HVN Environmental Assessment. Letter to FAA.

Gail Latrell, Director. FAA New England Region
1200 District Avenue
Burlington, MA 01803-5078

…introduction redacted for purposes of privacy. The signatories to this letter will be a matter of public record at the appropriate time…

Need and Purpose
The Tweed-New Haven 2021 Master Plan calls for various Airside and Landside Projects. The potential impacts, potential need for impact mitigation and alternatives were submitted by the HVN Airport Authority under an Environmental Assessment (EA). This EA is currently under review by your office ( FAA New England Region). The collective comments that follow will speak to the two projects that potentially involve the greatest scope of work and potential for impact (negative or positive):

*Passenger Terminal relocation from West Side to East Side.

The current Passenger Terminal complex (West Side) has reached and exceeded its design limits. While the current Air Carrier is a welcome and highly successful addition to HVN, its success has led to the daily illustration of this exceedance of building and facility design limits. Such illustrations include:

1. The need for additional, temporary terminal “Modular” type structures. These offer the air traveler a “disjointed” and complicated ground experience. This includes time spent outside going from one building to another. Such exposure to the elements creates pedestrian customer safety risks and general dissatisfaction.

2. The Airport and tenant airline have instituted numerous West Ramp aircraft parking configurations to maximize ground operations. This current situation can create a backlog of aircraft spilling out onto active movement areas which lead to delays for other aircraft and inefficient use of airport surfaces.

3. Passenger loading is done without the use of traditional Jetways or Jet Bridges. The lack of this airport infrastructure detracts from the passenger experience by exposing them to heat, cold, wind and rain. This exposure can create airport pedestrian safety and health risks. This can be a dangerous health situation for one to experience prior to boarding a flight.

4. The current set of passenger facilities do not function in a way commensurate with “Green Technology”. This makes the current terminal complex a detriment to the environment.

5. The current and primary means of vehicular access to the West Side Passenger Terminal is accomplished via Townsend Avenue and Fort Hale Road (New Haven).

These roads provide airport access through non-commercial (residential) zones. Said access is less than optimal for an airport that handles the level of enplanement activity that HVN currently experiences. This poses safety risks and quality of life concerns for residents in said areas.

6. The current cluster of vehicular parking lots are a patchwork of “add-ons” and are often at capacity. Additionally, the vehicle flow-patterns around and near the West Side Terminal Complex are constricted and often backed up during periods of high demand. This does not promote environmentally friendly vehicle patterns or use.

Given the above concerns (not all inclusive), a NO BUILD ALTERNATIVE May be considered ill-advised. A NO BUILD ALTERNATIVE would continue these deleterious impacts to HVN air travel patrons as well as residents proximal to Tweed-New Haven Airport. To do nothing would be environmentally detrimental.

Should the East Side Passenger Terminal be constructed, the following improvements can be expected:

1. A single, uniform structure can be provided HVN Air Travelers. Additional square footage in this new terminal can improve the passenger customer service and safety experience by negating the need for exposure to the weather elements. This would additionally be accomplished via the availability of passenger Jet Bridges. Passenger safety and experience is directly improved by new passenger facilities.

2. A new aircraft parking apron (as called for in the AMP) with more standard geometry (rectangular versus the current trapezoid shape) would improve parking logistics for air carrier aircraft and could provide for De-Icing of Aircraft in an area separate from static aircraft parking (that used for enplaning and deplaning passengers).

This new set-up improves efficiency of aircraft ground operations and reduces potential for delay. This reduction in time spent on the ground by aircraft has direct benefits to the environment and the community, i.e., aircraft are not holding on the ground, running engines and APU’s while waiting for necessary services.

Finally, to create the greatest distance possible between passenger movement areas, ramp personnel activities and de icing operations would provide a higher level of personnel safety for all involved.

3. A new Passenger Terminal on the East Side can be expected to utilize a host of environmentally sound construction methods, techniques and upkeep techniques . As such, a new terminal can be expected to have a smaller carbon footprint than is current. This is a direct benefit to the environment.

4. An East Side Passenger Terminal will divert current airport vehicular traffic from Residential Zones (New Haven) to Commercial Zones (East Haven). This will be accomplished through use of a current State Road and the addition of a short access road leading to the new Terminal. This will directly benefit safety and quality of life in the neighborhoods who currently see traffic to and from the West Side Terminal.

This diversion of traffic can also be seen to improve the efficiency of airport access. Efficiency of access leads to direct benefits for the environment. The positive impact that this element of the project can have on the environment should be greatly considered as compared to the environmental consequences of a new, short access road.

5. The provision of new parking spaces around the new East Side Terminal will be constructed with greater planning and efficiency than the current complex on the West Side. This will lead to improvements in terms of passenger experience, neighborhood concerns and environmental matters.

