MEMO 1- 2016-2022 CIP AOEE

MEMORANDUM TO: Planning, Development and Environment Committee FROM: Chad E. Leqve – Director of Environment (725-6326) SUBJECT: 2016-2022 CAPITAL IMPROVEMENT PROGRAM

1. Assessment of Environmental Effects DATE: November 27, 2015 Since Commission approval of the Preliminary 2016-2022 Capital Improvement Program (CIP) on September 21, 2015, the environmental review process has continued as scheduled. Documentation was prepared to meet legislative requirements prior to final action on the CIP. An Assessment of Environmental Effects (AOEE) for the Metropolitan Airports Commission Seven-Year Capital Improvement Program 2016-2022 was prepared. This document examined the cumulative environmental effects of the projects in the seven-year CIP at each of the MAC’s seven airports. On November 2, 2015, at 11:13 am, a public hearing to receive public testimony was held at the Minneapolis-St. Paul International Airport, Terminal 1 – Lindbergh, Room 3048A, Mezzanine Level. The hearing was advertised in the Minneapolis Star Tribune, St. Paul Pioneer Press, and the EQB Monitor. The public record remained open until 5:00 pm on November 12, 2015. During the public comment period two oral comments and eleven written comments were received. A proposed Hearing Officer’s Report is included in this package for consideration and adoption by the Committee serving as the Hearing Officers. The report includes Findings of Fact and Recommendation for the AOEE. A transcript of the public hearing, written comments, and responses to all written and oral comments received on the AOEE are attached. Only projects listed in the CIP for 2016 will be brought back to the Commission for award of contracts after plans and specifications are prepared and bids received. The 2017 project scopes of work and costs will be developed further through additional studies and plans and specifications will be prepared for consideration in the 2017 CIP process. The 2018 project scopes of work and costs will be developed further through additional studies, as well as by preparation of preliminary plans and specifications. Similarly, the projects listed in the CIP for all future years will be reviewed again when the 2017-2023 CIP is prepared. COMMITTEE ACTION REQUESTED RECOMMEND TO THE FULL COMMISSION ADOPTION OF THE HEARING OFFICER’S REPORT, THE FINDINGS OF FACT AND RECOMMENDATION REGARDING THE ASSESSMENT OF ENVIRONMENTAL EFFECTS OF THE PROPOSED 2016-2022 CAPITAL IMPROVEMENT PROGRAM. FURTHER, THAT THE EXECUTIVE DIRECTOR/CEO OR HIS DESIGNEE BE AUTHORIZED TO NOTIFY THE ENVIRONMENTAL QUALITY BOARD AND THOSE ON ITS DISTRIBUTION LIST OF THE COMMISSION ACTION.

PD&E 12/7/2015 ITEM IV B1

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HEARING OFFICER'S REPORT ASSESSMENT OF ENVIRONMENTAL EFFECTS OF THE METROPOLITAN AIRPORTS COMMISSION 2016-2022 SEVEN-YEAR CAPITAL IMPROVEMENT PROGRAM A public hearing was held on Monday, November 2, 2015, at the Minneapolis-St. Paul International Airport, Terminal 1 – Lindbergh, Room 3048A, Mezzanine Level at 11:13 am. The purpose of this public hearing was to receive public comments on the Assessment of Environmental Effects (AOEE) of all projects in the Metropolitan Airports Commission’s Seven-year Capital Improvement Program (CIP) from 2016 through 2022. This hearing was held pursuant to Minnesota Statutes, Section 473.614, which requires the Metropolitan Airports Commission (MAC) to prepare an AOEE for all projects at each MAC airport in the Commission’s seven-year CIP. The statute also requires the MAC to prepare an Environmental Assessment Worksheet (EAW) in accordance with the Minnesota Environmental Policy Act (MEPA) and the Minnesota Environmental Quality Board (EQB) rules implementing MEPA for projects in the CIP that meet the conditions prescribed in Minn. Stat. § 473.614, or that meet the requirements for a mandatory EAW in the MEQB rules. In addition, Minn. Stat. § 473.614 requires the MAC to hold a public hearing on the AOEE before adopting the CIP. MAC prepared an AOEE for all projects in the proposed 2016-2022 CIP, and that AOEE has been available for public review since October 12, 2015. Representing the Commission at the hearing were Dan Boivin, MAC Commission Chair; Steve Cramer, Planning, Development & Environment (PD&E) Committee Chair; Pat Harris, PD&E Committee Vice Chair; Don Monaco; Lisa Peilen; Erica Prosser; Timothy Geisler, Finance and Administration Committee Chair; Rick King, Management & Operations (M&O) Committee Chair; and MAC staff Jeff Hamiel, Executive Director and CEO; Dennis Probst, Executive Vice President; Tom Anderson, General Counsel; Gary Warren, Vice President – Planning, Development & Environment; Jenn Felger, Secretary – Planning, Development and Environment Committee; Roy Fuhrmann, Vice President – Management & Operations; Mike Maxwell CIO; Steve Busch, Vice President – Finance and Administration. Following introductory statements presented by Chair Cramer, comments from the public were invited. Two individuals commented at the public hearing. The hearing record remained open until 5:00 pm November 12, 2015. A court stenographer prepared a transcript of the public hearing, which is provided in Appendix A.


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ASSESSMENT OF ENVIRONMENTAL EFFECTS OF THE METROPOLITAN AIRPORTS COMMISSION 2016-2022 SEVEN-YEAR CAPITAL IMPROVEMENT PROGRAM FINDINGS OF FACT AND RECOMMENDATION Background In October 2015, the Metropolitan Airports Commission (MAC) completed an Assessment of Environmental Effects (AOEE) of all the projects included in the MAC’s seven-year Capital Improvement Program (CIP) and plan. The MAC prepared the AOEE in compliance with the requirements of the Commission’s enabling statute, Minn. Stat. § 473.614. Concerning the AOEE, Minn. Stat. § 473.614, subdivision 1, states the following:

"The commission shall prepare an assessment of the environmental effects of projects in the commission's seven-year capital improvement program and plan at each airport owned and operated by the commission. The assessment must examine the cumulative environmental effects at each airport of the projects at that airport, considered collectively. The commission need not prepare an assessment for an airport when the capital improvement program and plan for that airport has not changed from the one adopted the previous year or when the changes in the program and plan will have only trivial environmental effects."

