RECENT ADDITIONS:

Response to Nigel Finney on matter of FEIS Approval EQB
January 19, 2006

Talktrans/Zero Expansion Comments/Attachments For EQB Meeting
January 19, 2006

Talktrans/ZeroExpansion Response to Reliever Task Force Recommendations
January 10, 2006

TalkTrans/Zero Expansion position related to expansion at FCM sent to MAC full Commission Meeting
10-17-05

Pressure on Airports for Restrictions Grows Nationwide
9-28-05

Corporate PIMBY 9-20-05

Local Transportation Research Group Cites AOPA for Disinformation to its Members
September 2005

Facts, not Fear-mongering, Drive Airport Concerns
August 10, 2005

Meetimg with Ramstad August 5, 2005

My View: Lax security at Flying Cloud Airport could pose a danger 7-20-05

Eden Prairie News Letter to the Editor 6-23-05

Response to EP Sun Article 6-16-05

Zero Expansion-talktrans Press Release 6-14-05

Zero Expansion Policy Change 6-13-05

Transportation and the Economy:
Incentives beyond economic value, the viability of the reliever airport system

Zero Expansion’s Position Statement on Expanding FCM

Eden Prairie City Staff Audit of Final Agreement with MAC
and MAC Commitments March 2005

Zero Expansion Meets with Governor Pawlenty's Finance Commissioner Dan McElroy at the Capital February 1, 2005
Expansion is Unnecessary & Unwise

Data, Questions, and Methods for Investigating Need Versus Expense of FCM Expansion: "Will spending 82.9 million dollars have any discernable effect at MSP or FCM?"

Fuel Spills

MAPP: Mothers Against Airport Pollution

MAC raising rent, fees

Open Letter to MAC

City to do audit on 2002 airport pact with MAC

Press Release! 4-24-05




Transportation and the Economy:
Incentives beyond economic value, the viability of the reliever airport system
CTS Transportation Conference April 26, 2005
Talktrans/Zeroexpansion
www.talktrans.com
talktransporation@yahoo.com

1. GAO (General Accounting Office) reports, analysis and testimony to Congress identify a decreased need for reliever airports, as they were intended, and a new use for more commercial operations that require different land use. In Testimony given in 1994 on the AIP, Airport Improvement Plan, the GAO reported to the Chairman and Members of the Subcommittee on Aviation Committee on Transportation and Infrastructure at the House of Representatives. In their testimony the GAO stated that the "FAA did not consider general aviation to be a significant factor in congestion at commercial airports because of an overall decline in general aviation traffic. The GAO also identified "excessive access for General Aviation operations in areas where relievers are located." FAA projections at that time (for 1994 to 2005) for General Aviation traffic suggested that "the future of reliever airports in alleviating congestion and delays would likely remain small. Scaling back the number of relievers appeared to have wide spread support." Flying Cloud Airport, one of 6 reliever airports in the metro area, has experienced a steady decline in operations in the 90’s. In 2003 the airport had a 12% decline in operations.

2. Studies indicate a need for increased cargo capacity for the aviation system in the state. The ability of the state to compete in global markets is seriously affected by the lack of a dedicated state-of-the-art cargo facility with a 10,000 ft runway. (Reliever airports were originally designated with land use planning that included runway lengths under 5,000ft. In the 90’s the legislature changed the status of relievers from minor use airports to intermediate use which would allow 5,000ft runways.) A new FAA policy weakens a pavement strength limitation in order to service 100,000lb plus aircraft at smaller airports; this new ruling could facilitate cargo operations. A study done by the Swiss consulting firm SITA, SITA Geneva (Switzerland) and MNDOT 2001, reported that Minnesota displays an absence of shipper demand for better international service. Minnesota could lose companies due to insufficiencies in its cargo system. Task force members also said that an air-cargo airport in a less densely populated area would allow more night flights to serve cargo/ shipping needs. Night flights at MSP, despite voluntary restrictions, have been a continuing irritation for residents of south Minneapolis.

3. The relievers have been heavily subsidized by fees, taxes, and revenues from MSP so under pressure from NWA, MAC has instituted higher rates and charges to the users of reliever airports. MAC commissioned several aviation business consultants to assess the economic options available in order to make the relievers more self-sustaining. But, because these airports are so highly regulated and have land constraints, which inhibit their ability to have off-site sources of revenue, GCW Consulting affirmed that in order to turn around the deficit, rates had to be increased dramatically as well as charges for services. According to GCW, MAC’s largest relievers only “generate one-third to one-half of the expected level of revenue.” Operating revenue at the relievers increased from $1.7M in 1999 to $2.6M in 2002 showing that the six reliever airports continue to operate at a significant loss. Since 1999, the operating expenses have been four times greater than the operating revenues, and the deficit continues to grow annually. But users buck rate hikes and charges and say they will be forced to go out of business. The AOPA, Airline Operators and Pilots Association, the largest aviation lobby group in the nation,
http://www.aopa.org/whatsnew/newsitems/2004/040929mac.html Vice President of Airports Bill Dunn argued “against giving MAC a "blank check" to add special assessments for new projects, such as a runway extensions at Flying Cloud Airport. The majority of tenants at that airport may not need or benefit from this project, yet they would be forced to pay for it.” NOTE: Rates at the relievers have not changed for over 30 years.

