Loading...
10-05-88 agenda CITY OF RICHFIELD MONDAY, OCTOBER 5, 1998 REGULAR CITY COUNCIL STUDY SESSION 7:00 P.M. COUNCIL CHAMBERS AGENDA • CALL TO ORDER ROLL CALL I. 7:00-7:30 P.M. ANNUAL MEETING WITH PLANNING COMMISSION II. 7:30-7:45 P.M. PRESENTATION FROM ADAPTIVE RECREATION AND LEARNING EXCHANGE III. 7:45-8:00 P.M. DISCUSSION OF STATUS OF AIRPORT RELATED ISSUES STUDY SESSION LETTER NO. 47 8:00 P.M. ADJOURNMENT AUXILIARY AIDS FOR INDIVIDUALS WITH DISABILITIES ARE AVAILABLE UPON REQUEST. REQUESTS MUST BE MADE AT LEAST 96 HOURS IN ADVANCE TO THE ADMINISTRATIVE SERVICES DIRECTOR AT 861-9702. • CITY OF RICHFIELD, MINNESOTA Study Session Letter No. 47 Agenda October 5, 1998 Issue Statement• Status of airport related issues. Background: Recent developments regarding airport issues include the following:. • Runway 4/22 Northwest Airline's decision to suspend direct flights from MSP to Hong Kong could mean that the 1,000 foot extension on to Runway 4-22 and the temporary extension on to the South Parallel Runway will be put on hold for awhile. Because Asia's financial crisis (poor economic conditions and a fall in tourism) has stifled travel to this -area, NWA has suspended travel to Hong Kong indefinitely. While some work has already been performed in building the temporary extension, the 4-22 extension has..-not been started. Proponents of the extensions believe that, "build it and they will come." At September's Planning and Environment Committee Meeting, MAC staff questioned the committee on how to proceed with the issue of 4-22 runway use (noise spreading). MAC's General Counsel, reported that additional federal environmental documentation needs to be reviewed and the Met Council needs to approved the RUS before it can be implemented. Himle concluded that the commission needs to be aware of the steps needed to be taken if MSP is headed in the direction of a modified RUS. • Proposed Runway 17/35 On September 11 Richfield's airport attorneys and consultants met to discuss transportation changes in relation to MAC expansion plans. Gary Warren, MAC staff, began the meeting by explaining the proposed changes that MAC be performed to the 66th Street and TH77 interchange. When MnDOT was asked what changes will need to take place on TH77 with the anticipated increase of traffic, staff replied that any change for this highway was not in the plans for at least 20 years. A letter was sent to Chairman Grieve of the MAC addressing recurring statements John Himle has made about the credibility of Richfield's environmental noise studies and the City's commitment to resolve the issue without a legal confrontation. Mayor Kirsch reiterated the extensive professional backgrounds of the noise consultants, studies in correlation that have been conducted by MAC's own noise experts and the two dozen documented sources that show Richfield seeking a meeting with the MAC and FAA. Within a month two trips to Washington will take place. On September 17, Mayor Kirsch and Council Member Sandahl met with Representative Sabo to discuss the frustrations that City Council was experiencing when having the issue of low frequency noise addressed. Council Member Sandahl, City Manager Jim Prosser, Legal Counsel Steve Pflaum, and noise consultant Sandy Fidell will now be going to Washington on October 6. They will be meeting with national FAA representatives: 1) Paul L. Galis, Director, Office of Airport Planning and Programming; 2) Lynne S. Pickard, Manager, Community and Environmental Needs Division, Office of Airport Planning and Programming (Pickard reports to Galis -Sandy Fidell reports that Pickard negotiated the agreement with the US Fish & Wildlife Service regarding the MN Valley National Wildlife Refuge; 3) • Thomas L. Connor, Manager, Technology Division, Office of Environment & Energy. Connor is probably the FAA official most familiar with the technical aspects of low frequency noise. At the meeting the City will be asking the FAA for three things: • That the FAA stipulates that MAC identify a mutually agreeable plan to mitigate low frequency noise impacts. • That the FAA advise MAC that they can use airport revenue to pay for the mitigation effort. • That the FAA work with the City to identify federal money that can be used to pay for the City's mitigation efforts. Richfield will also be meeting with Capitol Noise, which is a lobbying group comprised of cities located near airports. They have agreed to give the City two pages in their next newsletter for an update. Prosser will be providing an article and additional information at the time of the meeting. In addition, there are several other meetings that staff is currently working on. They are: * A meeting with Rep. Bud Schuster and Rep. James Oberstar. * A meeting with the Star Tribune and/or Pioneer Washington editors. * Meetings with Wellstone, Grams, and Saba * A meeting with BWI officials. The. federal Record of Decision was issued the last week of September. The FAA discounted the various issues that Richfield brought forth, and concluded that, "In the case of low frequency noise, no adverse impacts have been determined." [See Attachment A] A press release has been issued to media contacts. [See Attachment B] • Candidate Forum • On Tuesday, October 20 the City of Richfield and the Richfield CARE Team will be co- hosting acandidate forum. It will be located at the Rich Acres Gold Course and will take place from 5 p.m. until dusk (which is about 6:30 p.m.). The purpose of this event is to invite the next gubernatorial, legislator, and council member candidates out to the golf course and portray to them the impact of a runway two blocks away from homes. Staff will be inviting all of the state-wide candidates, the Hennepin County Attorney candidates, all of the local candidates, as well as all Richfield elected officials. The event will be organized into a very large meet-and-greet format. The City will be providing refreshments as well as table-space for all of the campaigns. The City's stated purpose for this event is to help educate citizens on the candidates so they can make an informed decision on election day. The candidates will be free to work from behind there table or to mingle in the crowd. The event will be heavily advertised. The City will also be occupying a booth with the CARE Team in order to offer the residents an update on what is going on at the airport. Five hundred to one thousand people are expected to turn out for this event. Airport issues have always been a consistent draw in Richfield and teaming with the campaigns, it is expected to remain so. • AMM Policy Committee AMM's Transportation and General Government policy committee recently approved a new airport noise mitigation policy. The policy includes the position that: * By the year 2000, the EQB should establish guidelines for airport noise (including low frequency) in consultation with the MAC, Metropolitan Council and affected cities. this may include expansion of the sound insulation program to the 55 DNL. The MAC should establish a plan to assure funding for required environmental impact mitigation for legislative action by the conclusion of the year 2000 session and levy a property tax on MAC-owned and leased property if it is not approved. * Due to operations increase of 27% by 2010, noise impact fees should be created to encourage conversion to real Stage III aircraft. • * The policy has now been forwarded to the AMM Board for approval. • MASAC Meeting This month's MASAC meeting took place on September 22 at MAC headquarters. The main issue discussed was MAC's "1998 Ground Noise Report." The report was called in to serious question by a large number of MASAC members, the main complaint was that it did not address the issue of low-frequency noise. Richfield MASAC member Kristal Stokes presented a letter and a analysis (from Sandy Fidell of BBN Technologies) requesting that the report should be refereed back to MAC for further work. The letter was referred to the MASAC's Operation's Committee for further study. [See :Attachment. C] Recommended Motion: Discuss current airport issues. Basis of Recommendation: It is important for the Council to provide direction to staff regarding airport concerns. Alternative Recommendation: Defer discussion to another date. Discussion/Decision Mode: This matter will be discussed at the Study Session of October 5, 1998. Respectf submitted, • Jams .Prosser City anager JDP:cak (. The City of Richfield, tilinnesota ("Richfield") submits these wmments on the Final Enviroomeatal Impact Statement ("FEIS' for the Dual Track Airport Planning Process az Minneapolis St Paul Intonational Airport (the "Project"). As explained below, the FEIS fails to A~ accomplish its ptincipa! purpose: to provide those who will decide the faze of the project with an acctuate understanding of the Cnvitonmenta) impacts, potential alternatives, and feasible mitigation measura relating to the project The information that is disclosed in the FEIS also fails to provide an adcgtate basis, under eitho federal or state law, for a decision to approve the Project Moreover, the inadequacies in the FEIS prevent neighboring cities and their raidents from being able to assess the conditions that would be experienced if the Project were toacatrcted or to determine the mature and extent of required mitigation • The following eornmcnts do not attempt to state all of Rich$eld's concerac regazding the FEIS. No responses have ever been provided to many of Richfield's prior comments, while B, many of the raponses that have been provided raise more Questions thaw they answer. Consequently, Richfield continues to rely on all of the comments that it has previously submitted in connection with the Project II. COMM1LFNTS RR t2 ING CC~~ LiMt~twrtY S£CTiON The forecast tiaffic growth and terminal facility requirements included in the FEIS are fundamentally flawed and ur-domine the entire document The FEIS should be revised to include realistic forecasts, and to address the name and timing of facility improvements needed to aceontmodate the forecast flight levels (or the implications of not providing the passenger Ci" terminal and other facility improvements needed to accommodate those flight levels). These issues are further explicated in the Affidavit of Dr. Geoffiey D. Gosling, a prominent airport phoning expert, which is included in the appendix to these comments az Tab 1. The stated purpose of the project ignores the consideratiat of potential alternatives. Especially under NEPA, the fact ffiat the Minnesota legishturc has approved the constrtution of D" Runway 17-35 should not preordain state or federal decisions regarding the existence of feasible alternative. The failure of the FEIS to recognize that a fiardamental purpose of the FEIS is to evaluate potential alternatives indicates that the FEIS is simply a post hoc rationalization of a prior decision to approve the runway. The third paragraph of this section limits the proposed action w "iatplemrntation ofthe MSP 2010 LTCP,"even though MAC is clearly aware that the state legislanac required a concept plm for 2020 to describe the rretrtomploe build out of the airpoR For example, MAC's reply C to the bfimesota Deparnnent of Transportation corameats, at page I-27 of the E, FEIS. u»>Fdently discusses °R?re>r a new west terminal [excluded from the definition of the currently ProP~ action] is needed ... ," not whetter such a terminal may some day be required. This reply is inconsistent with the claim in the Executive Summary thaz "T'hc 2020 Concept Plan u evaluated to the extent possible in order to disclose the potential long-term A. The FAA and the MAC maintain that the May 1998 FEIS was adequate for the purposes of disclosure of impacts and for soliciting public input on the proposed action. MAC 's commitment to provide for reasonable mitigation is also clearly stated and addressed whhin various sections. Ths FEIS represents the culmination of estate-mandated study process that has been very long and detailed throughout -with considerable public end agency involvement lase Section VIII of the FEISI. TM process has considered a vast range of aherttstives and has increasingly focused on the development of reasonable and feasible environmental mhigations. The acknowledged 'unresolved issues,' noted on page ix of the Executive Summary (low frequency noise mitigation and wildlife refuge mitigationl. were both analyzed in response to important issues raised within Graft EIS comments and have since rssuhed in further coordination, additional studies, and specific mitigation proposals. The FEIS was published for public and agency review/comment before the FAA and the State of Minnesota could render any final project decisions. In publishing the FEIS, the FAA end the MAC made ' clear that they are committed to continue to work with stakeholders to address further details. See General Responses 1,2 and 7 for the results of further analysis of the unresolved issues. B. FAA and MAC have responded to all written comments submitted by Richfield. C. See General Response 3 for response to the comment and the Gosling Affidavit. D. See General Response 6. The FAA decisions regarding the proposed expansion of MSP were the result of FAA's own decision-making process, and the state legislature's decision to select MSP expansion as the recommended alternative was considered as a factor, but not as diapositive, in the FAA decisions. E. AS noted in your comment, implementation of the new terminal and related airfield and roadway facilities will require approval by the Minnesota legislature and further environmental review and approval by the MAC, FAA and the Federal Highway Administration. This is correctly stated on page i of the Executive Summary end in other sections of the FEIS. Any inconsistencies in conveying this message were unintended. See General Response 4 for analysis showing operations in 2005 as the worst-case year for noise impacts. Based on SIMMOD analyses, the new north south runway can provide capacity to accommodate the 2020 MAC High Forecast operations, but with greater delays. efforts of the development of a new passcngcr terminal and related airfield and roadway facifitia." [n addition, the FEIS admits at page iii of the Executive Summary, in the section titled "MSP Expansion," thaz "MSP expansion consists of [borhJ the MSP 2010 LTCP and the bfSP E, 2020 Concept Plan." The absence of sny new nmway other than 17/35 as late as 2020 impiia that this runway alone will provide all of the additional capacity needed to support operations in 2020. This, is taro, implia considerably greater numbers of operations on the nmway than are disclosed for the year 2005. The FEIS should disclose the impacts associated with that reasonably foraeeable consequence of the Project The rationale stated for the purpose and need for the Project is "to provide for the efficient and economical ttwvemwt of people and goods ...." This rationale is unsupported by any detailed cost/beneft analysis that could justify commitment of public funds to the current Proles The ~P~n that ~ proposed airport expansion will produce a net economic bertcfit for the region demands eldse scrutiny in fight of the findings of Dempsey et al.' ([996, pp. 163 et seq.}concemiog similar elairrts elsewhere. Dempsey et al. evaluate the similar claim that improved passenger and cargo service resulting from wostruction of Denver International ~ (D~)~ would allow other communities in Colorado and the region to be better connected into the national and iatemational air transportation system. Businasa would then be more inclined to locate is this region because of the superior aceasibifity made possible by DIA. What seems to be occturing so far is that DIA has actually inhibited economic activity in the state and region .... Since United Airlines has become the dominant carrier at Denver, it has systematically raised its fora to Deaver from all points in which no other airline competition exists .... In short, instead of acting like an economic fountain spraying bene5ts ova the wmmunitia in the state and the Rgion, D1A has acted more like a vacuum cleaner, sucking money away fivm these eommunitia and from Deaver itxlf: to United's headquarters in Chicago. . The net annual loss to the local and regional economy associated with operation of D1A appears to be on the order of half a billion dollars a year. Dempsey et al. also document the tnanaer in which operation of a focbess hub at D[A has resulted in poora air transportation services to smaller cities, has impeded the growth of local ski tourism business, and has accelerated the growth of such business outside the region ~ Dempsey, PS., Goer; A.n., and S tawi~ 15.. "Denver lntemariooal A" rY ' upMt Lessom Learned," McGnw- t{iLL New Yat~ 19%. E. Response txt previous page. F. ~ F. The need to provide for the efficient and economical movement of people and goods is based on Goal B (FEIS, p. II-1! which is 'to provide an aviation system that is safe, efficient and economical', which means reducing travel delays. AS stated in the FEIS, the FAA's Airport Capacity Design Team tound that with annual operations ranging from 530,000 to 600,000, the ssvings due solely to reduced delays from the construction of Runway 17-35 would range from 21,000 to 44,000 hours per year -which resuhs in a 430 million to 463 million benefit per year. h is true, as noted in the comment, that average fares tend to be higher at hub airports than at non-hub airports of similar size. What is not noted is that airline hubs also provide more non-stop flights to more markets with greater frequency. The additional service provides an economic benefit from reduced travel time and more convenient schedules. •2- ;~ Given that the FEIS lacks a detailed cosvbenefit analysis w support the stated purpose of the Project the FEIS should be revised to evaluate this issue. The FEIS should include quanptapve documentation of these claims. or the issue should be submitted to independent audit and analysis, perhaps by the U.S. Genera! Accounting Office. A detailed cosNbenefit analysis of the Project would disclose that the Project will ant merely acconunodats true market demand for air transporattion services, but will actively stimulate growth in aviadon activity at MSP, u the tick of inefficient sad uaecononticat excess capacity if built premanaely. 'thus, when FAA sad MAC claim that "without substantial airfield, terminal, and access icrrprovemeuts, future growth is aviation activity at MSP will result in a sigaifiemdy decreased lave! of service twd itcreased user costs," the dcgrce to which these supposed cottscgtuaces ate linked w coructrctioa of the Project is not addressed. Leaving aside the paradoxical claim that "fume growth is aviation activity at MSP" wiU lead to a decline in the level of service for the region. the FEIS simply does not desaibc a specific need for the Project against which the trader may balance iu unavoidable impacts. The no action alternative should not consider increased use of the RUS associated with redistribution of airaaR operations through the use of raid-nmway departtaes >iom the extended Runway 422 (the "RUS project"). Consttuetioa of a queuing taxiway and the vse of Runway 422 in drat fashion has tat been approved by the Metropolitan Council, and it is doubtful whether the f44 million RUS project would proceed if the Runway 17-35 project goes forward. On the other hand, if the RUS project is properly addressed with the no action alternative, then that alternative should also include constntction of the proposed northerly extension of Runway 422. 