Showing posts with label Airport safety. Show all posts
Showing posts with label Airport safety. Show all posts

Thursday, October 28, 2021

Restoring NEPA procedures to protect the public and taxpayers


The National Environmental Policy Act (NEPA) is the law that ensures that you can have a voice in federal decisions. During the previous administration, changes were made to the way NEPA is implemented. These changes were intended to streamline the process and allow federal projects to be approved more quickly. Although a goal of speeding up federal bureaucracy is laudable, the streamlining was at the expense of public scrutiny rather than streamlining the internal working of government agencies and contractors. Currently, there is a Phase I proposal that would begin to restore the right of the public to be involved. This proposed rulemaking is available for public comment until November 22, 2021. Yesterday, I submitted the following comments.


National Environmental Policy Act Implementing Regulations Revisions

Public Comment

Agency name: Council on Environmental Quality

Docket number, CEQ-2021-0002

Commenter: Michael G. Waldon, Lafayette, Louisiana

NEPA is not just an environmental law, it is a GOOD GOVERNMENT law. NEPA requires that federal agencies think before they act and allow the public to critically review proposed actions. I am submitting this comment to support CEQ’s proposed phase 1 rules. Furthermore, I ask that CEQ quickly initiate phase 2 rulemaking with robust public involvement so that NEPA is fully restored. 

Public review and comment are essential safeguards against wasteful, harmful, and ill-conceived large government projects. For years, NEPA protected public health and the environment. But, that is not all. By allowing the public to examine proposed plans and designs, citizens have exposed deficiencies and errors before they became costly mistakes. NEPA has saved government agencies from making huge costly blunders.

I am commenting as an individual, but I am a member of my local Sierra Club and the Y-49 group in Lafayette who oppose construction of a new urban section of I-49 through the heart of our city. Additionally, I participate in the Louisiana Four Corners Coalition which is seeking reform of Louisiana transportation decision-making through increased public scrutiny and input. Here, I illustrate the importance of NEPA with two examples from these citizen groups and my own experience. 

My first example shows how NEPA procedures can raise awareness of risks associated with proposed projects. As a retired environmental engineer, I first became alarmed about the public health and financial risks of the proposed Lafayette I-49 urban interstate project. This project has been opposed for decades by local citizens and citizen groups. As part of a developing supplemental environmental impact statement, the Louisiana DOTD contractors revised the design and proposed constructing an elevated interstate over a federally recognized and un-remediated hazardous chemical site that is just over a thousand feet from Lafayette municipal drinking water wells. The elevated roadway would be supported on pilings that extend deep into our city’s drinking water aquifer. This project not only endangers our drinking water source, but could also move financial liability from the potentially responsible party to the taxpayers. We continue to oppose this dangerous and ill-conceived plan through NEPA mandated public input.

My second example involves an apparent design error that came to light during NEPA mandated public review. While reviewing the I-49 proposed urban interstate plan I became alarmed by the roadway design which proposed constructing an elevated overpass interchange with University Avenue flying over I-49 at the edge of our Lafayette airport. This tall structure was going to be positioned just past the end of one of our city’s runways. The EIS wanted to fill an area of wetland and shift the runway a few hundred feet east in order to meet FAA safety requirements. This small shift just didn’t seem sufficiently safe to me, so I did my own calculation using FAA guidance to see how far the runway needed to move. My calculation showed that a much larger shift was needed to meet FAA regulations. I submitted my calculation as a comment for the developing SEIS, and also wrote a blog post (ConnectorComments.org) detailing my calculation. I never even received a confirmation from DOTD that they received my comment. However, I can only assume that DOTD and their contractors agreed with my analysis because after I submitted that comment the plan was changed to tunnel University Avenue under the interstate rather than flying over it.

What would the environmental and financial consequences have been for residents of Lafayette if the NEPA process had been abbreviated? How much has NEPA’s required public involvement reduced the risk to our city’s drinking water and public health? How much waste would have happened before correction of the intersection design at the end of our airport runway? 

In summary, NEPA safeguards both taxpayers and the general public. Circumventing full NEPA consideration of projects increases the likelihood of wasteful government spending, environmental damage, and damage to public health. I therefore support the CEQ proposed rules.