4. Despite MAC’s economic indicators for Flying Cloud Airport’s expansion based on the FAA multiplier effect, it is apparent that General Aviation airports have limited use and potential for increased revenue when compared to mix-use development. The Millennium Plan for the reuse of Toro Air Force Base in California used an economic benefit analysis tool based on the Minnesota Implan Group (MIG) model, an industry standard model. Here are some of the results of this analysis. It is apparent that General Aviation airports have limited potential for increased revenue and in fact repress home values, high-paying jobs and quality-of-life as evidenced by the MIG analysis results:

  • The Millennium Plan will create approximately 50,000 high paying jobs on site and more than 100,000 jobs County wide. In comparison, airports generate many lower paying, shorter term jobs.
  • The Orange County Business Coalition, founded by a number of high tech companies such as Rainbow Technologies and Western Digital, are staunchly anti airport citing a lack of need and the negative impact on the environment which would harm their ability to attract top talent to their companies.
  • With The Millennium Plan, more than half the property becomes an economic engine driving technology based companies that will stimulate the economy in the future. This incubator for entrepreneurship and education is balanced with open space, including a 900+ acre habitat reserve and more than 2,000 acres in total park and recreational space.
  • The maintenance of the open space is offset by the revenues generated by other land uses resulting in a net positive cash flow to the County. Some portions of the open space, such as golf courses or community parks may be maintained through private development or user fees.
  • The reuse total output by year 2020 is expected to be $10.4 to $12.9 billion annually. This represents revenue that will all be put into the local economy. The total revenue to the County from property tax, sales tax and other fees is $17 million annually. The net revenue to the County, after all services to operate and maintain the property including fire, and police service is $8.2 million, per year.
  • Property that will generate jobs can be conveyed at some negotiated rate below fair market value. This is called an economic benefit conveyance.
  • A portion of the property will be considered public benefit and will be conveyed at essentially no cost. This would include the habitat reserve, park areas, college campus, arts center etc. This accounts for more than half the property.
  • The Millennium Plan will generate $1.08 billion in revenue from land sales and building leases, while infrastructure development, maintenance and operations over a 20 year period will cost $683 million, resulting in a net positive cash flow of $398 million to the reuse authority.
  • A 1996 study, funded by a grant from the Legislature of the State of Washington, found that the proposed expansion of the Seattle-Tacoma Airport would cost five nearby cities $500 million in total property values and $22 million in real-estate tax revenue.
  • Noise from a potential new airport at El Toro was determined to reduce the actual market value of real estate owned by residents and businesses in Orange County by $1.1 to $3.5 billion. The latter figure more than doubles the cost of the airport project.
  • The loss in market value from an airport, rather than mixed use, would result in an estimated $11 to $35 million annual loss of property tax revenue to the County, cities and school districts. This loss will have to be made up in some other way, such as through a reduction in public services.


5. How good are aviation forecasts when used to justify the building or expanding of airports?
In the case of Orange County, the El Toro project calls these forecasts an imprecise science. In 1980, SCAG, Southern California Aviation System Study projected that flight demand in Southern California would reach 109 million passengers by the year 1995. SCAG was about 36 million passengers off, that’s half. http://www.eltoroairport.org/issues/forecasts.html The FAA forecasts for 2110 for an expanded Flying Cloud Airport indicated 203,486 operations while MAC’s forecasts indicated 302, 982 operations. That’s overestimated by half. The cumulative cost of the expansion was projected to be $82.9M in 2004. That compares to $49.7M in the Draft EIS and $60.5M in the Supplemental EIS.

  1. Question: Since undeveloped land is so expensive, and the relievers which were mandated in 1946 to relieve MSP, no longer function in that capacity today, should MAC divest itself of the reliever system and let citys make the decision whether or not to manage their reliever airport themselves or reuse the undeveloped land for redevelopment purposes?

    Response most often given-YES.

  2. Question: Since cargo is essential to Minnesota’s economy, should MAC spend $90M dollars to lengthen runways at a reliever airport, for non-cargo operations, when general aviation operations are down trending annually? (MAC has stated there would be no cargo operations at Flying Cloud Airport. Yet, a new FAA policy allows heavier planes to access thousands of small airports around the nation.)

    Response most often given-NO.

  3. Question: Is it fiscally responsible for MAC to throw $90M to expand a reliever airport when its operations and revenues continue to down trend, but more than that because its own users don’t want to pay for it in increased rates and charges, all the while it’s the public who are subsidizing these users in the form of higher ticket prices, taxes and concessions at MSP?

    Response most often given-NO.

  4. Question: Do you think the MET Council, who are responsible for land use planning and its impact on the community, the legislature or even MAC have ever considered the real economic potential that exists in reuse of underused and highly subsidized airports?

    Response most often given-NO.

  5. Question: Shouldn’t development and expansion of transportation infrastructure, in particular General Aviation airports, which clearly have limited use, be assessed by utilizing an unbiased, non-industry, economic benefit analysis tool that would impartially determine economic impacts to a community?

    Response most often given-YES.

New! 2-5-05

Data, Questions, and Methods for Investigating Need Versus Expense of FCM Expansion: “Will spending 82.9 million dollars have any discernable effect at MSP or FCM?”

Background Proposed expansion at FCM: (1) Lengthen and shift westward the primary runway to 5000 feet to enable larger jet aircraft to use Flying Cloud Airport (“FCM”), (2) construct a new service road, (3) construct additional hangers. Cost of expansion: 82.9 million dollars. (FEIS at V-23)

Purpose and Need MAC staff claims that expansion is not required to meet any projected increase in operations at FCM; it is only to accommodate larger business jets with the intent to decrease general aviation (“GA”) congestion at MSP. (Final Environmental Impact Statement (“FEIS”) at pg. II-5).

MAC staff claims that the need to expand exists because a larger runway will decrease GA traffic at MSP in three ways: (1) aircraft based at MSP will move FCM; (2) stopovers from FCM to MSP will be eliminated; and (3) transient aircraft will use FCM over MSP. (FEIS at pg. II-1, 2, 3, 4)

MAC staff claim that construction of new hanger space is necessary because there is a waiting list of 50 – 100 of “persons” for hanger space at FCM that has fluctuated over the last several years. (FEIS at pg. II-4)

MAC staff claim that a service road is necessary to eliminate service and maintenance vehicles from crossing the runways. (FEIS at II-4)

Alternatives MAC staff is required by law to investigate alternatives to expansion that may achieve the same desired result. Minnesota Rules 4410.2300(g). Given the purpose of expansion is to decrease GA at MSP, MAC should investigate whether alternatives to expansion could decrease GA traffic at MSP, such as financial incentives, appropriate market rates or lease requirements. This should have been done for the FEIS and wasn’t. See my comments and Northwest Airline’s comments to the FEIS and Section VI below.

