Tweed-New Haven Airport EA: Unique considerations are what matter.

Recently, various elected officials have chimed in on the Tweed-New Haven Airport Environmental Assessment. Maybe they shouldn’t have done so.

In letters to the FAA, each of these officials have expressed insistence for an Environmental Impact Statement (EIS) as opposed to an Environmental Assessment (EA) by comparing past HVN projects and those of other airports to the current project proposals at Tweed. They postulate, “ if then, why not now”?

What these elected officials fail to consider is that every such project used in their comparison was and is entirely and uniquely different from those proposed currently at HVN and from one another. Also, these duly elected representatives wrongly compare scope of project to impact. Comparisons of scope and impact are not always directly related when it comes to EA versus an EIS.

Size does not necessarily directly relate to environmental complexity.
A major airport project could have very little environmental impact on its micro and macro environment whereas a small airport project could have major environmental impact. By example, when the Runway safety areas were improved at HVN some twenty years ago, an EIS was required because the project required the culverting and rerouting of a flowing body of water, ie Morris Creek (watercourse modification).

The above project was but one aspect with a relatively major impact to the environment that therefore necessitated an EIS. This project did not add runway length. This project did not involve construction of a new terminal. New airlines did not serve Tweed because of this project. But an EIS was determined by the FAA to be necessary. This was so because the project, though minor in the grand-scheme of the airport’s operation, made significant impact to the environment because of its specific features, not because it was inherently a massive or big project, but because it impacted certain and particular environmental systems in unique and specific ways.

Different is Different.

By comparison, the current slate of projects proposed at HVN under the 2020 Airport Master Plan require no such projects (such as diverting and culverting creeks) and therefore, why in the opinion of Tweed New-Haven Airport, an EA will suffice for the various improvements.

To illustrate that the scope (relative size) of airport projects/improvements and environmental impact are not directly related, let’s look at a MAJOR AIRPORT PROJECT currently under development in that of Charlotte-Douglas International Airport (CLT) . Said project includes the addition of a new 10,000 foot runway. It also includes the addition of hundreds of acres of aircraft parking aprons and the new construction of thousands of square feet of terminal space.

Do you know what the FAA found after after rigorous review of this project and the related EA? Finding Of No Significant Impact (FONSI). Gulp!

By using comparisons, as these elected officials have made in relation to Tweed, I have now shown them to be faulty comparisons and as such, these reasons ( side by side comparisons) do not substantiate the need for an EIS over an EA. Such comparisons by these officials highlight the lack of understanding that each has in terms of understanding Environmental Assessments, Environmental Impact Statements and Airports in general. These are not “one size fits all” or “if then scenarios”. In fact, they are detailed, thorough considerations for the unique circumstances of each airport, environment, community and proposed project.

Projects and improvements in the aeronautical setting are uniquely and intricately related to not just the scope of a given project, but to the entire matrix of the environment in which an airport resides. This validates the thoroughness of the EA/EIS process under NEPA. This means a seemingly small project could be determined to have big impacts…or not. Just depends.

By using this faulty logic as raised by these politicians (and certain civic action groups), should we expect a 10,000 foot runway to be constructed at Tweed simply because one airport project elsewhere yielded such a result (FONSI). Of course not! Tweed’s situation is entirely different and would be an entirely (and likely) different outcome if such were ever proposed( it’s not). This because Tweed and its current spat of projects are related to the environment in entirely different ways than CLT airport is to its environment.

No comparisons here!
Making comparisons to past, as well as other local airport projects, is entirely inappropriate when necessitating the need for an EIS versus an EA. Trusted, elected officials should know substantiating the need for an EIS over an EA requires much better logic than simple comparisons. Airports, their communities and their respective environmental concerns are unique and intricately related. These issues are not simple. I thought elected representatives and citizens groups with valiant concerns for the environment would know this. I guess I thought wrong.

Will allegations of conspiracies run amuck?

Could it be the FAA made a mistake in the case of CLT airport? Did the FAA receive a payoff from the resident airline? These are silly postulations of course. The FAA dutifully reviewed the data and impacts of this project (CLT) and thoughtfully, expertly and professionally published its ruling. This is exactly what we can expect in the case of Tweed. The FAA will consider the intricate and unique aspects to the current project as they relate to the community and the environment, not what has been done in the past with regard to entirely different projects.

I did not write this article to make a case for comparisons of airport projects to one another and their respective needs for an EIS over and EA…anything but. I wrote this article to illustrate that comparisons of such by elected officials and citizen action groups is utterly foolhardy and shows their complete lack of understanding to the unique and intricate considerations of airports, their communities and the environment. I’ll say it again…comparisons made as these groups do, as a cause for an EIS shows a principle misunderstanding of the very nature of what’s at hand.The environment needs better stewards.

If the FAA determines the need for an EIS, than so be it…just as if the FAA determines that an EA is sufficient for the improvements proposed at Tweed. In a way, it will be just as Nature intended it. The EIS is designed to be the next logical step in the NEPA process if and after an EA is determined not sufficient. That’s how the whole process works!

Public Officials and Civic groups who oppose Tweed-New Haven Airport (blowhards such as these) need to stop polluting the minds of citizens of this region with their anti-Tweed EA rhetoric, false assertions, vague and unsighted studies. They need to let a process designed for the very important issue of the environment analyze do its job, step by step! The environment does not need political grandstanding and the false authority of citizen action groups to muddy the issue.