The statute also states that the “commission shall prepare environmental assessment worksheets [for] those projects in the program for the airport that meet all of the following conditions: (1) the project is scheduled in the program for the succeeding calendar period; (2) the project is scheduled in the program for the expenditure of $5,000,000 or more at Minneapolis-St. Paul International Airport or $2,000,000 or more at any other airport and (3) the project involves (i) the construction of a new or expanded structure for handling passengers, cargo, vehicles, or aircraft; or (ii) the construction of a new or the extension of an existing runway or taxiway.” Minn. Stat. § 473.614, subd. 2. In determining whether to prepare an Environmental Assessment Worksheet (EAW) for each 2016 project in the CIP, the Commission also applied the criteria for mandatory EAWs specified in the Minnesota Environmental Quality Board (EQB) rules implementing the Minnesota Environmental Policy Act (MEPA), Minn. R. ch. 4410. The Commission circulated notice of the AOEE hearing consistent with EQB requirements. Availability of the AOEE was published in the October 12, 2015, EQB Monitor. The notice stated that copies of the AOEE were available for public review at the MAC offices and were available for download on the MAC website at: www.metroairports.org/Airport-Authority/Metropolitan-Airports-Commission/Administration/Publications.aspx


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The Commission also published notice of the public hearing for the AOEE in the Minneapolis Star Tribune and the St. Paul Pioneer Press on October 12, 2015. The MAC held a public hearing on Monday, November 2, 2015, at the Minneapolis-St. Paul International Airport, Terminal 1 – Lindbergh, Room 3048A, Mezzanine Level at 11:13 am to receive comments on the AOEE. Two individuals provided oral comments on the AOEE at the hearing. The hearing record remained open until 5:00 pm on November 12, 2015. A transcript of the public hearing, written comments, and responses to the oral and written comments received on the AOEE are presented in Appendix A. FINDINGS OF FACT AOEE Airport Projects The 2016-2022 CIP includes a number of projects from the 2020 Improvements EA/EAW, as well as additional Residential Noise Mitigation predicated on actual noise contours for the preceding year. On September 25, 2013 the First Amendment to Consent Decree (Amendment) was approved in City of Minneapolis, et al. v. Metropolitan Airports Commission, File No. 27-CV-05-005474 (Hennepin County District Court). The Amendment is designed to mitigate the impact of additional aircraft noise until the year 2023 and does not require completion of an EAW or EIS. The projects in the CIP focus on infrastructure replacement and maintenance/upgrades, information technology (IT), and tenant improvements at Minneapolis-St. Paul International Airport (MSP) and the MAC’s system of reliever airports. Additionally, the CIP includes projects consistent with the Long-Term Comprehensive Plans (LTCPs) for the respective airports. In the case of MSP, these planned projects flow from the Metropolitan Airports Commission’s (MAC) MSP 2030 Long-Term Comprehensive Plan Update that was published in July 2010. In September 2010, the MAC and the Federal Aviation Administration (FAA) began preparation of the 2020 Improvements EA/EAW, a joint document satisfying both MEPA and the National Environmental Policy Act (NEPA) requirements for projects the MAC may implement at MSP through the year 2020. In March 2013, the FAA determined that the 2020 Improvements EA/EAW was adequate under NEPA, and issued a Finding of No Significant Impact and Record of Decision for the projects discussed in the 2020 Improvements EA/EAW. In April 2013, the MAC determined that the 2020 Improvements EA/EAW was adequate under MEPA, and issued an Adequacy Determination and Negative Declaration on the need for an EIS for the projects discussed in the 2020 Improvements EA/EAW. As such, all projects programmed in 2016 have been evaluated in a manner that complies with Minn. Stat. § 473.614 and the EQB rules implementing MEPA, Minn. R. ch. 4410. The Concourse A/G Connector Bridge Phase 1 project, which will connect the MSP hotel with Concourse A, is shown in the Draft 2016-2022 CIP in 2016. An EAW for this project was completed in October 2015.


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At the September 8, 2015, MAC Planning, Development and Environment Committee meeting an adjustment was made to the Draft 2016-2022 CIP moving the Freight Building Remodel for DHL project to 2017. An EAW will be completed for this project prior to construction. The AOEE also assesses the environmental effects for projects proposed for the Reliever Airports, including the Crystal, Lake Elmo, Anoka County-Blaine, Airlake, St. Paul Downtown and Flying Cloud Airports. However, there are no Reliever Airport projects programmed for 2016 meeting the criteria for an EAW in the Commission’s enabling statute and the EQB rules implementing MEPA. RECOMMENDATION That the AOEE prepared for the 2016-2022 seven-year CIP adequately assesses the cumulative environmental effects of the projects at MSP and at each Reliever Airport included in the CIP.


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APPENDIX A

AOEE COMMENTS AND RESPONSES

Public Hearing Transcript/Oral Comments at the Public Hearing Mr. Jim Spensley, South Metro Airport Action Council Mr. Frank Lorenz Written Comments Received During the Comment Period The following parties submitted written comments, which are attached: Department of the Army Operations Regulatory (1996-01256-RMM) Hennepin County Public Works Mr. Jim Spensley, South Metro Airport Action Council Minnesota Department of Transportation Ms. Doris Overby AOEE Response to Comments Matrix A table containing responses to comments is attached.


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A

B


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B (cont.)


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C


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D

E

F


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F (cont.)

G

H


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H (cont.)

I


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I (cont.)

J


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J (cont.)

K


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K (cont.)

L

M


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N


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O

P


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P (cont.)

Q


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Q (cont.)


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R


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S


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S (cont.)


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T


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U

V


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X


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Y

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AB

AC

AD

AE


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AH

AI


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AK

AL

AM


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AN

AO

AP

AQ

AR

AS

AT


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AU

AV

AW


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BA

BB

BC

BD

BE

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From: "[email protected]" <[email protected]> Date: October 31, 2015 at 10:15:55 PM CDT To: "[email protected]" <[email protected]> Cc: "MAC (Jeff Hamiel)" <[email protected]>, "Dayton (Joanna Dornfeld)" <[email protected]>, "Environmental Quality Board " <[email protected]> Subject: Letter confirming prior email Reply-To: "[email protected]" <[email protected]>

Steve: The attached is a formalization of our request that the 2015 AOEE Hearing be continued at a more accessible location and conducted in a manner consistent with providing more complete information to the public, the EQB, the Legislature and Federal agencies. Perhaps the Committee intended more discussion or review in scheduling a loer than usual comment period. It would be well to consider that the Federal government is mindful of public harm from commercial overflights due to carbon-reduction treaties and the GHG global warming finding earlier this year. -- Jim Spensley President, SMAAC 520.229.7657 Cell

From: "[email protected]" <[email protected]> Date: October 31, 2015 at 11:50:17 AM CDT To: Steve Cramer <[email protected]> Cc: Environmental Quality Board <[email protected]>, "MAC (Jeff Hamiel)" <[email protected]>, "[email protected]" <[email protected]>, "Dayton (Joanna Dornfeld)" <[email protected]>, Courtney Ahlers-Nelson <[email protected]> Subject: AOEE Public Hearing and Findings Reply-To: "[email protected]" <[email protected]>

Commissioner Cramer: All Summer, the South Metro Airport Action Council (SMAAC) has been engaged with MAC staff to correct the public record and draw attention to the absence of an assessment of GHG and sub-micron particulate emissions in the 2014 AOEE Report. Jet engines create these emissions, increased per flight by lower-altitude overflights and accumulated from lower, slower operations at MSP since 2010. These effects are established by studies at Los Angeles International Airport and MSP has essentially the same fleet. [[http://www.scpr.org/news/2014/05/29/44433/air-pollution-from-lax-jets-worse-than-previously/]]. As you know, an Administrative Appeal regarding these matters for the 2014 AOEE Hearing Examiners' Report is on hold pending mutually advantageous changes for the 2015 Hearing. Mr. Hamiel was to schedule, we understood, a meeting to discuss SMAAC suggestions. In a conversation with Mr. Hamiel on 23 October, it was implied that A] SMAAC' s comments would be heard in full at the November 2 meeting (the format is a Power-Point Presentation included as a document in the public record); B] Any questions about the SMAAC testimony by the PDE members or staff would be recorded and answered by SMAAC before the comments period ended; C] Staff recommendations would not be published as Findings without a recorded vote of the named hearing officers, and a certification of the public record as complete as subnitted to the EQB. [[Note: Mr. Anderson may disagree, but these points were confirmed by the Attorney-