What are current GA conditions at MSP? If the purpose of expansion is to relieve GA traffic at MSP, current and future GA conditions at MSP should be analyzed.

Does GA traffic cause delay at MSP? GA traffic at MSP has declined significantly. In 1997, there were about 60,000 general aviation operations at MSP (12% of MSP operations). In 2002, general aviation operations at MSP decreased to 25,075 (6% of MSP operations). There are no individually owned GA aircraft based at MSP.

Since 1994, “FAA does not consider general aviation to be a significant factor in congestion at commercial airports today.” “FAA’s analysis showed . . . [g]eneral aviation was not identified as a major cause of delay.” “Although congestion caused by general aviation at commercial airports was a consideration when the reliever program was established, it has largely ceased to be one now.” See the 1994 US General Accounting Office Report.

How many operations would leave MSP if FCM was expanded? It is significantly more expensive to base aircraft at MSP over reliever airports. There are business reasons, other than runway length, for using MSP over reliever airports, such as location, ability to connect with commercial flights, and Signature Service. MAC staff state that there are 2 operators who would move from MSP to FCM if the runway were extended. Who are they and how many operations would leave MSP as a result of the move? What are the numbers of operations that will move to FCM compared to the total number of GA operations at MSP? Compared to total operations at MSP? Will these operators move to a reliever if there is no FCM expansion? Would they move to St. Paul Holman where larger runways already exist?

What are predictions for future GA at MSP? Will GA traffic continue to decline as it has for the last decade in Minnesota? Look at the statistics for GA traffic at all the reliever airports and MSP. Previous predictions of increased GA traffic by MAC staff and consultants have been significantly incorrect. What does FAA and other government agencies predict?

Will expansion bring larger jets to FCM? The entire purpose of spending 82.9 million dollars is to allow larger jets to use FCM. There is no data or information so far to support MAC staff’s claims that any significant number of larger jets will come if 82.9 million is spent on 5000-foot runway. It is clear that MAC staff/consultants have done a poor job investigating this critical question. What little information MAC staff has to answer this question was poorly gathered.

MAC’s 1997, 1998, 1999 survey of 39 non-FCM jet operators. A survey was conducted in 1997 and was updated in 1998 and 1999. Of 39 non-FCM based jet operators interviewed in the metro area, only two stated that they would move operations to FCM if the runway were expanded. Some survey information was included in MAC’s “Flying Cloud Airport Expansion Technical Report: Activity Forecasts 1999, however, this information is not accurate. HNTB clarified that only 2 operators would potentially move to FCM if the runway were expanded to 5000 feet, explained in a memo to me from MAC’s consultant HNTB dated 12/4/01 that is attached to this document. More importantly, HNTB did not provide me with all of the answers these respondents provided in the updated survey, including what types of aircraft they would move to FCM and how many operations that would involve. Are they aircraft that could currently use FCM without expansion? For an expense of $82.9 million, MAC commissioners should review the actual notes from the interviews and/or these operators should be questioned again about specifics.

MAC’s study of expansions to 5000-foot runways at comparable airports did not answer the question. MAC hired a consultant to see what effect expanded runways had at other comparable reliever airports. According to MAC’s “Flying Cloud Airport Expansion Technical Report: Activity Forecasts 1999” none of the seven comparable reliever airports studied for comparison of a runway extension from 4000 to 5000 feet had an increase in operations attributable to lengthening the runway. According to HNTB, the critical question of whether larger jets used the expanded runway was not discernable from the types of data reviewed, only the number of operations post expansion could be determined. MAC staff did not investigate further whether there was any effect whatsoever on the size of the aircraft using the extended runways at the comparable airports. More investigation is needed.

Do FCM stopovers cause GA congestion at MSP and will they stop as a result of expansion? MAC staff claims that three types of aircraft originating from FCM must stop over at MSP to refuel or pick up passengers as a result of a runway length under 5000 feet. These are the Cessna 550, Beechjet 400, and Beechjet 400A. MAC staff claims stopovers cause GA congestion at MSP. The critical questions are (1) Do stopovers cause congestion at MSP? (2) Will stopovers to MSP cease when the runway is extended? (3) Will stopovers significantly increase in the future? Again, these are critical because MAC staff claim expansion is necessary because of stopovers.

How many Cessna 550, Beechjet 400, and Beechjet 4 are based at FCM? MAC staff has never provided this important information because it has always exaggerated the number of stopovers it claims, as seen below. If the number of these three types of based aircraft were given, the number of stopovers claimed could be better analyzed.

How many stopovers? MAC conducted a survey in 1997 of six FBOs, in which they were asked:

“After taking off from Flying Cloud Airport, have you at any time in the past year had to take on additional fuel or pick up passengers at another metro airport such as St. Paul Downtown or Minneapolis-St. Paul International before continuing on to your final destination? Yes or No. If yes, how many times?”

See Appendix D of the Flying Cloud Airport Expansion Technical Report Activity Forecasts November 1999 (emphasis added). Only 2 of the 6 FBOs responded yes to stopovers. The survey states: “The two firms combined for a total of 16-29 times,” and provides Table D-4 that shows one firm responded “5-10 times flown out light” and one firm responded “11-19 times flown out light”. The survey does not specify whether the FBO went to MSP or STP. Even assuming all of the 16-29 operations went to MSP, obviously, 16-29 operations in a year is a minimal amount.

