The SeaTac-POS ILA: Good or Bad?

‘ILA’ sounds like it has potential to be extremely boring, but from what people are saying around Sea-Tac Airport (KSEA), we all need to know what an ‘InterLocal Agreement’ is, and how much harm it can do. Some are saying that the latest ILA draft is yet another bad act by the Port of Seattle: spending taxpayer money to BUY silence from the tiny few elected officials who otherwise could do the most to help mitigate growing airport impact problems.

In this example, a new ILA has been drafted to expedite further growth of the airport and operations. It was drafted by a ‘JAC’ (Joint Advisory Committee), which is a team of five officials, two representing the Port of Seattle (aka POS, operator of KSEA) and three from the city of SeaTac (which essentially surrounds the POS properties). Of course, it is easy to see the push for an ILA comes entirely from POS; we would never see a small community approach an airport authority and ‘ask’ for an ILA. And, when dealing with POS, the relatively inexperienced officials at SeaTac just cave in when monetary treats are offered; money is the drug, and nobody fails to see who is the dealer and who is the addict.

An Analysis by aiReform

A few hours were spent studying the ILA draft, and comments/highlights were added; all of this is viewable in the scrollable PDF below.

One predominant concern is that an ILA appears to be a way for an airport authority to sidestep addressing problems, such as happen related to over-expansion at KSEA. Instead of meeting with impacted area residents and solving problems – finding the right balance between air commerce and local health and quality of life – POS chooses to ‘pay off’ local elected officials, buying their cooperation. Then, if/when local residents go to their elected body for help, well, that’s been cut off by the ILA.

Another general concern is how the city is enabling POS to entirely self-regulate, in exchange for annual cash payments; not too hard for POS to do, since they collect property taxes from residents throughout the Seattle area. Also, with the intended expedited processes, the window for citizen input is essentially shut tight; just not enough time for you or me to read a draft and submit a meaningful concern or suggestion.

In a democratic society, it almost feels like an ILA should be illegal. Federal agencies like FAA should be pressing for rules that protect people against the excesses of ILA’s such as this one. Not surprisingly, FAA remains mute; after all, they serve the airlines first.

People need to take a close look at this, identify what fails, and demand better governance. Airports should serve communities, not airlines.

Click on the image below for a scrollable view; the PDF file may be downloaded.

FAA/Industry’s Own Data Exposes ‘Greener Skies’ as an Environmental Fraud

This Post looks at data in two online documents, presenting further evidence of the ‘Greener Skies’ fraud that FAA, Port of Seattle, and industry players are foisting on the Public. For all intents and purposes, this is the same fraud being pushed throughout the U.S., and by industry and Congress as well, under the NextGen label.

The data are at:

  1. Projected average day fuel burn on approaches, with no change: 2.64M lbs
  2. Projected average day fuel burn WITH RNAV/RNP changes: 2.61M lbs.

These figures were presented in units (pounds) that make the numbers impressively ‘bigger’, but also make it harder to intuitively comprehend. To correct this, the figures are converted in this table (to gallons, then to annual consumption):

Fuel burn (lbs) Converted to gallons Gallons per year
No Change 2,640,000 388,200 141.7M
‘Greener Skies’ 2,610,000 383,800 140.1M
Difference: 30,000 4,400 gal/day 1.6M gal/year

So, the proposal is expected to achieve a savings of 1.6 million gallons annually … at an airport that sold 487.1 million gallons that year. In other words, this proposed savings is less than one third of one percent of total fuel sold at Sea-Tac. Now, to the airlines, this (~0.3%) translates to more profits; indeed, the two dominant players at KSEA, Delta and Alaska, might each save around $1,000,000 per year in fuel. But, the costs shifted onto neighborhoods and health far exceed these added corporate profits.