Thursday, June 29, 2017

LFT Airport Update


(Why is there a $200 million problem looming at LFT? Be sure to read to the end to find out.)

A presentation on the current status of the Lafayette Airport (LFT) and planned airport renovations was an agenda item for the June 20, 2017 Lafayette City/Parish Council meeting. Presenters were Valerie Garrett, Chairwoman of the Lafayette Airport Commission, and Steven Picou, LFT Executive Director. Paul Guilbeau, Vice-Chairman of the Lafayette Airport Commission was also in attendance. Their summary update document provided by the Council Clerk is available here.



View the 12 minute video of the airport update by clicking here or view it in the frame at the bottom of this post.

STEVEN L. PICOU
LFT Executive Director

Steven Picou's update summarized these points:

  • LFT has hired their Program Management/Construction Management (PMCM) firm
  • 5000 citizens gave public input that contributed to the selection of the Journey renovation design
  • The Disadvantaged Business Enterprise (DBE)program at LFT is a priority
  • Part 139 inspection had zero discrepancies
  • LFT is prepared for tropical storms and hurricanes
  • Past year's cargo handling of 24.6 million pounds is up from the prior year 
  • The cargo handling facility is opening, UPS and Fed-X are moving in

The I-49 Connector plan requires moving a runway at LFT -

Dr. Michael Waldon asked during public comment if the runway displacement required by the I-49 Connector project would result in any changes to the renovations. He also cited his minimum safety requirement calculation that shows that the displacement would need to be 860 feet rather than the 350 feet stated in the I-49 FEIS. This calculation was published last year in the ConnectorComments.org post titled Airport angles and increased risk. Mr. Picou replied that he had not seen the published recalculation of the displacement. Further, he said that new FAA regulations would require an additional 1000 feet of runway if it is reconstructed. Mr. Picou stated that the airport "has hired a firm to look at that information." Currently the airport is constructing an EMAS system (engineered materials arrestor system) at the end of this runway. He also said that Dr. Kam Movassaghi had led a student design project that might eliminate or reduce the required displacement, but DOTD has not reported any study of such options.

District 9 Councilman Theriot asked whose responsibility would it be if the runway had to be displaced. Mr. Picou answered that FAA has taken the stance that it is not their responsibility, and it is not the airport's responsibility. He went on to say that in his opinion "It is Federal Highways responsibility." FAA takes the stance, he said, that millions of their dollars have already been spent on the airport, and it is not their responsibility.

The bombshell of the evening occurred when Councilman Theriot followed up by asking what the cost would be. Mr. Picou replied that a rough order-of-magnitude estimate is $200 million dollars. In part, this cost is so high because the FAA would no longer allow the use of an EMAS at this end of the runway, which results in an added runway length requirement of 1000 feet.

While there may be intergovernmental discussion of which tax dollars will fund this $200 million (or more), in the every case it is taxpayers who will pay and citizens who will suffer added flooding from the loss of flood storage currently provided to Lafayette and St. Martin Parish residents by the Cypress Island Swamp.


LPC-AirpotUpdate-2017-06-20 from Mike Waldon on Vimeo.


Wednesday, April 26, 2017

Public comment from 16 years ago documents our citizens' struggle against the I-49 Con


Click on letter to enlarge.
The following comment by Kelly Roberts Caldwell dated April 30, 2001 was included in the FEIS, Volume II, page 299.  

Today, citizens continue to "battle a proposal that is, on its face, senseless." Now the senseless plan is called the I-49 Con.  




Secretary Kam Movassaghi
Department of Transportation & Development
P.O. Box 94245
Baton Rouge, LA 70804
Dear Sir:

The citizens of Lafayette fully support the extension of I-49 South. We strongly support a
Lafayette eastern bypass and are deeply opposed to an elevated interstate thru the heart of
our city. In July, 1992, a public meeting was held after an EIS was distributed of the Evangeline
Thruway corridor plan. Citizens voiced overwhelming opposition resulting in its withdrawal. In
1997, the project was restarted by DOTD at the urging of the chamber of Commerce leadership
who have relentlessly pursued the Evangeline Thruway placement. New strategy! Lead the
public to believe that other alternatives are being considered. Many reasonably assumed that the
1992 official public rejection eliminated Evangeline Thruway. Wrong! Residents realized very
late thai the "alternatives" were all simply "variations" of the previously rejected Thruway plan.