'the failure of the FEIS to evaluate any aiternsrives other rhea the ao action alternative deprives the FEIS of any basis to determine that the Rtmway 17-35 project is the environmentally prefetablc alternative. F. ~ F. Resptxue on previous page. C7. G. At the onset of the MSP Attemative noise impact analysis, the increased use of the RUS was sDPropriate for the No Action Akemative due the Runway 422 Extension EIS Record of Decision, and the RUS was and is MAC policy. H. H. See Gerteral Response 8. iL ss the FEIS suggests, "[i]mplementation ofthe proposed action may require modifications by FAA of the affecud airspace ... " (FEIS u v), then selection of the rtmway beading should await pnbUcatioa of results of as airspace utiUption study. Such a study must be ~, doac in a more wmprehensive manner than the preliminary effort summarised in Appendix G. The statement that "[d]evelopment beyond 2010 is subject a further environmental assessment ..." (FEIS at v) implies that all of the items listed immediately above as part of the prefermd alternative ate to be completed prior to 2010. Where is the schedule that shows ,. consetttction phasing and completion of each of the Usted itetnt? The vague statement at Section E, Page [-4 (FAA Anions}that "development of the proposed action will be accomplished over a period of years, within the limits of available appropriations in any particular fiscal year and subject to other demands for funds"-is insufficient to provide the, -3- I. The airspace screening analysis presented in Appendix G was completed to determine potential noise impacts associated with anticipated changes in air traffic control procedures. A complete airspace analysis was completed by the FAA after submission of the Airport Layout Plan in 1998. The airspace analyses, including the flight tracks and procedures assumed in the FEIS, have been reviewed by FAA and are reasonable and adequate for the purposes of a NEPA analysis. FAA will develop air traffic control and airspace management procedures that ors consistent with operating conside-ations in the FEiS and designed to effect the safe and efficient movement of air traffic to and from the new runway. This will include the development of a system for the routing of arriving and departing traffic and the design, establishment and publication of standardized flight operating procedures, such as standard instrument approach departing procedures and runway utilization practices that ors consistent with those described in the FEIS on Page A.3-17. J. Page 1-11 of the Final EIS provides a general schedule for implementation of the 2010 LTCP. TMre is no requirement that an FEIS provide a more detailed construction phasing plan, or that it address the phasing of appropriations to fund the construction process. Furthermore, efforts to make certain such details are inappropriate prior to the approval of a federal Record of Decision (RODE. trader with any indication of the anticipated construction schedule or the coasequcnca of any t J• absence of or delay in funding. The statement that "[tjhe preferred alternative will have less impact on air quality .. " ~ K• (FEIS at v) is a ltss-than-straightforward way to admit that the pcefernd a[teroative will generate greater raise impacts. The stated cost of the Rutrway 17-35 project (FEIS at vi) excludes the cost of adequately ' L, mitigating low frequency noise impacts in Richfield and impacts on the bfiaaesota Valley National Wildlife Refuge ~'bfVNWR'~. The stated conclusions regarding trnavoidable significant impacts (regarding historic impacts, wildlife rcfirgt impacts, etc. (FEIS at vi)) are ertoaeous because they are predicated on the assumption that there arc ra feasible alternative to the Runway 17.35 project By refusing to address any alternative other than the no action alternative, the FEIS don not provide any M• support for that assumption ' The proposed noise mitigation meastua improperly defer development and implementation of mitigation for bw (iequerrey noise. Thcre is no mason why the FEIS does not contain what it propose to defer, i.e., "noise impact models which reflect the impact of ground keel raise on raidentisl properties." Nor is there any reason why mitigation for those impacts has not already been developed and committed to. Because MAC and FAA failed to analyze the extent to which tow 5equrncy noise produced by the Project would produce cornmurriry annoyance, Richfield has analyzed that issue and developed a mitigation plan to address those pacts. (A copy of Richfield's mitigation plan is submitted undo separate cover.) The FEIS trld be revised to adopt Richfield's plea or another reasooabie proposal for mitigating the of low frequency noise on Richfield. J. Resporae on previous page. K The FEtS statement is accurate. his true that the proposed action would expose 300 more people to noise levels of DNL 65 +, but would expose 5,360 less people to DNL 60+, compared to no action. L Conceptual mitigation costs were presented in the FEIS for the refuge. See also General Response 7. No significant adverse impacts of low frequency noise were identified in the FEIS; therefore, no mitigation was required. See also General Responses 1 and 2. M. See General Response 8. N. ~ N. See General Responses 1 and 2. The statement in one of the bullets (FEIS at vi) that "support from the state of Minnesota 0. will be sought" falls short of a guarantee that bfAC wilt provide finding if it cannot obtain '' fundittg from another source for MAC's. noise impacu. The FEIS improperly fails to disclose the extent to which finding for the Runway 17-35 project mitigation pcogr'am, ir-cltding the residential sound insulation program, is uneertatq and P• should condition approval of the project on obtaining sufficient hording (much like the FAA conditioned approval of the RUS project on MAC's demoasuatioa that it has the wherewithal to eonpkte that project, including the related mitigation program, with or without federal funds). At a minimtnn, the FEIS should disclose the extent of the potentially tmmitigated significant environmental impacts dtre to unavailable finding for the mitigation progcara The mitigation program is an integral and essential part of the Rtmway 17-35 project Accordingly, it is erroneous to condition the mitigation program, but not the construction of the Q• runway and related fi-cilities, upon MAC maintaining a hood rating of at least A. -4- O. MAC has committed to implement the program. As stated in the FEIS, funds will only be sought from the state if MAC is unable to fund the expanded program in a reasonable period of time. P. While all details of a project funding program are not fully assessed in this FEIS, this was neither necessary nor appropriate prior to the FAA's approval of the project (see also Response J, above). The FAA's approval of the project in the Record of Decision is specifically conditioned on the implementation of the mitigation measures contained in the FEIS. D. MAC will consider applying this condition to the runway construction. C • • The proposed Working Group to address adverse impacts of the airport on rnearby neighborhoods does rtot constitute a legally adequate substitute for analysis of thox impacts, and devdopment of feasible mitigation measures. in the FEIS. Why has MAC waited so long w implement the 1996 legislative tnaadate to prohibit use of Stage 2 aircraft after December 31, 1999? If the FAA grants any exemptions that permit operation of any Stage 2 aircraft after that daze, MAC would love to prepare a study pursuant to Part 16l of the Federal Aviation Regulations to be able to occlude those operations fiom MSP. Although such a study requites a 6•moneh cotnmetu period before it can be implemented, these is no indication thaz MAC has taken any steps to begin such a study. These is no tasoa to "evaluate" thaz tnasare in a Part 150 Study since it has been tnatdated by the Legislature and the FAA cahoot approve that measure without eornpletion of a PaR 161 Study. The generality sad lack of compuLwry action described by most of the bullet items oa page viii of the FE[S deprives them of practical import. &i Affidavit of Dr. Sanford FideU, included in the appet-dix to thexe wmments at Tab 2. The fourth line fmm the bottom of page vui refers a "the 1996 DNL 65 contour." 'This contour is not described in detail in the FEIS. The FEIS should be tevixd to include a full description of this wntour with full supporting detail. R. Ths proposed Working Group is not a substitute for analysis of impacts and development of feasible mitigation measures. Ths Working Group is listed only as one measure within a fist of approximately 12 community noise mitigation measures approved by the MAC. The MAC is committed to providing for all of these measures. 3. The elimination of Stage 2 aircraft by December 31, 1999 is required by federal law; implementing regulations are contained in CFR Tttle 14, Part 91. In the 1996 FAA Progress Report on the Transition to Quieter Aircraft (Report to Congress) 75.5 percent of the active fleet, which includes 277 operators, wars composed of Stage 3 aircraft. Part 91 requires that by R. December 31, 1998, 75 percent of the active fleet be Stags 3. Considering the 1996 FAA report, tM majority of operator are well ahead of tM Stager 2 phase-out requirements. NWA reported that 83.4 percent of their fleet was Stage 3 by December 31, S. 1996. The development of a Part 161 Study at this time to limit Stage 2 aircraft after December 31, 1999 prejudges NWA's ability to meet the mandatory deadline. T. The items listed on page viii in bullet format ors best considered within a F.A.R. Part 150 study and T. any commitment to implement any of the items will depend on the resuka of the study. The comment by Fideli (Affidavit X131 on the proposed noise monitoring relates to low frequency noise. The extent end details V. The FEIS wntemplates that FAA and the U.S. Department of the Interior (Fish do Wildlife Seswia) will trash m agteenteat concerning mitigation of the Runway 17-35 project's impacts on the MVNWR, and that "the agreed upon mitigation wiU be reported in the FAA V• Record of Decision." (FEIS at ix.) This comctty rata the tequiremeat that such an agreement be reached before the Record of Decision can be issued. Tn a related vein, the FEIS discloses that "[d]etails of the MVNWR mitigation plan arc " W' unresolved. Q~) Pursuant to both state anti federal law (incltding NEPA, Section 4(f) of the Depamneat of Traatiportation Act, MEPA, and the Minnesota Eaviromnental Rights Act - ("MERA'~), mitigation of the Rtmway 17-35 project's significant adverse impacts on the MVNWR must be resolved before any decision can be made whether to approve the project. The FEIS should diselox that Rtmway 17-35 would. (tat "could," as stated in the FEIS) " " X crate low 6egtrcacy nO1Se and vtbtatton that would (not could ) cease annoyance t0 restdeats • of Richfield. An FEIS should trot contain'timrewlved isstnes." Lrpacts should be idertfied sod determined to be either significant or imigttificant. Mitigation must be developed for aU significant impactt. ~ Y. Although the FEIS states that MAC is eotnmitted to study the low firegtxacy noise issue Z. further, it does tat commit MAC to either reach an agreement with Richfield concerning mitigation or otherwix mitigate all impacts to a level of it-tignificaoee. (See FEIS az ix.) of the proposed monkoring have not been determined; they will be determined as part of a separate study (nee General Response 1) and Richfield will be afforded the opportunity to participate in this study. MAC cannot take compulsory action at this time regarding matters to be considered in s Part 150 update without predisposing the results of that study on all of the communities surrounding the airport. U. The 1998 DNL 85 contour is described in detail within the last MSP Part 150 study; use of the contour is in reference to requirements for a future insulation program determined by the MSP Noise Mitigation Committee. The extent and development of the 1996 DNL 65 was public knowledge through the Part 150 process. The 1998 DNL 85 contour is not used to determine potential impacts and therefore doss not require full disclosure within the FEIS. V. See General Response W. See General Response 7. X. See General Responses 1 and 2. Y. The MAC is committed to providing for reasonable mitigation measures. See General -S- Responses 1, 2 and 7. Z As the FEIS was being prepared, Richfield developed an assessment of low frequency noise issues and proposed a mitigation plan. This work was completed independently, and not as part of a project consultation process with the MAC. Therefore, when the FEIS was published, k was reasonable for the MAC to commit only to providing for additional study and to the development and implementation of a plan to address any significant adverse impacts that are identified. • AA. Section V.D, &rd-Aircraft Hazards, evaluates the potential for bird-aircraft strikes. The body of the FEIS also summarizes the reviews/actions of FAA's Air Traffic Division (FEIS page I-6 and Appendix G), which discuss issues related to safety review. Ths FEIS also references the runway protection zones of Runway 17- 35 and state safety zones A and 8 (e.g., pages V-88 end 891. The Summary of Impacts discloses that the Runway 17-35 project would dramatically increase the number of aircraR operations conducted inclose proximity to areas where birds ~, wngtcgate. (FEIS at xi.) While the FEIS purports to arralyzc the resulting bird-aircraft hazards, it does trot contain any other analysis of safety issues. Particularly in light of the fan that Runway 17.35 is not parallel to existing runways at MSP, the FEIS should analyze the impGcarioas, in tetras of safety, of the missed approach A B. procedure that would be used in connection with arrivals oa Runway 35. The Summary of Impacts irnproperiy states that the project would not displace any Section 4(f) pant and recreation leads. (FEIS at xii.) Ia truth, the project involves the acquisition and use for airport proposes of two parks located in New Ford Town and Rich Acres, both within AC. Richfield. .. DI. ~OlrIIriENTS REGARDING INTRODUCTION AB. Development of a new runway includes missed approach procedures analysis. Prior to the Runway 17- 35 alignment dsctision, FAA completed an airspace analysis which included missed approach procedures; in 1994 the FAA examined the airspace capacity around MSP in an effort to determine the safety effects of the proposed airfield improvements in the MSP LTCP. In its conditional approval of the Airport Layout Plsn on April 25, 1997, FAA concurred with the proposed airfield development for planning purposes based on current safety, utilhy, and efficiency standards. AC. The two parks are not related to the proposed action. The need to acquire the parks was based on existing conditions, and the acquisition decision was made in 1992 when the future of the airport was still in doubt. AD. The third parallel runway is addressed in the FEIS in accordance with the EQB-approved Attemetive Environmental Review Process. See also General Response 6. The FEIS analyzes the 2020 Concept Plan even though development of the new west terminal is prohrbited without future legislative approval. This reveals that the need for future AD. AE. See General Response 8. legislative approval of a parallel runway north of existing runway 12L-30R is not a basis for refusing to analyu that alternative in the FEIS. • AF. A Major Investment Study is not needed in Elimination of the New Airport Alternative 8vm analysis in the FEIS (one such scenario ' AE. relation to the 2010 surface transportation west mentioned in the DEIS) further tedrrces the aheady improperly narrow range of alternatives. improvements identified in the FEIS Section V.W and within Appendix F. For more information, see pages 9- The FEIS discloses that the analysis of surface transportation alternatives required by the 11 in Appendix F. 191 lntermodai Surface TraaSportation Efficiency Act is normally performed in a Major AF. lnvesimrnt Study (FEIS at 3), but does not state whether such a Study is being performed for this AG. The 1,000-foot extension of Runway 4-22 was project In any evrnt, the FEIS should include as analysis of surface transportation alternatives. not 'deleted' from the project description for the It is improper to delete the 1,000-foot extension of Runway 422 from the project • AG Runway 17-35 project because it has always been l d l l d i description for the Runway 17-35 FEIS. Even if the runway ezteasion had "independent utility" . eva uate as a separate, a though re ate , act on. from other componerm of the Runway 17-35 project, the runway extension should be considered Within the context of the Duai Track Airport Planning part of the Long Term Comprehatsive Plm for MSP. The same is true for the light rail transit Process, the Runway 422 extension, including a proj~, temporary runway extension during the construction • period, is a reasonably foreseeable and separate airport The conclusion that there are m significant crmtulative noise impacts associated with the AH. Rrmway 4-22 exteation, as measued by the DNL metric (DEIS at Imo), does not justify refusing to aaalyu the fuU range of ctunuhuive noise impacts and other cumulative rnvironmrntal impacts. -6- improvement action that arose separately, quite recently, and for a different reason. Therefore, it was evaluated ss a related action in terms of its cumulative impacts within the FEIS. Further, it is noted that the runway extension project concerns only long-haul international departures assigned either to Runway 422 or to Runway 12R-30L. As a rssuk, the runway extension does not have any effect on the operations of the new 8,000-foot north-south runway. FAA and MAC recognize that Northwest Airlinsa (NWA) has recently announced suspension of its current non-stop MSP to Hong Kong service effective November 1, 1998. Aher this announcement, discussions between MAC and NWA have not determined if this change in service should substantially influence progress on the proposed extension of Runway 4/22 to 12,000 feet. Therefore, MAC is continuing to proceed with the project. See also USEPA Response B. Regarding the LRT-airport project issues, see General Response 5. AH. Together, the Dual Track FEIS and the environmental assessment for the Runway 4-22 extension analyze the full range of cumulative noise impacts and other cumulative snvironmsntel impacts. Noise impacts of the No Action and MSP Alternatives were evelwted in the FEIS, including analysis with and • • Although the FEIS asserts that "the two runway exteruiotu [LE:. the extension of Runway 12R-30L and the 1,000-foot txteasion of Runway 472] are reazonawy foreseeable ... [and are] A[. analyzed in this FEIS" (EELS at 1.4), there is no indication that, other than with respect to eorestrerction impacts, the FEIS addresses the extension of Runway 12R-30L. In connection with the promised analysis of the extension of Runway 12R-30L, the FEIS should disclose the extent ofmid-runway departures (beginning south of the intersection with Runway 121,-30R) on Runway 22 and the impacts associated with those operations. Tlee AJ. consistrncy (or inconsistency) between that analysis and that contained is the Draft November 1997 Enviromneatal Assessment for the runway extensions should also be dixlosed. [V. COMMENTS REGARDING PURPOSE AND NEED Tlu FEIS inelerdes az s goal of the Project "the development of airport facilities to meet future aviation needs." (FEIS at II-2J The FEIS fails to disclose, as a result of the unreasonably low forecast of operations on wleieh d,e FEIS is based, ttuu the Rtmway 17-35 Projett will not meet future aviation needs unless terminal facilities are provided sooner and to a greats extent A K. than arc currently planned. The FEIS shoeild be cruised to analyze the facilities treaded to aeeommodaze a realistic forecast level of oprntions and to disclose the environmental, economic, and practical coacequet-ces of not providing those facilities is a timely fashion. The FEIS discloses that a planning goal is to "[djrvelop an airport that is conistent with state, regional, and loco! plmrr mrd eeonontic dtvelopment policies." (FEIS at II-2 (emphasis added).) The FEIS should disclose that the Runway 17-35 project is inconsistent with AL. Richfield's plans and economic development policies to the extent that the project fails to incorporate Richfield's mitigation proposal for the Runway 17-35 project or otherwise fails to . mitigate the projat's impacts.(including, in particular, low $equency noise impacts) on Richfield. The discem'son of the results of the "sensitivity analysis asserts that none of various impact categoric would require additional mitigation (FEIS at II-11.) That is not true with respect to air quality impacts, whore the seatitivity analysis reveals that the Project would far AM. exceed the de minirners level needed for a determination that the Projta complies with the Clean Air Act. in any event, the sensitivity analysis does not disclose whether the higher activity levels vrould create any additional significant adverse impacts'or whether the existing mitigation would fail to reduce any such impacts to a level of insignificance. - The se:asitivity analysis should analyze the effect of the revised projections on year 2010 and 2020 impacts. The FEIS improperly attempts to defer that analysis by stating that . "[a]dditional environmental impact studies would be requred to feather address impacts and AN. mitigation for the period beyond 2010 " Moreover, the FEIS does not provide any sensitivity analysis for noise irnpaets in the year 20 (0. Even if the greatest overd/ noise impacts worild be experienced in the year 2005. because the difference due to using the high-growth forecast increases over time. limiting the sensitivity analysis to that year obseeeees and reduces the relative difference between the projeetiorrt oa which the FEIS are based and those that are more realistic (higher) in fight of meet growth in the level of operations consistent with the high-growth projection. _7. without the runway extension in place (see the FEIS Section Q.1.31. In this regard, none of the measured points within community jurisdictions receive noise impacts of DNL 1.5 dBA increase, considered tM level of significance, in compering the MSP AReneative and the No Action Alternative to future scenarios shher with or without the Runway 422 extension. AI. The extension of Runway 12R-30L is a temporary requirement to build the proposed extension of Runway 422 and is therefore excluded from deisiled impact analysis. The Minnesota Environmental Quality Board, in its review of the EA prepared for the extension of Runway 422 to 12.000 feet, found that the temporary extension is exempt from review due to its temporary nature, no off-airport impacts, and tM infrequency of use. k will only bs used during construction of the Runway 422 extension. AJ. See Response AI. A displaced departure on Runway 22 was considered wthin the RUS sensitivity analysis within the EA for the Extension of Runway 4 22 to 72,000 feet. The potential impacts of sxtereding Runway 422 were evaluated within the EA without consideration of the RUS due to litigation between Richfield and MAC. AK. See General Response a. AL. See General Response 2. AM. The analysis in Appendix H, and Table H-2, discloses no additional significant adverse impacts by 2010, and therefore no additional mitigation is required for the 2010 plan. Additional mitigation is expected to be required by 2020. Although not required, MAC has committed to mitigate significant adverse impacts based on the MAC High Forecast instead of the Base Forecast in the FEIS. AN. The senskiviry analysis was made for both 2010 and 2020 for those impact categories senskivs to higher activity levels. The year 2005 is the worst-case year for DNL noise impacts even for activity levels exceeding the MAC High Forecast (see General Response 41. COhIIHENTS REGARDING INADEQUATE EVALUATION OF ~LT'ERNATiVFS The discussion of alternatives contained in the FEIS is grossly inadequate and plainly violates NEPA. The FEIS discusses in detail only two alternatives: the Runway 17-35 project and a no action alternative. nth respect to detailed discussion of other alternatives, the FEIS tcfers the teach to the Alternative Eavirorwental Documents ("AEIh'~ ptcpared in correction with the xgmeated MEPA envirotrmentai review process. Specifically, the FEIS states: The best six MSP coneepu were more fully evaluated in the LTCP. They were the subject of detailed enviromneatal a»afysi{ in the Final AF-D for the MSP Long Term Comprehensive Plan (LTCP) and detailed operational analysis is the MSP LTCQ Volume 5 sad 7 Technical Reports. FEIS uIII-g. The references is the FEIS to the AEDs sad the Long Term Comprehensive Plan- documents that were not prepared of circulated for public review by a federal agency-are no substitute for the detailed discussion of altaoatives which NEPA requires. In responding w Richfield's wtnments oa the DEIS raising this issue, the FEIS states that the United States Environmental Protection Agettry ("U.S. EPA") "concurred with the Dual Track environmeatat process" and "approved the Dual Track tnviroumeatal review process" (FEIS u I-12~. There is m reason to believe that the U.S. EPA's general corrctatence with the Dual Track process was intended to give FAA licenu to prepare art EIS that analyzod no attertntives other than the y 17-35 Project and the no action alternative. Of course, eves if U.S. EPA had "signed oa the approach taken with respect to the Project, U.S. EPA's approval of a procedure supersede or negate NEPA's requirements concerning the evaluation of a reasonable rartge of alternatives which must be present in the FEIS. A0. ~ AO. See General Resptxtse 8. The FEIS fails to disclox that the goats of the MSP alternative ace not wnststertt with the planning goats of the Dual Track Piocess stated on page 11-2. In particular, the goals of the MSP altetaative do not include development of an airport tltu is consistent with local plans and economic development policies. It is therefore not surprising that the Runway 17-35 project is AP. inconsistent with Richfield's plans and economic dcvelopment policies--a fact which the FEIS improperly fails to disclox. The FEIS should dixlox that the Runway 17-35 project is not tespoative to the needs ' and interests of Richfield and its residents to the exieat that it fails to include mitigation needed to reduce low Iiequwcy noix impacts to a level of iatigoificance. (See Fl]S u III-4.) The conclusion that the north parallel alternative would have less capacity than the rrorth- south nmway does not consider anticipated technical improvements expected to further reduce the minimum centerline to centerline distaoct between nmways needed to conduct independent AQ, operatiorss doting IFR conditions. A north parallel alternative that provides such independence -g- AP. The proposed action is considered consistent with Richfield's 1997-2007 adopted comprehensive plan. The Plsn was approved by the Metropolitan Council IMCI ss being consistent whh the current Metropolitan Airports System Plan which includes the MSP LTCP. Minnesota Statutes, sections 473.175 and 473.851.473.872, require local governmental units to modify their comprehensive plan if the MC determines that the plan has a substantial impact on metropolitan system plans. In terms of mitigation, see General Response 2. AQ. Airspace environmental analysis is typically completed using existing navigational technology. Although new technology may serve to reduce runway minimums, wake turbulence requirements for heavy aircraft still recommend 2,500 feet between runways for independent operations IIFR and VFR1. The largest separation considered for a north parallel within LTCP Volume 5 Airport Development Concepts was 800 feet due to property limitations and the potential for considerable environmental impacts. At this spacing for non-heavy aircraft, there would be independent VFR operations, but it is unlikely to provide for a third independent IFR approach in the foreseeable future. The MAC end FAA analysis showed that the north parallel runway provided good capacky benefits but not as good as the north-south runway. Ths nortMsouth runway was selected for a variety of reasons, not just capacity (see discussion in General Response 61. The advantages of the north-south runway alignment errs presented in the MSP LTCP Volume 5, Airport Development Concepts (published December 19911, and the Final Altemstive Environments) Document (published February 1995) which is incorporated as supporting documentation in Appendix A of the FEIS. C AO. Response on provlous page. AR. The impacts on historic resources of a north parallel nmway are greater than the proposed action because the north parallel runway would demolish contributing portions of the Fort Snelling National Historic Landmark District which is one of the most significant historic sites in the state of Minnesota - should be developed and analyzed In any event, the FE1S fails to quantify the asserted capacity ' f~(,~, and because rsssonsble mitigation measures advantages of the tarth-south nmway or evrn characterize the sigai5emce of those advantages. (relocation, documentation! are not considered viable The purported teatort, relating to impacts oo historic properties. for rejecting the north parallel alternatve fails to disclose the relative impacts of the north parallel and north-south nmway ahematives on such properties. (F~IS at IQ-g.) ELtewhcre, the FEIS acimowledges that AR. the Runway 17-35 project would have significant adverse impacts on historic resources. The F'EIS does not and cannot sate that the impacts of a north parallel alternative on historic resources are greater than those of the Runway 17-35 project The purported reason, relating to displacement of a 9-hole golf course and impacts on Bosun Field, for rejecting a north parallel alternative fails to discbse that Runway 17-35 would e{iminate the most heavily used Ili-I-ole golf course in the entice Twin Cities c+egion. remove two AS. II puke in Ncw Ford Town and Rich Acres, and significantly impact the MVNWR_ With good reason, the FEIS does not state that the impacts of a north parallel alternative oa parks, wildlife refuges, or other tt:ctt:ational assets are greater than those of the Runway 17-35 project The purported reason, relating to placing 2,010 mots ttwnthly flights less than 500 feet over areas where birds congregue, for eliminating the north parallel ninway alternative, fails to disclose that the Rtmway 17-35 project vrotdd piece as additional 2,030 monthly flights less than 500 feet over areas where birds congregate, compared with the no action alternative. (See FE1S AT. at xi J The FE[S does not, becertse it cannot, state that the notch parallel altcmadve world have greater adverse impacts concerning bw-altitude flights over great where birds congregate. The purported reason, relating to Minnesota legislation prohl6itittg the coastrtrction of a north parallel rmway without the approval of each affected dry sod requiring MAC to eater into a contract with each city stating that prohibition, fails to disclose that the Minnesota legislanue could repeal that legislation and abrogate any such contracts. In nay even, the existence of legislation prohibiting eonstruetioa of a new west terminal did not stop the FEIS from analyzing impacts associated with that aheraative. Since the west terminal is considered feasible A V. notwithstartd"mgthe current leg'tsiative pro156ition, it is incrousisteat for the FEIS to conclude that "due to state legislative requit~finents, the north-parallel nmway is currently not a feasible concept" (PETS at III-g.) The cursory, less than one page discussion of a new attpoR alternative is the FEIS provides no basis for determinutg thu that alternative is not feasible, pndent, or reasonable. In particular, the Minoesotsdegisbnine'srlirective that analysis of that alternative in the FEIS is tat AV. required does trot affect the requirements of NEPA that that analysis be inchtded. It is improper for the FEIS to state that °impiemrntation of the proposed action may require modifieatiotu by FAA of affected airspace...." fFEIS at III-13 (emphasis added).) The FEIS should disclose whether or rat such modificadont are necessary, artd if they art~ it should analyze the impacts of the modi5catiotu and propose nettled mitigation rneatrues. AW options. See Response I to Richfield comments On the MSP LTCP Fins! AED and Gerarst Response 8. AS. The impacts on parks and recreation areas, other than refuges, of s north parallel runway are greater than the proposed action because the Richfield goM course was always an interim use and the two parks are not connected to the proposed action (sae Response ACT. AT. Runway 17-35 would have /ewer flights less than 500 feet compared to no action las discussed in subsequent Response Cl). Ths north parallel aRemativs would have about 440 more operotitxu less than 500 feet over cress where birds congregate than Runway 17-35 /nee General Response 81. AU. The north parallel nmway alternative was eliminated as a tensible altsmativs in the Scoping Decision for the EIS, in accordance with the EnB~ approved Alternative Environmental Review Process - prior to legislative action. The proposed action is a phase of the MSP 2020 Concept Plsn (which includes the new west terminal coratntction) as mandated by the legislature, and therefore the 2020 plan is a connected or phased action and its known impacts must be disclosed in accordance wkh EOB rules. The legislative prohibition of constructing s new west terminal without legislature approval did not require MAC to enter into contracts with each affected city regarding the prohibition, as in the case of the north patellar runway prohibkion. h would appear that the west terminal prohibition is an acknowledgment that there are differing views on the ability of the existing terminal to accommodate the future demand and the legislature is deferring judgment on the issue. AV. See Response AY. AW. See Response I. above -9- The fact that post-2010 projects, including the new west terminal, would require additional environmental review and approvals does not justify failing to rigorously analyze those projects in the FE[S. There is no basis in the FEIS supporting the determination of the FAA that the new airport alternative was not a feasible or prudent alternative. Jt is noteworthy, however, that the FAA recognized that the decision of the Minnesota legislature to reject the new airport alternative is not dispositive of the issue, under federal law, whether that alternative is feasible or prudent. . VI. COMMENTS RFGA_R~ING ENViRONhiENTAL. CnNCF.fIiIF.Nf Ft The entire analysis in the FEIS is flawed, and violates Minn. Star. 473.614, subd. 2a, by failing to base its analysis of the MSP 2010 LTCP on "alternative assumptions of 600,000, 650,000, 700,000, and 750,000 aircraft operations." The FEIS must be revised to contain the information required by the Legislature. In addition to addressing the environmental impacts associated with the specified levels of operation, the revised document (which must be circulated for public review as a revised draft EIS) should address the question of whether the airfield co~guration could even handle each of those levels of traffic. This consideration is important for two reasons: first, because it would appear that the Legislature would not have directed an analysis of those flight levels unless it warted to ensure that the airfield could accommodate such operations; and second, because the ''.gher projections are consistent with the FAA's Temtinal Area Forecast and with the actual growth in operations experienced at MSP. (See Gosling Affidavit.) The importance of complying with the Legislature's mandate mderscores the deficiencies in the "Sensitivity Analysis" contained in the FEIS. Even at the lower levels contained in MAC's so-called High Forecast, there would be 655 daily arrivals that would be handled on runways other than 17-35. This exceeds the capacity of those runways stated in the FEIS's analysis of the no action alternative. That shortfall would be even higher with respect to analyses based on the Legislature's mandate or the FAA's Terminal Arca Forecast. In short, the entire Sensitivity Analysis is undermined-and hence the validity of the entire FEIS-by the failure to analyze (1) whether or not the airfield could handle levels of operation higher than those upon which the FEIS is based, and (2) the environmental and economic consequences if it cannot do so, either at all or without incurring significant delays. -10- AX. There is s substantial volume of analysis within the FEIS related to the 'post-2010 projects,' including the impacts of the new west terminal. Further, as stated in the FEIS, the impacts of the west terminal will also be evaluated in more detail if and when the decision is made to implement that element of the 2020 Concept Plan. AY. The Section 4(f) Evaluation, which is incorporated by reference into the FEIS, summarizes the FAA's determination that the New Airport Altemativs is not a feasible and prudent aRsmative. This discussion states that while aspects of the Nsw Airport Altemativs could ~X. have been technically feasible, the FAA found that it did not appear to be financially feasible. Furthermore, the FAA does not consider the Nsw Airport Atsmativs to be prudent because of a strong record of public and Y. agency opposkion, and concurred with the MAC that it did not warrant any further evaluation within the FEIS. See also General Response 8. The basis in the FEIS is on o. iii and o. III-g. AZ. See General Response 4 and General Response 3 for response to this comment and the Gosling Affidavit. AAA. The revel of traffic assumed for MSP under the No Action alternative 1473,500 annual operations) did not represent the maximum capacty of the existing airport. Rather, it repreaentsd an estimated level of traffic for the airport in the long term wkh the understanding that no additional gate and airfield ~. capacity was forthcoming and higher traffic levels would result in reduced levels of service. Also, in the long term future, as passenger growth continued with no additional capae'tty, two things would occur. First, the fleet mix st the airport would change slightly to include more wide bodied aircraft, which would serve more passengers with fewer operations. As the number of these aircraft increase, airport capacity is reduced due to their greater separation requirements from other aircraft. Second, with no prospects to increase the hub aize, Northwest would look to other locations to add hubbing capacity. As the local traffic continued to increase and needed to bs ~A accommodated, hubbing operations would be shifted away. These two factors would work towards a reduced level of traffic for the airport in the long term that was less than the absolute capacty. If the forecasts for no action are understated, the environmental impacts of the preferred alternative are overstated, nines those impacts srs based on the comparison of future conditions of the environment with the preferred alternative compared to the future conditions with no action. wth a new runway in place, and little constraints on growth, the hub at MSP would cominue to grow, end the Isvel of traffic on the parallel runways, as they are today, would likely szceed the No Action traffic levels forecast for the long term. The capacity analysis that was done both by MAC and FAA with the new nortMsouth runway demonstrated that MSP would be able to accommodate traffic levels in both the baseline and high forecast level through 2020 land 640,000 operations) with acceptable levels of delay. As such, there would De no economic or environmental consequences resulting from • lower level of operations. The Report to the legislature summarizes this finding. A. 1. O(f-AltpoR Sourea An ~r quality analysis (microscale carbon monoxide analysis) for off-airport sources (motor vehicle) was conducted for those intersections which meet Metropolitan Council screening criteria of 2,400 vehicles per hour during the P.M. peak hour of which at least 480 (20 petcenq arc airport-related traffic. Only one interchange meets the Metropolitan Council A1. screening uiteria: TH 55 at TH 62. Two additional interchanges were included in the FEIS. However, additional at-grade intersections and odoff tamps should be analyzed. Although improvements tray not have been recommended, roads such as 66" Street will be impacted and should be included in the atalysis. As noted in our comments on the DEIS. the transportation analysis was not specific enough to conduct an iatetsection level of service analysis, which is required as an input to the air quality analysis. On-Airport Sources On-airport sources include aircraR and ground support equipment, motor vehicles, and A2. stationary sources. The emissions for the MSP alternative ate presented is Table A-7 on page V- 9 ofthe FEIS. The on-airport carbon monoxide emissions from roadways for the year 2020 is almost 25 percent higher in the FEIS than reported in the DEIS (764 tons in the DEIS vs. 944 tons in the FEIS). No explanation is presented for this increase. However, the carbon monoxide emissions for the auxiliary power units drop from 1522 fora in the DEIS to 52 tons in the FEIS for the year 2020, although the parameters included in Appendix A appear to be the same. A1. TMss intersections along 88th Street were sasened as shown in Table A.1-i of Appendix A.1 of the FEIS (tor the year 2020) and found not to sxcsad ekhsr the threshold for total intersection volume or tM percent of airport-related traffic. Intersections to bs analyzed for Isvel of service and air gwlity will be identified based upon coordination with MPCA staff during preparation of the Indirect Sou-es Permit Application. New interchanges, which are sxpectad to carry a major share of traffic to and from the airport, were analyzed for traffic end air gwlity impacts. TM air quality impacts of vehicle queues at hesway on- ramps at these interchanges were included in the air gwlity analysis. A2. On-airport traffic volumes wed in the DEIS were extrapolated from a variety of traffic studies for selected scenarios. This led to traffic volumes that were not necessarily consistent with the numbs of operations on the airport or the number of originating passengers. In order to develop consistent traffic assumptions for the FEIS, on-airport motor vehicle access traffic to end from parking areas and the terminal area were related to originating passengers and the size of parking areas. Passenger originations and associated on-airport traffic for the No Action 2005 scenario were wed as a baseline for other scenarios, where traffic was estimated using the ratio of passenger originations. This approach provided a consistent set of traffic assumptions but Isd to increases in on-airport traffic for future scenarios. The effect of this increase in traffic was an associated increase in roadway and parking emissions. eecaws of the short travel distances on the airport, however, roadway emissions remain small relative to aircraft emissions. Ths auxiliary power unit (APUI emission methodology wed for the DEIS was based on the methodology developed by the Minnesota Pollution Control Agency for preparation of the 1990 Carbon Monoxide Emissions Inventory required by the Clean Air Act Amendments of 1990. That methodology was in tam based on information provided by representatives of Northwest Airlines, whose planes make up a large part of operations on the airport. That information indicated APU operational times lasting up to several hours. During the review of the air quality analysis in the DEIS, the high value of APU emissions relative to aircraft emissions wes questioned. Ths prsviow methodology was reviewed with Northwest Airlines and compared with new APU emission factors contained in the most recent update of the EOMS (Emissions and Dispersion Modeling Systeml. Becawe of the availability of electrical power at most pate poskions on MSP, a more accurate weraps APU operation time of 15 minutes was wed. This APU operation time is considersbly tower than the APU operation times assumed in the DEIS; thw, estimated APU emissions in the FEIS are well below those contained in the DEIS. LOW FREOUENCY NOISE ISSUES THE FINAL EIS MUST ADDRESS THE IMPACT OF LOW FREQUENCY NOISE ON THE CITY OF RICHFIELD EVEN THOUGH THERE ARE NO SPECIFIC REGULATIONS WHICH DIRECTLY ADDRESS LOW FREQUENCY NOISE. The Minnesota Environmrntal Policy Act, Minn. Slat. § 116D.04 (MEPA) requires the Environmental Impact SWtemrnt to analyze "significant environmental impacts" and to explore "methods by which adverse rnvironmentaJ impacu of an action could be mitigated." The impact of low frequency noise on the area immediately to the west of Cedar Avenue in Richfield will be significant as demonstrated by the comments sad materials submitted by Richfield. (See Fidcll Affidavit do article attached thereto (Appx. Tab 2); BBN Systems d< Technologies report concerning low frequency noise impscu in Richfield (Appx. Tab 3).) Such !ow frequency noise will cause vibrations iruide businesses and houses, and tattling of windows, doors, floors and objects within houses. The level of annoyance which will result from those impacts is at least az great as the level of annoyance which will occur in areaz exposed to levels of bigher frequency noise that the FEIS recognizes to be significant. MAC and FAA appear to take the position that since there ate ao state or federal standards that directly address the impacts of, or mitigation of, low frequency noise, it need not be addressed is the FEIS. However, whether a particulu rnvironmrntal impact is the subject of a specific regulation is immaterial. The issue is whether the impact is "significant," and if so, it must be addressed. Minn. Slat. § I16D.04, subd. 2(a). , Notably, the definition of "natural resources" in MEPA which is incorporated by reference from the Minnesota Environmental Righu Act, § 116B.02, subd. 4 (MERA), includes the term "quietude" az well az "land" and "recreational" resources. [n addition, MERA defines "pollution, impairmrnt or destruction" of the environment az cuher: 1) by proof that the conduct in question violates, or may violate, any environmental quality, standard, rule, or regulation of the state or any political subdivision thereof; or 2) by proof that the conduct complained of"materially, adversely affects or is likely to ...affect" the environment. Minn. Slat. § 116B:02, subd. S (emphasis added). Thus, an environmental impact which could be the bazis for enjoining a project (and therefore "sigttificant'~ need ~ be the subject of a regulation, if it is "material" and "adverse." The proposition that a particular type of noise need sot be the subject of a specific ronmental standard in order to be considered significant is conclusively demonstrated by nnesota Public !merest Research Group, v. iYhite Bear Rod and Gun Club, 257 N.W.2d 762 (Minn. 1977). Plaintiffs alleged that noise pollution by the gun club caused and would continue W cause loss of quietude, and that the loss of quietude would harm both wildlife and persons within the surrounding area. la addition, the Chief of the Noise Pollution Control Section of the Minnesota Pollution Convol Agency testified on behalf of the plaintiffs that the sounds of gunfire could cause general irritability, lou of sleep, and hearing damage. While b[innesota had no noise standards for impulsive