C.A.R.E                 CITIZENS AGAINST  RUNWAY EXPANSION AT VANCE BRAND AIRPORT - LONGMONT

 
30+ Reasons Why the Airport Master Plan Scope Process is Flawed:

Flawed because…

1.      Per Jviation’s February 24, 2010 consulting proposal to Longmont City, some Jviation consultants are former employees of the Federal Aviation Administration (FAA) and the Colorado Department of Transportation (CDOT) Aeronautics Division.  This includes a former director of CDOT Aeronautics and a former manager of the FAA’s Denver Airport District Office.  Concerns of conflicts of interest are aroused, here.

2.      Jviation has a close relationship with the FAA and CDOT.  It is the same type of relationship that met with a great deal of criticism in the Gulf Oil spill between US Minerals Management Service oil regulators and British Petroleum. 

3.      Per their winning consulting proposal, Jviation assures the city of Longmont that it will develop an Airport Master Plan (AMP) that will gain FAA and CDOT support and “timely buy-in” by these agencies.What?  No “timely buy-in” needed from the surrounding community?  See point #8. 

4.      Jviation was only founded in 2008.  Two year-old experts? Better said, mouthpieces of aviation interests.

5.      We know stimulus funds are borrowed money and add directly to the national debt.  Jviation highlights that they have secured $34 million in stimulus funding for 5 airports (3 in CO) in 2009. The FAA has received 1.1 billion dollars in stimulus funding and according to their website as of September 2010 they are still distributing those stimulus funds.  A source from which the city has obtained $150,000 in AMP funding.  In addition CDOT has received over 500 million in stimulus funding, another source from which the city has obtained about $37,000 for AMP.  As CARE has noted before, Secretary of State Hillary Clinton and Admiral Mullen, Chairman Joint Chiefs of Staff have highlighted the national debt, as the #1 threat to our national security.  

6.      A Jviation sub-consultant is a skydiver at Longmont airport. Enough said. 

7.      Jviation notes in their winning consulting proposal the extensive experience of their team members, and specifically, the large airport projects they have worked on that are relevant to Longmont’s AMP study.  Yet when CARE has submitted studies noting the negative impact of runway expansions from large, medium and smaller airports the response is that those airports are not the same size as Longmont’s and therefore not relevant comparisons.

8.      Jviation recommends AGAINST “…traditional public hearings where stakeholders are given the opportunity to make general statements about the Master Plan, [because they] are not a good forum in which to have beneficial discussions of issues. “   Jviation suggests open house meetings with interactive “stations” to provide information.  Thus, removing the ability of citizen’s to make comments for public record. 

9.      A Jviation survey will be used to collect flight data to justify extending runway based on “created” demand.  Jviation, per their winning consulting proposal, will survey aviation departments of companies to find out if they would use an extended runway at Longmont airport. This, in effect, is a kin to leading the witness. 

10.  Per Jviation’s comments at the September 16th Airport Advisory Board meeting, the AMP will use FAA data to estimate airplane traffic at Longmont.   Part of the FAA’s charter is to support the growth and expansion of aviation.   There is a conflict of interest that data provided by the FAA for Longmont airport will be biased towards expansion. 

11.  Jviation claims in its winning consulting proposal to the City of Longmont that it has specific Longmont economic data to support runway expansion.  However, despite FOIA requests for the same data, submitted to the City of Longmont, FAA and CDOT, no such data has been discovered.   

12.  The closest the City gets to providing data in support of runway extension is best illustrated in an open letter Howard Morgan, Chairman of the Airport Advisory Board, wrote on the Air West Flight Center for Longmont’s Vance Brand Airport website. He writes, “Our thoughts on the runway extension lead us to believe…” Again, no data, just thoughts and beliefs.  

13.  Tim Barth has said that the Longmont airport no longer records landing and takeoff data as they did for the 2004 Airport Master Plan.   City staff has said that the number of takeoffs and landings are down since the last AMP.   Why is the city no longer keeping track of this important data? 

14.  Last spring, the Mayor told the Longmont Realtor’s Association that Longmont was going to extend its runway. This was a direct violation of City Charter and FAA Regulations. 

15.  Last Spring, the Mayor told Longmont Magazine the City of Longmont was going to extend its runway, again, violating City Charter and FAA regulations.  

16.  Last Spring, the Mayor told the Longmont Ledger the City of Longmont was going to extend its runway, again, violating City Charter and FAA regulations.  

17.  Despite even the most superficial attempts by Longmont City officials to design a Scope of Work to promote an impartial Airport Master Plan as a monument to not only aviation advancement, but also to transparency, an open public process, runway expansion not being a forgone conclusion, an adherence to FAA regulations and by listening to all of the facts, all of the pageantry has been undone, exposing not so much a monument to aviation planning, as much as snake oil to a circus. In an email, acquired through a Freedom of Information Act request, drawn up by a CARE attorney, and filed with the City of Longmont, a shocking revelation was recently uncovered. In correspondence dated April 16, 2010 - that is, nearly 6 months ago – before CARE, before Town Halls, before editorials, before Consultants, before FAA grants, before Council Meetings, before AAB meetings, before the Community Involvement Committee, before the Scope - before the facts - a Longmont City Councilmember wrote, “I am supporting the extended runway because we have been asked to do so by the FAA.” 

 These words are shocking because their meaning and intent are in clear violation of City Charter and Federal Regulations by a Longmont City Official. These words are shocking because they implicate a Federal Agency, in this case the FAA, in being complicit with said violations. These words are shocking because the person these words belong to may have acted unlawfully.  Is this behavior unethical?  Untruthful?  Does it discredit the Councilperson?  This person is Councilmember Katie Witt. 