I am a spokesperson for a campaign by The Sierra Club, Citizens Speak Out, Sterling Grove
Historic Association, Tree Society of Acadiana, Annabelle Subdivision Association, and others
joined to promote an I-49 eastern bypass. Our petition has over 1000 signatures with more added
each day. Lafayette citizens arc now at risk from the 50,000 vehicles per day on Evangeline
Thruway, many hauling hazardous materials. Why plan to increase the risk with 100,000 daily
estimated for completed I-49? Proponents insist an eastern bypass was studied and rejected.
Rejected by whom? Where are the studies? Why choose this destruction and danger to our
community? ls it simply a price the local power structure is willing to pay to keep the project all
within Lafayette Parish - avoid sharing with our neighbor, St. Martin?

We are told a Lafayette eastern bypass would impact wetlands (though their plan requires moving
a runway at our airport into wetlands). Harold Schoeffler, a well known businessman and
environmentalist and Pierce Meleton, respected architect, and others actually mapped out a route
to the east between Breaux Bridge and Lafayette into St. Martin. It runs beyond Cypress Island
Swamp but west of the beautiful Teche thru sugar cane fields and pasture land coming back into
90 below Broussard. Destroys no homes or businesses. Gives St. Martin needed interstate
access and avoids the adverse impacts in Lafayette. Be vastly superior for evacuation- with two
highways out rather than the one sure to become an elevated trap in Lafayette. When taken to
highway engineers cost estimates were about half that of cutting thru lafayette. Likely you were
sent the St. Martin resolution asking that the Teche Ridge alternative be considered.

Citizens must battle to save themselves from a proposal that is, on its face, senseless? Impacts
to the human and natural environment so enormous that governments' talk of "mitigation" is a
joke in the community. An elevated federal interstate alongside a national historic district?
Elderly, poor and minorities disproportionately impacted? Their sector of the city walled of!?
Please do what you can.

Kelly Roberts Caldwell

Saturday, July 2, 2016

Airport angles and increased risk

SUMMARY: Because this is an unusually long post, you may wish to skip first to the SUMMARY at the end of this post before reading the entire post.

A LOT has been written on the topic of "things you just should never do."  One of these "never do" actions is to build tall structures next to your airport. This is precisely the DOTD plan for extending I-49 through Lafayette.

In an earlier post I talked in general about the problems associated with the Connector plans relative to the Lafayette Airport. In this post. I want to get down to specifics.

Figure 1.  Google Earth image of the northwest end of runway 11-29 in relation to the intersection of Evangeline Thruway, University Ave, and Surrey St.  

Federal safety guidance defines the maximum height that objects should not exceed in the vicinity of airports. This definition is based on a number of imaginary surfaces through which no objects sitting on the ground should penetrate. Keeping aircraft above the imaginary surfaces, and all terrestrial objects below, provides for safe landings and takeoffs.

The lowest of these imaginary surfaces, the primary surface, is a rectangle at the elevation of the runway. The primary surface extends 200 feet beyond each end of the runway and 500 feet on each side of the runway centerline. Beyond each end of the primary surface there is an approach surface. The approach surface begins at the primary surface elevation and rises, for runway 11-29, at a slope of 34:1 (termed a 3% slope). That is, for every 34 feet of center-line distance the surface rises 1 foot.  At their intersection, the width of the approach surface is the same as the primary surface, 1000 feet, and is centered on the runway center-line. The approach surface widens to 4000 feet at 10,000 feet ground distance from the primary surface. That is, the approach surface width is 1000+0.3x, where x is the ground distance along the center-line away from the primary surface. There are other defined surfaces (transitional surface, horizontal surface, conical surface), but only the primary and approach surfaces are relevant to the issue of runway displacement for 11-29.

