These are the excerpts from the comments the FAA decided to respond to here. For this document, they took the bits and pieces of the letters submitted during the comment period they felt like responding to, and ignored the other parts. This doesn't sound like a fair response to the questons and comments people submitted. It is not fair for them to pick and choose only part of the legitiment concverns citizens have to respond to. They should have to respond to all questions and comments, not just the ones they like. Note: We have not corrected any spelling, grammer or misstatements of fact on this page. It is exactly as published except it has been put in .HTML format for viewing on the web. We have no idea what happened to the missing sections.
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As an editorial comment, I would like to point out that the FAA's oft-used comment of "Based on information available in the scientific literature, there is no known "cause-and-effect" between toxic air emissions from planes and health problems around airports." sounds an awful lot like the tobacco companies claims back in the 1970's that "there is no scientific proof that tobacco causes cancer." Read the below responses to comments (or questions) with a grain of salt, and make your own decisions as to the validity of the responses. | |
Piedmont Triad International Airport
1. Purpose and Need
1-1 Comment
Have PTIA's current and projected average service volumes (ASVs) been recalculated to reflect PTIA's reduced flight operations subsequent to 9/11/01? If so, is PTIA's current ASV at or close to the 60% level the FAA considers the minimum level at which it is appropriate to begin the planning process for an airport expansion? If PTIA's current and projected ASV's have not been recalculated subsequent to 9/11/01, why haven't they?
Response
PTIA's current and projected annual service volume (ASV) have not been recalculated by the FAA in light of the events of 9/11/01. As stated in Chapter 2 of the FEIS, because of the unique operational scenario under which the proposed Mid-Atlantic Hub is anticipated to operate, the FAA did not rely solely on the typical ASV calculation to demonstrate the need for capacity enhancement or the need for the proposed project. (The FAA used the TAAM analysis to determine whether the air cargo hub would operate more efficiently under the widely spaced parallel runway configuration or under the existing. perpendicular runway configuration.) See also response to Comment 2-16.
While the events of September 11, 2001, have affected all of our personal and business lives, the resumption of pre-September 11th business patterns continues, as of this writing. Air carrier cargo operations decreased in FY 2001 compared to FY 2000, but the FAA expects these operations to grow again.
1-2 Comment
The assumption of FedEx operations remaining the same during Phase 2 contradicts the pubic record of FedEx's growth thereby underestimating noise impacts.
Response
The FedEx operational levels used by the FAA in the FEIS were obtained directly from the PTAA and FedEx, and represent the best information available to the FAA with which to evaluate the impacts of the proposed project. If operational levels change significantly in the future from what was evaluated by the FAA in the FEIS, the PTAA will have to coordinate with the FAA to determine if additional environmental evaluation and/or mitigation is required.
1-3 Comment
The FAA has not demonstrated any true need for a cargo hub in Greensboro that serves the pubic welfare.
Response
The FAA is specifically tasked with evaluating airport improvement proposals that are submitted to the FAA by airport sponsors. The definition of "need" from the local standpoint differs from the definition of "need" from the federal standpoint: for the FAA, the need for a project is determined by the air transportation objective it is proposed to achieve, and whether the specific improvement or construction elements offered by the sponsor are appropriate to that objective. In its review, the FAA is obligated to evaluate environmental impacts (which include impacts on air, water, land, and other quality-of-life attributes) and determine that if a project alternative is accepted, all reasonable steps have been taken to minimize any harm that might be associated with that alternative.
As supported by the Purpose and Need and Impacts sections of this FEIS, it is the FAA's decision that (i) the placement of an air cargo hub at PTIA meets a legitimate air transportation purpose, which is supported by policies articulated in 49 USC 47101, and (ii) that through Alternative W1-A1, the improvements and mitigation connected with this alternative can be implemented without harming the environment.
1-4 Comment
The purpose and need is based solely on the criteria established by a private company and was not based on a public need and compliant with the entire National Transportation Policy.
Response
As stated in the response to Comment 1-3, the FAA is not charged with determining whether the proposed cargo hub is needed from a local perspective. That is a matter that the citizens and state and local entities must decide, and the ultimate decision as to whether a project will or will not proceed is in their control.
From a federal perspective, FAA's responsibility was to determine whether the airport improvements proposed by the Airport Sponsor (i.e., the proposed widely spaced parallel runway and associated improvement) met an air transportation objective, as that is defined by FAA policy, and whether the objective could be realized if the particular improvements were implemented. The proposed parallel runway as designed to accommodate an overnight air cargo hub does fall within the boundaries of national transportation objectives, and its development is consistent with specific provisions of statutory policy (see, e.g., 49 CFR 47101).
1-5 Comment
The evaluation of staggered landings and departures, as well as taxi times, should have been evaluated in the TAAM model before eliminating the Citizens Alternative.
Response
The TAAM analysis did conduct an evaluation of staggered landings and departures, as well as taxi times, associated with the runway configuration proposed in the Citizens Alternative.
1-6 Comment
Dual simultaneous independent operations are not a condition of operation at other FedEx hub facilities in Memphis, Indianapolis, or Fort Worth and should not be required at PTIA based on one private air cargo operator's request.
Response
As noted in the FEIS, FedEx set its critical "push-back-to-wheels-up" time for PTIA at five-to-fifteen minutes. This means that FedEx departure operations, from gate push-back of the departing aircraft to taxi to runway to takeoff, must conclude within that brief time window. FedEx notified PTAA of this critical requirement. The FAA input this parameter into the TAAMs analysis, also described in the FEIS. The results showed that to meet the time requirement for the number of operations FedEx proposed, dual simultaneous independent operational capabilities would be necessary. At other hubs, the existing airport configuration and proposed number of operations, among other factors, might produce different airfield operations requirements. As to other FedEx hub sites, both the Memphis and Indianapolis airports allow FedEx to use dual simultaneous independent operations. Fort Worth does not.
1-7 Comment
The FAA improperly suggest that this project has been planned for years.
Response
The FEIS statement that a widely-spaced parallel runway has been depicted on the PTIA ALP since 1968 is a correct statement; this statement, however, does not suggest that the runway depicted was historically an air carrier runway. The original runway depiction extended to about 6,000 feet. The FAA statement that a project like the proposed FedEx project has been planned for years at PTIA is supported by the fact that a widely-spaced transport category runway and an area reserved for cargo development on the north side of PTIA have been depicted on the PTIA ALP since 1994.
1-8 Comment
The FAA has failed to demonstrate that there is a need for this project.
Response
As discussed in Section 2.2.3 of the FEIS, the need for the proposed new parallel runway is not based on FAA's standard approach to airfield capacity. The purpose of the proposed new parallel runway is related to particular capacity parameters that meet the operational requirements of an overnight, express air cargo hub at PTIA. Specifically, the parallel runway is needed to provide runway redundancy in the case of adverse weather or runway closure due to maintenance or incidents. In addition, the parallel runway is needed to allow for dual simultaneous independent operations and head-to-head operations, on widely spaced parallel runways, to satisfy minimum departure and "push-back-to-wheels-up" times required to operate the air cargo hub.
The FEIS used baseline data describing (i) anticipated FedEx operational levels (number of operations) and characteristics (minimum departure times and "push-back-to-wheels-up" times), (ii) PTIA historic runway closures, and (iii) PTIA Annual Service Volume (ASV) calculations, based on the most recent and best available information provided to the FAA by both the PTAA and FedEx. The FedEx operational levels and characteristics provided by FedEx to the PTAA, and then to the FAA, were used to determine whether the current airfield could accommodate hub requirements. PTAA developed the ASV calculations as part of its ongoing Master Plan Update and provided the results to FAA for use in the EIS. However, as described in FEIS Section 2.2.3.2, the ASV did not adequately address air and landside issues associated with the time-limited operations of a nighttime air cargo hub. Therefore, the FAA also relied on the TAAM analysis, described in Section 2.2.3.2. The results demonstrated that if PTAA is to support an air cargo hub, the proposed parallel runway and related improvements are needed.
Please see also the response to Comment 1-3 above.
1-9 Comment
Expansion is unnecessary since PTIA is not operating near its capacity.
Response
As discussed in Section 2.2.3 of the FEIS, the need for the proposed new parallel runway is not solely based on FAA's standard methodology of calculating airfield capacity. The purpose of the proposed new parallel runway is to meet the operational requirements of an overnight, express air cargo hub at PTIA. Specifically, the parallel runway is needed to provide runway redundancy in the case of adverse weather or runway closure due to maintenance or incident. In addition, the parallel runway is needed to allow for the ability to conduct dual simultaneous independent operations and efficient head-to-head operations on widely spaced parallel runways to meet the operational needs of the air cargo hub.
1-10 Comment
Please identify the "long-term" capacity needs of PTIA starting in the year 2015 without FedEx.
Response
Table 2.2-3 in the FEIS shows the long-term capacity needs of PTIA without the introduction of the FedEx Mid-Atlantic Hub. The table depicts the forecast of aircraft operations at PTIA, the corresponding ASV associated with the forecast operational levels, and the annual operations as a percent of the ASV through the year 2019, the last year for which FAA approved forecasts are available for PTIA.
See also response to Comment 2-16.
1-11 Comment
The FAA has improperly defined the purpose of the project.
Response
Because FedEx selected PTIA for development of its Mid-Atlantic air cargo hub, no other airport presented a proposal for this facility to the FAA. Moreover, the FAA lacks the authority to direct that the facility be developed elsewhere. In light of these and other considerations discussed in Section 2.2 of the FEIS, including applicable Congressional policy (e.g., 49 U.S.C. § 47101(a)(4),(5), and (7)), the FAA has identified the purpose and need of the proposed project to include the development of the air cargo hub at PTIA (see Section 2.2.3.5 of the FEIS), through the addition of a parallel air carrier runway and other improvements, and included this criterion in the Level 1 alternatives screening process described in Chapter 3 of the FEIS.
1-12 Comment
FedEx should go to a less remote area.
Response
As explained in the FEIS, the FAA is not authorized to direct FedEx to expand or contract its operations, or to select particular airports for those operations. Nor is the FAA able to compel FedEx to choose remote locations for its hubs. To the best of the FAA's knowledge, FedEx undertook a detailed site selection study before making the determination to develop the proposed air cargo sorting/distribution facility at PTIA. Section 2.2.2.2 of the FEIS describes the process undertaken by FedEx (to the extent revealed to the FAA) in selecting PTIA as the proposed site of its Mid-Atlantic Hub. The FAA's role is limited to evaluating proposals presented to it by an airport sponsor, in this case, the proposal from the PTAA to accommodate the airside and landside requirements associated with an overnight air cargo hub operation.
Piedmont Triad International Airport
2. Alternatives
2-1 Comment
The FAA and PTIA should provide reasonable assurances to the citizens of Guilford County that planes larger than the 727s mentioned in the study will not be used as part of the cargo hub operation. Specifically, that planes capable of flying directly to European destinations will not be a part of the future repertoire of the hub. Should these flights occur, the findings in the EIS grossly understate the impacts of the project.
Response
The B-727s analyzed in the noise section of the FEIS represents the loudest commercial aircraft that FedEx anticipates to operate at the Mid-Atlantic Hub, and that is why it was used for the sleep disturbance analysis. At least one aircraft proposed for use by FedEx, the DC-10, is larger in size than the B-727. However, the size of an aircraft is only one of many factors to consider in the generation of aircraft noise. Other factors that are more significant include the number of engines used, engine design or airframe design.
The FAA cannot restrict the type of aircraft used by an air carrier, with the exception of the requirement that all commercial aircraft weighing greater than 75,000 pounds meet Stage 3 noise requirements. All aircraft proposed for operation by FedEx at the Mid-Atlantic Hub meet this requirement. The noise evaluation contained in the FEIS represents the best information available to the FAA from the proposed air cargo hub operator in terms of aircraft fleet mix and number of operations. If FedEx or any other air carrier introduced service to PTIA with an aircraft type that had never operated into PTIA before, it would be necessary for the FAA to modify specifications associated with the air carrier operating certificate. This would constitute a federal action by the FAA, which would make the change subject to the appropriate level of NEPA analysis.
2-2 Comment
The FEIS does not provide any assurances that the levels of impacts will not be exceeded. I request that the FAA obtain written confirmation from PTIA and FedEx that no increase will occur in the total number of planes larger than the current 727s taking off or landing at PTIA between the hours of 11:00 p.m. and 7:00 a.m. If this is not obtained, I am requesting that the FAA reject PTIA's expansion proposal.