BT

BU

BV


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General in a letter to SMAAC finding that an Administrative Review by the EQB was required by Minnesota Rules. The public, the FAA, the EQB, and the Legislature. Mr. Anderson agreed, I think, that a qualitative assessment of off-site effects, such as particulate pollution or GHG emissions in he AOEE was required by Minnesota Law.]] It was also our understanding that the hearing would be accessible to the public and not time-limited as a part of the regular PDE meeting schedule. Therefore, we request that the scheduled AOEE Hearing be continued and the contiuation held off-MSP at a public location or at least outside TSA security at the MAC Administrative offices as last year. Otherwise, the public's legitimate concerns about safety, health risks, global warming, and other aspects of increased low altitude overflights at MSP will not be acknowledged or lead to EAws; neither will environmental impacts (effects) be properly reported, reduced, or mitigated per Minnesota and Federal Law. Respectfully, -- Jim Spensley President, SMAAC 520.229.7657 Cell

From: [email protected] [mailto:[email protected]] Sent: Wednesday, November 04, 2015 5:17 PM To: Hamiel, Jeffrey <[email protected]>; Leqve, Chad <[email protected]>; Cramer, Steve <[email protected]>; MAC (Dan Boivin) <[email protected]> Subject: Final AOEE Comments We were not pleased that our requests that the AOEE Report be based on testimony only and the findings acknowledged as the work of the panel convened to review the hearing and written comments. A. It is clear that something will be sent to the EQB sometime about the LAX particulates study; it is not clear if the intent was to correc he 2014 report/record or to include the LA Times story or the actual LAX study report as evidence of accu ulations ner MSP until refuted by a local study. B. Our specific request that staff comments be considered testimony and not deliberation seems to be a missed point. I discussed this point with Hamiel and Anderson as part of the Appeal. If staff's job is to confirm or rebut our testimony, their evidence rather than their opinion (argument) needs to be evaluated. C. We accept that the MAC can approve and continue the CIP projects whether or not the AOEE findings are correct in a technical or forecast sense, but we doubt that a series of MSP operations have never and will never impact air or water qualty or violate noise exposure limits lacks credibility -- Jim Spensley President, SMAAC 520.229.7657 Cell From: [email protected] [mailto:[email protected]] Sent: Tuesday, November 03, 2015 2:44 PM To: Hamiel, Jeffrey <[email protected]>; Cramer, Steve <[email protected]>; Leqve, Chad <[email protected]> Cc: Hamiel, Jeffrey <[email protected]>; Leqve, Chad <[email protected]> Subject: AOEE Comments

BW

BX

BY

BZ

CA


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Thank you for your assistance in presenting SMAAC's AOEE comments. Your concerns were appreciated. In spite of my appearance and blurry vision, I was healhty and pain-free. We had planned for a different hearing time and place; the alternative presenter was not able to arrange time off Monday morning.. Next: 1] We will clarify our comments including remarks about past inattention to air pollution and answering any questions MAC reviewers ask about our testimony. The latter may be considered a necessity; as SMAAC does not intend to allow unrebutted distortions of our comments. 2] Although I mentioned the 2014 Administrative Appeal, we do not consider the Appeal settled. Attorneys are researching what alternatives we have after EQB in effect refused a review. Perhaps the Chair's assertion that the article or a link to the article and the LAX study would be sent to EQB was inended to correct 2014 record?. 3] SMAAC dues not expect a useful noise map will result from an "analysis" of runway use for the winter months. Even the limited data used (in the past, at least) will not be typical of operations the last half of CY 2015. We have reason to expect a variety of ATC and schedule changes in the next 12 months due to the Federal fuel-burn and GHG emissions policies. 4] We do not expect extensive deployent of Next Gen in the six Metroplexes in GFY 2016 --and certainly not at MSP. Much of he above situation cannot be anticipated, much less controlled by airport managers, but neither can national policies and airline reactions be planned very far ahead at MSP. -- . Jim Spensley President, SMAAC 520.229.7657 Cell From: Steve Cramer <[email protected]> Date: November 1, 2015 at 6:36:23 AM CST To: "[email protected]" <[email protected]> Cc: "[email protected]" <[email protected]>, "MAC (Jeff Hamiel)" <[email protected]>, "Dayton (Joanna Dornfeld)" <[email protected]>, Environmental Quality Board <[email protected]> Subject: Re: Letter confirming prior email

Jim, I'll make sure the Committee is aware of this letter on Monday. Sent from my iPhone On Oct 31, 2015, at 10:16 PM, "[email protected]" <[email protected]> wrote:

Steve: The attached is a formalization of our request that the 2015 AOEE Hearing be continued at a more accessible location and conducted in a manner consistent with providing more complete information to the public, the EQB, the Legislature and Federal agencies. Perhaps the Committee intended more discussion or review in scheduling a loer than usual comment period. It would be well to consider that the Federal government is mindful of public harm from commercial overflights due to carbon-reduction treaties and the GHG global warming finding earlier this year. -- Jim Spensley President, SMAAC

CC

CD

CE


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520.229.7657 Cell From: "[email protected]" <[email protected]> Date: October 31, 2015 at 11:50:17 AM CDT To: Steve Cramer <[email protected]> Cc: Environmental Quality Board <[email protected]>, "MAC (Jeff Hamiel)" <[email protected]>, "[email protected]" <[email protected]>, "Dayton (Joanna Dornfeld)" <[email protected]>, Courtney Ahlers-Nelson <[email protected]> Subject: AOEE Public Hearing and Findings Reply-To: "[email protected]" <[email protected]>