noise, tests indicated decibel levels in excess of that considered permissible to avoid health threats and degradation of the environment. The Court in Whin Bear found that once a prima facie case of pollution, impairment, or destruction had been shown, the burden waz on the gun club to rebut plaintiffs' rase by the submission of evidence contrary or by way of affirmative defenses. /d at 780, 781. Thus, the court held that where the plaintiffs did not attempt to show violations of rules or standards but relied upon their right, under the statute to show that the conduct of the Gun Club materially adversely affected the environment, then under Mimn Slat. § 116B.0~3, the burden was on the gun club to rebut plaintiffs' ease or show through as affirmative defense that no feasible and prudent alternative existed. ,fie Minnesota Public 1»ttrest Research Group v. if'hitt Bcar Rad and Gun Club, 257 N. W.2d 762, 781 (Minn.1977). The court concluded that the fact that PCA had not developed standards for impulsive sounds did not prevent a cause of action under the Environmental Rights Act for the gun club's alleged impairment of quietude, a protected resource under the Act. The Environmental Righu Act created a right in cash person to bring action for protection of the environment whether or not there existed standards or regulations issued by a governmental body concerning the alleged violations. E,. B2. B1. Ses General Response 1. The Fdell Affidavit asserts that 'Although low-frequency noise in general is not as directly annoying to people as higher- frsquency noise of similar sound pressure levels, low- frequency noise from aircraft operations is readily audible and distinctive in character. At high enough noise levels, low-frequency aircraft noise may also be directly annoying.' (Emphasis added.) In the BBN Technical Report 8196 conducted for Richfield by Mr. Fdell's company end included in his affidavit, ackpowledgment is made that no formal standard or recommsndstion by an agency with regulatory acoustic interests identifies a particular low frequency sound Isvsl likely to produce secondary emissions inside residences. k only suggests a sound Isvel range capable of producing indoor rattling noises in residences (page 231. The report further states that 'conventional architectural treatments considered for mitigating sircrett noise impacts em unliks/y to provide meaningful increases in transmission loss of homes in the low frequency range', and that attenuation measures 'are not likey to be practically affordable or esthetically acceptable' Ipage 251. (Emphasis added.) These statements are inconclusive concerning the amount and extent of low-frequency noise effects, and the means and regulatory measures needed to insure that any effects can be adequately dealt with. The resulting symmetrical patterns of results from the analysis, that appear in aNected areas and parallel runway heading without regard for runway operational direction, percentage of use, flight profiles, or distance from the runway, raises questions regarding study methodology. Given the complexity of this issue and the uncertainties of effects acknowledged by agencies involved with this matter as well as in the BBN report, and the discussion in General Response 1, the approach contained in General Response 2 is a reasoned means of dealing objectively and conclusively with this matter. B2. See General Responses 1 and 2 In the case of low frequency noise impacts upon Richfield. because the "A" scale of noise meazurcmrnt (used in the state and federal regulations) is weighted in a way which minimizes the effect of low frcqurncy noise, impacts of low frequency sounds do not appear significant on B$, B3. See General Response 1. the "A" scale. But such noise, nevertheless, haz a very real 6npact on the daily lives of citizens inside their homes and businessu. !t rcsulu in "significant" impacu and cannot be ignored. •12- l • LOW FREQ(JENCY NOISE MITIGATION IS A NECESSARY COMPONENT.OF THE FEIS. Pursuant to Mum. Stet § 116D.pa, subd. 6 , Minnesow law requites that as "EIS must sddms one or mote alternatives of each of the following typo of alternatives or provide a concise explanation of why no altemative of a pacticulsr type is included in the EIS: alternative sites, altemative technologies, modified designs or layouts, modified scale or magnitude, and alternatives iaeorpontiag tYasoaabk ttritiptioa measoro ideatifled thtroagb the comments received dutieg the commwt periods of EIS scopiog or for the draft EiLS." Rule 4410.2300(G) (emphasis added). Rule 4410.2300 also requires thu the coruent of the EIS include as examination of aheroatives which iocorponte reasonable mitigation measures. NEPA also requires that possible mitigation measures be fully discussed in a Final Envtrottmeatal Impact Statement In Robsnron v. Msrhow Vdlcy Cinssnr Cowreil, 490 U.S. 332, 109 S. Ct 1835 (1989), the court recognized the importance of the discttssioa of mitigation is a 6na1 federal Eaviroomeatal Impact Statement: To be sate, oae important ingredient of an EIS is the discuaion of steps that can be takes a mitigate adverse eavirotuneatal cottsegtrertas. The regtutemeat that an EIS contain a detailed discussion of possible mitigation measures flows both 5om the language of the Aa nod, mote expressly, from CEQ's implementing regulations. Implicit in P1EPA's demand that as agency Prepare a detailed statement on "any adverse eavirotrmeatal effects which cannot be awided should the proposal be implaneated," 42 U.S.C. § 4332(Cxit7, is as understanding that the EIS will discuss the extent to which adverse effects can be avoided. See D. Mandelker, NEPA Law and Litigation § 10:38 (1994). More generally, omission of a reasonably complete discuuion of possible tnidgation measures would tmdermine the "action-foreioe [traction of NEPA. Without such a discussion, neither the agency tar other interested groups sad individuals can properly evaluate the severity of the adverse effects. An adverse effect that as be fully remedied by, for example, as inconsequential public expenditure is certainly ant az serious as a similar effect that can ody be modestly ameliorated tluough the commitment of vast public sad private resources. Recognizing the importance of such s disctusion in guaranteeing thu the agency has takes a "hard look" at the envuoomeatal canequeaces of proposed federal action, CEQ regulations require that the agency discuss posstble mitigation measures is defining the scope of the EIS, 40 CFR § 1508.25(b), (19871, is discussing aixetaatives to the proposed action § 1502.14(f), and conscgttexes of that action, § 1502,16(h), anti in explaining its ultimate decision. § 15051(c). Id., 490 U.S. a<351-352 (footoou omitted). •l3- ~. B4. See Responses A, Z, and AL above. his observed that the court's opinion, cited in the comment, states that an EIS should contain a detailed discussion of osp sibee mkigation measures (emphasis added). h also states that this approach should be applied to unavoidable adverse impacts. In the case of low frequency noise, no adverse impacts have Deen determined. See General Response 1. The discussion of mitigation measures in an E1S is evrn more significant under MEPA than it is under NF.PA, since the state law goes beyond the fedora! law in imposing a substantive B5. BS. See Minnesota Rule 4410.2500, Incomplete or standard of conduct for state agencies. Under Mica. Stet. § 116D.04, state actions such as the Unsvailabls Information. Rule 4410.2500 provides a kind which will be required of state agrncies including MAC and the Metropolitan Council to means for ~ determinstion of sdequscy when essential approve the runway, cannot be allowed, where the action "is likely to cause pollution, informstion on potentially significant impacts and impairment or destnrction of the air, water, land or other nanaal resotcces located within the , mhigstion is incomplete or unsvailable. Response 81 state, so long as there is a feasible and prudent alternative consistent with the reasonable and General Responses 1 and 2 discuss the requirements of the public health, safety, welfare and the state's paramount concern for the deficiencies of Richfield's analysis of low frequency protection of its air, water, land and other cannel resonates fiom pollution, impairment or noise impacts, the approach to determine the desauctioa Economic considerations alone shall not justify such conduct." Thus, givrn significance of the impacts, and MAC's commkment to MEPA's express provision that alternatives include mitigation and the requirement that mkigate any identified significant adverse impacts to a mitigation be discussed, and given the substantive standard of MEPA in Minn. Stet. § 116D.04, level of insignificsnce prior to operation of the new strbd. 6, quoted above, a full disctusion of mitigation is oecewty for decision makers to runway. determine whether "feasible and pnrdrnt alternatives" to t}x proposed action an available If so, they must either be incorporated in the actior4 or the action mnst not be taken. 3., IT IS NOT SUFFICIENT FOR THE FEIS TO TREAT LOW FREQUENCY NOISE AND MEASURES NECESSARY TO M117GATE THAT IMPACT AS AN "UNRESOLVED ISSUE." An Environmental Impact Statement shall describe the proposed action in detail, analyze its sitmificaat eovironme>>W imnaets. discuss appropriate alternatives to the proposed action and their acts, and e>;plore methods by which adverse eaviwamenW impaeb of an action could be mitigated. Mmn. Stet § 11tiD.04, subd. 2(a). Mrnnesota Rule 44102800 Deterrnioation of Adequacy subpart 4 Conditions, requites ~te final EIS to be prepared is compliance with procedures of the Ad in Pacts4410.0200 - 4410.6500. Under Rule 4410.2800, The Determirmtion of Adequacy, the Snal E1S must, in part, address "the potentially significant issues sad alternatives raised in scopiog so that all significant issues for which information ran reatoorlbly be obtained have been analyzed in conformance with Part 44102300, Items G and H." Rule 4410.2300(G) refers to the requirement that the EIS shall address alternatives, and (M requites analysis of rnviroruneatal, economic, employment. and sociological impacts. "Data and analysis shall be commeastuate with the importmtce of the impact and the xlevanee of the information w a reasoned choice among alternatives and to the consideration of the need for mitigation meaAaes ..." Ruk 44102300(li). The EIS is required to address mitigation measures by identifying those measures "that could reasonably eliminate or minimize any adverse eavitonoxntal, economic, employment, or sociological affects of the proposed project" Rule 44102300(I). MAC is required in its EIS w provide detailed information on all alternatives is order for the EIS to be evaluated and play its proper role in the decisioo-maldng process under Minn. Scat § 116D.04, subd. 6. wee Cedes-Riverside En+irorrmentd Defense Frond v. XilLr, 422 F. Supp. 294, (D.C. Mme 19717. Ia Cedm-Riverside the court found that in part becauu the EIS failed to -14- ' Bs. ~ B6. See Response B5. 86. Response on previous page. • • evaluate alternatives in the greats detail required by state law, the EIS violated the requirements of the Mittoesota Eavirotwteatal Policy Act (MEPA). Micro. Star § 116D.04. It is rat sufficient Bs, for an FEIS to describe a significant enviromoental impact as as "unresolved issue," and leave it u that It may be a politically uoraolved issue, but the effccu and mitigation of low frequency raise must be addressed in the FEIS. C. Why would the Rtmway 17-35 project irtctease the number of overflights ova Mother Lake? (Ste FEiS at V-33.) Since there would be relatively few arrivals oa Ranway t 7 or dtpmtures on Runway 35, v+ouldo't such overflights wnsiu almost entirely of arrivals on Rtmway 12R or depattttra on Runway 30L? Wouldn't the number of stae6 operations on C ~ . Runway 12Rl30L be expected to decease with the coaurtrction of Rmtway 17/35, given that the latter runway is portrayed by its proponents as a meant to shift to the south of MSP operations that otherwise would take place aoRhwest of MSP? The FEIS indicates a dramatic inaease is what the FE[S desea'bes ss "the samba of flights expected over bird eonceatna6os areas at aitical altitudes." However, the FEIS does not (`,2, state whether this wastitutes a signifcant safety hazard. This omission is alarating, given the , fact that the FEiS proposes ao mitigation whatsoever for overflights over Gun Club Lake or dte Long Meadow LakeBlack Dog Lakc complex. (Ste FEIS at V-32.) The ittcrcase is flights blow 2,000 feet over the MVNWR appears to be iacoasisteat with the FAA's commitment to the Deparmoent of the Interior in the patties Interagency Agteerneat A ropy of the Agreement is included in the Appendix to these comments at Tab S. D. CO The discussion of the temporary extension of Runway 12R-30L appears to jumble a~ eonfiue issues pettaiming to (I) the closus of Runway 422 during the coatatrction of the 01 additional 1,000-foot extcadoa of thattuuway, and (2) the extension of Rtmway 12R-30L and the closure of portions of thu remway in connection with the monsrtucdon of that runway. Morc 6mdaoieatally, the FELS improperly limits its coatidcration of the impacts associated with the recoasattction of Runway 12R-30L to coasttuction impacts. In particular, the FEIS fails to disclose soy noise impacts associated with that reconstntctioa Thee is no bgical basis for aoalyziag some, but not aU, of the eavironmwtal impacts associated with the reconstruction project E. IIrIPACTS ON THREATENED AND ENDANGERED SPECIES The FEIS discloses that the Rtmway 17-35 pmjcct would have an "sdvase impact" on ' E,~ . Forsta's tenet, but improperly fails to disclose wbetha that adverse impact u significant. (FEIS -iS- C1. Due to concerns expressed regarding bw attirtude overflights of bird sensitive areas, the overflights analysis was reviewed and the values in the FEIS are not correct due to input errors in the openti0ns assigned to the flight tracks, and chanpss to Figures Q- 2and ll-S and Table D-5 in Section V.D were required. The revised figures and table era attached to Genanl Response 8. The revisions resuk in 1,050 fewer operations from the preferred akemative over Mother Lake in 2010 than No Action, and 910 fewer operations in 2020. C2. Regardless of the technique used to estimate tM number of birds in an area, attention centers on the number that could cause a potentially hazardous condhion to occur. To date, the numbers of birds have not caused any significant problems st the prsseMly developed airport. No airport can totally eliminate birds from the surrounding airspace. Nevertheless, the FAA and MAC are concerned about the issue of bird strikes and there will be coordination with the USFWS concerning any proposed control measures, whether they are proposed for safety purposes or to limit biological impacts. The proposal to permit arriving and departing flights to occur below 2,000 feet is not inconsistent with any FAA commitments based on the 1993 Interagency Agreement. Ths referenced agreement is advisory in nature and is primarily intended to increase pilot awareness or modify procedures, if possible, to avoid low-altitude overflights of natural resource lands. Furthermore, the FAA has acknowledged tM interagency agreement with reference to this refuge, has determined that there are no feasible and prudent alternatives, and has committed to provide for reasonable mitigation. Dt. Ths FEIS diisctoses the noise impacts of the temporary extension of Runway 12R in Section V.E and refers the reader to the Environmental Assessment for Extension of Runway 422 to 12,000 Feet for the detailed analysis of impacts. Ef. As stated in the FEIS, the potential for impacts to Forster's tam, a state species of special concem, is unclear since only one nest has been observed in Mother Lake since 1987. Given the extremely limited use Mother Lake has received by this species over the last 10 years, any potential adverse impacts to the Forster's rem population would not rise to the level of being significant under NEPA. In fact, the additional runoff from the proposed development's impervious surface wilt raise and stabilize water levels in Mother Lake, which would improve the habitat end the success of the rem nests (more stable water levels reduce the flooding of nests). Species of special concem are not protected by state law or rule. Sse Minn. Stet. section 84.0895 and Minn. Rules Parts 6212.1800 - 6212.2300 and Part 6134.0150. Accordingly, there are no substantive legal rsquiremsnts applicable to potential imparts of the MSP alternative upon the Forster'a tem. az V-36 to Y-37.) In addition to addressing the significance issue, the FE1S should disclose the ~ E1. E1. Response on previous page. substantive legal ra{uiremeats applicable to projects thaz have thaz kind of impact oo a state species of special concern like the Forster's tem. F. ECONOMIC IMP The tax capacity impacts shown in the FEIS for the Ciry of Richfield (FE1S az V-54) improperly omit impacts associated with removal of residences is eomectioa with eSorts to midgatt low 6equeacy noise impacts. F1. F1. See General Responses 1 and 2. The development costs foc the LTCP and the 2020 Concept Plan (PETS at V.54) fail to include costs associated with mitigation of bw 6xquency noise in Richfield. (See Richfield's mitigation proposal submitted under separate coves.) Does the 5803 million cost for MSP 2010 shown in the FEIS include the f255 million in F2, F2. The no action costs are not included in the 2010 improvements included in the no action alternative, te., is MSP 2010 expected to cost as LTCP; only those costs directly attributable to the additional 5548 million? if the cost of those improveraeats is not included in MSP 2010, then LTCP are included, which were estimated to be about the FEIS is underestimating the absolute and relative expense ofthaz project 5803 million. G. IMPACTS ON HLSTORIC/ARCHITECTURAL RESOURCES The FEIS reveals that the Runway 17-35 project would result in significant adverse impacts on historic and architeetinal resources and thereby triggers the substaz-tive requirements of the National Historic Preservation Ad. Section 4(f) of the Departme»t of Transportation Act, G1 • G1. A Programmatic Agreement regarding the affects ` MEPA, and MERA. (FEIS az V-66.) Due to the inadequate alternatives analysis is the FEIS, upon potentially historic resources has been signed by (` is no basis for tanking the requisite determination regarding the existence of feasible a the appropriate agencies and is included in Appendix C. ~ntrleat alternatives. Sea also General Response 6. H. )j,YDUCED SOClOECOIYOMIC IMPACTS The FEIS fails to analyze the induced commercial, office, a~ retail devebpment is east Richfield associated with either the redevelopment needed to mitigate against the low frequency H 1. noise impacts of the 2010 LTCP or the western entrance to the airport contained in the 2020 Corteept Plan. -' ~i fit' , The FEIS understates important impacts of the Runway 17-35 project by assettiag thaz acquisition of New Fad Towo and Rich Acra "is not considered as impact of MSP exparuiori" beaux that acquisition is complete. (EFTS az V-70J Thu acquisition occurred P~~IY 11. because of the proposed runway. Was there another EA or ELS in which the environmental impacts of that acquusition were analyzed? -16- H1. See General Responses 1 and 2. Anew west terminal would not induce development inconsistent with Richfield's currently adopted plan; rather it should help Richfield realize the planned redevelopment. 11. This acquisition was requested by Richfield based on existing noise impacts, which was documented in the Environmsnta/Asssssment; New Fad Town end Rich Aeros Noise Abatement, MAC, December 1992. C7 .J J, jIOISE IMPA~ The FEIS improperly fails to disclose the projected mrnrber (not just the pert:entages) of ' .~ 1 arrivals and depatttnes on each nmway erd. The FEIS improperly fails to analyze noise impacts fot the year 2020. Even if the year 2005 is an appropriate year to cvaluate noise impacts for the 2010 LTCP, that does not justify ignoring the year 2020 to analyze impacts associated with the 2020 Concept Piaa. By confining the entire noise analysis to 2005, the FFIS provides no means to evaluate the additional noiu .~Z. impacts associated with coattrnetion of the 2020 Concept Plan as compared with either the 2010 LTCP or the no action alternative. AU of the noise analyses presented for 2005 should also be provided for 2020. . Even if 2005 represents the'tvorst case" year in ietat5 of Ctrtute noise impacts-a dubious proposition since that conclusion is based entirely on consideration of DNL impacts--it is not true thu "[tJhe raise impacts of the MSP 2020 Concept Plan and MSP 2010 LTCP are ~ j$, identical...." (FEIS at V-87.) The F615 provides ~ basis whatsoever for comparing the irnpects of those projects because it contains no analysis of impacts relating to the 2020 Concept Plea. ](. IMPACTS ON PARKS AND 1ZEt:'ItEATiON .The FEIS improperly ignores consideration of the two parks is Rich Acres and New Ford Tows that would be eliminated by wnmtrction of the Rtmway 17-35 project The proposed roawsy would apparently litcrally tun througti one of those parks. (Documents regarding IvtAC's K1. pleas to acquire the parks are included is the Appendix to these comments at Tab 4.) By ignoring the parks located is Rich Acres and New Ford Town, the FEIS erroneously concludes that no mitigation is required with respect to impacts on parks. (FEIS at V-95J The FEIS also tails w disclose that the elimination of those padre for the new nmway would constitute a use of parks that triggers the substantive provisions of Section 4(f) of the Deparnnent of Transportation Act, MEPA, anti MERA. L IMPACTS The FEIS fails to disclose relocation impacts associated with the miagatioa needed to address low fiequency noise impacts in Richfield. , J1. The numbers of arrivals and departures sue given itt FEIS Appendix A by type d airuaR The use of the runways will bs the acme on a percentage bask regardless of the forecast of operations, which apows the reader to easily calculate the numbers for dtffsrsnt forecasts end years. J2. The FEIS provides • tabular and graphical analysis of the noise impacts associated whh the MSP Altemativs high forecast scenarios for the years 2005 end 2020. Attached Figure CR-1 provides a graphical comparison of the MSP Aftemative baseline forecasts for 2005 and 2020. Neither the 2020 high nor baseline forecasts produce any further significant noise impacts, increase noise mitigation measures, Or significantly change land use compatibility when compared to the 2005 high and baseline forecasts noise contours. See also General Response 4., J3. The comment when considered out of context' implies that the 2010 and 2020 plans are the same. The referenced sentence k meant to convey that 1:he year 2005 forecast was used to determine noise impacts so there is no difference between the noise impacts of the 2010 and 2020 plans because the combination of 2005 operations and fleet mix results in the maximum noise impact. K1. The acquisition of these two parks was the result of an earlier project: They were net considered s Section 4if) impact by Richfield because they were determined to be insignificant, as stated in the November 19, 1992 letter to Nigel Finney of MAC. from James D. Prosser, City Manager. Ses FA referenced in Response ll. L1. , Lt. Sae Gertcral Rt~portse 2. -17- • • IN. IMPACTS ON ~CTiON 1/A F OCntCES 'r, u The FEIS uodustates Section 4{t) impacts by errotteotnly stating that "(a]o parks and re°eui°a areas s"bject to Seciioa 4(f) revie+v will be aegvised for devdopmeat of the MSP Alternative." (PETS u V-115.) In autiy MAC scelcs to acquire two patios is Rich Aces acrd M1. Ifi1. See Response K1. New Ford Towa for that purpose. The acquisition of those parks would wnstitute a'Lse" of Section 4(t) properties. The FEiS correctly concludes that the Runway 17-35 project "will substantially impair public use or enjoyment of Scctiort 4(f) resources within the MVNWR" d h f " sa t eYe ore would result in the coashttctive ttse of a portion of the Refttge.