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| | |-+  Post reply ( Re: SMAAC Testimony on MSP 2015 Capital Improvements and Environmental Assessment )

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Topic Summary

Posted by: Forum Manager
« on: July 12, 2016, 11:54:38 AM »

 At the Metropolitan Airports Commission (MAC), Planning, Development and Environment (PDE) Committee [2 November 2015], SMAAC presented testimony supplementing written commens on the 2015 AOEE, the MSP 2016 to 2023 Caital Improvements Plan. We also reported our concern that the CRO Order was a signal that peak-hour operations needed to be re-planned.
A. Many aspects of the Draft MSP Capital Improvements Plan (CIP) and Assessment of Environmental Effects 2016 to 2022 lack a credible basis in fact or law and do not properly report environmental impacts for lack of appropriate investigation of the causes thereof. These findings were contrary to a large number of observations of overflights, runway use and profiles.
B. Most noise, air pollution and other health and environmental impacts are a result of overflights, and current and reliable assessments of these impacts are needed, but missing.
C. References in the 2015 Draft AOEE Report to prior environmental reviews that resulted in a Finding of No Significant Impacts are misleading. Several prior noise assessments were based on models that did not include flight profiles and applied to annual operations per runway during years with frequent significant changes in runway use, routes and rates of ascent and descent during the year.
D. The extension of this modeling to 2015 over 2014 is the stated plan of the MAC for noise impacts; The best engineering practice would be base year 2009, target-year, 2016..
E. Previous AOEEs reported no accumulations of pollutants on land or affecting water quality, but no investigative effort was reported or scheduled in MAC budgets since 1995. MAC staff claimed to monitor air and water quality studies in 2011, 2012, 2013 and 2014. The monitoring was an annual Memo to the Noise Oversight Committee, whose Co-Chair denies NOCs authority or interest in air pollution. In the absence of local studies, the best engineering practice would be comparison with similar airports where studies were completed.*
F. The Draft 2015 AOEE is incomplete, uninformative and draws unjustified conclusions
It is our further conclusion that postponement of the 2035 MSP Long-Term Comprehensive Plan update is necessary, but the limited reason modeling minor changes in runway use and routes resulting from pending Air Traffic Control (ATC) procedures changes in Converging Runway Operations is unlikely to have any meaningful interpretation of the validity or predictive shortcomings of the DNL standards, and most certainly will not confirm anything regarding the absence of air and water pollution.

SMAAC published a more complete version as a PDF as a public record.  Some of our comments on the CIP were inclued in the AOEE Record, and some of our enviropnmental impact comments were not included.  In that, MAC staff eveluators may or may not have been guided by law or MAC policy. 
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