Response
As stated in the response to Comment 2-1, the FAA cannot restrict the type of aircraft used by an air carrier, with the exception of the requirement that all commercial aircraft weighing greater than 75,000 pounds meet Stage 3 noise requirements. All aircraft proposed for operation by FedEx at the Mid-Atlantic Hub meet this requirement. The noise evaluation contained in the FEIS represents the best information available to the FAA from the proposed air cargo hub operator in terms of type and number of aircraft to be used at the proposed Hub.
The FAA cannot limit the number of aircraft operations or dictate the type of aircraft that will be used at the proposed Mid-Atlantic Hub. However, if a significant change in the aircraft fleet used by FedEx introduces a new aircraft type to PTIA, federal action may be invoked, which would trigger NEPA analysis. In addition, through PTAA's noise monitoring and mitigation commitments, if air cargo operations significantly vary from what was evaluated by the FAA in the FEIS, the PTAA will have to re-evaluate noise impacts and develop a new mitigation program.
2-3 Comment
FedEx should be located 10 to 20 miles out in the open country. It would also be served by a four lane super highway point to point.
Response
Please see response to Comment 1-12 above.
2-4 Comment
Alternative sites such as Kinston, Raleigh, and Charlotte have runway configurations that would accommodate this project and require less Federal tax dollars.
Response
The FAA is not authorized to approach airports and solicit proposals from them for particular projects. In FEIS Chapter 3, however, the FAA evaluated other airports in the region as an alternative to the proposed project at PTIA. The FAA concluded that some of these airports might have been able to meet some of the requirements of an overnight air cargo hub. The FAA further concluded in the FEIS that no other airport could meet the Purpose and Need for the proposed project. Because no other airport sponsor proposed any similar project to the FAA, and because no other airport could meet the purpose and need for this project, the FAA did not analyze alternative existing sites in heavy detail.
2-5 Comment
The FEIS never properly evaluated the Citizens Scoping Alternative. The citizens alternative meets the purpose, costs less, lessens noise impacts, and has a less of a negative impact on wetlands, water quality and floodplains.
Response
As an alternative to the proposed project at PTIA, the Citizen's Scoping Alternative did not meet all of the Level 1 screening criteria and therefore, was not retained for further analysis in the EIS in accordance with CEQ regulations, 40, CFR Parts 1500-1508. In particular, the perpendicular runway configuration and lack of adequate space for a package processing facility were prohibitive.
2-6 Comment
Under the Citizens Scoping Alternative, the City of Greensboro fire station at the corner of Burgess Road and West Market Street should remain intact, not taken as the consultant states, in its evaluation. The fire station would be an asset to the FedEx facilities.
Response
The Citizens Scoping Alternative states that the City of Greensboro Fire Station could remain in place. However, FAA's evaluation of this alternative indicates that in order to provide a contiguous 300 acres for development of the proposed air cargo sorting/distribution facility, the City of Greensboro Fire Station and the 1.4 acre cemetery would have to be relocated.
2-7 Comment
The Citizens Scoping Alternative would cost $120 million less than the sponsor's plan and would require less site preparation than other alternatives because of its relatively level terrain and nearby utilities. Thereby, elimination of full evaluation of this plan will violate Title 49 USC 40101 and Title 42 USC 4332(2)(E).
Response
Please see response to Comment 2-5 and 2-6.
2-8 Comment
The elimination of the Citizens Scoping Alternative is a violation of Title 49 USC 40101 because it does not give the highest priority to the public interest; it does not enhance safety and security.
Response
Please see response to Comment 2-5.
2-9 Comment
The configuration of the runways in the Citizens Scoping Alternative is identical to the ALP and Master Plan that PTAA adopted in 1990 and consistent with development plans that were part of the 1994 ALP and Master Plan. There was no public hearing for either the 1994 ALP or 1999 ALP. Therefore, it may be argued that the current PTIA ALP is actually the 1990 plan.
Response
The Citizen's Scoping Alternative is not consistent with the 1994 FAA-conditionally approved Airport Layout Plan (ALP) because the Citizen's Scoping Alternative depicts a 7,000-foot widely-spaced parallel runway. The 1994 ALP depicts a 10,000-foot widely-spaced parallel runway. The 1999/2000 ALP also depicts a 10,000 foot widely spaced parallel runway (initial 9,000 foot runway with a potential 1,000 foot extension). There is no requirement for public hearings of the Airport Sponsor's (PTAA) Master Plan or ALP, or the FAA's conditional acceptance of an ALP.
2-10 Comment
The decision to eliminate the Citizens Scoping Alternative is both arbitrary and capricious.
Response
Please see response to Comment 2-5.
2-11 Comment
The FEIS falsely indicates that the Citizens Scoping Alternative restricts an RPZ, changes local and potential regional flight patterns, increases daytime air passenger carrier operations.
Response
The FAA's evaluation of the Citizens Scoping Alternative is contained in Section 3.3.2.2, Section 3.3.2.3 , and Section 3.3.3.2. The FEIS indicates that the Citizens Scoping Alternative would result in significant non-compatible land uses within the RPZ of a future 10,000 foot runway at PTIA, and indicates that increased use of the cross-wind runway (Runway 14/32) would shift flight patterns at PTIA with increased east-west operations.
2-12 Comment
Any lost time in staggered landing operations will be recaptured in the shortened taxi times of the Citizens Scoping Alternative.
Response
An analysis of staggered landing and departure intervals and taxi times associated with the Citizens Scoping Alternative was not provided to the FAA by the citizens for evaluation purposes as part of either the Scoping process or the comment process on the DEIS. Therefore, the FAA could not conduct an evaluation of the validity of the statement made in this comment.
2-13 Comment
If wind speed and direction has no bearing on operations at PTIA, then 95% of the air cargo operations can occur in an easterly direction on Runway 14/32 as the Citizens Alternative proposed.
Response
Wind speed and bearing do have a significant affect on the operation of the runways at PTIA as well as at every other airport in the world. The wind analysis conducted for the EIS (see Section 5.1 of the FEIS) provides justification for the operational assumption that FedEx aircraft could operate in the "from the south - to the south, head-to-head-operational scenario for 95 percent of its operations. The wind analysis does not support the use of this proposed operational scenario on Runway 14/32.
2-14 Comment
URS and the FAA violated a number of Federal statutes, CEQ regulations and FAA internal regulations by eliminating the Citizens Scoping Alternative.
Response
Please see response to Comment 2-5.
2-15 Comment
The EIS should be re-opened and the Citizens Scoping Alternative be given full analysis and evaluation before a Record of Decision appropriating Federal funds for airport improvements.
Response
The FAA conducted a full and impartial evaluation of the Citizens Scoping Alternative as part of the EIS. This evaluation is contained in Section 3.3.2.2, Section 3.3.2.3 , and Section 3.3.3.2 of the FEIS. The Citizens Scoping Alternative was not retained for further consideration by the FAA in Level 2 of the alternatives evaluation because it did not meet all of the Purpose and Need criteria discussed in Chapter 2, Purpose and Need, of the FEIS. In particular, the Citizens Alternative featured a perpendicular runway configuration, which did not permit either the dual simultaneous or head-to-head operations that were determined to be necessary to the project, and failed to feature adequate acreage for the landside package processing facility.
2-16 Comment
One would think that some consistent and objective criteria such as current airport utilization being at some percentage of capacity or some percentage of air traffic being disrupted by the current runway configuration would have to be met before any airport expansion could even be considered.
Response
As noted by the commentor, the FAA does apply consistent and objective criteria to measure airport capacity and determine when capacity enhancing improvements are needed. As described in Section 2.2.3.2 of the FEIS, FAA planning guidelines for airports specify that when annual airport operations reach 60 percent of ASV capacity, the Airport Sponsor should initiate planning studies to evaluate means of increasing capacity, and when they reach 80 percent of ASV capacity, construction of improvements should begin (FAA AC 5090.3B, Table 3-2). Since PTIA is nearing this 60 percent threshold (see Table 2.2-3 of the FEIS), it has initiated one of the first steps in the planning process, which is the Federal environmental review process. In this case, the Federal environmental review has taken the form of an EIS. The EIS process begins when the sponsor has identified a problem or when there is a request for FAA to approve a revision to an ALP or request Federal funding assistance.
Also as discussed in Section 2.2.3.2 of the FEIS, PTAA is anticipated to reach the 80 percent threshold by approximately 2015 without the introduction of the air cargo sorting/distribution facility and by approximately 2008 with the introduction of the air cargo sorting/distribution facility.
2-17 Comment
The FAA has not given full and fair evaluation to the Citizens Scoping Alternative.
Response
The FAA has conducted a broad, exhaustive, technically accurate and fair evaluation of the proposed project and reasonable alternatives in the DEIS and FEIS documents, and has fully considered all information submitted by agencies and the general public. In addition, the FAA has thoroughly reviewed and considered the Citizen's Scoping Alternative in the EIS process. Please see Section 3.3. of the FEIS and the Response to Comment 2-5, above.
2-18 Comment
To complete your FEIS you requested copies of the air cargo operator's RFP. However, you never received these copies, yet you managed to complete the alternatives analysis without them. How can this be done?
Response
The proposed air cargo operator provided FAA with information that was critical to its decision making process without disclosing confidential materials provided by the respondents to its RFP. Based on this information, information provided by the PTAA and information developed by the FAA, the agency conducted a broad, exhaustive, technically accurate and fair evaluation of the proposed project and reasonable alternatives.
2-19 Comment
The FAA failed to explore rigorously all reasonable alternatives.
Response
The FAA has conducted a broad, exhaustive, technically accurate and fair evaluation of the proposed project and reasonable alternatives in the EIS. The alternatives analysis was based on alternatives to the projects proposed by the PTAA (i.e. new widely-spaced parallel runway, sorting/distribution facility and associated projects) and not the geographic location of the proposed air cargo hub (see Section 3.3.1 of the FEIS. The proposed air cargo operator provided FAA with information that was critical to its decision making process without disclosing confidential materials provided by the respondents to its RFP. Based on this information, information provided by the PTAA and information developed by the FAA, the agency fulfilled its' obligation to rigorously explore and evaluate all reasonable alternatives.
2-20 Comment
We are opposed to the building of a new runway and FedEx facility at PTIA.
Response
Comment noted.
2-21 Comment
What guarantees doe this community have that FedEx will indeed hold to this data of 126 flights?
Response
The FAA based its evaluation in the FEIS on data PTAA provided, which PTAA obtained from FedEx, containing flight information, fleet mix, long range plans, and operation assumptions. This information indicates that FedEx anticipates 24 nightly aircraft departures (48 operations) in Phase 1 and 63 nightly aircraft departures (126 operations) in Phase 2. FAA believes that this is consistent with operations typical of similar air cargo carriers at other airports. These assumptions are sufficiently conservative to encompass reasonably foreseeable future operations, including nighttime operations. The FAA cannot guarantee how FedEx will operate, but as far as FAA is aware at this time, there are no plans by FedEx to increase the proposed number of operations.
Piedmont Triad International Airport
3. Noise
3-1 Comment
My interpretation of the 65 DNL cutoff used by the FAA for qualification for noise mitigation assistance program has my home within its limits. I request clarification of the status of my home as it relates to the 65 DNL cutoff.
Response
The mitigation program approved by the FAA and which will be implemented by the PTAA indicates that all houses within the DNL 70 and 75 dBA noise contours will be purchased, and that all houses within the DNL 65 to 70 dBA noise contour will be acoustically treated (sound insulated) in order to achieve indoor noise levels that meet the standards established by EPA, HUD, and the FAA guidelines. The PTAA would receive an avigation easement as part of the acoustical treatment mitigation within the DNL 65 dBA noise contour.
The PTAA has information at their administrative office that provides further clarification as to whether a specific home is located within one of the PTIA noise contours. The FAA recommends that individuals with questions regarding their eligibility for the noise mitigation program contact the PTAA directly.
3-2 Comment
The proposed noise analysis diagrams grossly understate the impacts of the much larger heavily loaded cargo planes that organizations like Tradewinds periodically utilize. Even when these planes take off to the south, they must pause at the north end of the runway to get their engines accelerated to the necessary levels. At the present time, these planes rattle the windows of our house and we have personally recorded noise meter readings well in excess of 75 dBA.
