The Airport Commission authorized Gale Associates to generate an Environmental Assessment for $347,000, but no plan was disclosed on which to base this. The Final Assessment has been completed with the FAA in collaboration with Gale Associates after comments from the public. The FAA individual responsible for oversight of the National Environmental Policy Act (NEPA) is Mr Doucette. Comments on the Final Environmental Assessment should be sent directly to him at richard.doucette@faa.gov.
The following are comments on the Final Environmental Assessment.
The Draft Environmental Assessment (EA) was confusing, but also contradicted material in the AMPU, the Airport Layout Plan and the Five Year Plan. This Final Environmental Assessment (FEA) is also misleading.
The first project listed in the FEA is “Acquisition of Avigation Easements over 21 parcels”. This FEA makes the statement that “There are no environmental impacts associated with the acquisition of avigation easements”, which is literally true of the costly legal process, but, if implemented, the actual easements have enormous environmental, social and socio-economic impacts, which are not presented or discussed.
This FEA also wants to “obtain eligibility for future vegetation clearing efforts” in a “long term management plan” without identifying the details or properties, which is quite simply a slippery path for the future. This FEA tries to hide the fact that the goal of the proposal is to eliminate the existing Type 2 Visual Only Runway and create a brand new Type 4 Runway defined by the FAA “to accommodate instrument approaches having visibility greater than or equal to ¾ statute mile.” This implies landing in visibility much less than visual flight conditions. However to do this a Type 6 Runway “expected to accommodate instrument approaches with vertical guidance” is shown as being required in the cited reference. The Appendix shows that the existing Type 2 utility runway excludes jet turbine planes (jets), but whether this would this still be true for a Type 4 runway is not stated. Jets would be a noisier and more hazardous increase in traffic.
This FEA then states, without evidence, that “FAA Flight Procedures can design a non-precision approach with vertical guidance”, which “Reduces …. diversions (to Hyannis) when weather conditions result in low ceilings”. The cited FAA Advisory points out that, the use of vertical guidance requires a 200ft longer runway, a 30:1 approach surface and for visibility ≥3/4mile, a 6 times larger Runway Protection Zones (RPZ).
RPZs are required by the FAA to protect “people and property” from enhanced risk at the ends of the runway. Consequently the FAA strongly advocates for them to be completely empty of people, buildings and roads etc. The existing RPZs already include many homes, businesses and route 28. These larger RPZs would include most of Central West Chatham and many more residents at both ends of the runway. This is unconscionable in the extreme but is not discussed.
Even if the FAA were to modify the standards / grant variances, the risks would not go away. The important human impact of RPZs is not even touched on in this FEA. More space is devoted to Protection Zones for plants than for people. Socio-economics, Environmental Justice, and People’s Environmental Health and Safety Risks Categories are dismissed. This FEA no longer distinguishes removing vegetation to meet the existing PART77 requirements and the expanded TERPS surface requirements for this new Type 4 (Type 6?) Instrument Runway/Approach. Hence all vegetation removal is now attributed to the new Type 4 instrument runway, and, despite what is stated in the FEA, is not required under the PART 77 Airport Approach Protection Bylaw or FAA Grant Assurances.
The purpose of the Proposed Actions is said to comply with FAA safety design standards, but TERPS is not a required standard at the Airport today, and contrary to what is stated, there are no changes in FAA Engineering Brief No. 99 tables 3.2 and 3.4 that require this. In fact one standard being cited is a need for a 3200ft runway!
There is no evidence of significant increased hangar demand in the AMPU requiring 22 extra units on 3 acres of tarmac. Phasing out the NDB in 2030 is a specious argument since this FEA specifically rejects “actions not anticipated in the near future”.
The noise footprint is also a specious argument, since the noise of a plane at 1000ft, as required over the congested areas of Chatham, is negligible compared to the noise of planes approaching the Airport at low level and then using reverse thrust. Planes are much lower than 500ft over the total length (~2miles) of the approach surfaces shown in figure 2, which is why there are noise complaints from residents of North and South Chatham as well as West Chatham.
The proposal is for planes to fly straight-in without monitoring activity at the Airport, which is attractive to the charter planes, but without a control tower is hazardous for people in the air and on the ground.
Measured noise from several planes, including the turboprops, air-taxis and the airport manager’s biplane exceed the harm threshold of 85dBa, (90dBa in the RPZs) but the noise category has not been included in the FEA. Advisory Circular AC 150/5020-1 specifies noise as part of Compatibility Planning for Airports, and the FAA requires public and community involvement in discussing noise, when assessing economic versus social tradeoffs. The justification for the omission is based on a self-serving FAA rationale, that allows this, but it does not require it.
