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Policies on Environmental Regulation at MSP International Airport. 11 July 2003 | Policy on National Air Transportation Legislation

Policies on Environmental Regulation at MSP International Airport. 11 July 2003

1. SMAAC’s policy goal is to attain equitable noise abatement and mitigation programs for MSP.

1a. Timely Updates. Common sense and various regulations required equitable adjustments in the MSP Noise Control Plan and mitigation measures, the Sound Insulation Program. In 1996, it was already planned to install improved air traffic control systems at MSP to enhance operational rates to 40 operations per hour per runway, and these systems alone provided the “25% increase in capacity” given as the reason to add a runway. The actual outcome: traffic and noise from the parallels increased well before projected (in 1991 for 1996) and this use pattern will not necessarily change once the new runway is available. Since approval of the FEIS, in 1998, noise abatement and mitigation (the Sound Insulation Program, SIP) required therein, has not been re-planned or re-budgeted.

1b. Reasonable understanding and use of the Integrated Noise Model. An elaborate procedure for predicting airport noise exposure after reduction has developed involving the Integrated Noise Model (INM, a computer model). The predicted noise exposure over a certain level then must be reduced further or mitigated. For these purposes, MAC was required to develop and maintain a Noise Exposure Map using the INM. The map developed in 1993 has been used, in spite of proofs of its inaccuracy and inapplicability, to determine eligibility for noise mitigation programs and receive funds for that purpose for 10 years. Failure to properly understand, develop, maintain, and use the INM and resulting noise exposure maps resulted in demonstrated inequities in determining eligibility for and implementation of the Sound Insulation Program, ie. dissimilar “treatment” of properties with similar noise exposure.

2. SMAAC’s policy goal is to attain more appropriate oversight of MAC’s failure to comply with environmental and noise abatement regulations, including various formal audits and reports. MAC represented to the Minnesota legislature during hearings on the bill to mandate MSP expansion that a] environmental assessments had been made and costs for responsible compliance were included in the estimated $2.6 billion project. MAC testified that noise abatement and mitigation costs were funded by the Passenger Facility Charges (PFC). But knowledgeable experts testified that MAC’s estimated environmental compliance cost for MSP expansion was grossly wrong. MAC’s neighbors continue to be harmed by excess noise, congestion, and wide-ranging air and water pollution. The initial and inadequate SIP -- costing local travelers over $200 million -- has been 37% funded from Federal Airport Improvement Program (AIP) grants (1996-2002). Officially, MAC claims that the Legislature mandated expansion goals and construction costs and imposed other costs (such as LRT) which required various compromises, delays, and adjustments.

3. SMAAC’s policy goal is to attain compliance with environmental regulations, including noise abatement and mitigation, as imposed by Federal, State, and local conditions of the FEIS for MSP Expansion (1998). In the 1970's Congress pre-empted civil damage litigation and made airport noise a part of the National Environmental Protection Act (NEPA). FAA then promulgated regulations about how airport managers [MAC in this case] did the environmental assessments and impact statements, compliance plans, and mitigation plans. This is codified in Federal Aviation Regulations (FAR) Part 150. MSP had to file a Noise Control Program/Plan in two parts: Noise exposure abatement and mitigation. The EPA, acting through and with the Minnesota agencies and departments, and local agencies [such as watershed managers or municipalities], imposed conditions on the MSP expansion projects codified in the FEIS or required by the FEIS to be developed as expansion progressed. MAC often ignored or evaded permit applications, and when permits were applied for, MAC failed or delayed compliance projects or sought increases in permit limits in essentially every case.


Policy on National Air Transportation Legislation

During the last 20 years Federal policies and programs came to be centered on a “National Air Transportation System” that incorporates and intensifies the exiting hubs and favors the major airlines. The major airlines became “major” through a series of buy-outs and mergers which concentrated the ownership of equipment based at, and the facilities leased at, hub airports. Through fortress hubs, an airline effectively dominates a geographical segment of the US air transportation market.

Before fare deregulation, this market control was service driven. The hubs offered convenient national and international travel to a large region by connections through their hub. “Spoke” service made intra-regional city-to-city service more frequent and service costs were usually shared with connecting (national or long-haul) travelers. Because of cost-sharing, or load-factors, profitable operations were possible even though debt from leveraged buy-outs and fleet ownership made the major airlines’ per seat-mile cost higher than before and more than the seat-mile cost of smaller “direct” or city-to-city carriers.

Before de-regulation, fares were based on air mileage, tickets were inter-changeable, and interline reservations and connections were not only possible, but regulated. Today, the usual practice of the major airlines is anti-competitive. They concede hub markets to each other, they hold back reservations for city-to-city travel in order to charge high premiums for day-of-flight-purchase tickets.

However, operations at the large hubs became problematic. The system demands not only a larger fleet but concentrated operations. Ever larger “banks” of aircraft “meet” at the hubs, connections are made, and the aircraft move on. Thus peak-hour use taxes airport operations, and congestion – with its costly consequences when operational rates are degraded – limits hub growth. The major airlines’ lobby is well funded, and the airline PAC’s are major campaign contributors. The major airlines and their suppliers created the idea and the policy that a few major hubs were the “National Air Transportation System”.

The existing air transportation system is detrimental to the public good, not essential:
Expansion of the major hubs will increase the cost of government [unless safety and security are compromised], because systems and staffing must be sized to the peak operations.
Expansion of the major hubs will harm far more businesses than it helps. Airline fleet-size, staffing, and scheduling costs will be much higher per beneficial passenger mile; there will be less competition, so good connections will still be scarce enough for premium pricing.
No hub airport manager has been able to attract much airline competition.
Expansion of the major hubs will also be energy inefficient: a sizable number of trips are lengthened (e.g. Madison to New York City via MSP).
Expansion of the major hubs will be environmentally unsound: exposure to noise, air and water pollution, and other risks will be increased, and sprawl will result from re-location of city populations displaced by airports.

De-peaking operations and improving other airports may not please the major airlines, but it would be sounder, quieter, more secure, safer, and support more economic growth. It is depressing that so many elected officials recite the hogwash passed out by the ATA and the airline lobbies. I seriously doubt they believe putting time and policy pressure on Federal employees doing safety reviews of peak-hour airport operations is in the public interest, even if the airport is in your State.

National legislation is pending to “fast-track” EIS’s for airports. President Bush already promulgated an Executive Order going part-way. SMAAC has been opposing this with Minnesota Congressmen and Senators. It is important to reveal assumptions and discover errors during EIS preparation. SMAAC believes an investigation of improper influence and inadequate regulation is needed, not shortened reviews.

 
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