MAC’s 1997 survey is very clear that the question asked was not round trip flights or how many times per week. The question asked was operations per year. Nevertheless from this survey information, MAC claimed in the Draft EIS and Supplement EIS that the stopover operations from FCM to MSP were 8,300 a year! These fictitious 8300 stopovers a year was the basis for the calculated economic benefit of over 105 million dollars in the Supplement EIS! See the attached memo to me from HTNB, which calculates this fictitious benefit. In my comments I questioned the accuracy of 8,300 stopovers because this number is so high that it equals more than the total number of ALL business operations at Flying Cloud for that year!!! See Table 2 in the FEIS at page II-5.

How did MAC staff answer my question in the FEIS? MAC staff claimed to have contacted the survey respondents again, seven years after the survey, on January 6, 2004. MAC states in the FEIS that respondents now claim that seven years ago when the survey was conducted, they actually meant flights per week, not operations per year, even though the survey question was specific as to it being a “take-off,” not a round-trip flight, and asking per “year,” not a week. Seven years later, these 2 FBOs claim that since the 1997 survey, they continue to have the identical number of stopovers today that they had seven years ago. So, in the FEIS, MAC has now changed the number of stopovers from 8,300 to 2,340 (a significant decrease of over 5000 operations!) with an economic benefit of $67 million if the runway were extended and all of these were eliminated.

Even assuming MAC staff’s number of 2,500 stopovers at MSP is correct, stopovers do not cause congestion at MSP. Even assuming 2,500 stopovers a year from FCM to MSP, that is only 0.5% of total operations at MSP! Obviously 0.5% of operations do NOT cause congestion at MSP. Is it worth 82.9 million dollars to eliminate less than 0.5% of operations at MSP? Is it worth 82.9 million dollars to benefit only 1.6% of total operations at FCM that stopover at MSP?

Not all stopovers from FCM to MSP are due to inadequate runway length and therefore not all stopovers will be eliminated with expansion. Most stopovers from FCM to MSP are not the result of inadequate runway length. Many operations from FCM go to MSP in order to pick up packages or pick up passengers, at the passengers’ request. That is the nature of a charter service, to pick up the passengers at the destination selected by the customer.

How do you determine the correct number of stopovers from FCM to MSP because of inadequate runway length? According to expert MAC staffer Aaron Fraise who works in the noise complaint department, radar data from the Air Traffic Control Tower can be analyzed using the ANOMS software program to accurately count the number of take-offs from FCM that land at MSP by applying appropriate “Gates” around FCM. Those tracks can then be analyzed by aircraft type to identify whether the operation was one of the three types of aircraft that cannot take-off at full weight at FCM: Cessna 550, Beechjet 400, and Beechjet 4. Aaron said that he can correct any potential radar errors in misidentification of the aircraft because of his extensive experience and knowledge in the characteristics of aircraft types. He also said that it would be reasonable to look at this data for as long as a 12-month period. This would be the most accurate way to determine stopovers, given the questionable answers by the 2 FBOs who are seeking expansion and the fictitious numbers previously presented by MAC staff.

MAC Staff claim that FCM could become a corporate hub for the southwest metro given development in that metro area. Although this is not the purpose of expansion, MAC staff has often claimed that an expanded runway could make FCM into a corporate hub for the southwest metro area. Although this claim seems interesting, MAC staff has never presented any data to support the claim. Even with expansion, MAC staff’s data shows that this will not happen. What are the government’s estimates as to what will happen to GA business jets in the metro area? MAC staff estimates have always been significantly higher than what FAA has predicted, and have been incorrect. See Table 2 in the FEIS at page II-5 and Northwest Airline’s comments to the FEIS at page 3.

Data shows diminishing operations and aircraft at FCM. Operations at Flying Cloud have been diminishing since 1994 (232,130) and were at one of the lowest levels in decades in 2003 (155,837), the last year in which data is available. The number of aircraft based at Flying Cloud has been decreasing since 1987 and is at an all-time low of 463 aircraft.

Data shows most FCM operations are recreational and expansion is not intended to change that. According to MAC staff, currently, only 3% of operations at FCM are business jet operations. Even with proposed expansion, that number will increase only by 5% to a total of 8% business jet operations at FCM. Expansion therefore will not benefit 92% of users of FCM. FEIS at II-5.

Economic alternatives, instead of expansion, may exist to encourage use of FCM over MSP. Northwest Airlines and I proposed these in our comments to the FEIS. These should be investigated. Northwest Airlines points out that Flying Cloud has been operating with a deficit for years. The proposed Flying Cloud expansion without FCM operators’ financial accountability will only increase the deficit to the detriment of commercial airport users who pay direct and indirect costs for the Flying Cloud subsidy. The economic subsidy at all MAC reliever airports was 7.9 million in 2002 and was budgeted at 9.6 million for 2004. This deficit is illegal under Minn. Stat. Section 473.651 (reasonable and uniform charges with regard to value of and improvements on property) and FAA policy regarding airport rates and charges 61 Fed. Reg. 31994, 32014 (airports must be self-sufficient). The reliever airports’ deficit is caused by the following:

* MAC reliever airports generate much less revenue than other similar size reliever airports in the nation.

* MAC reliever airports are significantly less profitable than other similar size reliever airports in the nation.

* MAC charges lower rates at its reliever airports than rates charged by other comparable reliever airports in the nation.

* MAC’s sources of revenue at the reliever airports are significantly more limited than the sources of revenue at other similar size reliever airports in the nation.

* MAC has no reversionary clauses in its lease agreements so MAC tenants retain ownership of all improvements at lease termination, whereas nearly all comparables have reversionary clauses.

Economic tools, instead of the $82.9 million FCM expansion, can be used to persuade operators to use reliever airports over MSP while still increasing reliever rates. A 2004 report studying the costs of operating general aviation traffic at reliever airports versus MSP concluded that MSP is already an economically unattractive alternative for operators because of landing fees, higher fuel costs, taxi delays, and storage costs. Currently, it is nearly 300% to 450% more expensive to store a general aviation aircraft at MSP versus FCM. St. Paul Holman field already has a 5000-foot runway that can be better utilized with the construction of a dike to prevent flooding.

