Federal Aviation Regulations (FAR 150), provisions in the Final Environmental Impact Statement (FEIS) for MSP Expansion, and the Noise Control Program adopted by MAC in 1993 and approved by FAA in 1994 all require development of the airport plan with meaningful involvement of the impacted public and updates at least every five years. MAC has so far ignored public comments that the Noise Control Program updates for 2001, based on 1996 actual use, and for 2006, based on 2001 actual use, are being illegally skipped. MAC is now basing its current Noise Control Program on airline projections, unreliable in the past, and on assumptions about use of MSP in 2007 after the new runway 17-35 is available.
SMAAC raised these concerns at the July 22 public input meeting and wrote the Commission directly. MAC staff accepted the comments for forwarding to the Noise Oversight Committee (NOC). That group, however, met July 17 and had already recommended accepting the consultant's assumptions. NOC Co-Chair Kathleen Nelson, of Northwest Airlines, conducted a closed "pre-meeting" of NOC that day, and later ruled that only NOC members, MAC staff, and invited speakers, in this case the consulting firm, HNTB, could speak. NOC also voted not to review alternative scenarios, and not to recommend a trigger or other method for reviewing 2007 projected noise contours if actual use of MSP in 2003 to 2006 disproved the assumptions. The Integrated Noise Model and DNL contours lack resolution as used by MAC, and are easily manipulated, but regulations do require correcting INM-projected noise exposure maps so that noise mitigation follows actual noise exposure, not projected noise exposure. The Draft FEIS in 1995 anticipated a Part 150 update for 2004, after completion of 17-35 as then-sched uled, and an adjustment of the DNL contours and the MAC Sound Insulation Program (SIP) for use in 2005. Because the SIP underway was based on 1994-approved Part 150 Program map -- and because the for-2001 noise exposure map 65 DNL contour made for the EIS roughly overlaid the for-1996 60 DNL contour -- Minneapolis legislators and officials bargained for, and believed they obtained, an agreement with MAC to extend the SIP program to this contour. Besides the anticipated 2001 update, neighbors worried that the new runway and other aspects of the noise abatement plan would be delayed, making the 2004 noise contours invalid.
It remains to be seen if these neighborhood concerns are considered at today's Planning and Environment Committee meeting or the August MAC meeting. So far, MAC has not considered that HNTB has enplanements based on a different ratio to operations than the 1996 map or 2002 base year or that the airlines' projections of fleet-mix has both capacity and noise factors, suited to their financial goals perhaps, but unable to support sufficient local passengers for either economic need or to produce PFC revenues for noise control projects. The historical differences in actual aircraft replacements as compared to projected replacements surely is evidence bearing on the airport manager's findings: what are the motives for and credibility of airline testimony? Why would Northwest Airlines try to assure that neither the old agreement (1996 64-60 DNL) nor a 2001 or 2006 update is implemented? If MAC accepts airline fleet-mix (noise and capacity), schedules, hubbing factor (part of load-factor) projections as unchallenged "facts" not to be discussed. NOC, consisting of half airline reps, is the only auditor of airline inputs? NOC, consisting of half airline reps, meets early and does not allow public comments even though MAC tabled approval [Note: Approval, not discussion.] of HNTB's recommendations until after the July 22 public input meeting? Not attributing airline inputs is not the same as accepting them without question. Representative Wagenius suggested a fee-cost motive for Northwest's projections at the July 22 meeting. Local business travelers suggest continued market domination as a motive for Northwest's forecasts. Somehow there appears to be undue influence being applied in Minnesota as well as in Washington. Even if the airlines' are theoretically in the best position to project aircraft replacements, and are entitled to confidentiality, the dominant position of Northwest Airlines at MSP should be relevant. The consultant's use and interpretation of airline statements should stimulate discussion of the (unattributed) use projections, not suppress it. SMAAC would like to ask: after unsupported and undiscussed findings have been incorporated in a noise exposure map, what form of comment on the map, or on the evidence for the findings used to create the map, would not be considered an untimely comment on the assumptions?