The 2002 Final EIS asserts in numerous locations that the Lafayette Regional Airport runway 11-29 will need to be displaced 350 feet to the southeast toward Bayou Tortue and Cypress Island Swamp from its present location to meet minimum federal safety requirements for an approach surface slope of 34:1 and a 17 foot margin of safety (FEIS exhibit 4-4). While the FEIS makes the assertion that the 350 foot displacement is required, it does not show the underlying data or rationale needed to support the claim. I have therefore been forced to attempt to recreate these calculations. My calculations, however, do not agree with the conclusion in the FEIS. Lacking documentation of the FEIS methods, I conclude that the 350 foot assertion is likely in error.

A history and general information about the Lafayette Regional airport may be found in the Wikipedia article titled "Lafayette Regional Airport." Additional information on the airport AirNav.com. That web page also includes a link to a useful Airport Diagram. The diagram shows that runway 11-29 is 5401 feet long and 148 feet wide. Elevation at the northeastern end (designated 11) is 37 feet; elevation at the southeastern end (designated 29) is 35 feet.

Figure 1 is an image captured from Google Earth of the northwest end (designation 11) of runway 11-29. It illustrates that the runway does end quite close to the current highway. Measurement shows that the runway currently ends roughly 600 feet from Evangeline Thruway (Hwy 90), and roughly 700 feet from the intersection of the Evangeline Thruway, Surrey St, and University Ave.

Figure 2. This image is extracted from the FEIS Plate 2a2. North in this figure is to the right, and distance along the horizontal extent of the roadway in hundreds of feet is given on the horizontal axis; elevation in feet (NGVD 29 datum) is plotted on the vertical axis. The roadway is charted as the solid black line. The 40 foot elevation is highlighted by a dotted red line. Peak roadway height at the interchange is estimated to be 45 feet. 


Finally, it is necessary to estimate the height of objects above the roadway. This could include signs, streetlights, and aircraft warning lights. The FEIS does mention this, and suggests that special signage and lighting may be necessary. Thus, I will assume that the height of the vehicles on the roadway will be the tallest objects above the roadway. There is no Federal vehicle height requirement for commercial motor vehicles (CMVs). Most eastern states, including Louisiana, set a CMV height limit of 13.5 feet on most highways. Louisiana does allow heights of 14 feet on designated highways, and oversize permits can be routinely issued for heights up to 16 feet 5 inches. Without specific guidance from the Louisiana DOTD, it is unclear what height should be assumed. Here, I will simply assume a maximum height of 15 feet for all vehicles and objects on the roadway.

Assuming the peak height at the interchange structure controls the required runway displacement, the calculation of length for the approach surface is now straightforward.  The interchange height plus object height has an elevation of 60 feet (45+15). Adding the FAA 17 foot margin of safety gives a total elevation of 77 feet. Subtracting the runway height which defines the primary surface elevation then gives a height of 40 feet (77-37). At a slope of 34:1, the length of the approach surface to the primary surface is 1,360 feet (34x40). At this point along the approach surface, the approach surface width is 1408 feet (1000 + 0.3x1,360), or 704 feet on each side of the extended runway center-line (Figure 3). Adding the 200 foot width of the primary surface at the end of the runway gives a total distance form the peak of the interchange of 1,560 feet. The present distance is estimated to be 700 feet, so the total runway displacement required would be 860 feet (Figure 4). This is 510 feet longer than the value asserted in the FEIS. This difference significantly brings into question the economic, environmental, and engineering feasibility of the displacement.

Figure 3. The more northern half of the new approach surface (black outlined trapezoid) begins with a width which is 500 feet on either side of the extended runway centerline, and 200 feet beyond the new runway end (orange line). The distance to the centerline extends to 704 feet at the proposed elevated interchange.

The calculated extension will require very roughly the destruction of 45 acres of the Cypress Island Swamp west of the airport (Figure 4), and more if embankments in the swamp must be longer than existing embankments. This considerably exceeds the 5 acres estimated in the FEIS (p 4-92).