6. The construction of an East side Terminal will eliminate a large portion of the need for West Side Airside and Landside facilities. This will provide that side of the airport relief from the earlier mentioned issues and concerns. It will also provide for the restoration opportunity of open space therefore benefiting the environment, and improving the quality of life for west side area residents.

7. The above improvements occur on current airport property and do not involve expansion of the airport boundaries. This is a direct benefit to the environment and the entire community.

The matters described thus far demonstrate a NEED for a new East Side Passenger Terminal. A NO BUILD ALTERNATIVE would promulgate negative airport impacts and not promote opined improvements. The PURPOSE of the East Side Terminal would be to mitigate negative impacts and provide improvements to the many stakeholders impacted by HVN.

*Extension of Runway 2-20.

The current length of Runway 2-20 is 5,600 feet. The HVN AMP seeks to lengthen the runway by 1,035 feet. This is shown to occur in the north and south Runway Safety Areas. The NEED for this project exists because of the operational, economic and safety needs of the region.

1. Operationally, all aircraft perform as a function of ambient temperature, wind speed, wind direction and barometric pressure. Runway surface contaminants (in the form of ice, rain or snow) along with fuel, passenger and baggage load also effect aircraft takeoff performance (negatively).

With additional runway length (as called for by the AMP) aircraft operational envelopes will be increased as a whole: to include during times of active or remnant precipitation. This has a direct benefit to operational, economic and customer satisfaction elements.

By no means is the current runway length insufficient, but rather a lengthened runway offers an improvement in aircraft performance metrics.

The current mix of Air Carrier and Private Aircraft will be able to operate more efficiently, economically and with more utility than they currently do than with 5,600 feet available.

As a result of increased runway length, various types of aircraft may be able to operate at Reduced Takeoff Power Settings. This has direct benefits in terms of noise emission and therefore benefits quality of life for area residents. Additionally, reduced power setting takeoffs consume less fuel. This is a direct environmental and economic benefit.


2. In terms of landing performance, a lengthened runway (to 6,635’) once again provides net benefits to include: Less need for aircraft diversions during less-than-optimal runway conditions (i.e., Wet, snow or Ice).

As you know, runway contaminants (Wet, snow or Ice) are detrimental to aircraft stopping distance. Part 121 regulation requires the addition of regulatory performance margins when calculating landing distance under various runway conditions which adds to REQUIRED LANDING DISTANCES.

It so follows, that by lengthening Runway 2-20, landing performance numbers will more often fall within the 6,635-foot runway length as proposed by the HVN AMP than they do under the current 5,600 feet. As such, the need for diversions will be lessened.

3. A lessened need for aircraft diversions (due to landing performance calculations) will impact the environment in a positive way. Aircraft that DO NOT divert (or HOLD) will burn less fuel, not strain Air Traffic Control (by re-populating a controller’s sector) and not burden surrounding airports (Air Traffic Control, Airside and Landside facilities) with unplanned for air traffic.

An aircraft that flies less often (extra flight time due to diversions and reposition flights to restore airline operations) is less impactful to the environment.

4. The proposed runway 2-20 project is shown to occur entirely on airport property. The paving of current, turf safety overruns does not increase the footprint of the airport. This directly equates to minimal or no environmental impact. Additionally, this provides for no intrusion into the local neighborhood area.

5. A lengthened runway for purposes of landing can again help reduce noise. Aircraft that utilize maximum reverse thrust (TR) during landing rollout at Tweed will have less of a need to do so with a lengthened runway. The need for less Reverse Thrust May directly improve the quality of life in the nearby area by providing for a reduction in aircraft noise.

The matters described above demonstrate a NEED for a lengthened Runway 2-20. The purposes of such a project is to benefit the many stakeholders of HVN. A NO BUILD ALTERNATIVE would promulgate negative airport impacts and not promote opined improvements. Therefore, there is a NEED for a lengthened Runway.

SUMMARY NEED and PURPOSE
The Terminal and Runway project are no doubt the most important projects to the HVN 2021 Airport Master Plan and related EA. This is so because of the potential they offer to improve Tweed-New Haven Airport in the above mentioned ways. By improving Tweed-New Haven Airport in these two very important areas, the environment, the local community, and aviation users stand benefit than if nothing is done as proposed.

In-Action (No BUILD) will likely lead to continued deleterious effects to the surrounding community and current users, as the airport continues to not only function but does so in an increased way as granted by numerous local, state, and federal laws.

As such, it is our opinion that an Environmental Assessment (as required under NEPA) for Tweed New Haven Airport is sufficient to consider the many stakeholders to HVN.

Given that the airport will continue to operate no matter the course of the outcome (build or no-build), we ask you to consider our comments as valid leverage in support of an Environmental Assessment as related to Tweed-New Haven Airport. Thank you.

T.Lorenti. Captain, ATR, ERJ, C680, E-Jet. ATP,CFI,MEI