A little deeper research reveals another interesting fact: the alleged fuel savings of Greener Skies are massively dwarfed by annual increases at an airport scheduling more arrivals than the gates can handle. Here’s the data, from page 18 of the 2016 Annual Report for ‘Sea-Tac Fuel Facilities LLC’, showing year-to-year changes far greater than the comparatively measly 1.6 million gallons saved:

  Gallons Consumed Year-to-year Change 1.6M as a percentage…
2014 487.1M
2015 544.8M 57.7 (a 12% increase) 2.8% of increased consumption
2016 586.3M 41.5 (an 8% increase) 3.9% of increased consumption

The improvements are nothing when compared to the consumption growth trend. Here’s a chart showing the trends, in both annual fuel consumption and annual operations: And, here’s an analogy: imagine the public view if we were funding a drug-treatment program that was successfully helping 3% of addicts while the number of addicts was growing at such a huge rate. Would we smile if, for every three treatment successes, there were 97 new addicts? Of course, we would not. Only an idiot (or a con-artist) crows ‘success!’ about a failure.

Three realities stand out from this:

  1. The enormous sums spent pitching Greener Skies and eventually signing off on the proposal were all framed around being pro-environment. It was a massive marketing/propaganda campaign to get out into the communities, present alleged benefits, pretend to engage people to ‘help’ identify and resolve problems, all while parading the idea that FAA, POS and industry care deeply about the environment, air quality, climate change, etc. And yet, these numbers show clearly: there were to be no meaningful environmental improvements. FAA, POS and industry players all knew this fact, even before the Greener Skies briefings and publications that wrapped up in 2012. They also knew (and still know!) that this was all just a big dog-and-pony show, funded by the people and served onto the people.
  2. A full five years after the FONSI signoff, FAA’s controllers at Seattle TRACON are not even using the RNP procedure down the center of Elliott Bay that was the key component of Greener Skies, the one element supposed to enable the bulk of the environmental benefits. It is as if the entire Greener Skies public engagement process was just an exercise in propaganda.
  3. The figures presented in the 2012 Greener Skies EA may not even reflect reality. Look closely. The data source documents used in this Post, when combined, show FAA/POS claimed that 487.1 million gallons of jetfuel were pumped in 2014, while also claiming 141.7 million gallons were consumed by west side arrivals on the short descending flight portions between the arrival gates (HAWKZ to the southwest, and MARNR to the northwest). Carefully note, these estimates were ONLY for west side arrivals, and did not look at fuel consumption for east side arrivals. Now, here’s the problem: these portions of these flights are the most fuel-efficient phases for each flight, and are allegedly flown at or close to engine-idle; these portions also represent a small fraction of total flight distance. And yet, the numbers used to calculate potential fuel savings declare the fuel consumption on these relatively short descending flight segments represent nearly a third of the fuel pumped at Sea-Tac? And, bear in mind, Sea-Tac is a major international hub, serving flights across the Pacific Ocean and to Europe. It defies logic; there is no plausible explanatio. FAA and POS need to confirm the numbers, and they need to explain: how is it that the airlines operating in and out of Sea-Tac can allegedly burn so much fuel on these arrivals yet so little fuel on climbouts and enroute to and from all other airports around the world?

CONCLUSION:

Greener Skies was (and still is) both a fraud and a side-show ‘act’, using erroneous estimates while pretending to create benefits that STILL do not exist! And the impacts, using the questionable numbers provided by PoS/FAA, are astounding: they are saying, in 2014, arrivals to Sea-Tac consumed 2.6 million pounds of jetfuel PER DAY while on approach, creating noise and air pollution that we are all supposed to ignore.


See also:
  • 2/25/2011 – ‘Greener Skies Project’ presentation by Doug Marek (FAA, 11-pages)
  • 11/01/2012 – GreenerSkies, Final Environmental Assessment Documents, archived at aiREFORM

ATC Is Not the Real Cause of Airline Delays…

…and the airlines have long had all the tools they need to solve the problems caused by their own corporate greed and mismanagement. If NextGen impacts are out of control where you live, you need to read the article below.