Commissioner Cramer: All Summer, the South Metro Airport Action Council (SMAAC) has been engaged with MAC staff to correct the public record and draw attention to the absence of an assessment of GHG and sub-micron particulate emissions in the 2014 AOEE Report. Jet engines create these emissions, increased per flight by lower-altitude overflights and accumulated from lower, slower operations at MSP since 2010. These effects are established by studies at Los Angeles International Airport and MSP has essentially the same fleet. [[http://www.scpr.org/news/2014/05/29/44433/air-pollution-from-lax-jets-worse-than-previously/]]. As you know, an Administrative Appeal regarding these matters for the 2014 AOEE Hearing Examiners' Report is on hold pending mutually advantageous changes for the 2015 Hearing. Mr. Hamiel was to schedule, we understood, a meeting to discuss SMAAC suggestions. In a conversation with Mr. Hamiel on 23 October, it was implied that A] SMAAC' s comments would be heard in full at the November 2 meeting (the format is a Power-Point Presentation included as a document in the public record); B] Any questions about the SMAAC testimony by the PDE members or staff would be recorded and answered by SMAAC before the comments period ended; C] Staff recommendations would not be published as Findings without a recorded vote of the named hearing officers, and a certification of the public record as complete as subnitted to the EQB. [[Note: Mr. Anderson may disagree, but these points were confirmed by the Attorney-General in a letter to SMAAC finding that an Administrative Review by the EQB was required by Minnesota Rules. The public, the FAA, the EQB, and the Legislature. Mr. Anderson agreed, I think, that a qualitative assessment of off-site effects, such as particulate pollution or GHG emissions in he AOEE was required by Minnesota Law.]] It was also our understanding that the hearing would be accessible to the public and not time-limited as a part of the regular PDE meeting schedule. Therefore, we request that the scheduled AOEE Hearing be continued and the contiuation held off-MSP at a public location or at least outside TSA security at the MAC Administrative offices as last year. Otherwise, the public's legitimate concerns about safety, health risks, global warming, and other aspects of increased low altitude overflights at MSP will not be acknowledged or lead to EAws; neither will environmental impacts (effects) be properly reported, reduced, or mitigated per Minnesota and Federal Law. Respectfully, -- Jim Spensley President, SMAAC 520.229.7657 Cell


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CF


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CG


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AOEE Responses to Oral and Written Comments

Comments and Responses

Commenter ID Subject Response Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Oral Comment

A Greenhouse Gas and Ultra-Fine Particulate Emissions

The AOEE documents the 2020 MSP Improvements EA/EAW (2020 EA/EAW) analysis findings for the projects that required an EAW under Minn. Stat. § 473.614, and evaluates each project in the 2016-2022 CIP to determines if there is a potential for substantive environmental effect individually and collectively (relative to the three criteria in the AOEE statute). Those projects that are planned for 2016, and are determined to have the potential for substantive environmental effects, require an EAW under the Minn. Stat. § 473.614, which provides detailed environmental evaluation and assessment of cumulative effects consistent with the requirements of the Minnesota Environmental Policy Act (MEPA). The 2020 EA/EAW included an evaluation of greenhouse gas (GHG) emissions and determined that the projects that the 2020 EA/EAW evaluated increased GHG emissions by less than 1% from the No Action Alternative. Ultra-Fine Particulates (UFPs) are undefined and unregulated under the Clean Air Act. The science and health effects are undeveloped and there is currently no regulatory limit under the National Ambient Air Quality Standards (NAAQS), nor are UFPs a pollutant required for evaluation under the National Environmental Policy Act (NEPA) or MEPA. Moreover, monitoring UFPs is very difficult because the particles are so small they do not have mass and there are currently no models available to forecast future UFP levels. In June 2014, the Los Angeles World Airports (LAWA) completed an extensive Source Apportionment Study to evaluate the potential impacts of airport–related emissions on local air quality. The study detailed “that the very extremely small UFP, which have disproportionately higher contributions to particle number concentrations, are largely sulfuric acid aerosol from jet exhaust. The larger UFPs, which have disproportionately higher contributions to mass concentrations, appear to


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be related to on-road vehicle exhaust from local traffic.” The study went on to conclude that “future studies of the health impacts of airport emissions will need to consider these important chemical differences between UFP emission from jet and vehicle exhaust.” Beginning with the publication of the MAC’s 2013 Annual GHG Report, the MAC developed a new section that provides an update on UFPs and the related developments surrounding the topic. (the report is available for download at: www.mspairport.com/docs/about-msp/sustainability/FINAL-MSP-2013-GHG-Report-rev01.aspx) The MAC continues to invest in assets and activities that reduce GHG emissions. In addition to a 3 megawatt solar facility that has been constructed at Terminal 1-Lindbergh, and a second 1.5 megawatt facility planned at Terminal 2-Humphrey, in 2014 the MAC installed a charging station (providing eight ports) for electric Ground Service Equipment (GSE). This fast, energy-efficient charging station allows for simultaneous charging, adjustable charging rates, and automatic shut-off when the GSE are fully charged or when overheating occurs. The charging station was installed at Terminal 1-Lindbergh for use by Delta Air Lines GSE. This project fits into the proposed long-term goal of converting all Delta Air Lines GSE to electric power, thereby reducing overall air emissions from fossil fuel-burning GSE. Currently, $6.4 million is programed in the MAC’s capital improvement program out to 2020 to support the build out of this program. Additionally, since 2007, the MSP Noise Oversight Committee (NOC) has been actively engaged, in a leadership role, in evaluating and advancing the use of aircraft navigation technology at MSP to reduce noise impacts. As a result of these efforts, in March 2015 Area Navigation (RNAV), Standard Terminal Arrival Routes (STARs) incorporating Optimized Profile Decent (OPD) operations began at MSP. Required Navigation Performance (RNP) STARs with OPD were implemented in April 2015. As documented in the MAC’s Annual Voluntary GHG report, of the total CO2e emissions resulting from MSP,


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83% are generated by aircraft landing and takeoff cycles above 3,000 feet – the primary phase of arrival flight targeted by the RNAV/RNP STARs. These procedures will support more efficient use of the airspace and provide for the integration of constant rate descents at near-idle power settings. The FAA reported that between March 24, 2015 and May 11, 2015 a total of 24,778 arrival operation at MSP used the new procedure. Based on the associated fuel burn and emission reduction estimates made by the FAA, over 1.2 million gallons of jet fuel was saved and carbon emissions were reduced by as much as 12.2 metric tons. Implementation of these measures will also reduce pollutants other than GHGs.

Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Oral Comment

B AOEE Hearing Location and Process

On May 20, 2013 the MAC Full Commission adopted the following approach to determine the need to hold MAC meetings or hearings outside of airport security: “The Commission or Committee agenda items of broad public interest that have environmental impacts on the surrounding communities will be heard outside of the airport security area and in a location where a person can attend without providing personal identification documentation if, at least 21 days in advance of the meeting or hearing, the Commission Chair, in consultation with the Executive Director/CEO, determines that the item is likely to be of broad public interest, i.e. 50 or more persons, other than Commission Staff, are likely to attend for a specific agenda item.” Based on the level of interest and the number of comments received on the AOEE in advance of the meeting, the 50 person threshold was not reached. Throughout the year the MAC holds a number of meeting outside of airport security. Each quarter a Public Input Meeting is held at the MAC General Office Building, or at other predetermined locations in the communities. At these regularly scheduled public meeting attendees are provided updates on the latest information about the airport and the activities of the MSP Noise Oversight Committee (NOC), as well as the opportunity to provide their comments or questions related to the airport. All attendees who comment receive a written response to their comments and questions. Since 2002 the MAC has held 53 of these Public Input Meetings with over 950 written response provided citizens.