Response
The noise contours and associated analyses contained in the FEIS for each of the alternatives accurately represents the anticipated aircraft fleet mix at PTIA based on historical records and FAA approved forecasts of aviation activity. Departures to the southwest from PTIA would result in noticeable noise in areas to the northeast of PTIA from what is known as "backblast" noise. This type of noise was included in the modeling of the noise contours for each of the reasonable alternatives. The FEIS accurately presents average noise exposure in the DNL metric that would be experienced as a result of the operation of PTIA with the proposed Mid-Atlantic Hub.
3-3 Comment
Hub noise will affect thousands of families, night in and night out.
Response
"Nighttime noise is generally more disruptive than daytime noise because ambient noise levels are typically lower at night. All noise affects different people in different ways. Some people are not bothered or only slightly bothered by noise levels that are considered excessive by someone else. The FEIS contains an analysis of potential Sleep Disturbance impacts in Sections 5.1.3 and 5.1.4.
General research has provided information on what percentage of people might be awakened by different levels of aircraft noise. For the purposes of this study it is assumed that an aircraft arrival or departure event that creates outdoor noise levels equal to 100 dBA SEL would awaken no more than 10 percent of the adults sleeping indoors with windows closed. See Section 5.1.2 for further information."
The noise contours depicted in the FEIS show that hub noise will not reach thousands of families, and will affect a far smaller number of people. A mitigation plan, adopted by PTAA, will be in place to address their needs.
3-4 Comment
The Charlotte/Douglas International Airport study showed an SEL 95 for a hushkitted 727 extending four miles from the end of the runway. Such a contour would affect 10,000 people in Greensboro. This is exactly the kind of concern expressed by the EPA and airport area residents.
Response
There is no standard with a specific threshold of significant impact that has been adopted by the FAA with regard to the use of the SEL metric and the potential correlation for sleep disturbance. In response to public and EPA comments on the DEIS, the FAA added an evaluation of potential sleep disturbance impacts to the PTIA FEIS document. For the PTIA FEIS, the FAA chose to use the 100 SEL contour to evaluate the potential for sleep disturbance because it results in a similar degree (or percentage) of affected populations as the DNL 65 dBA noise contour.
For a 100-dBA SEL departure or arrival, assuming a conservative outdoor to indoor noise level reduction of 20 dBA, no more than about 10 percent of the adults sleeping indoors with windows closed are likely to be awakened by a single event. This 10 percent level is based on the Federal Interagency Committee on Aviation Noise (FICAN) Report's upper limit of observed field data (i.e., a worse case scenario).
As per FICAN, other studies show a lesser percentage of awakenings. In this analysis, the 100 dBA SEL contour was contained within the DNL 65 dBA noise contour. The FAA cannot concur with the commentor's statement that the use of a 95 SEL contour would affect 10,000 people in Greensboro. Although the 95 SEL contour would be larger in size than the 100 SEL contour, the percentage of people affected would be less than that affected by the 100 SEL contour.
The FEIS presents the results of the SEL analysis in Tables 5.1.3-4b and 4c, and Figures 5.1.3-3, -4, -6, -7, -9, -10, -12, -13, -15, -16, and -19.
3-5 Comment
The FEIS for PTIA does show a 100 SEL contour extending two miles and affecting 946 people. This is a serious discrepancy due to an arbitrary decision by the FAA to use 100 SEL instead of 95 SEL to define a contour.
Response
As stated in the response to Comment 3-4, there is no standard with a specific threshold of significant impact that has been adopted by the FAA with regard to the use of the SEL metric and the potential correlation for sleep disturbance. The FAA chose to use the 100 SEL contour to evaluate the potential for sleep disturbance because it results in a similar degree (or percentage) of affected populations as the DNL 65 dBA noise contour. In addition, FAA chose this SEL level based upon sleep disturbance research discussed in FICAN (1997) and the conservative 20 dB noise level reduction that typical home construction provides.
As shown in Table 5.1.3-4b of the FEIS, under the Preferred Alternative, it was estimated that the 100 SEL contour for a B-727 operation could result in sleep disturbance to approximately 190 people under Flow 1 and Flow 3 conditions, and approximately 946 people under Flow 2 conditions. Flow 1 conditions are expected to occur for approximately 95 percent of the FedEx operations. Flows 2 and 3 are anticipated to occur for approximately 2.5 percent of FedEx operations each. Therefore, for approximately 97.5 percent of FedEx operations, approximately 190 people might experience sleep disturbance.
3-6 Comment
The Charlotte/Douglas study explained that a 95 SEL is used because, after allowing for the noise reduction of a typical residence, a 95 SEL produces an interior noise that interferes with speech. One would therefore have expected the FAA to use a lower, not higher, noise level for SEL contours.
Response
Please see response to Comment 3-4.
3-7 Comment
Nothing in the FEIS reduces the validity of the EPA's conclusion that the hub introduces new overnight noise and to be reasonable environmentally, residential communities would need to be removed.
Response
As discussed in detail in Section 5.1 of the FEIS, the introduction of the Mid-Atlantic Hub at PTIA would introduce new nighttime noise and result in noise impacts to areas that are not currently experiencing significant aircraft generated noise levels. The PTAA has committed to a noise mitigation program that will combine land acquisition (removal of non-compatible land uses) and sound insulation, which will mitigate the noise impacts in the affected areas associated with the Preferred Alternative. Please see Section 6.3 of the FEIS.
3-8 Comment
Pilots frequently choose to fly over my neighborhood as they approach or leave PTIA late at night, in the middle of the night, and early in the morning. These flights occur on clear, windless nights and thus are not necessitated by weather conditions.
Response
Comment noted. During fair weather conditions, pilots can operate under Visual Flight Rules (VFR), which sometimes allow them more freedom in maneuvering around the airport's airspace.
3-9 Comment
Why has the FAA recommended no flight path restrictions relating to the additional projected overnight airplane traffic?
Response
The PTAA will develop recommended flight paths as part of the FAR Part 150 study that they will undertake after the FAA issues it's Record of Decision (ROD) on the proposed project at PTIA. These flight paths will be evaluated by the FAA as part of the Noise Compatibility Program (NCP) portion of the FAR Part 150 study.
3-10 Comment
Why does the Executive Summary section entitled "Inconsistency with Local Plans and Laws" exclude the mention of Guilford County Code Sections 12-4 and 12-5 (Disturbing the Peace) and exclude discussion of potential for current and future violations of this ordinance resulting from overnight activity at PTIA.
Response
Review of the referenced Guilford County Code sections indicates that these codes do not specifically reference aircraft noise and are therefore not subject to FAA review.
3-11 Comment
Why does the FAA's approved method for projecting noise impact continue to exclude any analysis or consideration of readily available empirical evidence of noise problems, such as noise complaint records, generated by existing airport operations?
Response
The FAA does not presume to discount or dismiss the annoyance people experience in connection with aircraft noise. However, noise complaints alone have not been demonstrated to provide a reliable basis for establishing specific noise evaluation criteria. According to the August 1992 Report of the Federal Interagency Committee on Noise, "Although annoyance is the recommended metric for characterization of community response to noise, complaints are not a measure of community impact...Annoyance can exist without complaints and, conversely, complaints may exist without high levels of annoyance. The current body of evidence indicates that complaints are an inadequate indicator of the full extent of noise effects on population." (Fields and Hall, 1987) Technical Report, page 3-6.
By way of contrast, the FAA's Integrated Noise Model (INM) and the Day-Night Noise Level (DNL) noise metric have been credited as reliable evaluators of potential aircraft generated noise impacts. The INM accepts input on a range of factors that produce noise, including aircraft engine data, and the DNL metric places extra weight on nighttime noise. These methods and their results, which have been tested and accepted by various federal courts, continue to present the most effective noise description tools the FAA has. These tools are described in detail in FEIS Section 5.1 and Appendix B.
3-12 Comment
Although the FAA is well aware its approved noise projection methodology consistently underestimates actual noise impact, it has not changed its approved noise projection methodology. Why has the FAA not approved or obtained approval for a noise projection methodology that more closely reflects reality?
Response
The FAA has incorporated standard, accepted noise methodology for assessing the noise impacts associated with the proposed project. The FAA continues to use this methodology because it is considered reliable, and because the Federal Interagency Committee on Noise (FICON) continues to support it:
"[The] DNL methodology has given consistent results in the national and international literature under a wide range of noise conditions, including loud and soft noise levels and frequent and infrequent numbers of aircraft noise events. Much of the criticism of the use of YDNL (yearly DNL) for community annoyance and land use compatibility around airports may stem from a failure to understand the metric. Another factor may be that some persons exposed to aircraft noise do not accept DNL 65 dB as the appropriate lower limit of noise exposure in considering noise impact.
"An average sound metric such as DNL takes into account the sound levels of all individual events that occur during a 24-hour period and the number of times those events occur. The averaging of sound over a 24-hour period does not ignore the louder single events, and it actually tends to emphasize both the sound level and number of those events. This is the basic concept of a time-averaged sound metric, and specifically DNL. The logarithmic nature of the dB unit causes sound levels of the loudest events to control the 24-hour average."
(Quote from Federal Agency Review of Selected Airport Noise Analysis issues, Federal Interagency Committee on Noise, August 1992, page B-16)
3-13 Comment
Residents impacted by the head-to-head operating scenario will have much greater noise impacts than residents affected under the current scenario.
Response
As discussed in Chapters 2, 3 and 5 of the FEIS, use of the head-to-head operational flow will result in aircraft arriving from and subsequently departing to the same direction. This scenario is atypical at PTIA and other airports, where aircraft typically arrive from one direction and depart to another direction. Under the FedEx head-to-head operational scenario, residents to the southwest of PTIA who live under the nighttime flight path in Flow 1 conditions (arrivals from the south and departures to the south) will experience both arrival and departure overflights, thereby increasing their noise exposure. Other scenarios exposed more residents in other areas around the airport to more noise. These impacts, including depictions of noise boundaries, are documented in Section 5.1 of the FEIS.
3-14 Comment
There is a high probability that the noise impacts will be greater than modeled.
Response
The FEIS presents the anticipated noise levels from the proposed project based on the best available information from the PTAA and FedEx using the most recent version of the FAA's Integrated Noise Model (INM). The INM method of analysis is viewed as a reliable indicator of both noise levels and geographic boundaries associated with these levels. See also response to Comments 3-11 and 3-12.
3-15 Comment
Using two different noise level reduction values (20 dBA for SEL and 15 dBA for TA) will result in inconsistent and unreliable conclusions.
Response
The discussion in Section 5.1.2 for the Sound Exposure Level (SEL) single-event noise metric refers to a 20 dB outdoor-to-indoor noise level reduction (NLR). This assumes a "windows closed" environment and is a conservatively low NLR assumption. In reality, many residences typically experience NLRs with windows closed of 25 to 30 dB. For this analysis, the windows closed environment was selected because the number of people within the 100 dBA SEL correlates to sleep disturbance criteria (most residences would most likely have windows closed.) The discussion in Section 5.1.2 for the Time Above (TA) noise metric refers to 15 dB outdoor-to-indoor NLR in a "windows open" environment. The TA metric correlates to speech interference criteria and uses a conservative windows open environment, in which residents might experience more impact.
3-16 Comment
Use of the 100 dBA SEL contour results in understatement of the sleep disturbed population as compared to the use of the "closed window" 15 dBA outdoor to indoor noise level reduction value.
Response
Please refer to the response to Comment 3-15 above.
3-17 Comment
Using DNL is designed to minimize the impact of airport noise on the surrounding community. The EPA recommends the adoption of the 55 dBA limit based on single events. Thus, the FAA's analysis serves no real scientific purpose other than minimizing the stated impacts, thereby refusing to truly mitigate the actual physiological damage that will result.
Response
Current FAA policy requires using the Integrated Noise Model (INM) and the Day-Night Noise Level (DNL) 65 dBA noise metric to evaluate potential aircraft generated noise. The FAA standards have been reviewed by the Federal Interagency Committee on Noise (FICON), which includes EPA as a member, and these standards have been found acceptable. INM analysis is viewed as providing a reliable indicator of both noise levels and the geographic boundaries associated with these levels. The DNL metric as a noise measure is used largely because of work that Schultz (1978) conducted.
According to the Federal Interagency Commission on Noise (FICON, 1992), Schultz's work "...remains the best source of empirical dosage-effect information to predict community response to transportation noise." FICON also notes that DNL "...continues to be the superior metric to account for variations in the noise environment, including such factors as the number of flights, loudness of individual aircraft, and percentage of nighttime flights." FICON reports that the DNL 65 dB level is used because predictions below this level become less accurate, and their reliabilities become questionable. There is no mandatory requirement to include DNL 60 dBA or lower in the overall noise analysis, since the effects on public health and welfare below DNL 60 dBA have not been well established. FICON does not recommend evaluating aviation noise impacts below DNL 60 dBA. DNL is accepted throughout the Federal government as the standard for assessing community annoyance and environmental noise.