A major topic of this FEA is taking avigation easements. It is the Town, which would be required to take property and airspace rights by eminent domain and then negotiate avigation easements. This would be an extremely bitter, lengthy and costly legal process for both individuals and the Town. It is not dealt with in the FEA despite being a named topic. It is dismissed by describing properties as being sparsely populated, which is definitely not true, as shown in the table in the FEA.
Gale Associates has previously dismissed tree trimming as ineffective, so this FEA portrays grand trees being cut 6” below grade and “replanted with ground cover, grasses and shrubs”. Avigation easements would affect individuals, the attractiveness and value of individual properties and neighborhoods, and the tax base. There is no socio-economic discussion in the EA of this, which is unacceptable.
What is not explicitly stated in the FEA, although shown in figure 6, is that there could be an additional need for avigation easements in the TERPS transition surfaces outside the flight path, ie. the proposed 21 avigation easements are not expected to be a one-time deal, but a slippery expensive path for the future.
TERPS also has a surface at 150ft above the Airport over a radius of 5000ft (Appendix A), which includes 2 water towers, which I believe are 165ft above the runway, but there is no mention of them in this FEA.
A 40:1 instrument departure surface is detailed in the Airport Layout Plan figure 12 and referenced in the FEA. The obvious implication is that without an approved instrument departure runway, if a plane lands under instrument flight rules, it would presumably have to wait for the weather to return to visual flight rules before it could leave. The departure surface covers an even larger area than TERPS. It has a slope of 40:1, which would require many more (>46) avigation easements, and tree cutting on private properties and in the wetlands to a lower level than the 20:1 TERPS approach surface proposed, but no mention of this is made in the FEA.
Mention is made that not allowing the full proposals would reduce revenue from fuel and rental cars, and the 2500 boardings allowed by the Airport’s voluntary membership in the National Plan of Integrated Airport Systems (NPIAS). Hence increasing traffic and commercialization of the airport are clearly being demanded and expected as a consequence of adopting the proposals, which has social and environmental impact.
In 1959, the runway was extended into the Wetlands, Vernal Pool area. It would have been a forgone conclusion that the trees in this area would grow, yet the FEA spells out removing all 13.4 acres of trees in and around the wetland and the Vernal Pool area, and all the trees around Ocean State, and replacing them by shrubs. The FEA dismisses this desecration by saying that the impact on the wetland and vernal pool would be temporary. However the MA Wetlands Act requires that the environment is restored within 2 years, which is clearly not being anticipated.
In the evaluation of the bike path, the wording of the evaluation refers to “construction”, but the bikepath is already constructed. No details of the proposal on which the evaluation is based are given. However this ruling does not appear to be based on a 500ft wide Runway Object Free Area (ROFA) along the length of the runway (as described below), which would put the bike-path in serious jeopardy.
According to FAA standards, a 500ft wide ROFA is required for design group II aircraft with a wingspan >49ft such as the Pilatus and King Air Turboprops. A letter from the Director of Airports Division, FAA Audits and Evaluation, states that if these planes exceed 250 annual arrivals, which will almost certainly happen this year, “the FAA will work with the Town of Chatham to improve the airport’s infrastructure to meet the design group II airport design standards.” Ie. the FAA recognizes the issue.
Now the FAA approved Airport Layout Plan shows that the Runway Design Code only allows design group I aircraft, but shows the 500ft ROFA. This is totally confusing and dishonest, especially since an order of magnitude more of these design group II planes land, than of the design aircraft designated in the AMPU.
These larger planes also require the length and width of the cleared areas at the ends of the runway safety area to be increased by 60ft and 30ft extending right over the vernal pool areas and wetlands. Nowhere does the FEA state that the plans are designed to accommodate design group II turboprop aircraft with these dimensions.
It is impossible as a reader to calculate the total tree clearing on and off the Airport. In the FEA it is stated to occur in an area of ~21 acres, but it seems that another 7 acres from clearing a ROFA is required. All this tree removal has considerable environmental impact.
The FEA states that “EAs are said to address a known safety issue at the airport by preventing future development of obstructions that are deemed incompatible with the airport.” This statement appears to say that the Airport is currently unsafe and should be closed.
An FAA guide points out that many Environmental Assessments contain analyses of vitally important social categories, such as airport noise, compatible land use, social impacts, and induced socioeconomic impacts. These have been omitted from this FEA, which is just not acceptable.
There are too many conflicting, misleading, included and omitted issues raised in this FEA. Horizontal and vertical guidance may be great for pilots at most airports, but the implications of applying the relevant FAA standards for design group I and II aircraft at geographically challenged, built-up Chatham Airport, with too short a runway, a 70ft hill and populated RPZs, which puts many more residents and Central West Chatham at risk. Subjecting some of these same residents and others to avigation easements, increased risk and literally deafening noise from more traffic is unconscionable and is a social issue that should have been raised in this FEA