Vicki Pellar-Price
www.zeroexpansion.com/www.talktrans.com


September 16, 2004

Final FEIS Response


The Star Tribune Editorial from 2001, Flying Cloud must take more of the load, was rife with inaccuracies.

Yet, MAC included it as evidence in the FEIS in support of the expansion at (FCM) Flying Cloud Airport.

Zero Expansion submitted a counterpoint, Flying Cloud Already Carrying Huge Load, to the Star Tribune's editorial, Sept 27, 2001, disputing their assertions, which was published in the paper; the published rebuke was not included in the Final EIS Statement.

The Zero Expansion counterpoint accused the Star Tribune of not checking their facts and reminded them that their own aviation beat reporter recently published numbers of operations which showed that Flying Cloud was in fact carrying the largest load of all the relievers, even without a 5,000 ft runway.

That MAC included the Strib editorial in the FEIS and not the counterpoint shows how industries and governments paint the picture they want you to see, which often is not the truth.
The Strib editorial is an opinion piece and its lack of factual data and supporting evidence does not provide substantive, factual corroboration for the project, which is what an FEIS should produce.

But more than just conjecture, there are numerous inaccuracies, which are misleading and deceptive. An unknowing public would swallow these inaccuracies as truths, but they hardly represent a meaningful and factual justification for an expansion:

1. The Strib asserts that general aviation airports are more secure.

In the article, Security Is Looser on Corporate Aircraft, New York Times, Print Media Edition: Late Edition (East Coast),New York, N.Y., Oct 28, 2003, the author, Joe Sharkey tells us that though 429 airports that handle commercial flights are set up for all the security drills, this is certainly not the case for over 5,000 General Aviation airports nationally. These GA airports handle over 10,000 companies that run 15, 500 fixed wing aircraft, two seat turbo-prop and humongous heavy iron jet operations that carry 50 passengers in what are termed ‘soft target’ situations because " few if any of the passengers on those planes receive the preboarding security checks by federal screeners that are standard practice at commercial airports. Also because there are thousands of fractional owners today, there is little ability to oversee or check the ever-changing ownerships of thousands of planes and their ever-changing users. Very few of these users, in fact, ever pass through a metal detector. And officials in the industry are increasingly worried that lax or haphazard security procedures have created an opportunity for terrorists."
Read the article which will be posted at www.zeroexpansion.com ; click on the security link (which is a chain link fence. As far as residents know, that’s the only barrier between terrorists and the community. The chain link gates are open all day long.)


2. The Strib asserts that all non-commercial jet operations move away from MSP for fewer delays.

Both the GAO and FAA have stated that General Aviation is not the cause for delays at major airports.

See NWA report, Metropolitan Airports Commission, Reliever Airport Seminar, April 29, 2004:

Northwest cites a 1994 US General Accounting Office (GAO) Report that said in part:

"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."


Reliever Airports. For many years, the AIP program included a set-aside for reliever airports. These were small airports that the FAA determined would help relieve congestion at nearby larger airports. However, GAO issued a study that found these airports were not effective in relieving congestion. As a result, the Federal Aviation Reauthorization Act of 1996 (P.L. 104-264) eliminated this set-aside.

NWA stated in their Reliever Seminar report that it’s economically unattractive for small operators to use MSP now. That may not have been the case back when the Met Council mandated that the relievers relieve MSP. NWA reported that MAC has the ability to further ‘incentivize’ the use of the relievers through minimum landing increases at MSP. So the rationale to relieve MSP is about as old as the Met Council’s reliever mandate, which needs to be overhauled.


3. The Strib asserts there is a need for more room for corporate or private jets

MAC’s projections for use (at an expanded FCM) submitted to the FAA were 49% more than what the FAA projected- FOIA city of Eden Prairie.
Flying Cloud Airport operations have decreased annually by 4.4% - NWA report Metropolitan Airports Commission Reliever Seminar Meeting, April 29th, 2004.

Even the AOPA’s Phil Boyer, President of the Aircraft Owners and Pilots Association, stated that MAC should not expand the runways at FCM at the Reliever Airport Seminar in April of 2004 because rates will go up even more. Though you’ll never find this on the AOPA web site, or in the minutes of that Reliever Airport Seminar meeting, he said it. MAC denies he said it. I was there and heard it. Boyer also said their surveys indicated what operators want the most and it’s not an extended runway.

There are already two 5,000ft runways, at St Paul Holman Field and at MSP.

Survey of members of the AOPA-
Extend Runways 30%
Upgrade facilities- 39%
More Hangars- 64%
More Maintenance- 82%
Keep rates same- 83%


The AOPA also suggests that MAC change the weight based pavement restriction for runways, which would allow larger, heavier plans to use the existing runways at FCM, without lengthening them. The problem with changing the weight based pavement restriction, which is supported by both the NBAA, National Business Aviation Association and the AOPA is that the city and MAC agreed to a 60,000lb limit on pavement strength.

There is new FAA rulemaking for no weight-based pavement airport access restrictions, which was proposed by the FAA after the city and MAC signed the Final Agreement. The legally binding agreement contains a MAC commitment to Eden Prairie to support a 60,000 lb pavement based weight restriction.

Everything is a moot point now because the MAC must uphold that restriction or risk a possible law suit with the city, or the FAA could allow it, and then the AOPA would end up paying for it? Anyway you look at it, it doesn’t bode well for MAC. If in fact the airport did not expand, and the runways, as is, serviced the larger planes, there could be two lawsuits, one by the city and a class-action lawsuit by Eden Prairie residents. Any way you look at it, MAC is up against it, even without NWA on their case.



4. The Strib asserts that FCM must expand to fulfill their mandate to relieve MSP.

The Met Council whose responsibility to oversee and protect land use compatibility and assurances that water quality and environmental consequences are minimized, needs to reassess reliever mandates from 50 years ago, which were based on non-jet use and no dense population centers adjacent airports; this mandate is out-of-date, and out-of-touch. The Met Council is remiss in its duties to protect the public in terms of land use compatibility which impacts security and environmental consequences.

The FAA's charter from Congress mandates that it serve two distinct functions: to oversee safety and to promote air travel. And, in fact, the vast majority of criticism leveled at the FAA in recent years is that it promotes air travel at the expense of safety.

In the case at Santa Monica Airport, in California, one of the busiest General Aviation Airports in the nation, airport officials last year, at significant cost to themselves, implemented a ban on larger private jets because the airport had inadequate safety margins – per the FAA's own standards – and no room to increase them. The FAA responded by serving the City of Santa Monica (which operates the airport) with a Notice of Investigation, claiming that it would be unlawful to prohibit the jets from landing – even as it acknowledged the inadequate safety margins. Could this happen in Eden Prairie at Flying Cloud Airport? This does not bode well for residents in Eden Prairie.

We’ve come to expect that the FAA and MAC do not act in a community’s best interests, but we do expect that the Met Council, whose mission is to oversee regional planning, transportation, housing, water quality and management and open spaces, would not become a bureaucratic arm of support, a rubber stamp, for a project that has so little justification and would do so much harm to the quality-of-life in Eden Prairie.



So much for truth.

Let’s see the impact it has on the Met Council, the MAC, legislators, the Minnesota Environmental Quality Board and the Governor. Let’s see whether bureaucratic rubber stamping for a project unsupported by need or fiscal accountability will win out again over community quality-of-life.

Vicki Pellar Price
For Zero Expansion

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