The FAA's threshold of incompatibility is based on persons living 24 hours per day in a dwelling, rather than on an annoyance level that might be assigned to outdoor activity. In accordance with the FAA's land use compatibility guidelines and FAA Order 5050.4A (Airport Environmental Handbook), the FAA conducts noise exposure analysis for those noise sensitive facilities located within the DNL 65, 70, and 75 dBA noise contours. Once the boundaries are defined, these contours are used as the thresholds for determining incompatible land use.
Through the noise analysis and the graphic results the INM/DNL combination produces, the FAA is able to identify areas where noise creates an undesirable effect on people, or, in other words, where aircraft noise and residential land use are incompatible. In these areas, the FAA requires to airport sponsor to carry out mitigation programs (e.g., land acquisition, soundproofing insulation), so that the negative effects of noise on people can be avoided. Through this analysis, the FAA has identified these areas in relation to Alternative W1-A1 and has obtained PTAA's commitment to pursue the required mitigation plan.
3-18 Comment
Pilots have a great deal of discretion to determine landing direction as it relates to wind speed and direction. The assumption of 95% of flights taking off to the southwest is unlikely and if even a change in 10% of the arrivals or departures were shifted to the northeast, the number of noise related impacts would increase significantly.
Response
Section 5.1.2.1 of the FEIS provides a detailed description of how FedEx's proposes to operate at PTIA after the establishment of the Mid-Atlantic Hub. The FAA conducted a "wind analysis" that supports the conclusion that the head-to-head scenario will be available for 95 percent of the nighttime operations.
3-19 Comment
I do not see anywhere in the FEIS the change in flight patterns that have occurred at PTIA since Sept. 11th and resulted in noise changes.
Response
PTAA has indicated that aircraft operating at PTIA are currently operating in the same manner, before and after September 11, 2001.
3-20 Comment
I find it profoundly unique as to how similar your graphs on the noise levels look. Almost too similar to be statistically valid.
Response
The noise contours associated with the "W" Alternatives are similar because the alternatives themselves are very similar. The only difference between them is a slight runway- to- runway centerline separation distance (Alternatives W2-A and W3-A vs. W1-A1), and a slight lateral shift to the north/south (Alternative W2-A vs. Alternatives W3-A and W1-A1).
3-21 Comment
The EPA recommends that the FAA extend residential land acquisition to include those homes that would be located in the DNL 65 dBA contour that experience a DNL 1.5 dBA increase or greater. Remaining residences that would be in the DNL 65 dBA contour but would not be significantly noise-elevated, should be acquired through the Part 150 Program.
Response
Comment noted. It is currently FAA policy to mitigate impacted properties within the DNL +75 dBA noise contour through an acquisition program and to mitigate impacted properties within the DNL 65 and 70 dBA noise contours by implementing a sound insulation program. The FAA has worked with the PTAA to enhance the PTAA Mitigation Program for the Preferred Alternative such that the PTAA will offer to purchase impacted properties within both the DNL 75 dBA and DNL 70 dBA noise contours. This mitigation will be implemented as part of the EIS mitigation program. The PTAA has also committed to undertaking a FAR Part 150 study after the FAA issues its ROD. Additional mitigation may be proposed as a result of this study.
3-22 Comment
The EPA states that noise mitigation for an EIS proposal should involve a commitment of funds from sources other than the Part 150 Program, to ensure that implementation will occur on a schedule in the near future as opposed to could occur sometime in the future.
Response
It is the FAA's understanding that the PTAA is committed to implementing Noise Mitigation Program Elements 1.1 through 1.5 as soon as practicable after the FAA's issuance of the ROD, and that the PTAA does not intend to wait until after the FAR Part 150 process is completed before it begins implementing the EIS mitigation program.
3-23 Comment
EPA recommends that noise modeling using actual operational data be conducted one year after the project start-up and periodically thereafter. Also, EPA recommends that monitoring also include areas outside the airport property where impacts to households can be expected. The location of these sites should be coordinated with the affected public.
Response
Comment noted. Element 1.4 of the Mitigation Program for the Preferred Alternative consists of the installation of a noise and operations monitoring system whose purpose is to obtain actual operational data for use by the PTAA to more fully evaluate the noise environment around the airport. Both FAA and the PTAA anticipate that this system will be operational before the completion of the new runway and the initiation of FedEx air cargo operations. The monitoring will take into account off-airport properties that could be affected by aircraft generated noise.
3-24 Comment
EPA considers it critical that the FAA commits to the acquisition by 2005 of households that would be in the DNL 70 and 75+ dBA contours, as indicated in FEIS Table 6.3-1.
Response
Comment noted. The FAA and the PTAA anticipate that the acquisition program will be initiated as soon as practicable after the FAA's issuance of the ROD.
3-25 Comment
The FEIS fails to disclose adequately the noise impacts of this project for the following reasons: 1. The FEIS relies too heavily on the DNL metric and an outdated noise model. 2. The FEIS should not have assumed that 95 percent of FedEx's operations would occur to the southwest. 3. There is no indication accounted for the heavy weight of cargo operations in its noise analysis. 4. FAA did not independently review the noise analysis and contours. 5. Sleep interference analysis is deficient and should reassess whether it properly assumed that FedEx would be using quieter planes.
Response
(1) The FEIS uses the most recent version of the FAA's Integrated Noise Model (INM). The INM method of analysis is the accepted and approved methodology for use in environmental studies and will continue in use until more satisfactory methods are developed, tested, and accepted.
(2) Section 5.1.2.1 of the FEIS provides a detailed description of how FedEx proposes to operate at PTIA. This section provides a detailed "wind analysis" that supports the conclusion that head-to-head operations can occur for 95 percent of FedEx operations.
(3) The noise analysis does account for the "heavy weight of cargo operations." The results of the analysis appear in the tables in Chapter 5, which reflect use of heavier aircraft such as the DC10 and A300. The noise analysis takes into account these aircraft, as well as the heavier weight of these and other aircraft. Aircraft that are heavier tend to fly more shallow departure profiles, ultimately creating more noise on the ground.
(4) The FAA, through its review of the DEIS and FEIS documents, has reviewed and approved the noise analysis, including the noise contours.
(5) The use of the SEL contours and the sleep interference analysis assumed that FedEx would introduce quieter aircraft into its fleet in the future years assumed in this analysis. Although it is not possible to guarantee that these aircraft will be introduced, FedEx has represented that it plans to achieve this fleet conversion because of the age and fuel inefficiency of portions of its existing fleet.
3-26 Comment
How can noise levels at monitoring stations M4 and M5 be lower than current levels?
Response
Table 4.2.5-4 shows good correlation between the measured and modeled noise levels. The differences between the measured and modeled levels at Sites 1, 2,3 and 6 ranges between 0 and 2 dB. These four sites were located under major flight corridors off the ends of the main runway at PTIA. Sites 4 and 5 were located away from existing flight corridors, but were located where residential areas are projected to receive overflights of aircraft from the proposed new runway. Therefore, the measured noise levels at Sites 4 and 5 came from local noise sources only, and were located well away from the airport. Modeled noise levels for the existing conditions are expected to show that modeled levels were much less than measured levels. Using the data from Sites 1,2,3, and 6, the FAA can state that the modeled levels are accurate. The FAA has also found that the measured levels are a factor that validates the INM.
3-27 Comment
FAA's noise maps should include the 55 dBA LDN contour. The additional noise contour map will disclose areas impacted by 55-65 dBA LDN noise levels that are not currently addressed by standard FAA policy.
Response
The EIS depicts the DNL 65 dBA noise contour, in accord with the FAA's National Environmental Policy Act (NEPA) implementing instructions. As noted in FAA Order 5050.4A, "Airport Environmental Handbook," this level is the FAA's established significant noise threshold. The Order does not require that an EIS depict noise contours below DNL 65; however, the DNL 60 dBA contour can be presented to further disclose project-related noise, if local planning departments request this information. Predictions of DNL levels below 65 dBA become less reliable and accurate (Federal Interagency Committee on Noise, 1992), so FICON does not recommend using contours below DNL 65. FICON's decision not to recommend noise predictions below the DNL 65 dB is also based on its opinion that public health and welfare effects below DNL 60 dB have not been well established (Federal Agency Review of Selected Airport Noise Analysis Issues, Federal Interagency Committee on Noise, August, 1992).
The EIS describes the current noise environment around PTIA in Section 4.2.5, describes noise analysis methodology in Appendix B and B-2, and describes anticipated noise impacts for all alternatives in Section 5.1. For this study, the FAA also used various supplemental noise metrics, such as SEL and Time Above analysis, which are discussed in EIS Section 5.2.1.
3-28 Comment
PTAA has indicated that "tests" were being conducted and complaints were being evaluated, but the EIS does not contain any new data or test results. If the PTAA was conducting noise studies independently of the FAA, the results should have been disclosed to the FAA and included in the FEIS.
Response
The PTAA has indicated to the FAA that they are not conducting any "tests" at this time. The PTAA does accept and consider noise complaints when they are submitted. However, the PTAA does not at this time have any formal noise complaint program.
3-29 Comment
Noise monitoring for only a few days in the middle of January when airport activity is low is not adequate for baseline modeling.
Response
Short-term noise measurements on the order of a few days to a few weeks are typically not representative of average noise levels on an annual basis. However, it should be noted that the noise measurements were used to establish baseline noise levels in selected areas, and were not used for noise modeling purposes.
3-30 Comment
The flight tracks clearly show flights over the northern portion of the airport, yet no mitigation is proposed to the north.
Response
Mitigation for aircraft generated noise impacts will occur both to the north and south of PTIA. Figure 5.1.4-5 of the FEIS depicts the DNL 65, 70 and 75 dBA noise contours associated with the Preferred Alternative. These contours are overlaid onto a land use base map which depicts residential land uses within the Generalized Study Area. The residential land uses within the noise contours are indicated by a light-yellow color on the graphic. The 262 homes eligible for noise mitigation are represented by the residential land uses within the DNL 65 dBA noise contour on this graphic.
3-31 Comment
How can an average including nights that FedEx is known not to fly be included in the INM when SEL's are the true measure of disturbance?
Response
The INM and DNL metric provide a weighted average that is viewed as a reliable indicator of where noise will fall. With the extensive input the INM uses, including operational details of the proposed FedEx operations, the FAA believes that the results are good predictors of the noise boundaries associated with the proposed project. The FAA has followed all Federal guidelines in the preparation of the FEIS for the analysis of noise impacts associated with aircraft generated noise levels. FAA guidelines require the use of the DNL metric and the Integrated Noise Model (INM) to evaluate aircraft generated noise impacts in its NEPA documentation. Per established and recognized methodology, the DNL metric developed from the INM is based on total annual operations divided by 365 days per year, which yields an average annual day of aircraft noise.
The FAA does not use peak noise moments alone to indicate noise exposure because DNL is preferable. "DNL methodology has given consistent results in the national and international literature under a wide range of noise conditions, including loud and soft noise levels and frequent and infrequent numbers of aircraft noise events. Much of the criticism of the use of YDNL for community annoyance and land use compatibility around airports may stem from a failure to understand the metric. Another factor may be that some persons exposed to aircraft noise do not accept DNL 65 dB as the appropriate lower limit of noise exposure in considering noise impact.
"An average sound metric such as DNL takes into account the sound levels of all individual events that occur during a 24-hour period and the number of times those events occur. The averaging of sound over a 24-hour period does not ignore the louder single events, and it actually tends to emphasize both the sound level and number of those events. This is the basic concept of a time-averaged sound metric, and specifically DNL. The logarithmic nature of the dB unit causes sound levels of the loudest events to control the 24-hour average." (Federal Agency Review of Selected Airport Noise Analysis issues, Federal Interagency Committee on Noise, August 1992, page B-16).
The FAA supplemented the DNL analysis in the FEIS to further disclose and evaluate the specifics of Fed Ex operations by presenting additional noise analysis data, either in the body of the document or in the technical appendices. This supplemental noise analysis includes noise metrics such as single event noise levels (Sound Exposure Levels or SELs) and average noise levels (Leq noise levels at night - 10:00 p.m. to 7:00 a.m. or Leq(9)).