^ The Appendix to these comments, u Tab 6 cotttsia i f M2 tiA2 d C , s trop cs o various brochures furt}ia doctmxnting outdoor educational anti other activities u the MVNWR that would be substantially impaired by the project . . orrrrtent note . Because the FEIS erroneotuty concludes that the Runway 17-35 project does not involve ~Y at:gtdsidoa of parks, it improperly fails to analyze or Propose any min gation measures. (FEIS u V-119.) Under these circumstances l , approva ofthe of the Departotent of T Proles would violate Section 4(t) raasportuioa Act, MEPA, and MERA. M3. M3. See Response K1. Absent fiaalizntioa of a mitigation agrceaxtrt between the FAA and the Fish do Wildlife Service, there is no basis for the FEIS to conclude that miti atio f i g n o mpacts on the MVNWR will be mitigated to a level of significance or to the fullest extort feasible. This prorides an M4. M4. See General Response 7. additional basis for concluding that approval of the project wouM violate Section 4(f), MEPA, and MERA. N. SURFACE Tt:sxSPORTATION 11-0'ACTS PROCESS USED TO ANALYZE IMPACTS AND DETERMEVE MTI7GATIONS The Process used to analyze rho impacts to the surface aansportation system was generally not inclusive of the Ciry of Richfield, did not eortdder the proper scope of analysis anti did not seer¢e commitments to perform the Deeded mitigation. Each of these is addressed 6ebw. Process Not Iadative Although the Ciry of Richfield inctas the majority of the impacts associated with MSP expansion, the City was geaeraity le@ nut of the Metropolitan Airport Commission (MAC) ~Y~ of eavitonmeata! impacts sad development of mitigatiaa strategic This is particularly hue in the surface hanspo[tation attn. Appendix F of the FEIS contains the document "Coaseaws Approach to Surface Tr+nsportstion !'rojcct Development Mmoeapolis-SL Paul Internstioaal Airport," May 13,1997, prepared by the Federal Aviation Adminishation (FAA) and MAC. Page 1 of the Coaseasus doettmeat lists the public agencies that participated in the development of the doctanent (FAA, Federal Highway Adntiaishatioa, Minnesota Transportation, Wucoasia Department of T Department of ransPortatio4 Minnesota F-nvironmeatal Quality -18- N1. Richfield was represented an the Dual Trade MSP Tetdtrtical CortxniCee which reviewed the approach and anayais of environrtteMal impacts. and was represented on the MSP Noise Mitigation Cortxrtiltee. N1. The FEIS does not propose the final solution and needed mitgation for the surface transportation projects. h presents the impacts of one feasible alternative. Additional surface transportation alternatives and design details are stilt to bs worked out during the next phase of work, which will include public and local government participation. Ths purpose of the Consensus Ooeumsnt was to determine the projects that were needed to implement the MSP aksmative and define the project development process - establish the purpose and need for the projects and the implementation and programming issues. Members of the Surface Transportation Committee met ' with Richfield on March 17, 1997, and informed Richfield of the approach being taken with the FEIS and Consensus Document. In responding to comments on the FEIS received from the Minnesota DOT, h is stated that the MAC will initiate a cooperative agreement with Mn/DOT, Hennepin County, and Richfield to develop the TH 77/66" Street interchange. This agreement may also address a more general study of the TH 77 corridor from 1-494 to TH 82. • C Bond, MAC and bietropoGtm Council). The individual cities impacted by the airport arc noticeably txH included in this group. and accordingly, their teehoial input is sot reflected in the N1. doeuoteat The City of Richfield prepared a detailed set of comments to the MetropoGtaa Airports Commission regarding the DEIS (letter dated February 19,1996). The wntneats relative to N2. surface trantportation issues appear on pages I-136 end I-137 of the FEIS. The responses in the FEIS to the February 19,1996. wmmrnu are incomplete and fail to address all issues raised by the concerns. Cosnmrnts raised on trsrck traffic volumes (cootmeat marked LLL in FEIS docmneat) sad detailed subarea traf5c analyses (comment MMM) are given cursory, norr- respoative answers. The City of Richfield has barn xtively developing a mitigation plan for the eastern portion of the City to respond to the impacts of airport expansion. This plan contains major land use changes. Becatsse the so-called "conunsus approach" to transportsaon issues was conducted N3. without City input, the proposed roadway layouts prepared by MAC for the FEIS do tx>< properly regard the circulation patterns std access Wads of the eastern portion of Richfield neacT.H. 77. • The City's role as a partner or participant on cooperative roadway projects is not fully described. Page S of the "Conseastu t)ocumrnt" notes thsf other cilia "and the City of .N4. Riehfxld may atso,be included as pasties to the cooperative agreemrnts(s)." Richfield believes that it must be part of such cooperative agteemeats, but rm further discussion of the details of this participation are provided in the FEIS or supporting doctmrertts. Limited Scope of Aaalysas The FEIS imProPcrfY fails to RYA surface baasportation impacts for the year 2010. CoaSequently, there is m data a analysis to support the bald conclusion in dbe FEIS that N5. "implementation of tfx MSP 2010 LTCP, would sot significantly affect traffic volumes on Principal arterials in the vicinit7 of MSP." (FEIS a< V•126.) Nor is there any basis in cbe FEIS - for determining whether or not (!) tfie Runway 17-35 project would have any significant surface nantportation impacts in 2010, or (2) there ate any feasible mitigation measures that could reduce any 2010 tsaf5c impxtt. The geographic scope and level of detail of the surfxe roadway amalyses is too limited. ~ N6. The analyses nexd to include intersection level of service computations, u these results arc Deeded for the assessment of air quality impacts. A regional modeling process was conducted to generate year 2020 volumes, as presented in MnDOT's report on impacts on dte State Highway System. However, this analysis did not imcltrde non-state roadways, which also will be impxted. This is a significant omission. To determine the specific impacts W Richfield, morn detailed information from asub-area trafrc N7. ~Y~ is Deeded. which should imelude (1) analysis of other major streets, such as 66e Street, Q) geometric, (3) capacity analysis, (4) delay, (S) intersection LOS, and (~ need for new a -19- N1. Response on provious page. NT. As stated in DEIS Response LLL, future truck volumes are estimated to be 5-8% of the daily traffic volumes. As stated in DEIS Response MMM, a detailed subarea traffic study was determined unnecessary because the differences in forecast traffic between the MSP end no action alternatives on the affected srtarials would not significantly change the levels of service in the area. The FEIS added a sha- specific air quality analysis for the TH 77/66'" Street interchange (FEIS pages V-10 through V•131, as well as a preliminary, feasible, layout for the interchange. Local traffic circulation issues were considered in the development and evaluation of potential interchange layouts. As noted in Response N1, above, MAC will intiate a cooperative agreement whh Mn/DOT, Hennepin County, and Richfield. Tha subsequent design study will address further details of local traffic circulation. N3. Detailed local circulation psttems and access needs were not addressed in the Consensus Document tiecause they are to be addressed in the next phase of project development (see Response N7). The layout shown in the FEIS, Figure W-g, represents one feasible configuration that could be evaluated to determine representative impacts. More analysis of layout options will be performed as part of the planned future design study efforts. N4. The MAC will initiate a cooperative agreement with Mn/00T, Hennepin County, end Richfield to develop the TH 77/86'" Street interchange. his not necessary to address more details without first issuing a final project decision for the airport expansion. N5. FEIS 2010 stxface Uansporta6onanpads are based on analysis of available traffic forecasts and the expected impact of the MSP 2010 LTCP on traffic psttems. No potentially significant impacts requiring mhigation were determined. The new cargo area on the west side of the airport is expected to increase traffic volumes on 7H 77, TH 82 end the TH 77/88th Street interchange. However, local street traffic characteristics are not expected to change significantly due to the airport project; in some cases, local street volumes can be reduced due to access control measures. As stated in Response N3, more details will be addressed ss part of the future design study. NB. Sse Assponse N2, above. N7. See Response N5, above. Local street traffic characteristics are not expettsd to change significantly due to the airport project. Mora details will be addressed as part of the future design. study. unproved traffic signals. This information is Deeded as it should also be used in the carbon ~ N7. M. Response on previous page. moaoude air quafiry analysis for each roadway improvement RegetdistS specific roadway improvemenu, some roadways will still be ova capacity. N8. Id!<. his coned that poor peak-hour levels of service eves if there is an improvement over existinE conditions. 1.494, [-35W, and T.H. 62 will be over would continue to exist along some segments of tM capacity in 2020. Additional roadway alaraatives should be coasideted as well as transit referenced roadways-even if expanded. This improvements. The FEIS Daly gives cursory mention of transit access. More emphasis should highlights the need for transit improvements and tM be placed on transit access, with specific aitornuives presented. potential benefits they may offer. Ths project development approach for the proposed 2020 roadway projects scknowtedges this by incorporating a Major e. Laelt of Mltiptioe Commltmeab Investment Study methodology. In the near-term, Mn/DOT, MAC, and other agencies are p-ocseding with Within the discussion of surface transportation eahatrcements there are no firm final design plans for s Light Rail Transit tLAT) commitments supplied by MAC to the mitigation measures identified in the FEIS. The connection, approved as part of apreviously-completed »Coasenstn Approach" document that supports the FEIS detiaeates needed roadway projects and environmental study. For more discussion, see General the document iadiata which saettcy should lead the development of each project. However, Response 5. oeitha the "Consensus" document nor the FF.IS provide the actual commitment by MAC to complete the referenced roadway projects. N9. N9. The two roadway projects needed to implement the 2010 LTCP (the west frontage road relocation and for example, eves though the FEIS states that "MAC and the employers on the airport the TH 77/66'" Strsst interchange rsconstructionl are site (particularly Northwest Air~ines:s the major on-site employer) will need to pursue an to be impiemsrnsd in connection with the airport eve package of TDM (travel demand maoagemeat] measuues," the FEIS fails to contain . expansion, and this is made clear within the FEIS and any ctimtmitment to those measures. (FQS at Y-139.) As a rault, the FEIS provides ao basis for the Consensus Document. The need for the roadway determinio~ whether those measures would reduce any impacts to a level of insignificance. projects associated with the 2020 Concept Plan wii! be reevaluated if plans to implement the west terminal proceed. The MAC and FAA cannot rely upon TDM 2. ACCESS NEEDS RELATIVE TO THE 2010 LTCP measures to produce the specific capacity improvements needed to support the 2010 LTCP and a. T.H. 77/66th Slrset IaterchaaEe the 2020 Concept Plen. 7DM approaches un help • reduce some traffic impacts, and the MAC will The T.H. T7/66th Street Interchange grill undergo a major reconstruction to save the continue to work with airport tenants to implement the measures listed on page V•139 of the FEIS; but the expanded needs of the 2010 LTCP. The City favors a single point diamond interchange design. MAC cannot force Northwest Airlines or other private With this there is the need for appropriate upgrades to T.H. 77 and improved access tnaasgemeat, lane wnfiQutatioat and exitleairanee tamp layout design along T.H. T7. The Ciry on•eirport smployara to implement TDM measures. snorrgly desues to be involved wrth the destga team that develops this mterchaage layout. N10. M N10. The design of the TH77/88 Strsst interchange As the design for the TN. 77/66th Street Interchange is developed, it must correspond to will be determined during the project's design phase, the City's planning for 66th Sweet sad other local roads west of T.H. 77. This area is slated to and will be determined based on system and lane chaoSe and redevelop tinder the City's overall mitigation planing for the import and the requirements, and engineering design details, such as circulation pattaas and needs of the 66th Street area must match with the overall interchange structural engineering factors (the current cost and ~~ estimate for the interchange has assumed that the existing bridge wilt be retained). Richfield will bs involved in the design process. -zo- C b. East Froata=e Road Faaetiso With airport eo~sasion Standish Avenue on the East side of T.H. T7 will be lost Currcatly this Woad saves an east frontage road fuxtioa to T.H. 77 with a connection between N11. N11. There is no room for a replscemsnt fronugs rwd 66th Street and 2tith Avenue. This toad serves Metro Ttaatit Bus Route lS and also is pert of without impacting the Mother Lake wetland. Metro the Ciry's bicycle route network. This 5rootage road function needs to be replaced cooctazzat Transit is aware of this and has planned for the ~~ ~ itttacha~e Mpppn, closure. t3icycls route continuity could be provided at a number of overpasses of TH 82 west of TH 77. e. 77th Street Uaderpa» With the increated development and tca~c volumes in the airport vicinity. the aced for expsaded local eireulation is heiahteaed. The City of Richfield 6rvors m underpass in the 77th Strut area to achieve circulation between the west sad east sides of T.H. 77. This tmderpeJS N12. N72. As stated in the Consensus Document, the 77" would fit is with the north frontage rwd of I.494 oa the east side of T.H. 77 sad would also fit Street underpass is not necessary to implement the with the 77th Street arterial aHgnmeat developed by the City of the west side. This underpass airport expansion. However, the need for this project would benefit the airport property by giving it augmented cirarlation to the west. and its impacts have previously been evaluated, federal funds have been earmarked, end Mn/DOT will lead its further development. As needed, the MAC will also d. Eni~aneed Airport Access continue to coordinate wkh Mn/DOT end Richfield. :With the 2010 LTCP the onty significant ixrcase is airport access capacity is via the T.H. 77/66th stmt Interchange, sad this point is Daly meant to serve ergo acrd service trade. The City favors coasidaatioa of an enhanced airport access system using multiple accesi points N13. N13. Airport access will be enhanced with the 77" St. and a ring road system to reduce congestion at any single location. underpass and an improved airport frontage road " Streets, interconnecting sccesa points at 88" and 77' and 34'" Ave. South. e. Biryele Access The surface transportation analyses do sot consider alternative transportation modes such N14 TDM di R N9 b N14 S as bicycling for airport employees. The roadway network plans must consider bicycle access . ng , a ove, regar ee esponse . opportunities acrd facilities. These should be related to the City's overall bicycle route planning. measures. The details of bicycle access, including route continuity, will be addressed during the final design phase. 3. ACCESS NEEDS RELATIVE TO THE 2020 LTCP a. TrafDe Forecasts The tra>~c forecam that support the roadway design eoxlusioas of the "Consensus N15. N15. This minor change in volume between No Action Doctmxat" appear questionable. Not enough background information is provided in the end the 2020 Concept Plan is understandable when doettmem to thoroughly checlt each volume projection; comments can only be made on the one considers how the 2020 Plsn would divert most of prolecuoas as presented. One specific area of coxes is the 2020 volume on T.FL 77 between the airport terminal access trips to the northwest 66th Street and [-494. Figure 1 of the "Conteasut Doctwteat" shows a "2020 No-Action" ADT comer of the airfield. Tttis would divert much of the of 73,000. The same figure shows a "2020 West Tetmiml Loation" ADT of 71,000. t;rivea that terminal-based traffic tied to origins and destinations to the access to the west terminal will be from T.H. 62 and T.l i. 77 it is vay difficult to tmdastaod the north (e.g., downtown Minneapolis) away from the TH 77 corridor. At the same time, the new terminal would attract more terminal-based trips onto TH 77 linked to nodes to the south and west. K is reasonable to expect that ttuse trip diversions would offset. -21- bow the vdume projection could dexsease undo the west tesminal scenario. The questionable ' N15. volutae projection raises concerns over the roadway analyses presented b. Bicycle Access As with the 2010 time frame, there is a similar concern over the need for bicycle access in N 16. the 2020 time 5•ame. The 2020 roadway network plans must also consider bicycle access opportuaitiex and facilities. These should be tdated to the Ciry's overall bicycle route planning. e: Improper Deferral of Eavirorameatal Review The FEIS improperly defexs impacts of the five surface ttaasportation improvements that would be required in connection with the 2020 Concept Plan if the west terminal is coastrttcted. (FEIS az V-140.) Astable, finite, and definite project is the sine qua non of eavironmrntal review under NEPA and MEPA. The FEIS cannot analyze some impacts of the 2020 Concept N 17. Plan and refuse >o analyze others, especially since the FEIS purports to analyze all impacts associated with the 2020 Concept Plan. Moreover, the FEIS purports w base its analysis of year 2020 au qualiry impacts oa cexuiderazion of year 2020 traffic volumes. (See FEIS az V-8 to Y-13, H-9.) PUBLIC TRANSPORTATION IIKPACTS N15. Response on previous page. N16. See Responses N14 and N9, above. N17. The FEIS does not defer analysis of the 2020 projects. tt discloses the impacts of feasible concepts in the same manner as the 2010 projects Ises Response N31 for the same impact categories. These concepts aces subject to additional study and environmental review if and when s new west terminal is authorized. The FIIS and supporting documents contain very little discussion of impacts to public traruportation. At a minimum, these will be a aced to maintain the route IS Metro Transit N78. N18. See Response N 11. service which currently uses the Standish Avrnue east fiontage mad function to access 28th Avrnue. Ideally, the east fjontage toad will be recanfiguned and tl-e btu mute will not be impacted. If the 5vntage road is lost, thrn suitable meastuex must be takrn to maintain the bus route function. The FEIS and wpporting documents make no reference to the proposed Ifiawazha Light Rail Tramit r'LRT'~ system drat would serve the airport There is no discussion of how the N 19. N19. See General Response 5. LRT would serve the ettneat airport terminal in the 2010 LTCP, how the LRT would serve the west terminal under the 2020 LTCP and how the LRT comeetions through the airport Property vrould malts the LRT accesn'ble for residents of the: easU:rn portion of Richfield. These LRT issues need to be addresud in the FEIS. TRAVEL DEMAND MANAGEMENT The FEIS contains a discussion of travel demand managernrnt (IDM) strategies on page Y-139. dexaibing the ability of TDM to reduce the number of drive alone trips. However. the N2~. N20. See Response N9. disctssion is very general and vague and is not foceised oa the exact parameters of as airport setting. Furthermore, and most importantly, the FEIS contains no commitments by MAC or nay .22. N20. Response On Previous page. of the major airport employers to actually carry out a TDM program. For the TDM discussion to ' N j0, be a meaningfid part of the ®cgation strategy it must come with firm employer commitmrntt. O. VISUAL IMPACTS Thexe is no basis for the coxlusioa in the FEIS that the replacement of the aesthetically pleasing Rich Arses Golf Cotax with cargo buildings and ainxaft aprons "are not considered adverse impacts." (PETS at V-143.) Tbc signiGcancc of this visual impact should be O1, acknowledged and appropriate mitigation proposed. . P. SCfRFACE WATER QUALITY IMPACTS The FEIS improperly fails to analyze cumulative surface water quality impacts associated with the 1,000-foot extension of Runway 4-22 a~ the reeoattruction of Rtmway 12R-30L. ' The FEIS impropoiy fails to analyze or propose mitigation t>ieasum for 2020 Concept PT Plea surface water quality impacts. Q. GROUNDWATER QUALITY IMPACTS The FEIS improperly fails to analyze cumulative groundwater quality impacts associated with aitaaR deicing operations in eonaectioa with the 1,000 foot exteation of Runway 4-22. is Q,~ . particular, the FEIS should disclose the number and sigoi6cance, in tettns of groundwater quality f impacts, of deparaaes that ace deiced at the north cad of Runway 22. The FEIS should alto ~talyze and propose mitigation measures needed to address any such impacts. . _23. 