18.  City Council appointed AAB Chairman, Howard Morgan, has written recently, in emails recovered via a FOIA request, that “airport runway extension is the most important piece of the AMP,” a violation of FAA regulations. 

19.  Howard Morgan recently posted an open letter at www.airwestflightcenter.com, which reads, “I am writing you today to ask for your help.  We are starting work on a new FAA Master Plan for our Airport which will include a runway extension.” He continues, “The extension is a key component of the new Master Plan.” He even refers to the Airport Master Plan process as “the runway extension process.” (All emphasis added) Again, violating City Charter and FAA regulations. 

20.  Every version of the Airport Master Plan scope - until the final version - included some reference to runway expansion that CARE has pointed out and reminded officials that they simply can not continue to promote and document runway expansion as a foregone conclusion. 

21.  The FAA does not require the study of how runway expansion impacts property values. Yet the FAA approved AMP process calls for an economic study of the airport’s impact.  This, even in light of the fact that the housing crisis is far from over. August 2010 marked the largest month for foreclosures yet and housing prices continue to fall.   

22.  The FAA does not require the study of how increased noise from runway expansion will negatively impact the more than 3,600 children who attend six public schools within Longmont’s airport influence zone.  By 11th grade 56 percent of Colorado students are reading below their grade level. Studies show that children who live inside airport influence zones lag behind in reading skills.  Do we want to continue to make it more difficult for our children to succeed? 

23.  Council was left no choice by the FAA but to vote in support of accepting FAA funding for the AMP study given the few day turn around time they faced. Typically, this turn around can take up to 3 months. 

24.  At the September 16th Airport Advisory Board (AAB) Meeting, Linda Bruce, FAA Airport Planner at the Denver Airports District Office, asserted that additional runway capacity, that is runway extension, is not a forgone conclusion. Later in an email dated October 14th, she wrote, “An airport master plan is intended to determine the aeronautical needs of an airport and to identify alternatives that will address these needs.  A master plan is not a study of a specific airport development, such as a runway extension.” She continued, “Why?  Federally funded development must be justified by aeronautical need, i.e., change in operations, lack of capacity, nonstandard condition, etc.   Also, an airport sponsor must follow the planning and environmental process for elevating and selecting a preferred alternative(s).  To do otherwise would predetermine the outcome of the environmental process, which would invalidate the environmental analysis and prevent Federal participation in the project (Emphasis added).” An airport sponsor is the owner/operator of an airport. In the case of Longmont, the owner/operator is the City of Longmont. And, as representatives of the City administrators, the Mayor, the Council and Council appointed Board Members are beholden to the rules of the process – in this case, the Airport Master Planning Process. And, as Linda outlines, above, not following the process predetermines the outcome and compromises Federal participation, violating federal regulations. And without Federal participation, such as funding, there is no process.   

25.  Traditionally AMP funds, from the FAA, could have been carried over to next year, when the process wouldn’t have been rushed, or flawed as it is now. 

26.  Falling short of carrying over AMP funds, from the FAA, the City could have simply reapplied for funds next year, again, when things wouldn’t be rushed or flawed. 

27.  Despite AAB Chair Howard Morgan and Mayor Baum making numerous claims that numerous companies have inquired about relocating to Longmont, but wouldn’t because of the airport’s runway length AAB Chair Howard Morgan, Mayor Baum, the LAEC and Airport Manager Tim Barth cannot substantiate these claims.

28.The Scope of Work/AMP Study reads, "The economic benefits will be calculated (for) the overall impact of airport improvements, but will not go to the extent of the FAA Airport Benefit-Cost Analysis Guidance or contain cost-benefit ratios." Here, again, "they" are deviating from the FAA AC that is supposed to be strictly followed AND they are saying they will NOT look at the economic COSTS, just the benefits. Not to mention this also contradicts the FAA Funding Application Assurances Tim signed, indicating economic analysis would be conducted. 

29.  According to the Airport Cooperative Research Program, Report 26, Guidebook for Conducting Airport User Surveys. Surveys of Area Businesses, Survey Methodology, Section 9.2, “Typically, all organizations in an area will compose the population of interest. To define a sample of these organizations, a list of all of them would ideally be developed, as—unlike air passengers—they cannot be sampled as they make use of the airport. Development of such a list can be difficult, if not impossible, and the surveyed population is often restricted to businesses for which contact information is readily available.” In other words, in the opinion of aviation research experts, it is impossible to get a good sample of area businesses to survey. This flaws data related to economics and use of airports.   

30.   The FAA Advisory Circular AC 150/5070 - 6B states clearly “… membership of the CAC (Longmont calls it a CIC) should be representative of all stakeholders.” The AAB has recommended removing CARE from the CIC and the City has stopped at least one neighborhood association from participating – the Table Mountain Association. 

31.  According to Longmont’s 2010 3rd Quarter Budget Review, the Longmont Area Visitor’s Association, a member of the CIC, has a $250K contract with the City. Another clear example of a conflict of interest and a flawed Airport Master Plan Scope process. 

32.  According to the March 30, 2010 Colorado Aeronautical Board Meeting minutes, the Colorado Department of Transportation Aeronautics Division reported, in reference to Longmont’s request for funding assistance for the Master Plan Update, “that the FAA, City of Longmont and the State have reached an agreement on the scope of work for this new request.” The AMP Scope of Work was decided nearly 7 months ago – before community involvement and well before the aforementioned facts were known.  

33.  Much of the data listed, above, was retrieved via FOIA requests. In other words, Longmont, FAA and CDOT officials were forced to legally share information.  Hardly a sharing of knowledge one would expect to be necessary in an open and transparent community process.