As a follow-up to yesterday’s Post, here is an outstanding article written by Michael Baiada, a retired United 747 pilot, who sees past the NextGen promotional frauds. Even better, Mr. Baiada gets into the details of how easily the U.S. air travel system could be made more efficient and less impactful, while also improving the flying experience for us consumers. Turns out, the root of the problem today is too many people abdicating their duties: airlines refusing to run their business, regulators who enable this management failure while also serving as cover, lobbyists too focused on perpetuating the lobbying revenue stream, and so forth.

The article is a bit technical but very well written, and Mr. Baiada does an outstanding job explaining system details that FAA/industry work so hard to make muddy and complex. I heartily recommend sitting down and carefully studying this article; you will learn a lot, to help fight for rational airports, serving the local communities ahead of the airlines.

Click on the image below for a scrollable view; the PDF file may be downloaded.

A copy of the article by Michael Boyd, as referenced in Baiada’s article, is archived here.

[ai-RCHIVE] 2017-11-02: Vashon Noise Meeting Presentation (15p)

The NextGen impacts at Vashon Island, under the HAWKZ RNAV arrival route, are terrible. This early-November presentation shows much has been learned by pushing past the roadblocks, getting the data, and framing the problems. Just 15 slides, and far more informative than the dog-and-pony shows FAA, POS and other ‘aviation stakeholders’ produce. Excellent work by David!

Click on the image below for a scrollable view; the PDF file may be downloaded.

Especially, look at the slide on page 10. Flights are now substantially lower over Puget Sound than they were, prior to the start of HAWKZ. The plan was to turn them down the center of Elliott Bay (the core idea in the Greener Skies program), thus there was a need to jam them lower and sooner. But, Elliott Bay is almost never used, because congestion at SeaTac is simply too high; instead, the lower and slower (and thus louder!) flights just cruise on north, burying Queen Anne, Ballard, Shoreline, Edmonds, and sometimes even Everett with more repetitive noise.

Ponder this, too: why are FAA and POS failing to locate HAWKZ arrivals mid-channel, between Three Tree Point and Vashon Island? Might it have something to do with the number of FAA/POS families living along the shorelines west and north of Burien? This could easily be done, using GPS waypoints that can minimize impacts on neighborhoods. NextGen technologies can be used to improve the environment, not just destroy communities in the name of air commerce.

New Brochure Debunks Greenwashing

A new brochure has been published by Finance & Trade Watch, an NGO based in Vienna, Austria. Authored by Magdalena Heuwieser, the 24-pages debunk many of the most common forms of aviation greenwashing. The brochure includes lots of interesting insight that will further inform about the state of regulatory capture that applies not just to FAA but also to the international body, ICAO.

Here is a short index:

  • Pg.4: Headlong growth in a green guise
  • Pg.7: Fantasy technologies and green kerosene
  • Pg.9: Offsetting emissions: a licence to pollute
  • Pg.11: International aviation’s climate plan: CORSIA
  • Pg.14: Green airports? Offsetting emissions and biodiversity
  • Pg.17: Flying with a clear conscience? Individual offsetting of air travel
  • Pg.19: What now? Summing up and looking ahead
  • Pg.21: On the move: resistance highlights

Click here to view an archived copy of the 2-page Executive Summary; click on the image below to view/download the full brochure.

Click on the image below for a scrollable view; the PDF file may be downloaded.


UPDATE, 11/30/2017: — Excellent overview posted at GAAM (the Global Anti-Aerotropolis Movement); more great work by Rose Bridger.

NAS Annual Ops Have Declined for Decades Now, And NextGen Is Just Hype

One of the most frustrating and damnable aspects of today’s FAA is their manipulation of data, to steer public opinion toward more aviation expansion. This propagandistic phenomenon has worsened in the last decade. Sometimes, to get to the facts, you have to dive deep and find what FAA wrote long ago. Here is an example…Let’s go back to early 2001.

