan (CIP) and budget, and MAC has usually complied. SMAAC says that higher operational rates at MSP during hours of peak use allow Northwest to increase its dominant position and competitive advantage. Northwest, in fact, absorbed the recent increase in peak-hour flight capacity by decreasing passenger capacity. Small wonder MAC cannot attract competitive airlines.
What about noise before 2007? A new plan could put continuation of current noise mitigation activities &Mac246; such as a modified plan for "64-60 DNL" areas &Mac246; in doubt. MAC has based SIP eligibility on a map based on assumptions and airline projections drawn before 1994. The projections were much different than actual operations, and MAC has not stated how, or if, mitigating this noise is a part of its revised Noise Control Plan. It appears the decade from 1996 to 2006 would be simply skipped.
Representative Paul Thissen [DFL, District 63A].complained at the SMAAC Spring Forum that "the MAC has not sufficiently accepted its commitment for noise treatment in the '64-60 DNL area, including homes in my district. We need greater legislative oversight of the MAC's 1996 commitment to complete this full sound insulation program after completion of the 1996-map 65 DNL areas."
Noise Control Plan. Various regulations and legal commitments, such as the FEIS for MSP Expansion, require MAC to adopt and follow a Noise Control Plan for MSP. Such plans have a noise abatement part and a noise mitigation part.
"The regulations say MAC needs to consider, and report, noise and safety issues raised at public hearings," Spensley said. "The rights of people who were, or may be, directly affected by airport noise and other pollution are closely tied to MAC's operational plans and projections.
"Commissioners have not concerned themselves with Œnon-compliant use' of MSP &Mac246; failures to abate noise as officially planned by retiring the noisiest aircraft, reducing night operations, or limiting flight paths to less-populated areas."
What are the right questions? SMAAC has key questions to ask bearing on the Commission's findings and Noise Control Plan Update. "Why aren't Minnesota, rather than national, economic forecasts and demographi cs applied to passenger demand? Does Met Council or the State have no pertinent data, or were they not asked?
"Will a 70% load factor finance a Northwest fleet with new smaller planes in the face of competition? What if Northwest does go bust? "What, if any, airline competition is assumed? What can be reasonably assumed about fleet mix for speculative new airlines using MSP? "What impact will corporate jets, time-shares, charters, and e-commerce have on demand? "What would terrorist threats or other perceived safety issues do to demand? "How about the safety issues and cost of operations implicit in the assumed daily use corresponding to increased hub use, larger banks, by Northwest?
"What if the use of new runway 17-35 assumed for the noise exposure map cannot be realized because such a high rate isn't safe, or it isn't feasible to staff (air traffic control for peak flight assumptions or airport screening for peak passenger use/load factor assumptions) due to cost? Don't the forecasts assume staff peaks will be budgeted by FAA and TSA; so isn't MAC unreasonably presumptive? Wouldn't noise then be increased if larger but noisier aircraft were used OR if lower peak rates made more night use necessary? Couldn't the purpose of high-rate INM assumptions be to pack daytime flights and avoid the night-operations 10 db noise penalty?
Spensley notes "All of these question arise from observing actual operations at MSP and comparing them to the 1994 Noise Control Plan assumptions and projections. It was inadequate findings then -- about runway use and fleet mix and noise abatement procedures -- that led MAC to delay, misrepresent, or evade aspects of the old Noise Control Plan because of mitigation costs."