(a)

(b)
Figure 4. The upper figure (a) shows the current airport runway at the southeast end of runway 11-29. The lower figure (b) is the same image with an 860 foot length of runway and associated area is copied onto the current end of the runway. The original image was printed from Google Earth. 
Construction would require significant fill, and consolidation of the underlying wetland soil will further aggravate the existing problems of soil stability at this end of runway 11-29.  The FEIS on page 2-10 states that "a prior runway extension of about 200' constructed in 1967 has subsided up to approximately four feet and has been removed from service." This fill will encounter even greater engineering challenges.

The new extension into the swamp will need to deal with a very significant drop in elevation (Figure 5). As much as 35 feet of fill will be required for the extension. If earthen embankments are used at the sides of the filled area, considerably more than the estimated 35 acre area of wetland may be required in order to accommodate the more extensive embankment areas.

(a)
(b)
Figure 5. In (a), the center line of the runway (red line) is extended at the southwest end of runway 11-29. The green bar indicates 860 feet from the end of the center line, and the thin white lie crossing the center line is 860 feet from the runway end. Figure (b) graphs elevation along the center line from 39 ft to 4 ft.  



Options: What are our options? They include:
  1. The No Build alternative should always be considered. If the currently planned I-49 Connector project is abandoned, it could be replaced by upgrades to the current Evangeline Thruway, and bypass to the east along the Teche-Ridge, west using the LRX alignment, or both to form an urban loop.
  2. Build the connector project as decided in the FEIS and ROD, and extend runway 11-29 as required to meet minimum FAA guidelines. This will require land acquisition and a Corps of Engineers wetland permit. Likely this alternative will further require wetland mitigation and flood mitigation.
  3. Build the connector project as decided in the FEIS and ROD, and request an FAA exemption from airport approach obstacle safety requirements.
  4. Abandon use of runway 11-29.
  5. Revise the design in of the selected alternative to eliminate roadway elevation in the vicinity of the 11-29 runway approach surface.

SUMMARY: The I-49 Connector FEIS identified unacceptable risk due to failure to meet FAA flight path obstruction guidance, resulting from the proposed interchange construction adjacent to the Lafayette Regional Airport. Without documenting calculations or rationale, the FEIS stated that in order to meet these minimum safety requirements, airport runway 11-29 would need to be displaced 350 feet southeast toward Bayou Tortue and the Cypress Island Swamp.

My calculations, based on FAA guidance, arrive at runway displacement considerably longer than that presented in the FEIS. Here, following FAA guidance, I calculated that the required displacement is 860 feet. This significant difference brings into question the economic, environmental, and engineering feasibility of the displacement. Impact of this displacement on flooding, wildlife, and wetlands should be carefully addressed and documented by DOTD.

The public attitude toward airport safety should always be conservative and circumspect. The Airport's 1975 Master Plan concludes "Conditions at the airport's periphery make expansion of its land area difficult or expensive or both." Even beyond the impacts of runway displacement discussed above, it is simply inappropriate to choose to construct any tall structures on the periphery of our airport which is already severely constrained at its location. Tall structures like the University and Kaliste Saloom interchanges constrain future airport runway alignment adjustments, and impact the ability to meet current requirements and future safety requirements should FAA guidance on safety margins or approach slopes change for any reason.

  

Friday, May 27, 2016

The I-49 Lafayette Bypass Option: Teche Ridge

Google Earth image showing the approximate path of the
proposed Teche Ridge bypass.

For nearly two decades, Acadiana residents and taxpayers have urged DOTD to consider an I-49 bypass option following the Teche Ridge in St. Martin Parish. This roadway would follow along the natural ridge that follows west of Bayou Teche. This area has few wetlands, does not flood, and is primarily in agricultural use. An engineering feasibility study, funded in part by the St. Martin Police Jury, was completed by the engineering firm T Baker Smith.

And, as taxpayers the difference in estimated cost is staggering. The 5.5 mile I-49 Connector (Divider) is estimated to cost over $1 billion, while the 20 mile Teche Ridge route would cost far less than one third of that total. This is over $200 million per mile for the Connector before costs of toxic waste cleanup and flood control are even considered. The 20 mile Teche Ridge route would cost a more conventional $15 million per mile.