(click on image to view archived copy of entire FAA report, from April 2001)

Here’s a screencap from April of that year, FAA’s 125-page NAS Capital Investment Plan 2002-2006. This one small screencap offers some unvarnished statements about capacity and delays (and the whole document contains many, MANY more!):

  • “Currently, traffic at the 25 busiest airports exceeds their practical capacity by about 1 million operations a year.”
  • “Either demand is reduced, or capacity expanded to bring the NAS into balance. It is normal to experience some delay in the NAS, the challenge is to manage excessive delay.”
  • RE: 15 new runways scheduled to open in the next five years: “If all of these runways are built as scheduled, they will add about 1.4 million operations a year in capacity.”

OK, so let’s take a closer look. First, let’s look at FAA’s ATADS data, the most precise database available for studying operations at all FAA and contract control towers in the U.S. Here’s a table created for the ‘top 25’ airports; in this case, the 25 busiest OEP-35 airports in calendar year 2000:What does this show? It shows a critical reality: this aviation system is NOT expanding, is NOT becoming increasingly complex, and in fact has been down-sizing for nearly two decades. In other words, the expensive changes that industry and FAA are pitching so aggressively are NOT needed, and serve only to further line the pockets of the cronies they advocate for. (…which, of course, is why they are advocating!)

Now, let’s take another look at those quotes above, and let’s do the math. Those 25 busiest airports were allegedly exceeding practical capacity by ‘about 1 million operations’ annually. The totals in the table above (use the ‘TOTALS’ column, not the ‘Commercial’ column, because that is the number that matters to define ATC workload) show 13.4 Million operations in 2000. Thus, this FAA document suggests the ‘practical capacity’ of the top 25 airports in 2000 was 12.4 Million annual operations. By 2016, three key forces (airline consolidation, hub realignment, and economic normalization) had reduced total ops to 11.1 Million annual ops, well below the alleged ‘practical capacity’. While total annual operations at the top 25 airports are down 17% (from 2000 to 2016), the only airports bucking this trend are the ones where airlines insist on over-scheduling. In other words, their pursuit of profits is the root cause of daily system delays, it also is the primary source for massive impacts upon neighboring residential communities, such as near KJFK, KCLT, and KSFO.

Note, too, that actual capacity has increased substantially (which, of course, reduces ATC complexity), with the construction not only of the ‘15 new runways’ by 2006, but the many other new runways between 2006 and 2017.

As a side note, ponder this: notice the green background stats in the table above. These are the very few airports where operations have actually increased from 2000 to 2016. Most people would assume automatically, Charlotte was tops, because of American’s massive expansion there to create a super-Hub. They would be wrong. In fact, Kennedy airport in NYC beat out Charlotte. FAA and PANYNJ accommodations to JetBlue, Delta and American are the reason that the western half of Long Island is constantly inundated with long and low arrival conga lines into JFK. The 28% increase is quite impactful.

CONCLUSION: when Bill Shuster et al stand before press cameras or preside at hearings where they pitch NextGen and ATC privatization, they are out of touch and, frankly, pitching a fraud. They should instead be focusing on managing hub capacity, imposing limits at the most congested hub airports, so that the entire system can achieve higher efficiencies and lower impacts.

Brendon Sewill’s Brilliant Work: Unspinning Aviation Spin in the UK

As has been seen so many times in the past, there is great value in studying aviation impacts on both sides of the Atlantic Ocean. In this Post, three analyses created by Brendon Sewill are offered. All were produced for the Aviation Environment Federation (AEF).

Mr. Sewill has an extensive background. After earning his economics degree from Cambridge, he served as an adviser in the Treasury as well as to the British Bankers Association, a member of the Council of the National Trust, a member of the CPRE national executive, and a vice president of the British Trust for Conservation Volunteers.

The first of Mr. Sewill’s three analyses was done in 2003, when he produced the 28-page ‘The Hidden Cost of Flying’. He had persuaded the UK government to rerun aviation computer forecasts, “…on the assumption that by 2030 air travel would be paying the same rate of tax as car travel….” What he found was shocking: the computer model rerun showed that the economic benefits of the UK aviation industry are grossly exaggerated, yet, in the meantime, elected officials are granting tax concessions worth £9 billion per year.

