FAA issues Draft Environmental Assessment for CLE-DTW Metroplex First Major NEPA Review since the Court Decision on PHX
The Federal Aviation Administration (FAA) has prepared a Draft Environmental Assessment (EA) for the Cleveland-Detroit Metroplex project that will be available for public comment beginning on Friday, November 10, 2017. The comment period will end on Monday, December 11, 2017. [Note by the title, the FAA is putting this review into the EA rather than the more intense, exacting Environmental Impact Statement process.]
In what has to be one of the largest ATC redesign for the NextGen operational, safety and environmental purposes, the geographical coverage is immense– 40 Ohio counties, 17 Michigan counties, three Pennsylvania counties and two counties in West Virginia. The 12 airports in the study area include, Cleveland Hopkins, Detroit Coleman Young, Akron-Canton Regional Airport, Cleveland Burke Lakefront Airport, Cuyahoga County Airport, Detroit Metropolitan Wayne County Airport, Oakland County International Airport, Toledo Express Airport, Wayne County Airport, Willow Run Airport, and Windsor Airport.
The FAA’s NEPA analysis will be limited to the potential environmental impacts from proposed aircraft routing changes that would occur below 10,000 feet.
The FAA’s release includes the following declaration:
The project’s proposed action would improve the efficiency of air traffic in and around the Cleveland and Detroit metropolitan areas. The project uses satellite-based technology to create changes to aircraft flight routes and altitudes in certain areas. Many of the routes overlay existing flight paths. It does not increase the number of aircraft taking off and landing, and it does not result in ground disturbance. Instead, the project develops more climbs and descents on departure and arrival routes, which can result in fewer delays. It enhances safety, and modernizes air traffic procedures to today’s standards.
Also significantly, this is the first major NEPA review initiated after the DC Circuit Court’s very negative opinion on a similar redesign in the Phoenix Metroplex and a multitude of complaints from the communities and Congress on the FAA’s process.
So, what’s new?
First, the Draft Environmental Assessment is 152 pages long and the introduction is a heavy dose well-written of ATC 101 material, thus giving the public with the basic terminology and design principles behind the architecture of the CLE-DTW Metroplex.
Second, the EA process, established by FAA Order 1050.1F, includes a heavy dose of six open-house workshops, which will be held in late November and early December. Three of the workshops will be held in the Detroit metropolitan area, and three will be held in the Cleveland area. The goal is both to educate the public about the proposed changes and to receive feedback.
Third and apparently most significantly, before it has issued a draft EA, the FAA has already had contact with the public as evidenced by these quotes from Section 3 of the draft EA:
Following completion of the designs, the D&I Team engaged the public (i.e., local residents, the general public, and stakeholders) by holding a series of informational meetings on the CLE-DTW Metroplex Project. Feedback received during the community involvement process was considered and incorporated in the proposed designs, as appropriate.
Community Involvement in Design Process
For the first time as part of a metroplex design process, the D&I Team engaged in community involvement. This included a number of meetings, briefings, and/or public workshops in the Study Area. Depending on the type of community outreach meeting, the D&I Team invited stakeholders, such as the Study Airport sponsors; local, state, and federal elected officials; user groups including pilots and air carriers; and/or the public to attend. The goal was to educate and involve the participants including the communities about this Metroplex project. During the different events, the D&I Team discussed the FAA’s NextGen program on a national level. Specific information was provided about this Metroplex project including graphics containing current and notational future flight tracks. The D&I Team invited comments from attendees about the preliminary designs. The D&I team then considered the comments in the development of the procedures. Individual responses were not developed for comments raised during the community involvement process. FAA requested that new comments be submitted during the Draft EA public comment period.
These words were included to address some of the deficiencies found by the Court of Appeals. It is not, however, abundantly clear whether these early comments were incorporated or not—compare “considered and incorporated” versus “…individual responses were not developed…”
In any event attending the November 28, 29 or 30 workshops would be well advised PLUS it is obvious that thoughtful, constructive comments should be submitted by no later than December 11, 2017. It might be wise to submit a formal request the comment period be extended at least 30 or as much as 60 days after the workshops (the holidays and the massive information to be reviewed).
A few recommendations on submissions:
- Comments from well-respected, existing organizations are more likely to be read first. The FAA staff/consultants who must read each and every paper submitted tend to read the ones which they recognize first. They recognize NIMBY type epistle and tend to delay their review.
- While it may be pleasing to vent your frustrations and/or satisfying to have some articulate advocate vent about the FAA, the airlines, etc., after the first three lines of vituperation the person, who is reviewing, tends to lose her/his attention. Find a way to pose your proposal as a realistic win/win, not a confrontation.
- It is important to remember that the FAA regards implementation of NextGen as critical to success in its safety and efficiency mission. The best response to the EA is to offer some win/win alternatives. No, you cannot just take out your ruler and draw an alternative line. Your preferred option must, at a minimum, meet the FAA’s objectives of safety and efficiency. Design of headings, altitudes, slope and procedures is not just linear algebra; it involves an arcane set of multiple and interdependent variables. Find someone who knows ATC (above the 101 level).
- Another critical consideration is NOT TO ASSUME that the FAA team knows all that you know. It may seem obvious to you that playground A, which is marked on the map, but planned to be closed soon should be under the final flight pattern, not playground B which is heavily used. Your local knowledge is superior; be specific and explain those nuances to the FAA.
- The good thing about RNP (see ATC 101) is that it is precise; the navigation tracks generated by this new system reduces dramatically the variation compared to the old radar guided patterns. The below graphs show clearly the diversity of the old flight paths. The RNP’s precision tends to concentrate the impact at points and along narrower corridors, arguably this “bad”/concentrated contour leads to greater negative reactions. One might appeal to the FAA that this new phenomenon merits a new metric of incompatibility.
The FAA Administrator and senior officials have promised that future NextGen implementations will be more responsive to the affected communities. At the same time, they are on the record that the billions of taxpayers’ dollars spent on the technology will be paid back with the benefits of a more efficient, safer and greener ATC operations. The CLE-DTW Metroplex story will demonstrate whether these two competing goals can be balanced.
The urgency of NextGen requires that this EA be completed soon. The comment which offers the Team a well-designed alternative is much more likely to see their preferred track adopted.
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