Demand for hanger space at FCM could be resolved by more efficient leasing rather than new construction. The demand for hanger space at FCM is the result of (1) under-pricing leases, such that demand exceeds supply; (2) 30-year leases that prevent turnover; and (3) the absence of reversionary clauses in reliever leases. These problems result in the use of hanger space for the storage of boats and RVs rather than aircraft.


New! 2-1-05

Data Shows that Flying Cloud Expansion Is Unnecessary and Wastes Money

Proposed expansion: (1) Lengthen and shift westward the primary runway to 5000 feet to enable larger jet aircraft to use Flying Cloud Airport (“FCM”), (2) construct a new service road, (3) construct additional hangers. MAC claims that expansion is not required to meet any projected increase in operations at FCM; it is only to accommodate larger business jets with the intent to decrease congestion at MSP. (Final Environmental Impact Statement (“FEIS”) at pg. II-5). Cost of expansion: 82.9 million dollars. (FEIS at V-23)

Data shows diminishing operations and aircraft at FCM
. Operations at Flying Cloud have been diminishing since 1994 (232,130) and were at one of the lowest levels in decades in 2003 (155,837), the last year in which data is available. The number of aircraft based at Flying Cloud has been decreasing since 1987 and is at an all-time low of 463 aircraft.

The FCM waitlist for hanger space can be remedied by appropriate pricing and lease practices without a $83 million expansion. The waitlist is the result of inefficient pricing and lease practices, including (1) under-pricing leases so that demand exceeds supply; (2) 30-year leases which prevent turnover and optimal use of hanger space; and (3) the absence of reversionary leases to the MAC such that tenants retain ownership of improvements at lease termination. This also results in the use of FCM hanger space for the storage of boats, RVs, and other non-aircraft.

Data shows most FCM operations are recreational and expansion is not intended to change that. Currently, only 3% of operations at FCM are business jet operations. Even with proposed expansion, that number will increase only by 5% . Expansion therefore will not benefit 92% of users of FCM. MAC estimates only 20 additional business jets will be based at FCM by 2010 if expansion occurs. $83 million for 20 jets.

Data shows FCM aircraft do not cause delay at MSP. In the FEIS, MAC claims that stopovers from FCM account for 0.5% of operations at MSP. This numbers is minimal and clearly does not result in delay at MSP. Two Fixed Based Operators, Elliot Aviation and Executive Aviation, who claim to have stopovers, state that their stopovers have not increased in 7 years. With appropriate financial incentives, FCM aircraft could utilize the airport at St. Paul Holman Field to refuel or pick up passengers instead of MSP. $83 million to change 0.5% of operations at MSP.

Data and studies show general aviation does not cause delay at MSP. Since 1994, “FAA does not consider general aviation to be a significant factor in congestion at commercial airports today.” “FAA’s analysis showed . . . [g]eneral aviation was not identified as a major cause of delay.” “Although congestion caused by general aviation at commercial airports was a consideration when the reliever program was established, it has largely ceased to be one now.” See the 1994 US General Accounting Office Report. For example, in 1997, there were about 60,000 general aviation operations at MSP (12% of MSP operations). In 2002, general aviation operations at MSP decreased to 25,075 (6% of MSP operations). There are no individually owned GA aircraft based at MSP. Many GA operations at MSP connect passengers to commercial flights or have passengers using Signature Service at MSP, which is not available at FCM.

MAC’s studies of comparable airports show that lengthening FCM runways will not result in increased operations. According to MAC’s “Flying Cloud Airport Expansion Technical Report: Activity Forecasts 1999” none of the seven comparable reliever airports studied for comparison of a runway extension from 4000 to 5000 feet had an increase in operations attributable to lengthening the runway. Even though none of these comparable airports had any increase in operations from lengthening the runway, MAC did not investigate whether there was any effect whatsoever on the size of the aircraft using the extended runways. According to MAC’s own studies, $83 million dollars will have no discernable impact at FCM or MSP.

Northwest Airlines’ Economic Data Shows Flying Cloud Expansion Is Unwise

Flying Cloud has been operating with a deficit for years. The proposed Flying Cloud expansion without FCM operators’ financial accountability will only increase the deficit to the detriment of commercial airport users who pay direct and indirect costs for the Flying Cloud subsidy. The economic subsidy at all MAC reliever airports was 7.9 million in 2002 and was budgeted at 9.6 million for 2004. This deficit is illegal under Minn. Stat. Section 473.651 (reasonable and uniform charges with regard to value of and improvements on property) and FAA policy regarding airport rates and charges 61 Fed. Reg. 31994, 32014 (airports must be self-sufficient). The reliever airports’ deficit is caused by the following:

* MAC reliever airports generate much less revenue than other similar size reliever airports in the nation.

* MAC reliever airports are significantly less profitable than other similar size reliever airports in the nation.

* MAC charges lower rates at its reliever airports than rates charged by other comparable reliever airports in the nation.

* MAC’s sources of revenue at the reliever airports are significantly more limited than the sources of revenue at other similar size reliever airports in the nation.

* MAC has no reversionary clauses in its lease agreements so MAC tenants retain ownership of all improvements at lease termination, whereas nearly all comparables have reversionary clauses.

Economic tools, instead of the $82.9 million FCM expansion, can be used to persuade operators to use reliever airports over MSP while still increasing reliever rates. A 2004 report studying the costs of operating general aviation traffic at reliever airports versus MSP concluded that MSP is already an economically unattractive alternative for operators because of landing fees, higher fuel costs, taxi delays, and storage costs. Currently, it is nearly 300% to 450% more expensive to store a general aviation aircraft at MSP versus FCM. St. Paul Holman field already has a 5000-foot runway that can be better utilized with the construction of a dike to prevent flooding.