01. Views of the referenced golf course are not integral to the existing aesthetics on the eastern side of Richfield. The aesthetics of this area are strongly affected by the intervening 7kf 77 freeway end frontage road corridor, which is almost 1,000 feet wide. Furthermore, the visual change from the golf coupe to airport use has long been anticipated, as stated by the MAC's 1978 lease with the City of Richfield: '...(Thal Commission at any time during the lease term shall have the right to take possession ... for airport purposes...' Based on these facts, the visual changes assocated with the proposed action will not appreciably aher the already urbanize0 character of lands west of the TH 77 corridor. Urban and commercial land uses, and the associated views, errs consistent with Aichfield's currently adopted comprehensive plan, and the referenced lease agreement makes clear that conversion of the golf coups to airport use is a reasonably foreseeable change. As part of the proposed action, MAC will also review final landscaping and architectural plans to ensure that the cargo area assthetica are consistent with the planned land use and the overall community setting. Pt. The 1000-foot extension of Runway 4/22 is not anticipated to have a significant impact on the quality of surface water run-off from the airport facility, for the following reasons: , The increase in flights and aircraft deicing activity associated with this extension bne additional flight per day) is negligible relative to the;total level of aviation activity at MSP. Aircraft deicing operations will not take place on the Runway 4/22 extension area. Drainage from the extension area will probably be directed to the MSP Minnesota River North drainage/ control system. This control system will be 4nhanced to meat anticipated NPDES requirements (see discussion in Sections V.BB.t.1 and V.66.1.2 of MSP watersheds and anticipated enhancements of detention capacities for the airport(. if the drainage from the extension area is directed to the Minneapolis storm sewer system rather than the Minnesota River North drainage/control system, Minneapolis requirements for controlling this run-off prior to discharge into the Minneapolis aystem would be met by the MAC. The additional amounts of runway deicing chemicals required as a result of the 1000-foot 4122 extension will be minor relative to the total amounts of such chemicals required for the entire airport. The MAC intends to limit and ultimately eliminate the use of ores at MSP, and replace it with materials with less potential for environmental impart. The reconstruction of Runway 12R/30L is not anticipated to have a significant impact on surface water discharges from the airport. Atl drainage from the reconstructed portions of this runway which currently tie in the Duck Lake/Mother Lake watershed will be directed south to the Minnesota River South drainage/control system (see discussion in Sections Y.BB.1.1 end V.BB.1.2). Thsrs errs no anticipated increases in flight and associated aircraft deicing activities directly attributable to the reconstruction projeM. The rr~getion measures for the 2020 Concept Plan ate the same as for the 2010 LTCP. See AppereQoc H.4. D1. Under the 2070 LTCP Ahemative, no aircraft deicing would take place anywhere on the 4-22 runwaY• Under the 2010 LTCP Akemative, there wig be less potential for groundwater impacts from aircraft deicing operations than under current conditions becatue of the intended development and use of five dedicated deicing pad facilities. Each of these pad spent aircraft deicing fluids, and will have glycol- contaminated snow management components. • R. Ltfonnation in the FEIS doe not support its conclusion that there arc tro feasible or practical altaaative to the destruction or modification of wetlands affected by the Runway 17-35 project The potattial significance as a safety issue of bird strr7ces is irxiieated by the aetmovrledganeat in the FEIS thta FAA polity opposes consideration of mitigating wetlands R1. impactt o0 airport property "because of the potential increase of bird strike by aircraft." (FEiS at V-lfi3.) The FEIS improperly fails to dixlose whetkrer the proposed wetlands mitigation would reduce the project's wetland impacts to a Level of imignificana. The FEIS faiLt to adequately atulyze mitigation of the significant adverse impacts of the Project on the MVNWR, a uniquely valuable reource enjoyed by residents of the Twin Citie $1. metropolitan artx inchtding thousands of RichfieM residents. Richfield joins in anti adopts the comments submitted by the United States Fish and Wildlife Service (United States Drpartmcnt of the Interior) correeraiog the nature, anti needed mitigation, of the impacts of the Project on the MVNWR. T. TRADEOFFS BETWEEN SHORT-AND LONG-TERM GAINS AND LOSSES The FEIS. fails to contain the requisite analysis of tradeoffs betaveen short- and Fong-term T1. environmental gams and losses, as expressly requred by Paragraph 86 of the Airport Environmental Handbook, FAA Order 5050.4A. instead, the FEIS purports to simply balance the short-perm envitoameotal bases agaiaSt the long-tam economic and social benefits. (FEIS at V-190.) VII. COMMENTS ON RESPOZiSES TO RiCRF~r•D'S DEIS COMMENTS The FEIS states in Reply W to Richfield's comments on the DEIS (FEIS at I-133) that the FEIS disclose (1) the Jmown effects of the proposed anion, and (2) tiye commitment of MAC to mitigate significant advax effects. The FEIS doe not, however, fidly dixiox the known annoyance of low fiequetrry noise and vibration that was brought w MAC's attrntion by V 1 the City of Richfield tttany momhs prior to publication of the FEIS, other than as as "unresolved .issue.° Neither NEPA ttor its implementing regulations can be interpreted as permitting an "umeolved issue" to save as a disclostre of a noix impact The principal'luuesolved" aspats of these noise impacts are not their existsace and nattim, but rather the xope of a federal ~ .. rcgtrlatory agermy's polity prefetenee and an airport proprietor's reltrcmnee to disclose a doeumrnted adverse effect of runway sideline noise. The committttent nferrcd W in the second pert of Reply W is apparently MAC's tmdataking "to study the iutre further. and worst widt Richfield and FAA to develop and implement a plan to address any adverse impacts that are idetrtified." (FEIS u ix.) This undertaking is so nebulotu as to lack practical meaning. The pledge, which commits MAC to no V,'t. definition of "sigttificrmt" adverse impact, no substantive action, oo specific study plan, tto xhedule, aood ao mitigation, deprives the FEIS of the very disclosures that NEPA mandates to inform environmcatal decision making. The FEIS also iodieate in Appendix B that "MAC should develop noise impact rnodeb which reflect the impact of ground level noise oa residential properties; mitigation for bw fitqueacy noise should be developed aRer wasultation with indcpeadent raise mitigation experts." This statement don littk to clarify MAC's vague pledge. Luce the pledge itself, the 113 -24- R1. The FEIS devotes almost an entire page explaining why there ere no ahsmatives to the impacts as proposed and gives Lull support to the FEIS conclusion regarding ahsmatives. As stated on page V-182 of the FEIS, a finding has been made in accordance wkh Executive Order 11990 and DOT Order 5860 that there are no feasible or practicable aksmstivss to the wetland impacts proposed. No specific shortcomings in the analysis are identified in this eommem. A d'~scussion of ahsmatives will also bs included in the psrmiLsppiication. The bird strike potential is one of the primary reasons why wetland mhigation is not proposed on a in dose proximity to the airport. Since no mitigation welands would be constnrctsd within or in dose proximity to the airport, no increased hazard of bird strikes is expected in association with the wetland mitigation for MSP. The wetland mitigation plan has not been finafaed; however, sufficient mkigation will be provided to adequately compensate for the impaired wetlands in the permitting process. The quality of the existing wetlands has bean described in sufficient detail in the FEIS. Ahhough the quality of these basins varies, there appear to bs no proposed impacts which cannot be reasonably mitigated with replacement basins that have functions end values that ere at least egwl to the impacted wetlands. Complete wetland mkigation plans will be included in permit applications under Section 404 of the Clean Water Act, the WCA and the DNR Protected Waters programs. Richfield will have another opportunity to comment on the adequacy of the mitigation plans at that time. These permits cannot be issued unless the various agencies are satisfied that the mitigation plan fully compensates fa the lost wetland functions and values. Any permits issued will also contain monitoring condhions that will ensure that the mitigation wetlands fufty replace tfis functions and values lost and corrective measures will be required if necessary. 31. See Gensrai Response 7 and the responses to USD01 comments. T1. FAA finds the FEIS analysis consistent with FAA Order 5050.4A, Paragraph 86, which is to examine the tradeoffs of short and long term environmental gains at the expense of long and short term environmental losses, respectivsiy, as applicable, for each environmental impact category. There is no known short term environmental gain due to the proposed action in any impact category that would tradeoff st the expense of a long term loss in the same category. Likewise, there is no known long term gains that would tradeoff at the expense of a short term loss in the same impact category. U1. Sse General Response 1. The FEIS analyzed all noise impacts and did not determine a significant adverse impact due to low frequency noise. U2. Sse General Responses 1 and 2. UJ. Sae General Response 2. The aourtd insulation program is txxttingent on MAC maintaining a bond rating of et least A;~it is rat contingent on FAA pdity.. ~J statement lacks specificity, a schedule, aM a commiomeat w actual mitigation. Further. MAC's V $. I Ul. R self-approval of this approach (as expressed is its noise mitigation program of October 28, 19%)' espouse on previous page. is contingent upon both MAC's bond ratioY and FAA policy. Unfortunately, the proposed rtmway will sate bw 5squexy sideline noise is Richfield , rt:gsrdless of MAC's bond rating or FAA's policies concerning qualificuions for access to U4, aviation trust funds. Mitigating the effects of aircraft noise hat been the airport proprietor's unique responsibility ever since the 1%2 U.S. Supreme Court decision in Griggs vs. Allegheny Corarry. NEPA unwuditionally requires that mviroommtal impacts be fully disclosed, regardless of a proprietor's or my other agency's ability, eligibility or interests in paying for mitigatio4 or of the degree of resolution of any agency's policies concerning them. Reply W W confuses two distinct noise metrics whr7e failing W address Richfield's canmeat Richfield's comment concerns the Time Above 85 dB ('I'A 85) analysis of the DE1S, not Day-Night Average Sound Level figures. Furthermore, INM does not, as implied by ' Reply W W. assign "the aprivalent of l0 daytime opctatioas" to every nighttime operation for U5• purposes of calculating values of the Time Above noise metric. Fidell A>~davit (lab 2 to Apvx).11a. The argument made in Reply 7IX that "the north south runway does not, pa se, incrt:ase tra>3ic" because "tlx forecast of cargo (nod other aviation) activity is an tmcoast:ained forecau" is not only irrelevant; it is alto either internally inconsistent, or strong evidence of the dubiousness of the asserted need for coostsvetion of the proposed infrutructtae. The argument that a new runway would not attract additional nighttime cargo activity to MSP is based, oa the one hand, on as admission of «cessive etarent nighttime capacity, and on the other hand, on the putative «ppetton that new airport infiastrtrcpae mtetded to support increased levels of mgltthme) cazgo operations on a new nmway will tat acnnlly attract additional traffic. ff the t cargo facilities are etarendy mtder-utilized, and if the proposed nmway and cazgo facilities will not attract additional operations is the future, it is simply irrational to propose constructing yet larger facilities in the expectation of eves greats under-utilization in the fume. No matter what other argtmteats MAC and FAA may offer to support a proposal to eonsonrct anew rtmvvay sad infiasOtttcttae to support cargo operations, it is simply not credible to imply that such projects have been sized for intentional under-utilization. The claim is Reply AM that "[t]he DNL metric wss specifically designed to model human response to cumulative noise impacts" (PETS at 1-134) is both historically incorrect sad inadequate as applied w Richfield's comment The initial description of DNL (EPA. 1974) mattes no explicit mention of the design of DNL to model human response to cumulative noise impacts. DNL was in fact specifically designed as m evolutionary extension of the "egtdvaleat levee noise metric: that is, as a convenient measure of community wise exposure rather than as a predictor of "human response to ctnnuhuive mix impacts." It was not tmtil four years after EPA introduced the noise metric that the first analysis leading todosage-response relationships between DNL and the prevalence of noisaioduced annoyance was publi.shed (SchultA 1978). Another fourteen years passed 6efort: the current olfieiallY recogaizeddnsage-response relationship (FICON,1992) was adopted. FideU Affidavit,115. U4. See Response U1 end Gensrsl Responses 1 and Uil. In response to Fdell Affidavk /14, it is true that the Time Above (TA) metric does not penalize nighttime operations. The Response YVW intended to convey that the DNL metric wss selected as the primary metric for addressing noise impacts, since k is the accepted criterion and addresses nighttime impacts by weighting nighttime operations by a factor of 10 over daytime operations. The level of 85 dBA was selected to represent the Isvel at which single event levels become disruptive. The metrics and TA threshold proposed for noise analysis were ateted in the AED and EIS Scoping Decisions and accepted by the Dusl Track committees as the basis for the analysis in the EIS. Us. U8. Activity levels at nighttime are much less than during the day, and therefore current airfield capacity is adequate to accommodate present and future nighttime demand. Consequently, the new north•south runway will not attract additional nighttime cargo activity. U7. U7. Comment and Fdelt Affidavit r15 noted. _~ • The remainder of Reply AAA does not respond w the substantive basis of Richfield's comment The tacit claim that the "specially designed"DNL noise metric is adequate to model human respoate to er®nlative noise impacts in the specific ei:crmsstaaees of the erarrat FIIS is U8. at best a controversial sad policy riven one that lacks persuasive evidentiary support Fidell. Silvan and Peatsoas (1998) Gave demonstrated that certain cumulative changes in noise exposure is an airport neighborhood, as quantified in units of DNL, are neither noticed by residential populations not predicted by DNL values. Fidell Affidavit, ~ 16 dt attached article. VIIL COMMENTS ON ~PPEND[Cs'~ A. APPENDIX B• NOISE M1Ti AT10N PLeN 'Ibis appendix desrn'bes a "plan" 611ed with good intentions, recommendations, sad Qeoeralities, and fails to address virtually all of the concerru the City of Richfield has atdressed. The "plan"commits the airport to very lisle substantive action. B. The analyses desrn'bed in this Appendix H. "Forecast Sensitivity Analysis" of the FEIS comparo the noise coasequeaees of two tmderestimates of the eventual air traffic capacity of an additional independent runway at MSP. Such a limited wmparison does not constitute s meaningful seatitiviry analysis for purposes of projecting eventual aircraft noise exposure levels sssociated with construction of the proposed nmway, nor a full disclosure, nor eves a considered rsview of the aviation demand forecasts on which the entire FEIS relies. (See Gosling Affidavit) The tvodamental problem with aviadon forecasts that must be tally disclosed is not that they are sometimes wrong in detail, but that t6ry are nearly always wrong, and often grossly so. ~P~Y ~ al- (1996) demonstrate not ody that "Projections of figure dema~ are mtorious for the large margin of ettors that are commonly involved,"but also the risk and folly of relying solely on forecaaed demand as a basis for commitment of public raotaees. FAA's fiduciary responsibilities require a far more eompreheative sad forthright ammiaation of the ~mcataiaties of aviation demand is this volatile iadrttocy. Given that the actual air traffic levels have already exceeded forecasted h:vels at MSP. FM must prepare a revised Drag ELS based on a revised foreast, similar m what oecrated in Seaale whey cants in eerGer aviation forecasts became evident attar publiation of an EELS. U8. In response to the comment and Edell Affidavit x118, it is true that 'gradual, long-term reductions in cumulstivs noise exposure may not directly reduce annoyance with aircraft noise exposure' Ms not been scisrrtiticslly proven, but annoyance is based in great part on community attkudes. Community attitudes an in taro based on many factors, one of which is reduction of absolute aircraft noise. Another factor is how the community has been treated in response to aircraft noise exposure -the airport's sound insulation program, for example. Although ONL values are not a predictor of a community's response in tM future, DNL is tM fsderallyaccspted metric for dstemtining impact and mkigation. As reprsssntstives of tM affected Twin Cities community, the MSP Noise Mitigation Committee recommended a series of rwiss mitigation operating procedures for the airport, and, based on DNL values, recommended sound insulation to the ONL 60 contow. k is also noted that the population exposed to ONL 85+ is estimated to decrease from 33,750 in 1994 to 7,650 in 2005, and for DNL 80+, from 98,900 in 1994 to 29,680, with the proposed action. This is a dramatic change in noise exposure and, coupled with the committed sound insulation program, is expected to substamiatiy reduce annoyance in the Twin Cities community. U8. ~ Ue. Ths essence of the adopted program was developed and recommended to MAC by the MSP Noise Mitigation Committee, which consisted primarily of the mayors of the affected municipatftiss, including Richfield. Each city presented its concsms and the committee reacted accordingly, and, after holding a public meeting, submitted the recommended program to MAC. U10 U10. In response to the comment and the Gosling Affidavit, actual passenger and aircraft operation activity levels, through 1997, are tracking below the MAC High Forecast, which confirms that the forecast sensitivity analysis is realistic and valid for use in the FEIS. See General Response 3. U11~ U11. The uncertainty inherent in any forecast is the reason that the forecast sensitivity analysis was conducted. See Response U10. Ia any event. the n of year 200.5 and 2020 noise impacts by reference to DNL contour areas provides a superficial sad misleading comparison of the rehuiive noise impacts in those two years. Even mac fimdammally, the comparison of 2005 and 2020 impacts for the U1 Runway 17-35 Project provides no information conee:niag the rrlative noix impacts for the year 2020 under the Runway 17-35 project sad m action alternatives. The Sensitivity Analysis should address aII alternatives sad aoalyxe each of the noise metric addressed in the body of the FEIS. U12. A comparison of the year 2020 with and without Runway 17-35 would not result in a significantly different outcome than reached in the year 2005 analysis, as both forecast years are based on the same growth rates. That is not to say that the same noise levels would be achieved in the year 2020, but that the absolute differences between the No Action and MSP Action would be similar to those determined for the year 2005. -26- r Tix FEIS discloses that use of the MSP high fonxast yields m inaea9e in oo-airport carbon monoxide emissions of 886 tofu. (PETS at H-5.) This is nearly nine times above the level (100 tons pet year) that constitutes the threshold for making a conformity determination. (Scc FEIS at Y-s, A 1.8.) While the FEIS states that conversion of ground service egtripmeat to either natural gas fitd or electriciry would result in a decrease of 975 togs per year, the FEIS does not impox that mitigation meastne, nor does it analyse the eavirontneotal impacts associated with those alternative final supplies (e.g., the use of electricity entails air quality impacts associated with the generation of the electricity). Under these ciramutmees, there is ao basis in the FEIS w support the detamioation that the Runvray 17-35 project complies with the Clean Air Act IiX CONCLUSION " TLc FF7S for the Dual Track Airport Planning Process fails to comply with the letter sad spirit of the full disclosure requirements of NEPA and META. IC likewise faits to provide a sufficient basis for the approval of the Project Hader Section 4(~ of the Transportation Aet, the Clem Air Act, the National iiistotic Preservation Act, Executive Order 11990, the Minnesota F.avironmeatal Rights Act, and the obligations of MAC, pursuant to Mum. Stet § 473.ti55,'to assure the residents of the met:opotitm area of the minimum environmental