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A number of actions were taken to publicize the hearing. The Commission circulated notice of the AOEE hearing consistent with MEQB requirements. Availability of the AOEE was published in the October 12, 2015, EQB Monitor. The notice stated that copies of the AOEE were available for public review at the MAC offices and were available for download on the MAC website at: www.metroairports.org/Airport-Authority/Metropolitan-Airports-Commission/Administration/Publications.aspx. The Commission also published notice of the public hearing for the AOEE in the Minneapolis Star Tribune and the St. Paul Pioneer Press on October 12, 2015. On Monday, November 2, 2015, the MAC held a public hearing to receive public comment on the AOEE. Two individuals provided oral comments on the AOEE at the hearing. The hearing record remained open until 5:00 pm November 12, 2015.


C Ultrafine Particulate Pollution and Fuel Efficiency

Please see the response to comment A. All of the comments submitted during the 2015-2021 CIP AOEE public comment period were included in the record and responded to in detail in the Hearing Officer’s Report, which was posted on the MAC’s website in November 2014. The Los Angeles World Airports (LAWA) Source Apportionment Study (the study is available for download at: www.lawa.org/AirQualityStudy/) detailed “that the very extremely small UFP, which have disproportionately higher contributions to particle number concentrations, are largely sulfuric acid aerosol from jet exhaust.” Over time, scientific and regulatory focus that began with an understanding of total particulate emissions has advanced to focus increasingly on fine particulate. EPA regulation under the federal Clean Air Act has moved from total particulate to PM10 (particulate matter 10 micrometers in size or less) to PM2.5 (particulate matter 2.5 micrometers or less). Most recent regulatory focus has been on understanding how to measure and regulate PM2.5 to meet federal ambient air quality standards for that pollutant. EPA and the states have significant work yet to do on this front. Ultrafine particulate matter (UFP), particulate substantially smaller than 2.5 microns, is yet to be well understood or evaluated. Currently, the EPA has determined that the evidence linking UFP to adverse


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health effects is not sufficient to support a separate health-based ambient air quality standard. As part of its commitment to human health and the environment, the MAC will continue to monitor the UFP studies as well as other emerging issues related to aviation. The 2011 World Health Organization report, Burden of disease from environmental noise, Quantification of healthy life years lost in Europe (the report is available for download at: www.euro.who.int/en/health-topics/environment-and-health/noise/publications/2011/burden-of-disease-from-environmental-noise.-quantification-of-healthy-life-years-lost-in-europe) cites air pollution as a confounding factor in health effects related to transportation noise. When describing air pollutants in the context of airports, the study states: “Further, cardiovascular effects of noise (hypertension) were also found for noise sources where air pollutants are less likely to be co-varying factors, e.g. occupational noise (20) and aircraft noise (121). It was shown that the relative contribution of airport operations to the emission levels of nitrogen oxides, carbon monoxide, sulfur dioxide, volatile organic compounds and black smoke was small compared to the background concentrations in the vicinity of an airport (158). In spite of this obvious co-exposure, there was a lack of interaction between the scientific community dealing with the health impacts of noise and that dealing with air pollution.”


D DNL does not predict noise exposure and pollution impacts

The FAA requires use of the Day-Night Average Sound Level (DNL) noise metric to determine and analyze aircraft noise exposure and land use compatibility issues around U.S. airports. Because the DNL metric correlates well with the degree of community annoyance from aircraft noise, DNL has been formally adopted by most federal agencies dealing with noise exposure. In addition to the FAA, these agencies include the Environmental Protection Agency, Department of Defense, Department of Housing and Urban Development, Federal Highway Administration, and the Veterans Administration. The use of DNL is a national standard and has been upheld by numerous federal courts. The MAC will continue to report, and consider the use of,


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alternative noise metrics, such as single-event metrics and threshold metrics. Before the MAC makes policy decisions that have a noise component, the MAC receives input from the MSP Noise Oversight Committee (NOC), which often analyzes noise impacts using alternative noise metrics and single-event noise descriptors. The NOC’s analysis of Area Navigation (RNAV) is an example of using alternative noise metrics to develop information on aircraft noise. Alternative noise metrics are reported monthly in the NOC Technical Advisor’s Reports and are published on the MAC Noise Program Office website at: www.macnoise.com. However, DNL remains the FAA’s accepted noise metric, and since the early 1990s the MAC has used the FAA’s INM-generated DNL noise contours as the mechanism for implementing a noise mitigation program at MSP totaling approximately $500 million. The noise mitigation program, which is required to use DNL, has substantial community support. Nevertheless, the MAC will continue to support efforts at the national level by the FAA and others to evaluate the effects of aircraft noise and to examine alternate ways to quantify noise impacts. As an example, on March 19, 2012, the MAC sent letters to the Airport Cooperative Research Program (ACRP) and the Partnership for AiR Transportation Noise and Emission Reduction (PARTNER) programs offering MSP as a willing participant in their ongoing studies of methods for understanding aircraft annoyance and sleep disturbance. The FAA is currently in the middle of a multi-year effort to update the scientific evidence on the relationship between aircraft noise exposure and its effects on communities around airports. The FAA is contacting residents around selected U.S. airports through mail and telephone to survey public perceptions of aviation noise throughout the course of a year. This will be the most comprehensive study using a single noise survey ever undertaken in the United States, polling communities surrounding 20 airports nationwide. To preserve the scientific integrity of the study, the FAA cannot disclose which communities will be polled. The FAA hopes to finish gathering data by the end of 2016. The agency will then analyze the results to determine whether to update its methods for determining exposure to noise. If changes are warranted, the FAA will


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propose revised policy and related guidance and regulations, subject to interagency coordination, as well as public review and comment. Additionally, the MAC will continue to produce an Annual GHG Inventory and Initiatives Report for MSP. On a related front, the MAC is in the process of initiating Level One Certification under the Airport Carbon Accreditation Program.


E Runway use intervals and noise exposure maps

The MAC cannot speak for the FAA, which governs air traffic control at MSP. The MAC is unaware of documentation supporting the position that “air traffic control of airport rates of descent and ascent for fuel efficiency and reduced greenhouse gas emissions will generally increase runway use intervals.”


F Increased pollution and noise affecting the economic benefits of the airport

The MAC is committed to a safe, environmentally sound, and economically strong MSP. Air Traffic Control (ATC) has the responsibility for the safe and efficient movement of air and ground traffic at MSP. Safety is ATC’s first priority. All FAA rules and procedures at MSP are subject to a rigorous Safety Management System review by the FAA to ensure that safety is never compromised. According to Elaine Buckner’s (FAA Air Traffic Manager at MSP) comments at the February 2, 2015 MAC Planning Development and Environment Committee (meeting minutes area available for download at: http://www.metroairports.org/Airport-Authority/Metropolitan-Airports-Commission/Public-Meetings/Board-Meetings.aspx), increases in air traffic do not result in degradation of safety. Instead, ATC’s standard operating procedure is to meter aircraft operations at a rate that ensures the system is able to safely handle the increased volume of air traffic. For example, aircraft departures might be subject to a temporary ground hold if there is insufficient capacity in the airspace for more aircraft on a specific route. Or, arriving aircraft may be directed to use a slower airspeed for sequencing to an arrival runway. Although ground holds or slower airspeeds may result in increased delay, FAA standard operating procedures for ensuring the safe separation and movement of aircraft still apply. FAA does not compromise safety in the name of providing