Demand for hanger space at FCM could be resolved by more efficient leasing rather than new construction. The demand for hanger space at FCM is the result of (1) under-pricing leases, such that demand exceeds supply; (2) 30-year leases that prevent turnover; and (3) the absence of reversionary clauses in reliever leases. These problems result in the use of hanger space for the storage of boats and RVs rather than aircraft.

Actions That Pawlenty’s Administration Can Do to Stop Flying Cloud Expansion


Educate and discuss with MAC Commissioners the data and information that show Flying Cloud Expansion is a waste of money. Commissioners do not receive complete information from MAC staff. MAC staff has been working too long on this project and may be unduly influenced by two fixed-based operators at Flying Cloud to have an objective and informed perspective on proposed expansion and its shortcomings.


Persuade MAC Commissioners to stop the environmental review process on Flying Cloud expansion. Currently, MAC has “indefinitely” terminated Flying Cloud expansion in its capital improvement budget. MAC must take this one step further and formally withdraw the expansion project from environmental review. If the project is not going forward, it is a waste of time and money for MAC to proceed with environmental review. The data, information, and basis for expansion in the Final Environmental Impact Statement are now outdated. If expansion is warranted in the future, a new environmental review process must start anyway.


Persuade MAC Commissioners to divest MAC of the $ 34 million land already acquired in Eden Prairie for the proposed expansion. According to EQB rules, this property should not have been purchased before final approval of the project by the EQB. The money MAC earns from selling this property could be used towards proposed expansion at MSP. By MAC needlessly holding onto the property in anticipation of future expansion, the City of Eden Prairie and local economy loses millions of dollars in beneficial use of the property for office, industrial and housing space. According to the City of Eden Prairie, as a result of MAC’s acquisition of 280 acres of land for this expansion, the City loses $ 126,991,644 from taxes, fees, and utilities over the life of the property at present worth. If expansion at Flying Cloud is needed in the future, MAC can condemn the property then.


Persuade MAC Commissioners to require any future costs from capital improvements at Flying Cloud to be approved and borne by those using Flying Cloud. It is unfair to commercial airport consumers and residents of the southwest metro area to continue to subsidize Flying Cloud at the past and current level. All costs of capital improvement, including depreciation and interest, should be added to rates charged to Flying Cloud users. This is a proven, effective tool for justifying and managing capital improvement decisions. See Northwest Airline’s Memorandum from Jim Greenwald to MAC dated October 9, 2004 regarding reliever airport fees.


NEW! Jan 3, 2005

Open Letter to MAC 1-3-05

Why is the airport being expanded for only 20 operators, when ops are down and alternatives are available ?

Dear Representative Paulsen, Chair Tigwell, Gary, Tim and MAC Commission Members,


An FOIA request for information has been sent to MAC's Bridgette Rief, from Zero Expansion/talktrans which asks the question, why is the airport being expanded for only 20 operators, when ops are downtrending every year and alternatives are available?

There has been much written and said, for and against, the expansion at Flying Cloud Airport. But little, or no information has been revealed about the
identities of the 20 operators who want to use Flying Cloud Airport in the event the reliever will expand.

In order for the public to understand and put into perspective the need for an expansion at FCM, it would certainly be helpful, if not absolutely necessary to know the nature of, location of their business, and the need of these 20 operators who wish to use FCM if expanded.

As NWA stated in their article in the EPN, "Subsidizing those who can afford to fly private airplanes.... is more than unfair. It is just not right to the thousands of Minnesotans who work for or benefit from the state’s commercial airlines."

It doesn't seem at all fair, or even logical, for the public to subsidize an expansion for 20 operators.

The question everyone is asking: Who are these corporate owners and why can't they fly out of existing airports that can accommodate larger corporate jets in preferably aviation compatible surroundings, adjacent to industrial and corporate business parks, not community neighborhoods?

We can't imagine the expansion of the new 312 receiving funding if there were only 20 new users.

The rationale for a longer runway for 20 corporate jet aircraft, subsidized by the public, is inconsistent with any funding process that constructs and maintains the public's transportation needs. Even if there was a gas tax, at least users would be paying for something they're using. In the case of expanding FCM, even if it were 40 corporate jet aircraft, or 60, the subsidy is still incommensurate, because it's coming out of someone else's pocket with no return on their investment, and little likelihood of using the services.

Think of it this way: Not only does the public get taxed to drive their own vehicles; ride a bus, or take a cab, all of which are taxable services, their travel tickets and parking get taxed at MSP to subsidize someone else's corporate plane flying out of FCM. That's preposterous.

So we ask the question: Who are these 20 operators and why do they expect the general public to subsidize their business travel?

If the answer is that these companies contribute millions to the local economy, jobs and taxes, and that's why we should subsidize their business travel, we don't buy it.

The public contributes en mass to the local economy and not one of us gets a free ride to where ever we want to go.



Zero Expansion/TalkTrans
www.talktrans.com
transportationtalk@yahoo.com


NEW! 12-21-04

MAC raising rent, fees on tenants at 'reliever airports'

Susan E. Peterson

Star Tribune December 21, 2004




Rents to rise at small airports – Pioneer Press

Tenants complain hikes are too steep

BY JACK SULLIVAN

Pioneer Press, Published on December 21, 2004



NEW! 12-10-04

South Metro Airport Action Council
** S M A A C **

Public Announcement/Press Release
29 November 2004

Media: For further information, contact
Jim Spensley at 612/824-9988 or email Reply.


Mishandling of MSP Fuel Spills
Should Have More Serious Consequences


By, Jim Spensely, President SMAAC -SMAAC maintains www.quiettheskies.org, with ROAR and www.nonoise.org with a national organization.