SELs were used to evaluate potential sleep disturbance impacts, while the Leq(9) were used to evaluate noise impact at night, since the time periods analyzed could be narrowed down to the typical air cargo nighttime hours of operation. The results of the SEL analyses are contained in Tables 5.1.3-4b and 4-c for all alternatives, and depicted in Figures 5.1.3-3, -4, -6, -7, -9, -10, -12, -13, -15, -16, -19. Note that in this EIS, the 100 dBA SEL contour was contained within the DNL 65 dBA contour.
Piedmont Triad International Airport
4. Land Use
4-1 Comment
By allowing residential development close to the airport, the Airport Authority and Guilford County have failed to make provisions for the possibility of a nighttime air cargo operation. They have allowed land use incompatibility to develop over the years and they should not now be allowed to change course at the expense of the community.
Response
The PTAA has worked with local municipalities and planning jurisdictions to prevent to the extent possible, the development on non-compatible land uses in the PTIA area. However, the PTAA does not have land use or zoning control over the lands outside the airport property boundary and cannot prevent the development of non-compatible land uses if they are allowed by local governments. PTAA was required to provide, and did provide, a land use assurance to the FAA (see FEIS Appendix J), which represents its commitment to work towards land use compatibility in all local areas affected by airport operations.
4-2 Comment
The project is not eligible for federal aid because it is not "reasonably" consistent with existing plans of public agencies for the development of the area in which PTIA is located", and "fair consideration has [not] been given to the interest of all communities in or near which the project is located".
Response
"It has been the long-standing policy of the FAA to rely heavily upon actions of metropolitan planning organizations (MPO's) to satisfy the consistency requirement of 49 USC 47106(a)(1). However, under the provisions of Federal and state law, no MPO has been designated for the Greensboro metropolitan area and given primary responsibility for transportation planning in the region. Instead, the affected jurisdictions have approached airport area planning by jointly developing an area use plan, in addition to individual locality plans. Both the legislative history and agency interpretations of the statutory provision that requires consistency make it clear that ""reasonable"", rather than ""absolute"", consistency is what is required."
At this time, Alternative W1-A1 is not consistent with the existing 1986 Airport Area Land Use Plan adopted by Guilford County, the City of Greensboro, and the City of High Point. However, the FAA has been advised that the update of that plan is in progress and that it will make the land use modifications necessary to accommodate the Preferred Alternative. The FAA has received reasonable assurance from PTAA that these agencies will adopt updated plans for development of the area surrounding the airport that are reasonably consistent with the project, and that this precondition for Federal funding will be met.
The FAA has determined that fair consideration was given to the interests of the communities where the project is located, through the EIS scoping, public workshop and hearing, and comment processes. PTAA has coordinated its developing plans and proposals with neighboring communities. Coordination between PTAA and neighboring jurisdictions concerning local planning proposals, public meetings, hearings and other occasions for public participation are discussed in FEIS Section 5.2. PTAA is also included in the current effort to update the Airport Area Land Use Plan.
4-3 Comment
Over the past 25 years, there is no evidence that the PTAA or the FAA, although "required, as a minimum, to use their best effort to assure proper zoning or other land use controls near PTIA", have done anything to encourage development of appropriate compatible land use controls in connection with possible construction of a parallel runway.
Response
PTAA and FAA have no zoning authority to regulate local land use. The PTIA cooperated with the Cities of High Point and Greensboro and Guilford County with the preparation of the 1986 Airport Land Use Plan and is now working with the local governments to update the Airport Area Plan as noted in Section 4.2.1.4 of the FEIS.
4-4 Comment
Where are the locations of the 262 families that are being impacted?
Response
Figure 5.1.4-5 of the FEIS depicts the DNL 65, 70 and 75 dBA noise contours associated with the Preferred Alternative. These contours are overlaid onto a land use base map which depicts residential land uses within the Generalized Study Area. The residential land uses within the noise contours are indicated by a light-yellow color on the graphic. The 262 homes eligible for noise mitigation are represented by the residential land uses within the DNL 65 dBA noise contour on this graphic.
4-5 Comment
The FEIS underestimates the number of residences that will be affected by this project.
Response
The estimates of the number of homes and people impacted by the reasonable alternatives is based on the most recent data available to the FAA as of the publication of the Draft and Final EIS documents. The methodology and data used to develop the noise contours is described in detail in Section 5.1.2 of the FEIS. The methodology and data used to determine the number of homes and people impacted by the alternatives is fully described in Section 5.3.2 of the FEIS.
4-6 Comment
There is no mention in the EIS that the ALP that PTAA recently submitted is incompatible with current surrounding land use.
Response
Please see response to Comment 4-2.
Piedmont Triad International Airport
5. Social Impacts
5-1 Comment
I purchased my home in January 2001 and was informed by the developer that it would not be within the noise contour.
Response
The Draft EIS, which contained the noise contours associated with all of the reasonable alternatives, has been available for public review at local libraries and the PTAA Administrative Office since April 2000. The noise contours contained in the FEIS did not change between the issuance of the DEIS and the FEIS. The FAA is not responsible for the actions of developers or individuals with regard to the dissemination of information that is contained in the DEIS or FEIS documents.
5-2 Comment
How does the FAA reconcile the difference between the FEIS assertion that there is "no significant correlation" between declining average home prices and the announcement of the airport improvement project when published newspaper articles indicate home prices trended up before the announcement of the improvements and down after the announcement?
Response
Review of recent newspaper articles indicates that the announcement of the Mid-Atlantic Hub at PTIA has had a varied affect on home sales and resales in the area around PTIA. The articles concluded that the affect greatly depended on the location of the individual home. The FAA's basis for the conclusions made in Section 5.3, Social Impacts, of the FEIS are discussed in detail in Appendix E, Section 7.
5-3 Comment
By picking which factors would be emphasized in the FEIS analysis and setting limits on calculating noise and air pollution, the FAA is allowing the condemnation of private property and/or decline in property values to support a private company.
Response
The FAA conducted a thorough evaluation of potential impacts to 23 environmental categories, as proscribed by FAA Orders 5050.4A and 1050.1D. None of the categories were emphasized over any other. Those that resulted in greater impacts were discussed in greater detail in order to more fully disclose potential environmental impacts. The FAA used the "thresholds of significance" established in its Orders to determine whether a significant impact would occur or not.
5-4 Comment
The negative impact to our community outweighs the dubiously positive outcomes of FedEx locating in our area.
Response
Comment noted. The impacts of the proposed project and Build Alternatives are discussed in Chapter 5 of the FEIS.
5-5 Comment
Purchasing thousands of homes and forcing people to relocate is wrong.
Response
Comment noted. As discussed in Section 6.3.1 of the FEIS, acquisitions for the Preferred Alternative W1-A1 would result in the purchase of 18 residences from construction activities as noted in Table 5.3.3-1. An additional 53 houses that are located in the DNL 70-75 and >75 dBA noise contour for Phase 2 would be acquired for noise mitigation as stated in Table 5.2.4-3. A total of 71 residences would be acquired.
5-6 Comment
The FEIS fails to estimate the economic harm which will be caused to nearby property owners.
Response
Section 5.3, Social Impacts, of the FEIS discusses potential impacts to property values as a result of implementation of the reasonable alternatives. Additional detailed information on the Property Value Analysis is contained in Appendix E, Section 7 of the FEIS.
5-7 Comment
Homes have declined in value since the FedEx announcement and no one will buy them.
Response
The FEIS property value analysis indicates that changes in noise contours resulting from changes in airport operations may have an affect on residential property values in the PTIA area. However, conclusive evidence has not been developed to-date because of the limited time-frame since the announcement of the potential hub and because no noise impacts from the operation of the hub have been realized yet. Over longer periods of time, a decrease in residential property value is often offset by an increase in overall property value in proximity to airports and elsewhere in the region as land uses change to accommodate more desirable and compatible uses. A detailed evaluation of potential property value impacts is contained in Section 5.3 of the FEIS and Section 7 of Appendix E in the FEIS.
Piedmont Triad International Airport
6. Induced Socioeconomic Impacts
6-1 Comment
Why is the cost-benefit analysis submitted to the FAA by PTIA not included in the FEIS? Where and how may the analysis be reviewed by the public?
Response
The cost benefit analysis was conducted as part of the ongoing Master Plan Update process and not part of the EIS process. Copies of the Benefit Cost Analysis can be obtained from the PTAA and/or the FAA upon request.
6-2 Comment
It would be useful to conduct a true cost-benefit analysis to determine whether tax incentives being given to FedEx would not be more beneficial in the long term if used to improve Greensboro's infrastructure.
Response
The FAA did not evaluate the tax incentive package being offered to FedEx by the State of North Carolina. The fiscal impact analysis discussed in Section 5.4.5 of the FEIS and Section 6 of Appendix E of the FEIS concludes that projected additional employment and population growth within the Six-County Socioeconomic Study Area has the potential to generate fiscal benefits for each of the counties included, reaching a total of nearly $15.4 million by 2019.
6-3 Comment
There is no evidence of economic growth resulting from the proposed project that would exceed the costs of the project.
Response
The FAA's evaluation of the socioeconomic impacts associated with the proposed project at PTIA are discussed in Section 5.4, Socioeconomic Impacts, and Appendix E of the FEIS. The results of this evaluation present FAA's best estimate of the economic impacts that would occur as a result of the development of the FedEx Mid-Atlantic Hub at PTIA. Based on this information, the long-term economic benefits experienced in the Triad area as a result of the proposed project would greatly exceed the project cost.
6-4 Comment
By using a selective economic analysis, the FAA only proved a pre-determined conclusion. The FEIS eliminated any comparison to any other hub except Memphis and used an inaccurate methodology of correlating increase cargo tonnage to employment growth.
Response
The technical memoranda included in the FEIS in Appendix E described in detail the analytical methodology and the testing of the cargo-based impact analysis model using several other air cargo hub locations. The report also included a detailed discussion of the results. In addition, the results of the analysis on other locations were reviewed in the context of independent studies prepared by others and reported in the text and in the list of references. The overall analytical approach used accepted trend analysis techniques and was unbiased in its application with results reported in their entirety as realized in the application.
6-5 Comment
The socioeconomic analysis is flawed. The FEIS fails to address the impact to the community from the induced growth that will result from the FedEx hub.
Response
The FEIS discloses the potential socioeconomic impacts of the reasonable alternatives in Section 5.4, Socioeconomic Impacts. Additional information concerning the impacts of induced growth is discussed to the extent practicable in FEIS Section 5.23, Cumulative Impacts.
Piedmont Triad International Airport
7. Air Quality
7-1 Comment
I am in strong opposition to the FedEx hub because of the air quality.
Response
Comment noted. In the FEIS, the FAA conducted a detailed analysis of the potential for air quality impacts as a result of the implementation of the reasonable alternatives for the development of PTIA. In accordance with the Federal Clean Air Act, FAA prepared both Draft and Final General Conformity Determinations for the Preferred Alternative and worked with the FHWA to evaluate whether the Preferred Alternative met the requirements for Transportation Conformity. As a result of these efforts, the FAA and the FHWA have made the determination that the Preferred Alternative, Alternative W1-A1, meets the requirements of both General and Transportation Conformity.
In other words, the FAA and the FHWA have determined that the emissions associated with the construction and operation of the Preferred Alternative are accounted for within the State of North Carolina State Implementation Plan (SIP). Both the Environmental Protection Agency (EPA) and the State of North Carolina Department of Environment and Natural Resources (NCDENR) have concurred with this finding.
7-2 Comment
I routinely have to clean the accumulation of black soot off personal items and often have to go inside because of the poor air quality.
Response
Citizen complaints and concerns about black deposits on outdoor items is shared by both those people that live near airports and those who do not. The atmosphere in an urban area is affected by many and varied sources of pollution that collectively contribute to the problem. As such, it is difficult, if not impossible, to differentiate those deposits that originate from aircraft from those that originate from motor vehicles, power plants, factories, etc. Air quality monitoring studies conducted at several major metropolitan airports across the U.S. have demonstrated this occurrence.
7-3 Comment
If the FedEx facility is approved, can you imagine what the noise and air quality will be like. The increase of trucks will also reduce the quality of air considerably.
Response
Sections 5.1.3 through 5.1.6 of the FEIS address noise impacts that will result from aircraft and non-aircraft (truck) operations at PTIA associated with the reasonable alternatives. The additional nighttime air cargo flights will result in more people living within the DNL 65+ dBA noise contours. In addition, the increased number of trucks and automobiles associated with the proposed new air cargo facility will slightly increase noise levels on roads leading to the air cargo sorting/distribution facility. However, these noise impacts will be mitigated by the PTAA as described in Section 6.3 of the FEIS.