The Teche Ridge route would obviate extending the Lafayette Regional Airport runway into the Cypress Island Swamp, avoid issues of diminished airport safety, obviate wetland loss from fill, and obviate induced flooding associated with the airport revisions. It also greatly improves resilience of hurricane evacuation for the large population living south of Lafayette.

Furthermore, the Teche Ridge route could be a part of a larger project to provide a bypass loop around our urban core. Combining the Teche Ridge route with the western Lafayette Regional Xpressway (LRX) would give Lafayette a full urban interstate loop. Now, note that this 80 mile loop would cost approximately the same as the 5.5 urban Divider being forced on our taxpayers and neighborhoods.


For more information on the Teche Ridge, check out these resources:

Teche Ridge Bypass Facebook page
  https://www.facebook.com/I-49-Teche-Ridge-Bypass-191859984503529/

Presentation by Harold Schoeffler to the St. Martin Parish Police Jury
 https://www.facebook.com/michael.waldon/posts/10204527887710661

Teche News article on the Teche Ridge Highway alternative.

The Daily Iberian, February 17, 2016, Teche Ridge I-49 proposal gets traction in St. Martin


Wednesday, May 25, 2016

The I-49 Lafayette Western Bypass Option: The "Lafayette Regional Xpressway"

One bypass alternative for Lafayette has been under study by the DOTD since 2003. At that time, the Lafayette Metropolitan Expressway Commission was created by the Louisiana State Legislature. They are commissioned to study alternatives for the Lafayette Regional Xpressway, or simply the LRX. The LRX would create a bypass loop which begins in the south at Highway 90 / I-49 south of Broussard, has a major interchanges as it crosses Highway 167 (Johnston Street) north of Abbeville, and I-10 between Duson and Scott. This portion of the roadway would be very roughly 25 miles. The bypass would then continue north and east for roughly 20 miles to return to I-49 north of Carencro. An eastern bypass leg of very roughly 15 miles would run south east from north of Carencro to I-10 west of Breaux Bridge. Total length of the Lafayette Regional Xpressway bypass would then be very roughly 60 miles.

 The Lafayette Metropolitan Expressway 2005 feasibility study’s rendering of a proposed expressway. (Photo: Lafayette Metropolitan Expressway)



At an estimated cost of $760 million, the cost per mile for this roadway is under $13 million per Interstate mile. The 5.5 mile Lafayette Connector project which now has cost estimates of over $1 billion before toxic waste removal and flood mitigation have even been considered. This gives the Connector a cost that will greatly exceed $182 million per mile. 


More information is available at

Lafayette Regional Xpressway Project Website  http://www.lrxpressway.com/

The Advertiser, October 23, 2015,  Citigroup and the Lafayette Loop — what's next?
 http://www.theadvertiser.com/story/news/2015/10/22/citigroup-and-lafayette-loop/74359164/

The Advertiser, October 23, 2015,  Is Lafayette ready for a traffic loop?
 http://www.theadvertiser.com/story/news/2015/07/01/still-loop/29588975/

Lafayette Regional Expressway Rendering
Source: http://www.lrxpressway.com/

Sunday, May 15, 2016

Impact of I-49 on the Lafayette Airport



Construction of any tall structures at the end of one of an airport runway is, at best, ill advised. Such structures inevitably increase risk of disaster. Allowing such construction by the I-49 Lafayette Connector project would give travelers the perception that Lafayette has a depreciated value for traveler safety. The Lafayette Airport Commissioners represent the public and are tasked with overseeing airport management and promoting the airport. It therefore seems remarkable that The Lafayette Airport Commission has not strenuously objected to plans to construct the elevated I-49 interstate on the airport boundary immediately at the end of one runway.

The 1975 Lafayette Regional Airport Master Plan Report concluded that conditions on the airport's periphery make any expansion difficult, or expensive, or both. The current plan to reroute Bayou Tortue, fill an area of wetlands within the Bayou's floodplain, and construct a runway extension on this unsupportive fill

  • will be an engineering challenge, 
  • will be environmentally destructive, 
  • will be very costly, and 
  • will be politically sensitive. 
The now-obsolete project EIS fails to evaluate or even consider these impacts.
  
from Lafayette Regional Airport Master Plan Report, 1975, page 11.