In response to reports that the Minnesota Pollution Control Agency (PCA) was investigating the Metropolitan Airport Commission (MAC) concerning unreported fuel discharges, Pat Hogan, the Airports Commission’s PR guy, said, November 25th, “no cover-up or under-handed dealings” were involved. What is the difference, Pat, between “Airport jet fuel leaks revealed” – the Star-Tribune page 1 headline November 24th, and “... uncovered.” Even though thousands of gallons of aviation fuels admittedly were “leaked and subsequently cleaned up,” even though the airlines spent over $4 million dollars to “repair leaks,” and even though Commission funds were expended for clean-ups and a consulting contract, MAC didn’t report the now-admitted leaks and discharges or clean-ups to PCA, other involved agencies or the public for months.

The Commission and staff have been, if not negligent, then, certainly, not forthcoming. If there were no cover-up, Mr. Hogan would produce a press statement, a memorandum, a message to PCA or a notice to emergency management officials sent before February 2003. Even so, what is the chance that unreported problems and clean-ups started last winter? Isn’t it more likely that the airlines made repairs because fuel prices were sharply up in 2002? Perhaps there are staff memos on file supporting “consent items” approving payments and unbudgeted costs for innocently mistitled projects? Or did the MAC openly fund all of this, unnoticed by the PCA, the press and the public? Were contracts for cleaning up fuel spills unnoticed because the MAC has routinely had spills for many years?

It is misleading to excuse fuel leaks as “not polluting ground water used as a public water supply” or “being diluted or dissipated by flows in the Minnesota River.” There are no permitted levels of aviation fuel discharges from the airport fueling system to the environment. All spills and leaks are to be reported. Who floated the idea that PCA allegations were being disputed? Reportedly, a settlement is being negotiated; one that, in effect credits MAC’s and the airlines’ clean-up and repair expenditures as if they had been self-reported and completed adequately under PCA and fire-safety oversight. The Federal Environmental Protection Agency states that aviation fuel contains poisons and cancer-causing substances. An underground connection was found from the area to the Coldwater Spring near Minnehaha Park. There are at least hand-pumps for fresh water wells in the Park, plus the spring water is consumed. PCA investigators said “fuel reached the river at least 17 times.”

Hogan left “notice required by law” statements untouched. Safety regulations require prompt reporting of fuel leaks and spills. An investigation of how leaked fuel was disposed of may reveal serious violations. Fuel found in the sanitary sewer system suggests either a purposeful discharge or a sanitary sewer system damaged during construction projects or exceedingly poorly maintained in practice by the airport. These are very important matters indeed, but not the PCA’s jurisdiction.

If the leaked fuel discovery was kept from the Commission, the responsible staff, Nigel Finney and perhaps others should be fired. (Finney, Deputy Director for Planning and Environment, is also responsible for information distributed to Commissioners.) If the problem was brought to the Commission but dealt with quietly, then the Commission Chair and the Planning and Environment Committee Chair at the time are culpable, and the Governor should replace them, if not the entire Commission.

Recovery assistance and future preventative measures should have been ordered immediately. Funds should have been allocated and a wider investigation initiated. These omissions and delays are Commission malfeasance or staff incompetence, take your pick.

_____________________________

SMAAC maintains www.quiettheskies.org, with ROAR and www.nonoise.org with a national organization.


More on the PCA Investigation and Its Implications.

Perhaps the bar for transparency and the public’s right to know should be raised beyond PCA’s findings of unreported discharges of jet fuel at MSP. During the settlement talks, were admissions (of two specific discharges) made by MAC to avoid further penalties? Were there actually more than two leaks or spills? How were these spills related to airport expansion? Isn’t PCA’s enforcement authority limited, and isn’t MAC’s compliance compromised, by both being State agencies? PCA’s lead investigator said “It’s a big deal.” Will the settlement be a big deal?

An independent investigation of how fuel got into the sanitary sewer system is needed.
How did enough fuel to be discovered in the Bishop Whipple building enter the sanitary sewer? Possibilities are: a. during clean-up, fuel or fuel-water mixtures were "flushed" or pumped off directly into the sanitary sewer. To reach the Whipple building (which is probably higher than the sanitary sewer main) the flows must have been high or there was a temporary blockage of the sanitary sewer main, perhaps due to re-routing during airport or highway construction.
b. there are connections between, or inadequate separation of, sanitary and storm sewers as a result of improper design or construction (for example, a sanitary drain mistakenly used by workers or "flooded" by a fuel leak or spill; a catch-basin may be improperly connected to a sanitary sewer pipe instead of a storm sewer pipe).
c. both the sanitary and storm sewer systems have damage under ground or under buildings and the volume of fuel lost from the delivery system was enough (a whole lot) for fuel or fuel-contaminated runoff to enter the sanitary sewer against its pressurized outflow into the same "pool". (Then, what caused the damage?)

An internal but thorough investigation is called for at MAC. What reports were made
by staff to the Commissioners and when? Who failed to report externally? Was this a decision by the Commissioners or its officers? Why were expenses for clean-up and repair and for contracts to Barr Engineering for its after-the-fact investigation not acknowledged publically?

PCA’s investigation should include the airlines’ Minnesota Fuel Group and its relationship with the MAC. Some ambiguity exists about who is responsible for operational safety and environmental oversight of the Aircraft Service International Group (ASIG) and the airlines’ use of the underground fueling systems. Was operational accountability diluted by new players and new arrangements for operating the new system?

Finally, considering similar reporting issues surrounding noise, de-icing fluid recovery and discharges, stormwater management, de-watering, tunneling and numerous other regulated activities of the MAC, an independent investigation is needed into administrative practices of the MAC, which should have dealt quickly and openly with the fuel leaks by design. Is public awareness, legislative oversight, and regulatory compliance clouded? There have been other allegations of erroneous or misleading reports, undue confidentiality of records and contracts, undue political influence, conflicts of interest, and lack of accountability. What laws, standards, and rules apply? What controls are in place to monitor staff activities and commission practices for compliance?

NEW! 12-10-04

MAAP
Contacts:
Denise Hepple, 847-925-0396
Arline Bronzaft, 212-288-7532
Virginia Kucera, 847-394-0549


MAAP-Child Experts Join Mothers Against Airport Evils
December 2004

The newly formed Mothers Against Airport Pollution (MAAP) met to discuss a plan of action to protect the millions of American children, whose health is being harmed by airports and aircraft. The steering committee met last Thursday, December 2nd, discussing strategy to get the organization up and running.