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increased hourly operational capacity. The level of operations throughout the day at MSP is driven by passenger demand. Aircraft flight tracking data show peak hour aircraft operations in August, when passenger demand is high, can be 25 percent greater than the peak hour operations in February when passenger demand is low. There are clear cyclical seasonal passenger demand patterns at MSP that affect the number of operations during the busiest hours. Nevertheless, hourly operations throughout the day are well below the operation levels forecast in the Dual-Track Airport Planning Process. Current updated annual operation forecast levels are also much lower than those forecast in the Dual Track Airport Planning Process. Current peak hour operations range from 90/hr. to 115/hr. On the environmental front, the MAC will continue its comment to one of the largest noise programs in the world as documented at www.macnoise.com. Moreover, the airport remains in compliance with the Clean Air and Clean Water Acts and continues to strive for advancement in its GHG reporting activities and efforts to reduce emissions as documented at: www.mspairport.com/about-msp/EnvironmentalStewardship.aspx. Cost per enplaned passenger is a metric used by the airline industry to compare costs among airports and is considered a metric of financial competiveness. MSP’s cost per enplaned passenger is in the lower third of large hub airports. This is a factor in MSP’s growing service offering in the form of added airline service. The planned developments will neither erode MSP’s competitive stance relative to the cost per enplaned passenger, nor will they affect the level of passenger facility charges paid by travelers using the airport. During the Dual-Track Planning Process, MSP’s airspace capacity was calculated to be approximately 640,000 operations. The peak year for operations at MSP was 2004 with approximately 540,000 operations. The 2014 operations were approximately 411,000. The 2015 operations are estimated to be below 2014 levels.


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The 2020 Improvements EA/EAW provided forecast operations to be approximately 485,000 by 2020 and 526,000 by 2025, which are still below the 2004 levels.


G Runway use intervals and rates of ascent and descent

Please see the response to comment F. The MSP Noise Oversight Committee (NOC) will continue to monitor runway use and aircraft procedures in close communication with the FAA.


H Air safety for 30R departures

Please see the response to comment F. An airport safety zoning ordinance has been in place at MSP since 1984. The ordinance was amended in 2004 to incorporate Runway 17-35. The ordinance provides for safety off the ends of the runways through land use controls and preventative measures.


I Increasing peak hour rates, Runway use

The level of operations throughout the day at MSP is driven by passenger demand. Aircraft flight tracking data show peak hour aircraft operations in August, when passenger demand is high, can be 25 percent greater than the peak hour operations in February when passenger demand is low. There are clear cyclical seasonal passenger demand patterns at MSP that affect the number of operations during the busiest hours. Nevertheless, hourly operations throughout the day are well below the operation levels forecast in the Dual-Track Airport Planning Process. Current updated annual operation forecast levels are also much lower than those forecast in the Dual Track Airport Planning Process. Current peak hour operations range from 90/hr to 115/hr. The source of the graph referenced in the comment is unknown and refuted by the flight track data from the Metropolitan Airport Commission Aircraft Noise and Operations Monitoring System (MACNOMS). According to MACNOMS, the number of annual operations during the top three peak hours has stayed consistent between 22-25% of the total annual operations since 2001. Conversely, the number of non-peak hour operations has stayed consistent between 75-78% of the total annual operations. The MAC Noise and Operations Monitoring System (MACNOMS) records operations and noise data 24 hours a day, 365 days a year and are made available interactively on the www.macnoise.com website.


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Additionally, all operational trends are incorporated into the annual noise contour analysis available at: www.macnoise.com/tools-reports/annual-reports.


J Hub airport trends, NextGen capabilities

Please see the responses to comments I. NextGen implementation is outside of the scope of the MAC’s proposed CIP and the AOEE process. The FAA has jurisdiction over the implementation of NextGen. The MAC cannot speak for the FAA.


K Lower altitudes increase noise and pollution

Aircraft emissions are a direct result of fuel combustion not aircraft trajectories.


L LTCP noise exposure map flawed

The MSP Long-Term Comprehensive Plan (LTCP) provides the best current estimate of the future facility needs and acts as a roadmap for possible future improvements to meet deficiencies identified through the process. The forecasted number of operations and passengers are key to understanding where and at what point in the future the airport will experience deficiencies in its facilities. The MSP LTCP will include a noise contour based on the best available information forecasted for the year 2035. The projected 2035 noise contours are meant to provide an additional level of information about the anticipated long-term outlook for MSP. Data inputs, such as the number of flights, mix of aircraft, runway use and flight routing are all forecasted for the year 2035. There may be deviations in these data inputs between now and the year 2035. The aviation industry as well as aircraft operations may differ from what MAC currently anticipates, based on best available information, for aircraft operations in the year 2035. But today, it is impossible to know what, how and when these deviations will take shape. Therefore, the MAC – along with its consulting and airline partners – make forecasted assumptions using the best information available at the time. Along with deviations in forecasted assumptions are constraints in the noise modeling process. The aircraft


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noise database in the Integrated Noise Model and the Aviation Environmental Design Tool do not include some aircraft types that are anticipated to be operating at MSP by the year 2035. For the purposes of the MSP LTCP, the newest available aircraft in the noise model database known today are used to represent these future aircraft. It is anticipated that approximately 1/3 of the future operations at MSP will be in Airbus New Engine Option (NEO) and Boeing B737 MAX aircraft. These aircraft are significantly quieter than those that were used in the 2035 forecast noise contour in the LTCP. Recognition of variabilities in the forecast and modeling constraints is why the MSP LTCP is updated every five years. Moreover, it is why the current Residential Home Mitigation Program uses noise contours generated annually, based on actual aircraft operations rather than on forecasts.


M AOEE Process Comment noted.


N AOEE Review Length, AOEE Process

Comment noted.

Mr. Frank Lorenz Edina, MN, Oral Comment

O Parking garage expansion, parking alternatives

As the commenter points out, the existing parking demand necessitates the additional parking ramp at MSP. The lack of parking capacity at Terminal 1 –Lindbergh is one of the most chronic customer service issues at the airport. This need was also evaluated and validated in the 2030 Long Term Comprehensive Plan, 2020 EA/EAW and is consistent with one of the organization’s key initiatives to evaluate and finalize a plan for solving the long term parking needs at MSP. The goals of this action are to provide parking capacity to meet long term needs, continue to provide and increase revenue streams, and improve customer service by


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reducing Terminal 1-Lindburgh diversions. Other considerations that increase the value proposition for the additional parking ramp at Terminal 1-Lindburgh include potential losses of offsite parking facilities in St. Paul and Bloomington, space requirements for the annual parking ramp rehabilitation program, future auto rental space needs, and the future rebuild of the Green and Gold ramps. Other emerging considerations include the possibility of using a parking ramp grace period to help mitigate the pressures currently existing on the arrival/departure curbs.


P MAC should encourage businesses to not use the parking garage

MAC will continue to offer Elite Parking for regular/frequent users of the airport whether they are travelling for business or pleasure. This program allows a guaranteed parking space without concern for the day to day variability of the remaining parking spaces.