The FEIS and the Final Draft General Conformity Determination analyses indicate that the increase in criteria pollutants will be de minimis except for volatile organic compounds and nitrogen oxides, the precursors of ozone. Through both the FAA General Conformity process and the FHWA Transportation Conformity process, it has been demonstrated by the FAA and FHWA that the emissions associated with the construction and operation of the Preferred Alternative are accounted for in the North Carolina State Implementation Plan (SIP). Therefore, the Preferred Alternative for development of PTIA will not interfere with the ability of the region to achieve the national ambient air quality standards for ozone.
7-4 Comment
Since we have moved to the Triad area, we have developed bad cases of allergies.
Response
Based on information available in the scientific literature, there is no known "cause-and-effect" between air emissions from planes and health problems around airports. Some studies are underway to better identify the potential contribution of aircraft emissions to overall air quality conditions in airport vicinities, but they are incomplete at this time. Diesel emissions from trucks and other heavy duty vehicles have been identified by the EPA as a source of toxic air emissions. As a result, new emission standards are being developed and implemented on new trucks to help reduce the potential impacts to health from these pollutants. Similar standards have not been imposed on aircraft engines.
7-5 Comment
Please inform me on how to measure Nitrogen Oxide by the TON and does a ton of air still weigh 2000 lbs.
Response
All atmospheric gases, including NOx, have weight. For example, the gram molecular weight of nitrogen dioxide (NO2) is 23 grams (N = 7 g. and 0 = 8 g.). By converting grams to pounds (1 lb. = 454 grams), then tons (1 ton = 2,000 lbs.), the weight of the gas can be determined in English units.
7-6 Comment
The additional air pollution has not been adequately accounted for. Using current conformity with levels of CO and PM as an excuse not to project and provide accurate layers of where these levels could be in 20 years is disturbing.
Response
The air quality analyses prepared for the EIS were conducted and completed in accordance with FAA and EPA guidelines. These current guidelines govern the analysis of CO and PM emissions. In addition to the FEIS analysis and the General/Transportation Conformity processes, the project will require a Transportation Facility Permit from the NCDENR Air Quality Division to proceed. The application for this permit examines CO emissions on a microscale level. Note that the EPA and NCDENR met with the FAA and worked closely on the air quality reviews and conformity determinations. Both EPA and NCDENR have accepted the analysis contained in the FEIS and the Conformity determination.
7-7 Comment
FAA should account for all project related emissions.
Response
The air quality analyses prepared in support of the EIS were conducted and completed in accordance with EPA and FAA guidelines. Following these guidelines, all project-related emissions are accounted for, including aircraft, GSE, on- and off-site vehicles and construction emissions.
7-8 Comment
Does the EDMS account for actual wind patterns due to the Piedmont's proximity to the Appalachian Mountain Range?
Response
The air quality analyses conducted in support of the EIS was based on emission inventory results. Because atmospheric dispersion modeling of emissions is not required as part of the EIS air quality analysis, the effects of wind patterns were not required to be included in the inventory and were not evaluated.
7-9 Comment
The project will exceed the de minimis levels for NOx in every year listed.
Response
When a project's or action's emissions exceed the CAA General Conformity Determination de minimis levels, this does not automatically indicate that these levels are prohibited. "De minimis" exceedances mean that further analysis and description is required, and that a General Conformity Determination must be completed to see if the Agency can ensure that the goals of the SIP are not delayed or compromised. The FAA analyzed and quantified the expected amounts of NOx emissions, as required. The results showed that the expected amounts fall within the allowable amounts prescribed by the SIP. The NOx emissions are therefore acceptable, under state as well as EPA standards.
Also, under 49 USC 47106, the Governor is required to review the proposed project and certify to the FAA his reasonable assurance that the project will be operated in compliance with applicable air and water quality standards. The Governor has provided this certification to the FAA, and it is attached to the FEIS and ROD.
7-10 Comment
The project will increase health problems due to excessive toxic emissions.
Response
Based on information available in the scientific literature, there is no known "cause-and-effect" between toxic air emissions from planes and health problems around airports. Some studies are underway to better identify the potential contribution of aircraft emissions to overall air quality conditions in airport vicinities, but they are incomplete at this time. Diesel emissions from trucks and other heavy duty vehicles have been identified by the EPA as a source of toxic air emissions. As a result, new emission standards are being developed and implemented on new trucks to help reduce the potential impacts to health from these pollutants. Similar standards have not been imposed on aircraft engines.
7-11 Comment
In looking for data on pollution release by aircraft engines, all I saw was a citation of the FAA Aircraft Engine Emission Database, which tells me nothing about the methodology nor verification. I challenge the accuracy of this database.
Response
The majority of the aircraft emission factors were obtained from the FAA Emissions Dispersion Modeling System (EDMS) database and supplemented, wherever necessary, with data from the older FAA Aircraft Engine Emission Database. These sources are considered to be the most accurate available for aircraft engine emission factors.
7-12 Comment
Of the thousands of tons of fuel burn, how much is CO, NOx, VOC, and PM-10? More importantly, how is it measured and how can this be verified?
Response
The primary fuel combustion by-products of aircraft engines are energy, water vapor and carbon dioxide. Emissions of CO, NOx, VOCs and PM-10 also occur but in much smaller quantities. These amounts are determined by aircraft engine manufactures and regulated by international standards. The results are expressed as aircraft engine emission factors, which are used in support of the air quality analysis for the EIS.
7-13 Comment
EPA has informed the FAA that all of our concerns had been adequately address and we believe the project meets the requirements of General Conformity. In addition, it appears that the road improvements associated with the proposed project are compliant with Transportation Conformity requirements.
Response
Comment noted.
7-14 Comment
The FEIS should have analyzed the impact from air toxics.
Response
Based on information available in the scientific literature, there is no known "cause-and-effect" between toxic air emissions from planes and health problems around airports. Some studies are underway to better identify the potential contribution of aircraft emissions to overall air quality conditions in airport vicinities, but they are incomplete at this time. Diesel emissions from trucks and other heavy duty vehicles have been identified by the EPA as a source of toxic air emissions. As a result, new emission standards are being developed and implemented on new trucks to help reduce the potential impacts to health from these pollutants. Similar standards have not been imposed on aircraft engines.
Piedmont Triad International Airport
8. Hazardous Materials
8-1 Comment
Since the UST program is primarily a delegated program, the State of North Carolina should be contacted regarding site investigations, possible tank removals, site clean-ups, and compliance with any associated State permitting.
Response
PTAA has already contacted the State in connection with the UST program. PTAA's Spill Prevention Control and Countermeasure Plan (SPCC), prepared for the State, has already been accepted. The plan addresses the potential for spills, the potential for discovery of unknown tanks, and PTAA's procedures for handling these events, should they occur. FEIS Section 4.3.7.2 describes PTAA's spill prevention plan, and FEIS Appendix H contains the database searches that were conducted to locate tanks in the project study area.
Piedmont Triad International Airport
9. Water Quality
9-1 Comment
Please provide careful and accurate analysis of the effects of the massive amount of additional impervious surfaces called for under the proposed improvement plan.
Response
The additional impervious surface from the proposed project will increase surface water runoff volumes and decrease the amount of water percolating to groundwater in the immediate vicinity of the proposed project. However, this surface water runoff will remain within the following three sub-basins on PTIA property; Brush Creek, Horsepen Creek and the East Fork Deep River. The surface water runoff generated from the new development will be collected in storm sewers, which will discharge to stormwater detention ponds for treatment and attenuation. Ground water recharge will occur within these detention ponds. These ponds will then discharge to either Brush Creek, Horsepen Creek or the East Fork Deep River.
PTAA must and will meet whatever limits the State of North Carolina specifies pursuant to the NPDES permitting process. PTAA will also use Best Management Practices in the draft Stormwater Protection Plan it continues to develop in connection with the NPDES process. The Plan incorporates any future land development, including the proposed development, in the overall specification to minimize water quality impacts. Mitigation measures described in Section 6.3 of the FEIS discuss PTAA's proposal to protect area waters receiving flows associated with impervious surfaces.
9-2 Comment
I request a detailed analysis of the annual loss of water to the Greensboro and High Point water systems due to the increased amount of impervious surfaces.
Response
New impervious surfaces cover up existing pervious areas where water historically infiltrated to the underlying aquifer. This water becomes stormwater runoff, which will be collected in adequately designed stormwater ponds constructed by the PTAA. These ponds retain water that will then infiltrate the underlying ground water aquifer. Section 5.6 of the FEIS provides an evaluation of the effects to ground water recharge areas as a result of the reasonable alternatives.
Impacts to groundwater recharge areas can be minimized with the use of Best Management Practices designed to treat and attenuate stormwater runoff. FEIS Section 6.3 of the FEIS, Preferred Alternative Mitigation Program, describes these practices in more detail.
9-3 Comment
The proposed project will have an adverse effect on the quality and quantity of water and the physical environment.
Response
As discussed in Section 5.6 of the FEIS, implementation of any of the Build Alternatives would not result in significant impacts in terms of water quality and water supply in the Triad area. Detailed discussion on the existing water quality and supply, water quality and supply impacts and water quality mitigation is located in Section 4.3.3.3, Water Supply, Section 5.6, Water Quality and Section 6.3 of the FEIS, respectively. It has also been determined by the Governor's office that there is reasonable assurance that the proposed project will be located, designed, constructed, and operated in compliance with applicable air and water quality standards. The Governor provided this assurance to the FAA in writing, as required by 49 USC 47106(c)(B), and supports the FAA's belief that the proposed project will not create unmitigated adverse effects on the physical environment.
In addition, the Section 404 and 401 permitting/certification process and the NPDES permitting process are underway. PTAA has submitted applications for these permits to the appropriate agencies, which will not issue permits/certification until relevant water quality and mitigation issues have been resolved to their satisfaction.
9-4 Comment
I request that the FAA assure citizens that the massive paving and building plans will not reduce or pollute the available ground water supplies and in so doing jeopardize the existing wells for both individual dwellings and industrial facilities.
Response
Section 5.6 of the FEIS provides a detailed discussion of the water quality impacts associated with the reasonable alternatives to the proposed project at PTIA. As discussed in this section, each of the alternatives will result in increases in impervious surface and stormwater runoff. However, measures to mitigate these impacts have been developed and are discussed in Section 6.3 of the FEIS. The mitigation measures include the development of stormwater retention/detention ponds for water quality and quantity attenuation as well as the implementation of Best Management Practices (BMP's) during the construction and operation of the facilities. The PTAA has committed to implementing these mitigation measures upon approval of the proposed project by the FAA. The FAA, in turn, has made it a condition of project approval in the ROD that these mitigation measures be implemented by the PTAA.
9-5 Comment
There is insufficient information in the FEIS that the proposed action will sufficiently mitigate the discharge of pollutants into the municipal water supplies, and as a result will pose an adverse effect on the municipal water supply.
Response
As discussed in Sections 6.2.4 and 6.3.4 of the FEIS, the PTAA has adopted new watershed protection rules which meet the requirements of local, county and state regulations pertaining to stormwater quality and quantity treatment. The PTAA's watershed protection rules have been approved by the Water Quality Committee of the North Carolina Environmental Management Commission. The PTAA watershed protection rules are being incorporated into the PTAA's Stormwater Management Plan (SWMP). The SWMP will provide design guidelines for the design of all projects on PTIA property such that all stormwater discharges meet current State of North Carolina stormwater quantity/quality treatment requirements.
9-6 Comment
The FEIS needs to address soluble pollutants and others like " wear of brakes, tires, paint, oil, and grease from vehicle drippings, heavy metals, and fuel and oil spills", not just total suspended solids.
Response
Elements 4.1, 4.2 and 4.3 of the Mitigation Program for the Preferred Alternative, which are discussed in Section 6.3 of the FEIS, detail the PTAA program to prevent the introduction of airport-related pollutants into receiving water bodies. In addition, the PTAA will be preparing and submitting an individual National Pollutant Discharge Elimination System (NPDES) permit to the State of North Carolina which will establish pollutant limits specifically applicable to PTIA.
9-7 Comment
It is not evident that the F sites (as noted in the SWMP) will remove 85% of TSS, let alone the nutrients, oil, and grease, rubber, deicing agents etc. Since these structures appear to be on the edge of the hub facility and adjacent to the Brush Creek floodplain, it appears this limits the feasibility of other downstream BMP's to achieve the removal of pollutants such as an extended detention wetland. Dry detention ponds with grass swales is a combination, which will not remove the majority of the pollutants from this large impervious area.