"MAAP believes that it is important to get the word out to mothers and families, so they know there is a place to turn to. It is also important that they know many others are concerned about this too. Our children's health and future need to be protected from this horrifying killer," stated Denise Hepple, MAAP's Chairman.

Just one example of the harm that has been abhorrently understated by the federal government can be found in a study commissioned by eight states environmental agencies and overseen by the U.S. EPA ("Controlling Airport-Related Air Pollution"). That study found that the United Nations and U. S. government were grossly underreporting the amounts of deadly pollution coming from airports/aircraft.

For example: Combined aircraft-related amounts of benzene totaled 20 tons at Logan, Bradley, and Manchester airports in 1999! For comparison, total benzene emissions from the largest stationary sources in Massachusetts,
Connecticut, and New Hampshire combined only totaled six tons in 1996! Benzene is a known human carcinogen (IARC 1982a,b.) Even more astoundingly, mega airports, such as Chicago's O'Hare, operate more aircraft annually than all of the three above-mentioned airports combined; thus, emitting even more harmful and even deadly pollution in heavily urban-populated areas.

A new study conducted by American and Chinese researchers shows that even tiny amounts of the unsafe chemical is even more dangerous than first believed. Benzene is only one of the hundreds of harmful chemicals released
by airport operations. Another study found that O'Hare airport is responsible in whole or part for the deaths of hundreds of people each year, from cancer alone. Sadly, cancer is only one of the dozens of airport-poisoning diseases and it is not even the worst public health problem.

"Airports and aircraft are astronomical sources of toxic pollution, when one considers all of the components of an airport's related sources. And unlike cars, trucks, etc. who's harmful effects generally fall within hundreds of
feet of a roadway, aircraft fly over our heads contaminating an area of 20 miles or more away from an airport," states Hepple.

Concerned about the serious pandemic public health effects airports cause to us and our children, some noteworthy people have already joined join the movement. Virginia Kucera, MA, an Illinois Arlington Heights Village Trustee and former Director of Division of Chapter Services for the American Academy of Pediatrics wants to protect children from this unparalleled harm.

Arline Bronzaft, Ph.D. a noted expert on children and noise effects has also joined the association. Among many accomplishments, she is a researcher, author, and lecturer on the harmful effects of noise to a child's health, education and development. Doctor Bronzaft is professor emeritus of psychology at Lehman College; she serves on Council on the Environment of New York City, consults to the League for Hard of Hearing, and advises throughout the United States and abroad.

Now that the states and municipalities have broken off five year talks with the federal government and air transportation industry, MAAP's believes that children's health and future must be staunchly guarded and MAAP must advise parents on how they can protect their children and families and give them someone they can turn to.

Denise Heppel, Chairman
Mothers Against Airport Pollution


NEW! 4-20-05

City to do audit on 2002 airport pact with MAC
By Stuart Sudak

Wednesday, April 20, 2005

Eden Prairie plans to do a management audit of its December 2002 agreement with the Metropolitan Airports Commission on Flying Cloud Airport.

City Manager Scott Neal said the idea for an audit came after he and City Attorney Ric Rosow met with two residents about the agreement. The more questions the residents asked, he said the more their answers became vague.

Through the 2002 pact, the city agreed to withdraw its opposition to the planned expansion of the reliever airport in exchange for MAC's commitment to adopt and enforce mandatory and voluntary noise control measures there and to abide by limits on future growth of Flying Cloud.

Plans call for the airport's main runway to be extended from 3,900 feet to 5,000 feet, a second runway to be extended from 3,600 feet to 3,900 feet, and the development of a new airport hangar area.

"We thought it was about time that we take a look at the entire agreement and audit it so we have a list and we have responses of whether the MAC is complying with the agreement, and whether the city is complying with the agreement, and whether the pilots and the other business owners are complying with it," Neal told the City Council last week.

Neal hopes to have the audit finished by Sept. 1. He has asked MAC officials for their assistance in providing information for the audit, and they have agreed to do so.

Council member Ron Case, who asked Neal to update the council on the meeting, said there are several changes in the world of aviation causing some residents, many involved in a resident's group called Zero Expansion, concern.

One of their concerns centers on a Federal Aviation Administration ruling that has "perceptually made it possible that our agreement might not be as strong as we thought it was," Case said.

"We are having our attorney's look at that," he added. "And it has to do with pavement depth. And the ruling tends to negate what communities have already negotiated. We just want to make sure our agreement is still strong."

A statement this week from Zero Expansion, a longtime resident's group opposed to Flying Cloud expansion, states that in view of FAA changes to laws and policies that directly impact general aviation, "we applaud city staff for their wise and prudent decision" to conduct an audit.

"In view of these policy changes, it's appropriate for the city to ensure that MAC upholds all its commitments to the city," Zero Expansion added.

Plans on hold
As for when work to expand Flying Cloud will actually begin, MAC spokesman Patrick Hogan recently said the project is still on hold.

Hogan said one of the commission's priorities this year is focusing on "larger system issues," such as reliever improvement funding options. Jack Lanners, one of the MAC commissioners, will study the reliever issues and report back this summer on options for moving forward.

In the meantime, Hogan said the commission's main focus for reliever airport expansion focuses on obtaining funding to build a flood wall at the St. Paul Downtown Airport (Holman Field), and working with Anoka County on the possibility of a county-led effort to make improvements (a new building and runway extension) at Anoka County/Blaine Airport.

"We don't know at this point what a realistic timetable will be for making the planned improvements to Flying Cloud Airport," he said. "I expect we'll have a much better idea in a few months."

Ssudak@swpub.com is Stuart Sudak's e-mail address. He can also be reached at 345-6474.