impact from air navigation and transportation." U13. Ths forecast and impact is estimated for the year 2020. As stated several times in the FEIS, the 2020 Concept Plan will have to undergo additional environmsntsl review before K can be implemented. Ores purpose of the sensitivity analysis is to show that U13. any additional 2020 significant potential adverse impacts could bs mitigated to a level of insignificance. in the case of on•airport CO emissions, the conversion of ground service equipment is one example that is provided to show that a feasible measure is available that could provide the required mitigation. Ult. The FAA and the MAC maintain that the FEiS, along with the responses to comments on its adequacy U14. and the Section 4(f) Evaluation document, complies with NEPA and MEPA requirements and provides s sufficient basis for approval under Section 4(fl of the Transportation Act. The proponatts of the Project must revise the FEIS to correct its many failings and circulate a revised Draft EIS for public review. The revisions and recirculation of a DEIS are necessary to discharge the legal duties of the proponents of the Project, and to ensure that the U 15. Runway 17-35 project has sufficient capacity to axoaimodate the higher than previously ticipated growth in operations at MSP, that eavirotttneatal considerations are not ignored as a of the Minnesota Legislaiwe's selection of that project, and that the impacts of that project mitigated to the fullest extant possible. Dated: June 15,1998 _27_ Respeetfitlly suba»ttedr Cif Y OF RICHFIELD, MINNESOTA James D. Prosser Richfield City Manager 6700 Portlmd Avenue Richfidd, MN 55423 (612) 861-9700 Charles IC Dayton . Leonard, Street dt Deinard 150 South Fifth Street Suite 2300 Minneapolis, MN 55402 (612)335-1500 U16. Ses Response A, above, and General Response 8. The FEIS shows that the 2010 LTCP will provide enough capacity at MSP to accommodate the MAC's highest range of forecast operations at MSP (see Section it-C and Appendix H). The environmental impacts of akematives were not ignored because of the Minnesota legislature's selection of the MSP expansion altematrvs, and the FEiS and these responses contain detailed information to show how the impacts of the project will be mitigated to the fullest extent possible lsee also General Responses 2 and 7 regarding planned mitigation for low frequency noise and for the Minnesota Valley National wldlifs Refuge). C Stevea F. Pflaum Charies M. Gering McDermott, WiU & Emery 227 Wat Monroe Sweet Chicago, Ulimois 60606 (312)372-2000 sy Stevea F. P V IMlIN1LtllV000ROIOAR • -2g- General Comments and Responses The following are comments on the FEIS received from several persons or agencies and the responses. Genera/ Comment 7. The impacts of low frequency noise have not been adequately addressed in the FE/S. General Response 1. The FAA and MAC properly evaluated reasonably foreseeable noise impacts of the proposed new runway in the FEIS using the A-weighted noise metric. In the EPA's "Levels Document" that addressed noise and public health, the EPA chose the A- weighted description of noise because it best reflects the range of frequencies important to human hearing. FAA for similar reasons selected the A-weighted metric as the single system for measuring noise around airports in its noise compatibility regulations, 14 CFR Part 150. See 49 USC 47502(a). In the August 1993 report entitled "Federal Agency Review of Selected Airport Noise Issues", the Federal Interagency Committee on Noise concludes "There are no new descriptors or metrics of sufficient scientific standing to substitute for the present DNL cumulative noise exposure metric." Also, "The dose-effect relationship, as represented by the DNL and 'Percent Highly Annoyed' remains the best available approach for analyzing overall health and welfare impacts for the vast majority of transportation noise analysis situations." The Committee also recommended "Continue use of the DNL metric as the principle means for describing long-term noise exposure of civil and military aircraft operations." The issue of low frequency aircraft noise and its impact on structures and people was explored in detail as part of the environmental assessment of the introduction of Concorde supersonic transport operations into the United States. Potential impacts were found to be negligible. Field studies found that the noise induced vibrations as a result of Concorde operations cause no structural damage. In addition, the Concorde sound pressure levels at low frequencies were found to be well below the EPA threshold for potential health impact. As a result of these findings, the FAA concluded that low frequency noise of subsonic aircraft in a typical airport environment had no significant impact on structures or health. The effect of aircraft noise induced structural vibration upon human response is a recently raised concern. However, unlike the widely accepted relationship between aircraft noise exposure in DNL and community annoyance, there does not currently exist a scientific consensus or Federal guidelines on the human impact of noise induced structural vibration. For example, the FICON report referenced above is silent on the issue. In the absence of established guidelines, the FAA is not obligated to assess such impacts in its EIS, nor does NEPA require FAA to issue a revised or supplemental EIS to assess such impacts. Overall evidence recently evaluated by the FAA suggests low frequency noise may generally be of concern only in areas already within the 65 DNL contour due to higher frequency noise. Low frequency noise and perceptible vibration may be experienced when aircraft noise levels are high (near the start of takeoff roll) and there are many aircraft events. This same combination of factors also tends to lead to high DNL levels (generally within the 65 DNL contour or higher). Based upon study and evidence to date, it is possible but highly improbable that homes outside the DNL 65 contour may experience levels of low frequency Responses to FEIS Comments A.1-1 noise that could produce perceptible vibration. Thus, low frequency noise is not a separate impact phenomenon, but rather is conrtiectecl to high cumulative aircraft noise exposure levels. Rather, perceptible vibrations due to low frequency noise are a secondary effect under certain conditions (e.g., home location relative to takeoff roll and aircraft fleet composition) in homes that are exposed to high levels of aircraft noise as calculated with the DNL metric. As was found by FAA in a recent study conducted by the acoustical consulting firm of Harris Miller Miller & Hanson Inc. for the Baltimore-Washington International Airport (BWI), homes that were affected by low frequency noise were already participating in a Federally funded sound insulation program due to their exposure to high DNL levels of aircraft noise. In the BWI example, homes within one subdivision located in the DNL 70 contour that exhibited low frequency noise received extra insulation treatment. FAA approved the additional mitigation as being specific to this area (i.e., subdivision) and not to be considered as a blanket endorsement of this type of sound insulation for all areas. Each potential situation must be considered on a case-by-case basis. In 1997, the City of Richfield independently commissioned two studies regarding (1) the anticipated low frequency aircraft noise in Richfield due to the operation of a proposed north- south runway at MSP, and (2) a field study of the annoyance of low frequency runway sideline noise. While the former study was based on analysis at MSP, the latter study was based on a sample survey of residents in EI Segundo, California, exposed to sideline noise from the Los Angeles International Airport (LAX). Copies of both studies were eventually provided to the FAA in response to the FEIS. After reviewing the .Richfield studies, the FAA and MAC are not able to conclude that a low frequency noise and perceptible vibration problem will occur in portions of the City of Richfield as a result of the proposed action at MSP. Richfield's consultant did not perform vibration measurements within those areas of Richfield exposed to airport-related noise. As stated previously, those factors that contribute to low frequency noise and perceptible vibration also tend to lead to high DNL levels (DNL 65 and greater). In contrast to the BWI example mentioned above, noise levels in Richfield are lower than DNL 70, and, in many instances, are lower than DNL 65. It is doubtful that the findings in the Richfield field study about annoyance apply to low frequency noise at MSP. As previously noted, this field study was conducted in EI Segundo, California, near LAX. To apply these findings, it is necessary to assume that the residential structures in EI Segundo have similar responses to aircraft noise excitations as those homes in Richfield, Minnesota. As the climates of these two communities are drastically different, structural qualities, such as stiffness and tightness, should be substantially different. These structural qualities contribute to how the structure responds to external excitation. Other aspects of the field study are also questionable, particularly the appropriateness of the measurement period, the survey questionnaire, and the lack of technical justification for the transference of EI Segundo, California data to Richfield, Minnesota. In the judgment of FAA and MAC, there is significant doubt whether the EI Segundo findings and the BWI experience in any way reflect the situation in Richfield. Responses to FEIS Comments A.1-2 General Comment 2. The FE/S does not provide mitigation for significant adverse impacts due to to w frequenc y noise. General Response 2. See General Response 1, above. Low frequency noise is not per se a potentially significant adverse impact. The FAA and MAC are not able to conclude that the proposed action at MSP would cause a low frequency noise and perceptible vibration problem in portions of the City of Richfield. It should be noted that in October 1996, MAC adopted a comprehensive noise mitigation program (see Appendix B, Noise Mitigation Plan, of the FEIS) for the Minneapolis-St. Paul International Airport. Among the many measures, the program provides for a residential sound insulation program for all residential areas within the 1996 DNL 65 + contour (this portion of the program is scheduled for completion by the year 2002). The sound insulation program will be expanded to incorporate those additional residential areas that are located within the projected 2005 DNL 60-65 contour, taking into account the effects of the proposed new runway. MAC intends to fund this sound insulation program on an accelerated basis beyond its current annual funding level of 525.5 million. Although not legally required, MAC is willing to conduct noise studies and vibration measurements to identify:(1) the level of low frequency noise from aircraft operations, and (21 the level of aircraft noise induced vibrations; and if found, to evaluate alternatives to minimize low frequency noise and perceptible vibration. However, these studies must be done in a comprehensive manner, with the involvement of a// potentially affected communities, including the City of Richfield. MAC proposes and commits to immediately address the issue. Low frequency noise has already been identified for analysis and potential mitigation in the adopted MSP Noise Mitigation Plan (see Appendix B of the FEIS). With the technical guidance and assistance of the FAA and others, the subsequent studies will, among other things, undertake necessary vibration measurements in Richfield and other potential areas to assist in documenting the existence of perceptible vibration impacts due to existing or planned operations at MSP. Although there is no established state or federal standard of significance for low frequency noise and vibration, guidelines for judging human perception of vibration levels have been published in several different forums. MAC could take into consideration the information in the Acoustical Society of America "Guide to the Evaluation of Human Exposure to Vibration in Buildings" (ANSI S3.29-1983) as well as research undertaken and published by Harvey Hubbard (Noise Induced House Vibrations and Human Perception, Noise Control Engineering Journal, Sep-Oct 1982). ANSI S3.29-1983 provides recommendations on the magnitude of vibration, in the frequency range 1-80Hz, that are perceptible and regarded as tolerable by occupants. It includes multiplying factors for building type, time of day, and source characteristics. It further recommends the root-mean-square (rms) acceleration as the quantity for measuring continuous vibration as it impacts humans. Hubbard examined the role of house vibrations in reactions to environmental noise and review of some human perception criteria and suggested criteria in sound pressure level for whole body perception of vibration in floors, walls, and windows. If supported by the studies, MAC will prepare and implement a low frequency noise mitigation program for those affected communities as part of an update to the MSP FAR Part 150 Plan. Responses to FEIS Comments A.1-3 The end result of such a mitigation program would be to offset any impacts of low frequency noise that would not be mitigated by conventional sound insulation treatment provided for under the existing MSP Noise Mitigation Plan. Genera/ Comment 3. The forecasts used in the FE/S are too low in relation to recent activity levels and the FAA's Terminal Area Forecasts and therefore the disclosed impacts are understated and the committed mitigation measures are inadequate. General Response 3. As noted in the FEIS, when the forecasts were developed in 1992 and 1993 they included input from a public scoping session, four expert panels, the State Legislative Auditor and the principal carriers at the airport, to make them as accurate as possible. It was understood at the time that uncertainty is inherent in any forecast, especially one encompassing atwenty-eight year horizon. To address this uncertainty, several forecast scenarios were developed, including the MAC High Forecast scenario which was used in the forecast sensitivity analysis in the FEIS. The FAA Terminal Area Forecasts (TAF) for MSP prepared in 1997 were used in the FEIS to review the MAC forecasts to ensure that they are realistic and provide an adequate justification for airport planning and development. The review concluded that the 1997 TAF is much higher than the MAC base forecast used in the FEIS, but is generally in line with the MAC High Forecasts. FAA believes the MAC High Forecasts to be reasonable forecasts based on its professional judgement and because the differences with the TAF are within the accuracy of forecasting. Since 1992, actual activity at MSP has exceeded that in the MAC base case forecast used in the FEIS, although it is still less than the MAC high forecast. Actual activity has exceeded the base case forecast because of a stronger than projected economy and because of several one- time events. These one-time events include the consolidation of Northwest's hub and spoke system, the development of sophisticated yield management systems, the liberalization of Canadian markets, and the lapse in the ticket tax. All these one-time events have served to stimulate the growth rate at MSP during the 1992-1997 period above long-term levels. Despite these one-time events, 1997 actual passenger enplanements and aircraft operations at MSP were tracking below the MAC High Forecast based on it's growth rates, as shown in the following comparison. er Enplanements Total Operations 1997 Actual 491,273 1997 MAC High Forecast 14,451,000 .................................................................... 500, 803 Although one-time events of various types will inevitably continue into the future, it is not anticipated that they will all continue to increase traffic at MSP. One-time events that could reduce traffic include: • Labor difficulties at Northwest. If there is disagreement on union contracts which results in awork-stoppage, Northwest would lose traffic during the period of the stoppage as it did in the September 1998 pilot union strike. A lengthy work stoppage could result in Northwest permanently losing some of its connecting market share to other carriers. ~ Increased maintenance costs. Northwest has one of the oldest fleets in the industry and the average age of their DC-9 fleet is almost thirty years. The DC-9 • Responses to FEIS Comments A.1-4 • _~ RMuchw~a,,+ g Press Release -CITY MANAGER'S OFFICE For more information, call: James D. Prosser 6700 Portland Avenue Richfield, MN 55423 Voice: (612)861-9705 FAX: (612)861-9749 For Release: October 2, 1998 Date: October 2, 1998 FAA'S RECORD OF DECISION ON MSP EXPANSION RICHFIELD, MN -- Richfield homes as close as two blocks from a new North-South Runway at the Minneapolis-St. Paul International Airport will not receive any noise mitigation for the low frequency ground noise of hundreds of daily takeoffs and landings, under the Environmental Impact Statement (EIS) just approved by the FAA. "The failure to address our concerns is like a slap in the face to our residents and our community," Richfield Mayor Martin Kirsch said on Thursday. "We have more than 1700 homes and 4000 residents that will be living. virtually on a runway, and the MAC and FAA are telling us that they won't be impacted. It's ridiculous." The FAA and MAC have a legal responsibility under national and state law to mitigate adverse environmental impacts as a consequence of airport expansion. "The law on this issue is quite clear. The courts have held that any significant environmental impact that would result from construction of a project must be identified in a mitigation plan included within the environmental document," said Chuck Dayton, Richfield environmental counsel. The FAA states in the Record of Decision document issued Wednesday approving the North- South Runway EIS that, "In the case of low frequency noise, no adverse impacts have been determined." "We have been asking MAC to deal with this issue for four years," Kirsch said. "They refused to study it, so we paid for an independent noise study. They ignored the study and refused to prepare a noise mitigation plan, so we paid to prepare a mitigation plan and submitted it to the MAC for the EIS. Since that time, we have been virtually stonewalled by the FAA and . MAC." In fact, the FAA recently approved funding for low frequency noise mitigation at the Baltimore-Washington Airport. MAC had said the FAA precluded a discussion of low frequency noise in the EIS because it was not a recognized environmental impact. At Baltimore-Washington Airport, noise insulation will be provided for homes farther away from the end of a runway than homes would be in Richfield with the location of the North- South Runway. Both the MAC and local FAA officials have denied any knowledge of low frequency noise mitigation at Baltimore-Washington Airport or the study that established the low frequency noise standard. "Their credibility is shot," said Kirsch, "The consulting firm that did the study resulting in FAA funding for noise mitigation at Baltimore-Washington Airport is MAC's own noise consultant Harris, Miller, Miller and Hansen. It appears we cannot trust MAC to provide us with any accurate information." "The FAA's approval means that they have given MAC the green light to build this runway. Our intent has never been to stop this runway. But the devastating impacts of low frequency ground noise must be addressed before one bulldozer moves onto airport property to break ground." Richfield's noise study found that: • At least 4,000 residents or 11 percent of the City's population, two schools, two churches and more than 100 businesses will be substantially impacted. • At least 1,760 residential units and 35 businesses will have to be removed to allow noise mitigation redevelopment to take place. The- Richfield School District could. lose up to 486 students due to noise impacts. • Substantially elevated low frequency noise levels will be experienced up to a mile from the runway that would affect 9,000 residents. • An acoustic barrier, such as a noise wall or berm, of sufficient size to provide effective low frequency noise reduction for eastern Richfield is not realistic, and current insulation and sound proofing programs will not relieve these impacts. • Low frequency noise exposure, which will be imposed on the eastern one-third of Richfield, have been the basis for noise complaints and remediation activities in communities near other airports. "We have been meeting in good faith with MAC and the Metropolitan Council," Kirsch said. "All Richfield wants is an assurance that our residents and community will receive the environmental protection that the law requires. The MAC's and FAA's intentions are now very clear -- expansion of the airport at whatever cost to communities. They have backed us into a corner, and we will need to consider all of our options." al'fiAG4~Vr1P.vW- G '~~ CITY OF RICHFIELD • Memorandum DATE: September 22, 1998 TO: MASAC Members FROM: ~Kristal Stokes, Richfield City Council Member and MASAC Member SUBJECT: Richfield's Review of MAC's "1998 Ground Noise Monitoring Technical Study" On March 10 and April 9, 1998 the City of Richfield sent Mr. Jeff Hamiel letters expressing concern about the high number of complaint calls the City had been receiving regarding ground level noise. In April alone, the City fielded 98 phone calls strictly dealing with noise from run-ups, maintenance activities, testing of engines, and idling of aircraft for hours at a time. MAC staff, particularly Ray Fuhrmann, was helpful in providing suggestions as to what might be the cause of the increased level of noise annoyance. However, no consensus was reached regarding the likely source of the increased noise levels. The City of Richfield requested additional information for two reasons. First, to identify the source of the noise in order to determine if there was any actions that could be undertaken to reduce annoyance level. Second, to use the information gathered from current ground level noise issues to help address potential issues related to the proposal for construction of Runway 17/35. We were particularly pleased with Mr. Hamiel's request that MASAC address this issue. Despite the good intentions of MAC, the information contained in the final report was clearly not targeted to respond to these issues. Specifically the design of the study, the nature of the noise measurements made, the site selected for monitoring, the analysis performed, the topics discussed, and the manner of presentation of information in the report of ground noise had little information for an informed discussion of issues of interest to the City of Richfield. While we realize that many other cities have little or no interest in ground level noise, the fact of the matter is, we are all neighbors of the airport and share in its impacts in different ways and to different extents. It is useful then that we all support gathering useful and clear report regarding airport impacts and possible solutions. Since the report provided to MASAC fails to analyze the problem properly, the proposed solutions are not meaningful. September 22, 1998 Page 2 We've attached for your review a review of the report by noise consultant. We ask for MASAC to support the following actions: • The report should be referred back to MAC for revisions in the areas noted in the BBN response, including measurement methods and metrics, relationship of measurements to future noise exposure, inappropriate frequency weighting procedures, and level of analysis and reporting. A draft copy of the revised report should be provided back to MASAC members for review and discussion of potential recommendations regarding solutions to the noise problems identified within the revised report. • MASAC should convene a discussion of the proposed recommendations to address the ground level noise issues for consideration by MAC. If MASAC is to continue to be an effective avenue for discussing and resolving concerns regarding sound abatement procedures, then it is essential that the information provided to us be responsive to our needs and that MASAC members have the opportunity to work together to address possible solutions to noise impacts on our community. We appreciate MASAC's consideration of these requests. KS:cak Attachment REVIEW OF MAC'S "1998 GROUND NOISE MONITORING TECHNICAL STUDY" DR. SANFORD FIDELL BBN TECHNOLOGIES 21128 VANOWEN STREET CANOGA PARK, CA 91303-2821 (818) 226-0323 REVIEW OF MAC'S "1998 GROUND NOISE MONITORING TECHNICAL STUDY" These comments review an undated report submitted by Mr. Roy Fuhrmann, manager of MAC's Aviation Noise and Satellite Programs, to the Metropolitan Airports Commission and the Metropolitan Aircraft Sound Abatement Council. Authorship of the report is unattributed, although it appears to be based at least in part on measurements and analyses that may have been performed by a noise consultant to MAC (cf. references on page 20 to information provided by the firm of IIlVIMI~. The report is referred to henceforth as the "ground noise study." 