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October 19, 2005
Mayor Scott Avedisian
Commentary for the October 19, 2005 public hearing
Draft Environmental Impact Statement
“Technical Memorandum 1, 2 and 3” -T.F.GreenAirport, Dated September 15, 2005 Drafted By Vanasse HangenBrustlin, Inc., (VHB)
The City of Warwick is preparing a detailed technical response for the Federal Aviation Administration (FAA), which will be submitted prior to the November public comment deadline.
Presently, however, I would like to speak to the City’s initial review of the technical memoranda, which presents a general lack of understanding and/or consideration of community concerns and the role of T.F. Green Airport within the City of Warwick .
The issues, concerns and negative impacts of the airport on the City’s residents are well documented and for years have been reiterated at countless public forums, including this evening. Despite these efforts, it is evident that the public’s concerns have not fundamentally changed the proposed “purpose need statement.” Instead, the statement reads more like a marketing or business plan based on assumed conditions and anticipated future market demands that are not factually substantiated. I am sad to say that the host community’s concerns have been completely ignored in the proposed “purpose and need statement.”
The generalized statements defining “purpose and need” in technical memorandum 1 entitled “airline industry trends” are misleading and rely exclusively on speculation and assumption. Technical memorandum 1 promotes costly infrastructure improvements based on an overstated air-capacity problem. The “If we build it they will come” mentality is the principal argument in support of the preferred alternative for the extension of runway 5/23. The environmental impacts of the preferred alternative presented in the “need” statement underestimate the disproportionate negative impact the proposal would have on Warwick and the residents who live within the airport’s shadow.
The “need” statement fosters the notion that T.F. Green Airport must provide all necessary infrastructure for every airline to accommodate any destination, including London . Yes, London England , which apparently has made its way onto the “wish list” as a new desirable international service destination. The technical memorandum describes a tremendous “need” that demands a build-out of all infrastructure, even though the FAA has not finalized its regional plan, which it initiated several years ago.
The draft “purpose and need statement” is internally conflicted between the need for direct competition between airports and the role of Green Airport within the New England region. The need for direct competition cited several times within Technical Memorandum 1 contradicts the arguments in favor of developing a FAA regional aviation plan. Further, the belief that the FAA can rationally adopt a “purpose and need” statement for T.F. Green Airport without a completed Regional Aviation Plan is unreasonable and counterproductive.
The draft “purpose and need” does not recognize the necessity and desire to capitalize on the assets of all airports within the New England region. It makes no sense for T.F. Green to adversely impact the environment and invest countless millions on infrastructure in order to provide potential service to London when Logan airport, only 50 miles away, already offers such service.
The documents presented to date are clearly biased in favor of airport expansion and ignore the various and wide-ranging community concerns that have been presented in numerous public forums throughout the past several years. It is unacceptable that the document does not acknowledge those public concerns and that they have not been factored into the purpose and need statement for the airport.
A public project of this magnitude, with its potential impact on the environment and those who reside in the surrounding area, must balance the airport’s needs with the needs of area residents. I am extremely concerned that this draft ‘purpose and need statement’ sets the stage for an EIS that will endorse the most costly project without regard to the environmental consequence. It is an unrealistic expectation that a public project of this type could be designed to a standard that meets all of the potential needs and desires of the traveling public under any circumstance without limitation.
The arguments presented for runway expansion are based on conjecture, assumption, and speculation. For example, the purpose and need statement speaks to the issue of “enhancing the efficiency of the airport” and immediately promotes the extension of runway R5/23 as the best way to do so.
The extension argument is primarily based on a persistent reference throughout the document to competition and a perceived loss in new air carrier service at T. F. Green Airport . The repeated reference to the startup service at Logan International Airport by “Jet Blue” is the most notable example of the draft purpose and need statement’s rationalization for the extension runway R5/23. This argument is clearly not an airport efficiency argument but is solely a competition driven economic expansion argument.
The inference is clear but entirely inaccurate. The so-called loss of Jet Blue service at T.F Green Airport as mentioned several times throughout the document infers that Jet Blue chose Logan International Airport over T.F. Green solely because of its longer runways. In fact, the Jet Blue’s business model targets alternate airports in order to avoid direct competition with Southwest Airlines, the nation’s largest low cost air carrier – a fact acknowledged by industry professionals.
The fact that Southwest Airlines has long served T. F. Green Airport and Manchester Airport passengers was a primary factor in Jet Blue’s decision to serve Logan Airport , NOT because T. F. Green Airport has inadequate infrastructure.
Technical Memorandum 1 must be redrafted to clearly illustrate the importance of the inefficiencies cited within the airport Master Plan, including a reclassification of alternatives as required or desired alternatives. For example, issues of immediate public safety may be considered required while the lengthening of R5/23 to 9,500 feet to enhance economic development and foster passenger growth should be classified as a desired activity. The desire of the Rhode Island Airport Corporation to realize financial gain through speculated increases in air service destinations may be an appropriate business decision, but is clearly a desire when consideration is given to the public project’s location within the geographic center of the second largest City in the State of Rhode Island .
It is disappointing that these public hearings are constantly skewed in favor of airport expansion proponents and consistently ignore the City and the concerns of its residents. The proposed “purpose and need statement” promotes the R5/23 runway extension in its economic arguments while refusing to recognize the project’s adverse impacts on the City of Warwick and offering no real alternative to the extension proposal.
Warwick has a legitimate right to demand that the federal process work to protect its citizens. The City of Warwick will not be satisfied that the process has been open and balanced until its concerns have been adequately addressed in the “purpose and need statement.”
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