Response
The exact type, size, configuration and location of stormwater treatment ponds at PTIA will not be determined until the design phase of the proposed project is underway. As discussed in Section 5.6 of the FEIS and in Element 4.1 of the Mitigation Program for the Preferred Alternative, removal of 85 percent of TSS for non-point source stormwater runoff is the current state standard established by the NCDENR. The ponds designed by the PTAA will meet this as well as any other quality/quantity treatment requirements in effect at the time final design of the proposed project is completed.
9-8 Comment
The net effect of hydrology and hydraulic calculation errors will result in less than the required control or will raise the top of dam of these sites if County criteria is met. A review is recommended by an outside consulting firm to review the designs in the SWMP and should be done before final approval of the EIS.
Response
The calculations for the exact type, size, configuration and location of stormwater treatment ponds at PTIA will not be finalized until the design phase of the proposed project is underway. The calculations contained in the FEIS are based on preliminary data only. The FAA and the PTAA acknowledge that these calculations will in all likelihood be revised during final design.
9-9 Comment
The EPA recommends that the FAA ROD address water issues and provide assurance for the successful completion of the ongoing NPDES and 404 permitting processes which would be needed in order for the proposed project to go forward.
Response
The FAA has reiterated in the ROD that the PTAA must obtain the necessary NPDES permits, Section 404 permit, and state Section 401certification before the proposed project can proceed. PTAA has already engaged the NPDES process, which is underway, and has started the 404 and 401 permitting/certification processes. The FAA is satisfied that through the consideration of PTAA's permit applications, the authorizing agencies will ensure proper handling of stormwater. The Section 404 permit process, which is particularly rigorous, will address wetland and other water quality mitigation plans in detail, and will require these plans to be modified or amended until they are acceptable.
9-10 Comment
EPA is concerned that PTIA is an unpermitted industrial waste (stormwater) discharger and that PTAA does not currently monitor the quantity of its stormwater runoff at PTIA. EPA is concerned that such unpermitted discharges may cause water quality impacts to Brush and Horsepen Creeks.
Response
Please see response to Comment 9-9, and note that through the NPDES process, which is already underway, PTAA will be required to develop and adhere to an appropriate stormwater management plan.
9-11 Comment
The FEIS fails to quantify the adverse environmental impacts from runoff.
Response
Section 5.6 of the FEIS discloses potential impacts from stormwater runoff associated with the reasonable alternatives. Section 6.3.4 of the FEIS presents the Mitigation Program for the Preferred Alternative which contains three measures to mitigate potential water quality impacts.
9-12 Comment
A dedicated deicing agent collection system MUST be required for the proposed air cargo facility.
Response
PTAA's strategy for the treatment of glycol-laden runoff is discussed in Sections 5.6, 6.2 and 6.3 of the FEIS.
9-13 Comment
What will be the impacts of each alternative on the increased nutrient loading into Greensboro's drinking water supply?
Response
Increased nutrients can adversely affect aquatic life by lowering dissolved oxygen concentrations with increases in the Biochemical Oxygen Demand (BOD). The greatest threat to increased nutrient loadings from airports is deicing wastewater because of the glycol content. PTAA's strategy for the treatment of glycol-laden runoff is discussed in Sections 5.6, 6.2 and 6.3 of the FEIS.
9-14 Comment
Now the replenishing of ground water will be restricted and what does flow into the aquifer will be polluted with airplane emissions.
Response
Impacts to groundwater recharge are located in the subheading "Groundwater Recharge/Discharge" for each alternative in Section 5.6, Water Quality in the FEIS.
Piedmont Triad International Airport
11. Historic Architectural and Archeological
11-1 Comment
It is premature for the FAA to approve the use of any historic sites.
Response
The FAA uses the FAR Part 150 Noise/Land Use Compatibility Guidelines from FAR Part 150, Appendix A, Table 1 to determine the compatibility of various land uses with aircraft generated noise levels. The FAA used the DNL 65 dBA noise contour to establish the Historic Resources Area of Potential Affect (APE) for this EIS, and believes that the contours were properly developed and depicted. Based on the noise contour/land use/historic resources analysis conducted by the FAA, the agency determined that the Preferred Alternative would have an indirect adverse effect upon (and not a direct use of) the Campbell-Gray Farm. The indirect effect is due to significant increases in noise; the North Carolina SHPO concurs with this determination. A Memorandum of Agreement (MOA) has been executed by the FAA, SHPO and PTAA to address the adverse noise impact on this resource. Please see Chapter 6.0, Mitigation, of the FEIS and the MOA in Appendix G of the FEIS.
The integration of the NEPA process and the Section 106 process is an approved methodology for the early identification, avoidance and mitigation of impacts to historic resources. This early intervention and study is preferred under NEPA and is not considered premature.
Piedmont Triad International Airport
13. Endangered and Threatened Species
13-1 Comment
The FEIS fails to give sufficient information regarding threatened and endangered species field studies for the public and other agencies to be able to determine the value of those studies.
Response
The FAA coordinated its evaluation of the potential for impacts to protected species with the Department of Interior. The Department of Interior provided correspondence to the FAA stating that it "concurs with the FAA's findings that this project is not likely to adversely affect any Federally listed species, their formally designated critical habitat, or species currently proposed for Federal listing under the Act" (see Appendix A of the FEIS).
13-2 Comment
There are discrepancies contained within the FEIS regarding the Bald Eagle.
Response
The Detailed Study Area evaluated in the EIS consists of the airport property and any area that would be physically disturbed as a result of implementation of any of the reasonable alternatives. As stated in Chapter 4, the Detailed Study Area does not contain preferred habitat for the Bald Eagle. Chapter 5, Section 5.10 of the FEIS explains that habitat within the Detailed Study Area is marginal for the Bald Eagle, and that the area may be used for occasional forage or migration. Because the Bald Eagle has the potential to occur in virtually any habitat type, the FAA included Bald Eagle habitat disturbance in Table 5.10.2-1 to disclose a possible worst case scenario of potential habitat disturbance. It is true that an active Bald Eagle nest has been documented within 3 to 5 miles of the PTIA. However, this area is outside the Detailed Study Area, and contains very different habitat types than that found within the Detailed Study Area.
The Department of Interior provided correspondence to the FAA stating that it "concurs with the FAA's findings that this project is not likely to adversely affect any Federally listed species, their formally designated critical habitat, or species currently proposed for Federal listing under the Act" (see Appendix A of the FEIS).
Piedmont Triad International Airport
14. Wetlands
14-1 Comment
In June 2001, the USACE rejected the Burlington sites that were listed for mitigation purposes because they were not located in the same river basin or county as PTIA. Therefore, the FEIS provides inaccurate information for concerned citizens.
Response
The FAA believes that to the best of its ability, it has provided accurate information to the public with regard to wetlands mitigation issues. The Section 404 Permitting process is under the jurisdiction of the USACE, and not the FAA. The PTAA has been working with the USACE to determine appropriate mitigation for the wetlands impacts associated with the Preferred Alternative at PTIA. The FAA, in coordination with the PTAA, presented the latest version of the draft wetlands mitigation plan in the FEIS, with the understanding that it was still subject to change based on negotiations between the PTAA and the USACE. The final mitigation plan will be included in the Section 404 Permit Application submitted by the PTAA to the USACE. This application will be available for public review by concerned citizens.
14-2 Comment
The FEIS does a disservice to our citizens and our environment by taking the approach of replacing wetlands in geographical locations situated far away from Guilford County. In addition, manmade wetlands are a poor substitute for the real thing.
Response
The PTAA has been working with the USACE to determine appropriate mitigation for the wetlands impacts associated with the Preferred Alternative at PTIA. The final mitigation plan will be included in the Section 404 Permit Application submitted by the PTAA to the USACE. This application will be available for public review by concerned citizens. The USACE will make the determination as to whether the PTAA's proposed mitigation program sufficiently provides compensatory mitigation for lost wetland functions and values.
14-3 Comment
EPA does not believe PTAA's current mitigation plan provides adequate compensation for the proposed wetland impacts. We believe it may be difficult for PTAA to adequately compensate for impacts to such high quality systems. EPA Region 4 Wetlands Regulatory Section plans to continue working with PTAA and other resources agencies to address concerns with the mitigation plan.
Response
Comment noted. The PTAA has been working with the USACE to determine appropriate mitigation for the wetlands impacts associated with the Preferred Alternative at PTIA. The final mitigation plan will be included in the Section 404 Permit Application submitted by the PTAA to the USACE. This application will reflect the recommendations of the EPA. The USACE will make the determination as to whether the PTAA's proposed mitigation program sufficiently provides compensatory mitigation for lost wetland functions and values. If PTAA's current mitigation plan does not meet the exacting standards of the USACE, it will be changed (this is a frequent feature of the Section 404 permitting process, i.e., mitigation plans are revised, modified, and at time completely redesigned, to ensure that wetlands mitigation will be not only appropriate, but appropriately located).
14-4 Comment
EPA does not object to the use of treated stormwater as a source of hydrology for compensatory mitigation projects provided that there is adequate treatment of the water prior to discharge to the wetlands. However, during the 404 permitting process, EPA Region 4 expects to object to any proposals to utilize waters of the U.S. (including mitigation areas) for stormwater treatment for this proposed facility.
Response
Comment noted. The PTAA anticipates that all discharges from stormwater quality/quantity treatment ponds will meet state water quality standards. At this time, the PTAA does not anticipate the use of wetlands as water quality treatment facilities. The Section 404, 401, and NPDES permit processes are expected to continue in a rigorous manner, and PTAA has assured the FAA that it will cooperate with the authorizing agencies and will meet the required environmental protection standards that permits require.
14-5 Comment
The FEIS does not demonstrate that this project meets strict requirements for destroying wetlands under Section 404 of the Clean Water Act. In addition, the 404 mitigation plan is not sufficient.
Response
Comment noted. Please see response to Comment 14-3.
Piedmont Triad International Airport
18. Solid Waste Impacts
18-1 Comment
It needs to be highlighted that landfill capacity is indeed an issue for the Piedmont Triad. Our area has experienced a population boom, and it is projected that the Greensboro landfill will be full by the year 2008. Some have projected that the landfill will be full by 2005. It is misleading to indicate that the landfill has adequate capacity.
Response
According to the City of Greensboro, the White Street Landfill's Phase III will have a life span of 7.25 years, or until March 2004. Future phases of the landfill have not yet been developed for the remaining 178 acres of land designated to hold MSW. See Section 5.18.2 of the FEIS for more information. According to the City of Greensboro, the White Street Landfill has adequate capacity until 2007 to accommodate the increase in MSW as a result of the proposed project. The City of Greensboro does not predict landfill capacity past the year 2007 for customers outside the city limits.
Piedmont Triad International Airport
21. Public Involvement
21-1 Comment
I request an extension of time for submitting comment. The comment period established by the FAA includes Thanksgiving and Hanukkah. This will make it difficult to submit comments within the 30-day time period. I ask that the FAA grant a 21-day extension for submitting comments.
Response
The DEIS has been available for public and agency review since April, 2000. The FAA made substantial changes to that document in response to public and state, federal, and local agency comments. The FEIS, published in November, 2001 contains those changes. Those portions of the FEIS that were substantially revised, or supplemented with additional analysis, were highlighted in Chapter 1 of the FEIS to assist non-FAA reviewers with quickly finding and reviewing the new information. The FAA decided to issue its ROD in accord with CEQ regulations (40 CFR 1506.10), which state a decision on a proposed action may not be taken until 30 days after publication of the Federal Register notice announcing issuance of the FEIS. The FAA has diligently reviewed, analyzed, and responded to comments received throughout the EIS process, and has used the comments to modify its analyses as appropriate. All comments, including those received after publication of the FEIS, have been reviewed and considered in connection with issuance of this ROD.
21-2 Comment
The response to Comment 3-140 of the FEIS ignores the fact that PTIA already has a record of noise complaints relating to the operations of its two existing runways (as indicated in the attached response letter from the airport's executive director). Why is the existence of PTIA noise complaint records not acknowledged in the FEIS?
Response
The FEIS analysis of environmental impacts focuses on the potential future impacts of the proposed project or "build alternatives" compared to the future No-Action Alternative impacts. Because of the unique operational scenario that will be employed by FedEx after the establishment of the Mid-Atlantic Hub, complaints based on current operational conditions cannot be directly correlated to the revised future operational conditions.