Q MAC should consider a bus program

Metro Transit currently operates bus service to the airport. MAC is currently working with Metro Transit to expand the operating hours of some of the routes (both bus and LRT) to better enable airport workers to arrive when required for their jobs. MAC will continue working with Metro Transit to enhance the existing service routes.


R A new garage will defeat the efficacy of light rail

Please see the response to comment Q.

Mr. Ryan Malterud, Senior Project Manager, Department of the Army Operations Regulatory, Written Comment

S Discharge of dredge or fill into waters of the United States

Comment noted. The MAC will ensure compliance with CWA Section 404 as detailed in the commenter’s letter. The projects in the 2016-2020 CIP do not require the discharge of dredge or fill material into waters of the United States.

Mr. David Jaeger, Environmental Policy, Hennepin County Public Works Written Comment

T No Comment. Comment noted.

Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC),

U 2014 AOEE Appeal

Please see the response to comments A and C. All of the comments submitted by the commenter during the 2015-2021 CIP AOEE public comment period were included in the record and responded to in detail in the Hearing Officer’s Report which was posted on the MAC’s


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Written Comment website in November 2014. The AOEE it is not a Minnesota Environmental Policy Act (MEPA) document and the 2020 EA/EAW has addressed the NEPA/MEPA environmental review requirements for the projects (4) currently shown as 2016 projects in the CIP that require such review. The AOEE documents this, and evaluates each project in the 2016-2022 CIP and determines if there is a potential for substantive environmental effect individually and collectively (relative to the three criteria in the AOEE statute). MAC prepared the AOEE for the Seven-Year Capital Improvement Program 2016-2022 in accordance with the requirements of Minn. Stat. § 473.614. The AOEE presents an assessment of the environmental effects of projects in the MAC’s Seven-Year CIP from 2016 to 2022 for each MAC airport. Under Minnesota law, the MAC is required to “examine the cumulative environmental effects at each airport of the projects at that airport (in the seven-year CIP), considered collectively.” Minn. Stat. § 473.614. For informational purposes, Table 1-1 of the AOEE for the Seven-Year Capital Improvement Program 2016-2022 identifies projects in the CIP that do not have a potential substantive effect on the environment (such as the repair, reconstruction or rehabilitation of pavement and buildings, and replacement of existing facilities). The notes in Table 1-1 offer further explanation of the type of work that each project entails and why this work will not have a substantive effect on the environment. Appendix A provides a description of each project in the CIP currently scheduled to be implemented in the years 2016 and 2017, as well as those projects currently scheduled to be implemented in 2018 through 2022 that may have potential substantive environmental effects. The descriptions of projects scheduled to be implemented in 2018 through 2022 are preliminary and subject to change. The major capital projects contemplated in the MAC's 2016-2022 CIP are the result of a comprehensive FAA and MAC planning effort and an extensive environmental review process. (Additional coordination occurs with the FAA on proposed projects through the Airport Layout


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Plan approval process.) The CIP planning and environmental review processes included major stakeholder collaboration components, opportunities for public review and comment, and thorough MAC responses to public comments. There are no new runways or major airfield expansions planned. Rather, the development focuses on landside facilities and terminal modifications. These developments are driven larger by origination and destination passengers and are planned in a manner that considers aircraft fleet mix and passenger load trends, with a focus on enhancing the passenger experience through safe and efficient airport facilities and related access to air transportation. MAC anticipates that the forecasted aircraft operations and passenger enplanements will occur at MSP regardless of the proposed developments. The projects in the CIP are designed to maintain and improve passenger service at the airport. The MAC is unaware of an Administrative Appeal regarding matters related to the 2014 Hearing Officer’s Report that “is on hold pending mutually advantageous changes for the 2015 hearing.” It is the MAC’s position that the EQB and Attorney General Office responses to the commenter’s allegations do not support the commenter’s position. In her July 31, 2015 letter, Ms. Courtney Ahlers-Nelson, EQB Principle Planner, wrote: “…the EQB recommends that the SMAAC work with the MAC to address your concerns. The MAC is the responsible governmental unit and has prepared the AOEE report and is therefore responsible for its accuracy.” The MAC General Counsel has determined that the MAC’s AOEE process fully complies with Minn. Stat. § 473.614.

Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

V AOEE hearing process and location

Please see the response to comment B.

Mr. Jim Spensley, W 2014 AOEE Please see the response to comment U.


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Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

Appeal


X AOEE publication

Please see the response to comment U.


Y AOEE does not report environmental impacts



Z Overflight impacts are not provided



AA Prior environmental reviews, Prior noise assessments



AB Noise modeling Comment noted.


AC Previous pollutant accumulation reports



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Written Comment Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

AD AOEE is incomplete



AE 2035 LTCP postponement and eventual results

Comment noted. Please see the response to comment U.


AF Previous AOEE and Environmental Assessment findings



AG Forecasts, runway use, CIP / LTCP financing

Existing origination and destination passenger demand and facility requirements are driving many of the near-term facility improvements proposed in the CIP. The Long-Term Comprehensive Plan (LTCP) is an infrastructure planning tool updated regularly based on projected passenger demand and aircraft operations levels. It is forward-looking in nature and does not authorize actual construction or serve as a basis for noise mitigation. The assumptions used in the forecasts developed for the LTCP are based on input from airline and Airport officials, previous MSP studies, relevant literature, and professional experience. Forecasting, however, is not an exact science. Departures from forecast levels in the local and national economy and in the airline business environment may have a significant effect on the projections. These uncertainties increase towards the end of the forecast period, when new technologies and business strategies and changes in work and recreational practices may have an unpredictable impact on aviation activity. For these reasons, the forecasts will be periodically


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compared with actual Airport activity levels, and Airport plans, policies, and capital investment programs adjusted accordingly to match demand as it materializes. The effects of the FAA’s Converging Runway Operations (CRO) procedures will be considered in the runway use forecast assumptions used in the MSP LTCP update 2035 noise contours. Regardless, the FAA’s CRO activities are outside of the scope of the MAC’s AOEE process. As detailed in the annual noise contour analysis (the report is available for download at: https://www.macnoise.com/tools-reports/annual-reports), noise impacts at MSP have been steadily decreasing since 2005. The CIP cost estimates are provided in the AOEE document. These expenses will be funded by a combination of airport revenue, passenger facility charges, grants and bonds.


AH Increased operations cost to environment and safety

Please see the responses to comments F and U. The MAC has a long history of rigorously analyzing environmental impacts and aggressively mitigating those that result from MSP operations and development, the noise program being a major example. The forecasted increase in aircraft operations and passengers is anticipated regardless of the proposed developments. An assertion that the proposed developments are going to result in demand that will increase aircraft operations requiring an EIS is a mischaracterization of the circumstances and of the environmental review required under state and federal law.


AI LTCP alternatives

The MAC is in the process of updating the MSP LTCP. 40 CFR 1502.14(a) states: “Rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” The MAC utilizes this approach in its long-term plans and federal environmental review documents.

Mr. Jim Spensley, AJ Forecasting Please see the response to comment AG.


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methods


AK Forecast unrealistic

Please see the response to comment AG.


AL CIP modifications

Comment noted.