In 2005, his economic analysis was ‘Fly now, grieve later: How to reduce the impact of air travel on climate change’. In this 47-page report, he “…summarises the concerns about the impact of air travel on climate change, and explores the political and practical problems in making airlines pay sensible rates of tax….” Within this analysis, he also makes a compelling case for how large subsidies granted to aviation by nations across the planet are in fact generating the excessive aviation growth (and resultant increases in aviation impacts).

“At present the average American flies twice as far each year as the average European, and the average European flies ten times as far as the average inhabitant of Asia (even including Japan). If people in the rest of the world were to fly as much as those in the United States, the number of planes in the sky would rise nearly twenty-fold. Climate change disaster would be upon us.”                 – excerpt from pg.21

Finally, in 2009, Mr. Sewill wrote ‘Airport jobs – false hopes, cruel hoax’, a 23-page analysis in which he makes many brilliant points, debunking the alleged economic gains associated with massive airport development. For example, he notes how UK airports send more people AWAY from the UK to spend vacation dollars, which has the effect of displacing jobs (since that money is no longer spent at or near home). Simply, “…if the jobs created by aviation are to be counted, then the jobs lost by aviation must also be included….”

All three of these documents are well worth reading. Each is extremely relevant to the aviation impact issues found in the United States, too. They reveal greenwashing tactics by industry and the UK regulator (which, just like FAA, is arguably a ‘faux-regulator’ that serves industry, not the general population); the same greenwashing tactics are used at Sea-Tac, Boston-Logan, LaGuardia, and essentially all U.S. airports. Likewise, in the U.S., federal and local officials everywhere are found to be granting the same excessive subsidies, while also imposing uncompensated environmental costs upon thousands of residents under the concentrated flight paths.

Did This Letter Motivate Huerta’s Response to Governor Hogan?

Activists in Maryland shared a copy of this letter, another excellent effort by their Governor, Larry Hogan.

(click on image to view archived copy of full letter)

Essentially, the Governor sent a letter on May 11, pressing FAA to take actions to reduce impacts on constituents under flight paths for both Reagan National [KDCA] and Baltimore-Washington [KBWI]. Nearly three months after sending his letter to Michael Huerta, and having gotten no reply, Governor Hogan followed up with a letter to the Secretary of Transportation, Elaine Chao. Here’s an excerpt:FAA’s reply letter, dated 8/3/2017, is here. That is, if you can even call it a reply.

FAA has a shameful record of not just blowing off everyone – even Governors! – but also engaging in obfuscation to frustrate activists. This pattern of failure needs to end.

President Trump: You Need to Fire Michael Huerta

Whatever happened to draining the swamp? Is there any agency more dysfunctional, more corrupt and more locked into serving industry cronies than the FAA, the faux-regulator headed by Administrator Huerta?

Here’s the latest example of how out of control this agency has become, and how badly Mr. Huerta fails at leading long overdue change. Back in early May, the Governor of Maryland wrote an excellent letter (view a copy here), pressing FAA to bring relief to thousands losing sleep and health under NextGen routes. It took nearly three months for Mr. Huerta to finally send a response letter. The long delay was not necessary to do any difficult analysis or produce any changes. No, nothing was analyzed, and nothing was changed; the long delay was just to waste time. In fact, Huerta’s letter was chock full of platitudes and unsupported sales pitches. Here’s a PDF copy of the entire letter, showing portions with footnoted analysis added by aiREFORM:

Click on the image below for a scrollable view; the PDF file may be downloaded.

Enough is enough. Huerta’s belated reply letter is garbage: a classic example of what we would expect from an agency head who views the airlines as his ‘customers’, not the regulatory subject for the rigorous regulations FAA fails to write and fails to apply. Through the botched NextGen implementation, Mr. Huerta’s agency has also become a case study in ‘runaway captured regulators’. FAA is a perfect target for sweeping reforms. If President Trump wants to do good while throwing fire and fury, he should direct his energies domestically. Cleaning up FAA can set the example for how all federal agencies need to be trimmed back to a focused mission and restrained from federal over-reach, while becoming massively transparent and accountable.