21-3 Comment
A month prior to the release of the FEIS, a member of the governor's staff attended a meeting between the NCDNER, PTIA, FAA and FedEx to discuss the sufficiency of air quality impact projections. Is it the FAA's standard practice to invite and/or allow political appointees from the staff of the governor of the state in which a proposed airport construction project is located to attend non-public meetings between state regulators and FEIS stakeholder? If so, what is the governor's staff member's role in the FEIS process? If not so, why was one of the governor's staff members invited and allowed to attend a meeting between state regulators and parties with a vested interest in getting approval for the project under review by the regulators?
Response
The attendees at the referenced meeting consisted of the FAA, the FAA's consultant, the PTAA, and the NCDENR (FedEx did not participate in the meeting). The purpose of the meeting was to discuss the air quality analysis conducted by the FAA for to the General Conformity Determination, and the status of the State Implementation Plan (SIP). The FAA did not invite representatives of the Governor's office to attend or participate. However, a representative of the Governor was present. Since the meeting included state regulators who report to the Governor, it was not appropriate to restrict the representative from attending.
In addition, it is necessary for the Governor to rely on state regulators to provide the information he needs to evaluate the environmental implications of the proposed project. This is necessary so that the Governor can decide whether or not to provide the certification to the FAA required by 49 U.S.C. 47106(c)(B). This statute says airport development projects can only be approved if the Governor certifies in writing to the Secretary of Transportation that there is reasonable assurance that the project will be operated in compliance with applicable air and water quality standards. Since the meeting did take place to discuss air quality issues, it would be a source of information pertinent to the Governor's certification decision.
21-4 Comment
Why are certain comments printed as "RESERVED" with no responses? How may the public review these "RESERVED" comments?
Response
In the FEIS Comment Database, "Reserved" simply means that a comment has been moved from one comment category to another, and a place-holder has been left so as to not have to re-number all subsequent comments in that category. For example, a comment was originally coded as a comment on Category 1, "Purpose and Need". However, further review by the FAA indicates that the comment really pertains to comment Category 2, "Alternatives". The comment was removed from the "Purpose and Need" category, the statement "Reserved" was used to replace the moved comment and the original comment was placed in the "Alternatives" category.
21-5 Comment
Why does the Degree of Controversy section of the Executive Summary exclude appointed officials use of millions of public dollars to fund a for-profit corporation without prior input from or notice to the community?
Response
The "Degree of Controversy" section of the FEIS pertains to the amount of concern raised over the project based on environmental grounds, and does not typically discuss political issues.
21-6 Comment
Why has a Citizen's Advisory Committee never been established?
Response
The FAA is not required to establish a Citizen's Advisory Committee (CAC) for an EIS project. In fact, in the EIS process, the FAA is expressly forbidden by Federal law, from forming an advisory committee whose purpose is to reach consensus on a proposed program. CAC's are more typically part of a Master Plan or FAR Part 150 noise study where a consensus on a proposed project or plan is generally sought and then implemented .
21-7 Comment
I am upset that I was not part of any decision making process for something that affects me so directly.
Response
Federal, state, and local agencies as well as the general public have been given opportunities to express comments and concerns on the proposed development at PTIA since the EIS process was started. All letters, e-mails, and petitions have been read by the FAA, are a part of the EIS, and have been incorporated into this Comment/Response Database. Decisionmaking is reserved to the Federal agency, which accepts and evaluates input from interested parties before making that decision.
21-8 Comment
The public has been given a massive amount of misinformation and somebody needs to collate and deliver accurate information in a way the general public can understand.
Response
The FAA has compiled accurate information on the impacts associated with the proposed project and reasonable alternatives in the DEIS and FEIS documents. The FAA makes every attempt to present the information in the EIS in a manner such that it can be fully comprehended by all readers. However, due to the nature of the technology used in some of the analyses, this goal is not always achieved. One of the reasons that the FAA conducted public Scoping as well as Information Workshops and a Public Hearing was to provide the public an opportunity to ask questions and clarify any information contained in the EIS document that was unclear or hard to understand.
21-9 Comment
Citizens were never informed through public hearings, community notification or community input of any airport development plans until the announcement of the expansion was made.
Response
The decision to invite FedEx to PTIA was made by the PTAA. PTIA requested environmental approval from the FAA in connection with its intent to seek Federal funds for the development of a cargo hub. Once PTAA presented its proposal to the FAA, the FAA issued a Notice of Intent to prepare an EIS, advertised and held a Scoping Meeting, two Public Information Workshops, and conducted a Public Hearing on the DEIS. Throughout the entire EIS process, up to and including the issuance of this ROD, the FAA has also accepted comments from affected agencies and from the general public.
21-10 Comment
None of the citizens comment letters against the FedEx hub and third runway were printed in full in the DEIS.
Response
All comment letters received by the FAA were summarized and included in the Comment/Response Database. Copies of all letters received over the course of the EIS study are included in a supplemental reference volume to the FEIS, which is available for review at the PTAA Administrative Office.
Piedmont Triad International Airport
22. Cost Considerations
22-1 Comment
The sorting facility is being funded by a revenue bond and not Federal funds. Therefore, the inclusion, analysis, and evaluation of a sorting facility funded with private funds and leased to a private corporation in the EIS is improper.
Response
Although the proposed sorting/distribution facility is being privately funded, it is considered by the FAA to be a "connected action" to the proposed new runway project in terms of timing and proximity. The FAA is obligated, under Federal regulations, to evaluate the environmental and social impacts associated with it. Also, the area surrounding the actual building includes aircraft service areas, such as aprons and ramps, that must meet FAA design specifications.
22-2 Comment
The project will not provide enough economic benefit to warrant the expense of the third runway.
Response
The FAA's evaluation of the socioeconomic impacts associated with the proposed project at PTIA is discussed in Section 5.4, Socioeconomic Impacts, and Appendix E of the FEIS. The results of this evaluation present FAA's best estimate of the economic impacts that would occur as a result of the development of the FedEx Mid-Atlantic Hub at PTIA. Based on this information, the FAA expects that the long-term economic benefits experienced in the Triad area as a result of the proposed project would exceed the project cost.
22-3 Comment
The Citizens Scoping Alternative costs far less than the proposed action by PTIA.
Response
The FAA considers numerous factors in the evaluation of alternatives for a proposed project. Although an alternative may cost less to construct, it may also result in greater environmental and/or social impacts. The FAA strives to reach a balance. However, this combination of factors is not always available.
In the case of the Citizens Scoping Alternative, this alternative did not meet the purpose and need for the proposed project, therefore it was not retained for further consideration by the FAA, particularly in light of its proposed runway configuration and package processing facility location. Please see Chapter 3, Alternatives, of the FEIS for more information.
22-4 Comment
FAA uses the cost of the project as a method of determining the feasibility of alternatives without including the source of the cost information. Also, the Benefit Cost Analysis is misleading and should not have been relied upon by the FAA in reviewing alternatives.
Response
The FAA used the cost of each of the alternatives in the Level 2 alternatives screening analysis as one of numerous factors to evaluate the feasibility and reasonableness of the alternatives. As can be seen from review of FEIS Chapter 3, Alternatives, the cost of an alternative in the Level 2 screening process, whether it came from the Benefit Cost Analysis or other preliminary design estimates provided by the PTAA, was not used as a criteria that eliminated any alternative from further consideration.
22-5 Comment
It's unlawful and wrong to use federal tax money to supplement private enterprise.
Response
The proposed improvements to the PTIA will be funded through numerous sources, including the federal airport trust fund. The improvements themselves, with the exception of the package processing facility, will be available to other airport users. Public airports provide operating sites for air carriers that engage in private enterprise, and Congress has made public funds available to these airports, pursuant to a rigorous grant application process. Airports may receive these funds if their proposed projects meet FAA as well as other national and local standards.
Piedmont Triad International Airport
23. EIS Process and Scope
23-1 Comment
Will the FAA provide statistics on the number of airport projects proposed, declined, or significantly modified for whatever time period the FAA has those statistics available?
Response
The FAA does not maintain statistics on how many airport projects have been approved, declined or significantly modified.
23-2 Comment
The entire EIS process has been carried out from the perspective of justifying the project to suit the business plan of a private company.
Response
The FAA has conducted a comprehensive, impartial and independent evaluation of the proposed project, including the evaluation of Purpose and Need, Alternatives, and environmental impact analysis.
23-3 Comment
The FAA does not have the expertise to conduct and assess effects of environmental agents on human health, nor do they have the personnel with qualifications to oversee and assure its quality of the analysis conducted by the consultant, an aeronautical engineering company with limited expertise in the biological sciences.
Response
The FAA is the lead Federal agency for any proposed project that occurs at an airport that receives or is requesting Federal funding. The FAA has Environmental Program Specialists and other environmental professionals who are fully trained and qualified to manage the NEPA process, oversee technical consultants and assure that quality work is prepared. In addition, the FAA distributes the EIS to a variety of Federal, state, and local agencies such as the EPA, Department of Interior, U.S. Army Corps of Engineers, FHWA, and NCDENR for review comments in their area of expertise. The qualifications of the individuals participating in the EIS are listed in Chapter 8 of the FEIS.
23-4 Comment
URS Greiner has worked closely with FedEx and the FAA on other projects; is paid by the PTAA and is therefore not in a position to make unbiased judgments with regard to effects of this development.
Response
The FAA, and not URS Greiner, is responsible for making independent judgments associated with the NEPA review as well as project determinations and approvals. The FAA, in accord with NEPA, selects a consultant to assist with the preparation of the EIS, and the FAA is responsible for the accuracy of the EIS. The consultant must report directly to the FAA. The airport sponsor funds the work. This arrangement is conducted pursuant to a "Third-Party Agreement", in which the following directions are agreed to by all the parties: the FAA is in charge of the EIS and is accountable for the information contained in it, the consultant assists the FAA in the preparation of the EIS, and the Airport Sponsor provides input and assistance to the FAA as needed. CEQ regulations permit this plan; at 40 CFR 1506.5, CEQ states that the agency alone must select the contractor.
It is correct that URS has worked for FedEx, but the last time was more than ten years ago. The FAA did not find that this history should bar URS, which was qualified to perform the work, from the project. URS (and all consultants who assist the FAA with EIS preparation) had to sign a "conflict of interest" certification, in which it was asked to certify that it has no financial or other interest in the outcome of this project. URS did sign this certification.
23-5 Comment
The consultant has a conflict of interest and not the expertise or quality control to assure fair, independent, and unbiased review that needs to be done. I request that URS Greiner, Inc. be dismissed and the study be voided and began again.
Response
The FAA required each of the consultants assisting in the EIS preparation to sign Disclosure Statements revealing any potential conflicts of interest associated with the PTIA EIS. This is a requirement that must be satisfied, by CEQ regulation. FAA reviewed these Disclosure Statements and found that none of the consultants has a conflict of interest for this project. The FAA and the consultant team have fully complied with the NEPA process, FAA Orders 5050.4A and 1050.1D, as well as applicable Federal, state, and local laws to produce a technically competent, fair and unbiased document.
Piedmont Triad International Airport
24. Quality of Life
24-1 Comment
We are concerned of the potential impacts to the quality of life in the Triad.
Response
Chapter 5, Environmental Consequences, of the FEIS discloses the environmental and social impacts associated with the proposed project and reasonable alternatives. In addition, Chapter 6, Mitigation, of the FEIS outlines the mitigation program proposed by the PTAA to mitigate impacts associated with the Preferred Alternative, Alternative W1-A1.
24-2 Comment
The project will result in air, water, and noise pollution, and destroy the quality of life of nearby communities.
Response
The FEIS document discloses the potential Noise (Section 5.1), Air Quality (Section 5.5), and Water Quality (Section 5.6) impacts within the Generalized and Detailed Study Areas associated with each of the reasonable alternatives. Chapter 6, Section 6.3 of the FEIS document presents the Mitigation Program for the Preferred Alternative that will be implemented by the PTAA in order to mitigate impacts from the Preferred Alternative, Alternative W1-A1. The FAA has determined that under Alternative W1-A1, all reasonable steps have been taken to minimize any potential harm to the environment associated with this alternative. The FAA will enforce PTAA's mitigation and other obligations in connection with Alternative W1-A1 through the FAA's grant program. The grant program awards funds pursuant to grant assurances that PTAA must agree to, in writing, as a condition of gr