AM Peak hour operations, Project priority list

Please see the response to comment F. The use of runways and the implementation of NextGen are the jurisdiction of the FAA and are outside the scope of the AOEE. The MAC cannot comment for the FAA.


AN Overflight emissions

Please see the responses to comments A, C, and U.


AO Noise impacts, Runway use

The MAC assess the noise impacts of actual operations on an annual basis and noise mitigation eligibility is determined based on actual noise impacts. This analysis incorporates actual runway use, aircraft routes, and profiles. The forecast 2035 noise impacts in the MSP LTCP update will consider these baseline circumstances along with forecast variables that include the effects of the FAA’s Converging Runway Operations procedures on runway use.

Mr. Jim Spensley, Minneapolis, MN,

AP FAA / EPA science



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South Metro Airport Action Council (SMAAC), Written Comment Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

AQ Low altitude emissions



AR Overflight pollution



AS DNL modeling Please see the responses to comments A, C, D, and U.


AT Greenhouse gas emissions



AU Greenhouse gas emissions, Runway use

Please see the responses to comments C, D, E, K, and AH. A 2015 Airport Cooperative Research Program (ACRP) report, Understanding Airport Air Quality and Public Health Studies Related to Airports (the report is available for download at: http://apps.trb.org/cmsfeed/TRBNetProjectDisplay.asp?ProjectID=3247) reviewed past studies and synthesized findings from the existing body of knowledge on airport air quality and public health to better understand airport-related air quality health concerns. The report states: “The state of airport air quality and health research is


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currently not mature enough to allow definitive conclusions in most cases. As such, all conclusions should be considered snapshots in time since future research may provide further details. However, the current research efforts appear to be aligned with the prioritization of pollutant health risks. Based on the relative number of studies and the recent focus, available resources appear to be correctly being applied to [particulate matter] and [Hazardous Air Pollutants] research, with consideration of ozone for regional-scale analyses.” The report goes on to conclude: “Regarding airport contributions to local air quality, studies have shown that airport emissions and resulting concentration contributions can be well correlated to airport operations (e.g., aircraft usage) as part of source identification and apportionment work. The more pertinent issue is in quantifying these contributions. The current research efforts appear to be aligned with the need for further measurements and understanding of health impacts.”


AV Fuel usage Please see the response to comment J.


AW Noise exposure, New aircraft technology

Advancements in aircraft and engine technology are being realized through R&D investments targeting efficiency and reduced environmental impacts. As an example, per the FAA’s website (www.faa.gov/news/press_releases/news_story.cfm?newsid=19454&omnirss=press_releasesaoc&cid=102_p_r), the second phase of FAA’s Continuous Lower Energy, Emissions, and Noise (CLEEN II) Program is providing approximately $100 million over five years to accelerate development and commercial deployment of environmentally promising aircraft technologies and sustainable alternative fuels. The CLEEN II program will build on the success of the original cleen program, a public-private partnership that began in 2010 and is a key part of the FAA’s NextGen efforts to make aviation more environmentally friendly. The goal of the program is


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to reduce aircraft noise, emissions, and fuel burn. FAA reports that it has awarded five-year agreements to Boeing, General Electric, Honeywell, Pratt & Whitney, Rolls-Royce, Delta TechOps/MDS Coating Technologies/America’s Phenix and Rohr, Inc/UTC Aerospace Systems. These companies will match or exceed the FAA’s investment in this cost-sharing program, bringing the total to at least $200 million. The FAA’s website reports the CLEEN II program goals including developing and demonstrating:

Reducing fuel burn by 40 percent relative to the most efficient aircraft in service during the year 2000;

Cutting nitrogen oxide emissions during takeoff and landing by 70 percent over the 2011 International Civil Aviation Organization standard without increasing other emissions;

Lowering noise levels by 32 decibels (dBs) relative to the FAA Stage 4 noise standard; and

Expediting the commercialization of “drop-in” sustainable jet fuels through support for the fuel approval process.

Technologies onboard the B737 MAX and Airbus New Engine Option (NEO) aircraft are a product of this collaborative initiative.


AX Peak hour operations

Please see the response to comment F.


AY Noise, pollution, and safety risk management costs

Please see the response to comments A and AH. The MAC has developed countless environmental documents and continues to produce volumes of data and reports on the environmental impacts of MSP. This has all been done incompliance with state and federal environmental laws, and in many cases goes beyond those requirements.

Mr. Jim Spensley, Minneapolis, MN, South Metro

AZ Peak hour operation safety



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Airport Action Council (SMAAC), Written Comment Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

BA Overflight pollution

Please see the responses to comments A, C and U.


BB Airline fares Please the response to comment F.


BC Environmental standards exemptions

Comment noted.


BD Airlines ignore public health risks

Comment noted.


BE MSP Residential noise mitigation program

Comment noted. Please see the response to comment D. The MAC has invested approximately $500 million in mitigating more than 15,000 homes and 19 schools around MSP. Recent efforts, consistent with the Consent Decree, have focused on noise mitigation beyond the FAA’s threshold of 65 DNL to the 60 DNL noise contour around MSP.

Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council

BF Met Council forecasting responsibility

Comment noted.


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(SMAAC), Written Comment Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

BG Overflight emissions

Please see the response to comment AN.


BH Noise impact analyses

Please see the response to comment AO.


BI FAA / EPA science

Please see the response to comment AP.


BJ Peak hour operation safety



BK Overflight pollution



BL Airline fares Please see the response to comment F.

Mr. Jim Spensley, Minneapolis, MN, South Metro

BM Environmental standards exemptions

Comment noted.


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Airport Action Council (SMAAC), Written Comment Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

BN Noise and pollution impacts

Please see the response to comments A and AH.


BO Peak hour operations

Please see the response to comment F and I.


BP Hub operations Please see the response to comment F.


BQ MSP capacity Please see the response to comment F.


BR Increased capacity



BS Airline competition and fees


Mr. Jim Spensley, BT AOEE location Please see the response to comment B, C, and U.


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and process


BU Greenhouse gas and ultrafine particulate emissions

Please see the response to comment B, C, K, and U.


BV 2014 AOEE Appeal



BW AOEE review Please see the response to comment U.


BX AOEE location and process

Please see the responses to comments B and U.


BY LAX particulates study

Please see the response to comments A, B, C, F, and U.


BZ AOEE process Please see the responses to comments B and U.


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Written Comment Mr. Jim Spensley, Minneapolis, MN, South Metro Airport Action Council (SMAAC), Written Comment

CA CIP projects and AOEE findings

Comment noted.


CB AOEE process Please see the responses to comments B and U.


CC 2014 AOEE appeal



CD New noise exposure map

Comment noted.


CE NextGen deployment

Comment noted.

Minnesota Department of Transportation, Written Comment

CF Minnesota Highway System, MAC and MnDOT Coordination

The MAC works cooperatively with all regulatory agencies, including MnDOT, every year in applying for and procuring the necessary permits prior to initiating construction.

Ms. Doris Overby, Minneapolis, MN, Written Comment

CG AOEE public hearing location, AOEE public hearing notifications

Please see the response to comment B.


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Documents

MEMO 1- 2016-2022 CIP AOEE