1 ORGANIZATION OF REPORT OF GROUND NOISE STUDY The ground noise study contains four numbered text sections, five appendices, glossaries of terms and acronyms, and references. 1.1 SECTION 1: OVERVIEW The Overview section of the report identifies requests from Richfield as the impetus for the conduct of the ground noise study; cites a "critical" need to understand aircraft noise impacts for planning "valid courses of mitigative action"; and characterizes a cursory approach to measurement as a "disservice" to people living in noise-impacted environments. The section also contains brief descriptions of noise measurement conditions and instrumentation, and a map showing the location of short-term monitoring sites. It lacks any summary tables or graphics, or discussion of findings. 1.2 SECTION 2: DATA ANALYSIS AND RESULTS This section contains various tables and maps (but no other charts or technical graphics). Descriptions of technical aspects of the study aze sometimes cursory or gazbled.' 1.2.1 Section 2.4: Monitored Airport Noise Events at Airport Sites Two tables summarizing measurements of various aircraft ground noise sources at two on- airport sites form the substance of Section 2.4. The findings suggest, among other things, that maximum A-weighted sound levels produced by taxiing operations and monitored at some locations may not differ greatly from sound levels produced by ground run-ups. The section also includes the following three-sentence rationale for measurement and reporting of A- and C-weighted aircraft noise levels: "*Note: The use of A-weighting is the accepted standard for aircraft noise measurements, since the human eaz's frequency response capability is most sensitive in approximately the 1,000 Hz to 5,000 Hz frequency ~ e.g., Section 2.1, page 9, "The averaging was accomplished by using an arithmetic method of the sound level decibel value in decibels:' range. This study focuses on the A-weighted monitored noise levels since the Federal Aviation Administration has developed guidelines for mitigation throughout these frequencies and best approximates the human ear's frequency range. The C-weighted values are included for comparison purposes only and will be used to provide insight into the impact of noise events within the frequency ranges tailored to the C-weighted metric." This rationale is worth a closer examination because of the tacit assumptions that it embodies. The first sentence of the rationale is an oversimplified statement about human hearing acuity. Hearing acuity depends not only on frequency, but also on absolute sound pressure level. The A-, B-and C-weighting networks were developed initially to permit appropriate characterization of the loudness of sounds in increasing ranges of sound pressure levels. More to the point, however, is that hearing acuity is not the sole issue that should affect selection of a frequency weighting network for current purposes. In the present context, the audibility, noisiness and annoyance of sounds, as well as the need to consider structural responses of residences to low-frequency aircraft noise, also require consideration. The seeming (but unstated) basis for primary reliance on A-weighted measurements is a belief that A-weighted measurements optimally predict the annoyance of aircraft noise events. If prediction of the annoyance of sounds with considerable low frequency content were truly the controlling purpose of the ground noise study, however, greater caze would have been taken to measure noise in a manner that could have permitted calculation of additional noise metrics more closely linked than A-levels to audibility and annoyance.2 Furthermore, because A-weighted measurements aze highly insensitive to sound at frequencies that can lead to rattling noises inside homes, it can be argued with equal force that A-weighted measurements are highly inappropriate for purposes of predicting residential annoyance with low-frequency aircraft noise 3 The first part of the second sentence of the rationale implies the primacy of FAA guidelines for aircraft noise mitigation for study design purposes, while the second part of the sentence restates the oversimplified rationale of the prior sentence. The fact that FAA has made known its policy- driven preferences for providing access to federal funding for airport noise mitigation does not compel MAC to make only A-weighted noise measurements. FAA regulations explicitly subordinate the agency's policy preferences, expressed as generic "land use compatibility" guidelines, to those 2 One way that this could have been accomplished would have been to design the study to focus data collection on broadband recordings of noise events, rather than on routine, relatively inexpensive automated measurements of time series of noise levels. ' Since aircraft overflight noise generally reaches residential neighborhoods via air-to-ground paths, atmospheric absorption is usually responsible for most frequency-specific propagation losses. Runway sideline noise often reaches residences in the vicinity of airports via paths that further attenuate high-frequency noise through ground impedance effects, thus increasing the relative low-fmyuency content ofnoise produced by aircraft ground operations. Outdoor A-weighted noise measurements may not adequately characterize high levels of low-frequency noise that may induce potentially annoying secondary emissions inside residences neaz runways. Aircraft ground operation noise is characteristically described in complaints as a dull, rumbling sound with a slow onset time. Aircraft ground noise may be distinctively audible at considerable distances from airports, particularly at night, when less masked by other urban noise sources. 2 of local zoning authorities. MAC is not required in any event to pay for its noise-related liabilities with federal funds only.4 In short, the rationale of Section 2.4 supports only abusiness-as-usual approach to the study oflow-frequency noise impact issues. 1.2.2 Sections 2.8: Run-Up Noise Contours for Selected Aircraft This section describes computer simulations of engine run-up noise contours in far greater detail than is accorded to other matters more relevant to Richfield's concerns. The A-weighted contours displayed in Figures 2 through 8 (of the ground noise study) aze not directly relevant to prediction of the rattling noises that engine run-ups may produce inside residences in eastern :Richfield. 1.3 SECTION 3: AIRLINE MAINTENANCE SURVEY This short section describes and interprets the findings of appazently informal interviews with three airlines. The text of the section describes the motivation for ground run-ups, the inability of .airlines to control or schedule them, the necessity to point aircraft into the. wind when conducting run-ups, and the airlines' preferences for measures (e.g., improved run-up pad lighting) that could encourage the conduct of even more ground run-ups. 1.4 SECTION 4: CONCLUSIONS AND RECOMMENDATIONS 1.4.1 Conclusions The report draws ten conclusions from the measurements of the ground noise study. Most of them aze only tangentially relevant to Richfield's concerns about noise impacts from operations on Proposed Runway 17/35. None of them is particulazly pertinent to assessment of potential low-frequency noise effects. - - 1.4.1.1 Conclusion 1 The first conclusion indicates that aircraft takeoffs aze currently the "predominant" noise source at measurement positions on airport property and in eastern Richfield. It cannot be determined from this observation whether departure noise will continue to dominate the noise exposure of eastern Richfield if and when operations on proposed Runway 17 create low-frequency sideline noise. It is also not cleaz from this observation how faz west of Proposed Runway 17 such noise will be audible, aimoying, or capable of exciting secondary emissions in residences. 1.4.1.2 Conclusion 2 The second conclusion identifies noise from aircraft taxiing as responsible for neazly a quarter of the discrete noise events measured during the study. The report provides little basis for a Although airport authorities sometimes azgue that federal regulation prohibits diversion of airport revenues for unrelated purposes, noise mitigation is a fully recognized and approved use of locally-generated airport funds. 3 applying this information to noise from future taxiways. Subsequent conclusions confirm that other aircraft noise sources (auxiliary power units and thrust reversal) make further contributions to aircraft ground noise in Richfield. The report does not indicate how many such noise events and what noise levels may be produced by future operations of an airport with a modified runway layout and operating patterns. 1.4.1.3 Conclusions 3 and 4 These conclusions indicate that auxiliary power units contribute little to the total aircraft- relatedground noise produced at MSP, and that thrust reverser noise is readily noticeable in episodes of 10 -15 seconds in duration, at least a mile away from its point of application. 1.4.1.4 Conclusion S This lengthy conclusion indicates that noise produced by aircraft during takeoff roll and in neaz-ground flight shortly after takeoffcan be confused with ground run-up noise, especially during busy periods at the airport, when lazge numbers of arrival and departure operations occur on various runways. The conclusion also notes that such aircraft noise is readily audible in Richfield, particulazly at night, regazdless of runway usage. 1.4.1.5 Conclusion 6 This conclusion notes that nearly 200 discrete run-up noise events occurred during the relatively brief (per Section 1.3.3) period of the ground noise study. This suggests that thousands of such run-up noise events may occur over the course of a yeaz, although "run-ups are not being conducted for long durations of one or more hours at a time," and typically last about ten to fifteen minutes each -although 16% may occur between 5:00 AM and 7:00 AM. 1.4.1.6 Conclusion 7 Conclusion 7 concerns calculated values oftime-averaged, A-weighted sound levels for the few days during which noise measurements were made.s Long-term, average A-weighted sound levels have little to do with annoyance due to rattle or vibration produced by discrete aircraft noise events. 1.4.1.7 Conclusion 8 Conclusion 8 appears intended to reinforce the rationale of Section 2.4 (see above). In essence, the conclusion azgues that A-weighted measurements should be preferred to C-weighted measurements of aircraft ground noise because A-weighted measurements exhibit less variability. The logic of this assertion is weak, because a frequency weighting network itself is not the sole potential source of variability in measurements. 5 Airport administrations often dismiss such calculations (when made by others) as uninformative or uninterpretable because they may be unrepresentative of annual conditions. 4 ,, The relative variability in A-weighted and C-weighted aircraft noise measurements could equally well be due to variability in the low-frequency content of the noise sources themselves, or even to various artifacts of measurement 6 If a weighting network that is insensitive to low-frequency energy is elected to measure noise sources that differ considerably inlow-frequency content, it is not surprising that measurements so made are less variable than measurements made with a frequency weighting network that can differentiate between noise sources of differing low-frequency content. Thus, if aircraft engines of different types and power produce different amounts of low-frequency acoustic energy, and if measurements aze desired to quantify the consequences of such differences, C-weighted measurements would be preferred to A-weighted measurements on these grounds alone -even though the resulting measurements would show a greater range of variability than A-weighted measurements. 1.4.1.8 Conclusion 9 This conclusion confirms expectations that noise levels produced by airport sources decrease in a reasonable manner at increased distances from the airport. 1.4.1.9 Conclusion 10 Conclusion 10 notes the confusability of ground noise sources with noise produced by neaz- ground aircraft in flight while retreating from observers at fixed points. 1.4.2 Recommendations The ground noise report contains two recommendations. The first of these is to modify an existing field rule concerning engine maintenance run-ups. The second recommendation states, in essence, that no other form of source control of aircraft ground noise is feasible at MSP. 1.5 APPENDIX A: UNDERSTANDING ACOUSTICS This appendix asserts that its readers "must grasp" the pastiche of technical information that it contains to understand the conclusions of the report. Much of the mathematical detail is gratuitous and may unnecessarily intimidate non-technical readers. Little of the information presented in the appendix is truly needed to understand most of the report's conclusions, while more relevant matters escape mention. 1.6 APPENDIX B: L-VALUE DATA The tables and figures of this Appendix contain 32 tables and 18 charts summarizing raw data. Apart from the captions of the charts (none is provided for the tables), this mass of information is unaccompanied by explanatory or interpretive text. The information is azguably useful for " The effects of wind gusts and other artifacts on low-level and low-frequency acoustic measurements are widely understood and readily avoidable or remediable if sufficient care.is taken in instrumentation, data collection procedures, and post-processing. Elaborate measures with which MSP's noise consultants are familiar have been taken in other field measurement programs to control such artifacts of measurement. 5 '~ documenting a subset of the information collected during the ground noise study, although the time M history charts lack C-weighted information. 1.7 APPENDICES C and D Appendix C contains 53 pages of weather reports and runway use logs. Appendix D presents another 32 pages of operational information. The two appendices of information that MAC routinely collects for purposes other than the ground noise study occupy more than twice as many pages in the ground noise report as the four substantive sections. 1.8 APPENDIX E: MONITORING EQUIPMENT This short appendix documents the settings of one automated noise monitoring instrument at one site on one day of the measurement program. 1.9 GLOSSARY The Glossary contains an assortment of informal definitions of terms, some of which do not appear to be mentioned in the text of the report. The definitions do not generally conform to standazdized terminology, as embodied, for example, in American National Standard SI.1-1994 Acoustical Terminology. 2 SUMMARY The em hasis of MAC's ound noise stud is mis laced with re ' p gr y p gazd to Richfield s concerns for assessment of the needs for mitigation oflow-frequency runway sideline noise. The following aze among the inadequacies of an aircraft ground noise study. intended to address Richfield's concerns for evaluating needs for mitigation oflow-frequency runway sideline noise. 2.1 MEASUREMENT METHODS AND METRICS The bulk of the measurements collected in MAC's studies aze derived from routine measurements made at twelve automated and unattended noise monitoring sites (eight million records, according to the report of the ground noise study). Measurements of this type have no direct bearing on analyses of the low-frequency spectral content of pazticulaz interest for present purposes. 2.2 RELATIONSHIP OF MEASUREMENTS TO FUTURE NOISE EXPOSURE The report of the ground noise study makes no effort to extrapolate from current to future conditions, or to otherwise predict anticipatable future noise impacts. Figure 1 shows the points atwhichthe C-weighted and A-weighted aircraft noise events were monitored in MAC's 1998 ground noise study. Figure 2 transposes these measurement points from their positions with respect to Runway 22 (the source of much of the acoustic energy measured) to 6 ~ their positions with respect to Proposed Runway 17 at MSP. This transposition permits estimation of C-weighted sound levels likely to be produced by operations on Runway 17 by the same fleet currently operating at MSP. Note that in relation to departures on Proposed Runway 17, the measurement sites yield little information about potential runway sideline noise in Richfield. ® w~c iwe c~oo~e nen. we~~o,no s~.. NNw, a~.w.r N W E S Figure 1 Points at which C- and A-weighted aircraft noise events were monitored in MAC's 1998 ground noise study. 2.3 INAPPROPRIATE FREQUENCY WEIGHTING PROCEDURES Although some C-weighted time series measurements were made during the ground noise study, they receive short shrift in the report of the study. For example, the contention in Conclusion 8 (page 38) of the report that "...the A-weighted metric is better suited for use with the frequency ranges associated with aircraft generated noise" is misleadingly limited. Useful efforts to assess noise impacts associated with low-frequency runway sideline noise are even better served by measurements of noise levels in discrete one-third octave band levels at frequencies below 100 Hz. 2.4 LEVEL OF ANALYSIS AND REPORTING The report contains for the most part summary and highly processed information, presented in a manner that permits only scant opportunity for independent analyses and verification of findings. The report presents no detailed spectral information that could be used to predict audibility ranges oflow-frequency aircraft noise from present or future airport operations. Likewise, the report does not contain information useful for predicting the number, noticeability, and annoyance of low-frequency noise intrusions inside present or future residences, nor the likelihood of sensible vibration or secondary emissions (rattling sounds) in Richfield residences. 7 1 0 1 2 Miba • TrensDOSW MonROr LOCeOOns NNew Runway N W E S Figure 2 Transposition of measurement points from their positions with respectto Runway 22 to their positions with respect to Proposed Runway 17 at MSP. 1 0 1 2 Miles Richfield Complaint/Question Log: September • Date Name and Address Concern 1 1-Sep Resident @ 6320 Girad Does he qualify for part 150? 2 -Sep E resident Richfield Why is 4-22 being used? Endless Noise, the City has no muscle -she's going to have to move -all her neighbors are you know. This is all Carlson's fault he is in NWA back pocket. 3 1-Sep Richfield Resident Complained about the heavy use of 4-22 4 3-Sep 7439 11 Ave. Does this house receive a lot of noise? 5 3-Sep 6909 17th Question about the Sun Current article -what is the redevelopment timeline. 6 8-Sep 7400 block 16th Ave Wondering whether to stay or go. 7 8-Sep Resident @ 18th & 72 Client wants to buy a home. Agent is looking for information. 8 10-Sep Resident @ 17 & 73rd Question about flight patterns 9 11-Sep Richfield Resident Question about noise levels? 10 11-Sep Resident @ 7145 -17th Why are the planes still using 4-22? 11 14-Sep Richfield Resident Question about STRIB Article- wondering if the article was talking about the n/s runway. 12 14-Sep Resident @ 6309 4th Ave South Noise starting up again -are they under part 150. 13 15-Sep Edina Resident Thinking about buying a home at 74th & Xerxes -wondering how the n/s runway will effect? 14 18-Sep Richfield Resident @ 6938 - 17th Ave New resident wants to discuss the airport. 15 18-Sep Richfield Resident @ 6709 & 17th General airport questions. 16 24-Sep 7415 Bloomington When will he be sound insulated? 17 29-Sep 6509 - 2nd Ave south Question about soundproofing? Page 1.