It’s an easy call: fire Michael Huerta, and make FAA serve the people, first.

URGENT – The SeaTac Hardstand Needs to Be Appealed by July 28th

If there is one matter that people around SeaTac Airport [KSEA] need to focus on right now, it is the urgent deadline, just over a week away, for filing an appeal at King County Superior Court. That appeal, if granted, would force review of POS’s recent SEPA ‘Determination of Non-Significance’, or ‘DNS’, for the so-called ‘Hardstand’ expansion project. What exactly is a DNS? In this case, the DNS is POS’s way of administratively declaring, “oh, we want to enable the airlines to park 6 more airplanes for handling their through-passengers, but this will not increase flights and will have no significant impacts.” Really!?! Hmmm … this determination seems to lack plausibility.

A Closer Look at the Environmental Review Process

The Port of Seattle (POS) has an environmental staff, and one of their duties is to maintain a webpage listing various projects for both NEPA (federal) and SEPA (state) environmental review. People need to understand how these processes flow, and how they are so strongly biased to enable airport over-expansion while creating an illusion that the general public was involved in the process. This Post takes a closer look at the state portion, SEPA.

So, how does the SEPA work in the State of Washington? Probably very much like what has evolved (or devolved??) for environmental review in most states. As has become a common strategy at major airports across the nation, a bunch of paperwork is created, and procedures are ‘checked off’. At the right point in time (usually, immediately after seeing that it looks like all boxes were checked), the airport authority can then simply do what they intended from the start: declare their ‘Determination of Non-Significance’, or ‘DNS’. So long as nobody finds time or money to file an appeal at the courts, it is ‘Game Over’. The airlines (served by the airport authorities) get more expansion, and more profit potential; the airport authority gets a fatter budget and more passenger fee revenues; the controllers see an increase in traffic and may finally nudge past a threshold to get a nice pay raise.

And what about the thousands more residents now awoken by night flights? Not a problem; they were determined by POS to be ‘Not Significant’. And if that seems inaccurate, well, just try to fix it!

In short, it’s a rigged system. No surprises there. So, what do we do about it? Demand the system be improved, and take action to fix what has been done wrong. We all need to get our community leaders to file appeals, before that looming deadline (July 28th).

Here’s a plausible sample letter or email, that defines the concerns we need to communicate to the City Manager and Council Members at Des Moines:

Example of letter for individual use: Request for appeal of POS’s ‘SeaTac Hardstand DNS’
The new ‘Hardstand’ capacity expansion proposal at SeaTac Airport, with all of its implications for increased aircraft support activity and toxic emissions, should be given the consideration of a full Environmental Impact Study (EIS). With all due respect, a determination of non-significance issued by the Port of Seattle does not inspire one with confidence, nor does it guarantee that this project will not further negatively impact the citizens living under and around the concentrated NextGen flight corridors.
Up to this point in time, the Port of Seattle and the FAA have been woefully lacking in following adequate procedures for public notification and transparency regarding airport expansion plans. Their preferred method of operation seems to be fast-tracking, in order to quickly implement changes while minimizing citizen opportunities for comment or input.  A full EIS performed by an impartial entity should be mandated before the Port of Seattle is allowed to proceed with any further expansion.
This airport is already overcrowded, and the schedule has been expanded too far. Please file the necessary appeal.

For reference, the table below lists archived copies of the key documents POS created; they hope to begin construction of the hardstand capacity expansion, later this year.

6/6/2017 SEPA DNS (3pg) [link] .. one odd puzzle about this DNS: it appears to cover only the so-called ‘hardstand holdroom’ building, but not the actual hardstand
6/6/2017 Checklist for SEPA DNS (22pg) [link]
6/21/2017 Comment Period Extension (1pg) [link]
7/7/2017 Final SEPA DNS (6pg) [link] .. declares 7/28 deadline to appeal for review, at King County Superior Court
7/18/2017 ADDENDUM to Final SEPA DNS (2pg) [link]