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04/23/2023 07:17 AMA group of citizens and citizen scientists feel Branford has been left out, at its peril, of the Tweed New-Haven Airport expansion Environmental Assessment (EA) equation. On April 19, three of them came before the Board of Selectmen (BOS) to make an impassioned pitch for last-ditch action from more citizens and the board itself.
They are urging the request of a full Environmental Impact Study (EIS) to be undertaken to address issues they said are undiscussed in the current EA, including noise, traffic, and air pollution impacting Branford. They want the selectmen to support the request, noting the request already has area bipartisan elected leader support, such as that of East Haven mayor Joseph Carfora (R), State Senator Christine Cohen (D, District 12), and several state legislators representing area towns.
An EIS is undertaken by federal and other agencies. By contrast, the EA has been produced by a consulting firm hired by the airport.
That EA is now under review by the Federal Aviation Administration (FAA), including a public input period, which will end Monday, May 1. A public hearing held in East Haven on April 1 has been continued to a virtual Zoom hearing set for April 25, 6 to 8 p.m. Residents can register to give input at the Zoom hearing at this link. Written comments will be accepted until May 1 via mail or email at: HVN-EA Public Comments, McFarland Johnson, 49 Court Street, Suite 240, Binghamton, NY 13901 or hvn-ea@mjinc.com
On March 2, in accordance with the National Environmental Policy Act (NEPA), the Tweed New Haven Airport Authority released its Draft EA for public review and comment. According to a press release from Tweed New Haven Airport, the EA addresses “...the foreseeable environmental, social, and economic consequences associated with the proposed extension of Runway 02-20 and construction of a new airport terminal (“East Terminal”) and associated facilities at Tweed New Haven Airport. The analysis of potential environmental impacts in the EA was conducted in accordance with FAA Order 1050.1F, “Environmental Impacts: Policies and Procedures.”
An electronic copy of the Draft EA can be accessed at tweedmasterplan.com/nepa-documents
During citizens’ statements at the April 19 BOS meeting, residents Sandra Reiners, Wanda Bubriski, and Margaret Wheeler addressed the board. A main concern they addressed is that, if the EA is accepted as presented, the FAA will declare it a Finding of No Significance (FONS), clearing the way for the proposed expansion of runway, addition of a new terminal in East Haven, and additional parking.
They said one among many reasons that an EIS is needed is that the EA, when released in March, did not contain any input, as required by federal law, from agencies including the Department of Energy and Environmental Protection (DEEP), Environmental Protection Agency (EPS), Army Corps of Engineers and others.
Wheeler, a retired university biology professor, said she made that point at the EA public hearing on April 1 at the Hagaman Library in East Haven. At that time, she said she was told that the required agencies’ input would “get there” by May 1.
“That’s supposed to be the deadline for our [EA] letters,” said Wheeler, leaving the question of how these environmental issues can be raised if the letter writers cannot find those details in the EA before May 1.
Wheeler said such agency input is required by law (through the federal Council of Environmental Quality).
“When you release an EA, you have to have input from [these] government agencies,” said Wheeler. “But there were no comments in there because it wasn’t ready.”
For example, she said the expansion calls for putting in 61,700 cubic yards of fill into a coastal flood plain; and digging in wetlands, requiring evaluations such as those by the Army Corps of Engineers and the EPA.
The three said even more concerning to citizens should be the fact that Branford is not included in the EA, despite clearly being impacted by planes arriving and departing at air height levels less than those required by the FAA.
As reflected by 2,500 signatures gathered on a petition requesting a full ESI by grass-roots citizens group Save Our Sound (SOS), the three said commercial airliner noise created by Tweed is clearly impacting areas across town, from Short Beach to Indian Neck and other locales, including one designated an Environmental Justice block in Branford Hills.
According to FAA policy (faa.gov), Executive Order 12898, signed in 1994, requires federal agencies to achieve Environmental Justice by “...identifying and addressing disproportionately high and adverse human health and environmental effects, including interrelated social and economic effects, of their programs, policies, and activities on minority populations and low-income populations.”
Another area of concern with the EA, which Reniers pointed out, is that the EA uses FAA computer models to build its assessment, summary, and conclusion, which is “not a measurement of reality,” she said.
“Many people have found a lot of flaws and a lot of incomplete data. The study does not even include Branford -- it stops at the Farm River,” said Reiners. “We urge the selectmen to advocate strongly for something which measures, not just models, the environmental impact.”
She said the EA noise model does not extend further than an area between the Annex in New Haven and the Farm River in East Haven to portray a contour line showing noise and emissions from Avelo commercial airliners departing and arriving at Tweed.
“That does not quite jibe with what we hear in Branford with the over-flying aircraft,” said Reiners.
Avelo Airlines first began operating passenger flights with low ticket prices out of Tweed in April 2021. Reiners said air traffic has increased 14-fold from 2021 to 2022, an increase that is “visible and tangible” in Branford.
“It’s a very significant issue for Branford,” said Reiners.
She said Branford is impacted by regular flight paths of northbound departures, usually turning east over Branford, as well as any arrivals coming south to the runway.
“So Branford is getting a lion’s share of overhead aircraft under 2,000 feet in altitude, and there are 24 flights a day at the moment,” said Reiners. “The projected model shows there might be up to 56 flights a day by 2031, and by 2026, it’s 44 flights a day. That’s an enormous increase in noise as well as air quality and pollution.”
Wheeler also noted the airport proposal to reach a maximum of 56 flights a day in eight years’ time would also involve plans to increase its number of larger 737-800 series passenger jets in the fleet, some of which are being used now, she said.
“It will give them less flights and more money instead of 737-700 series [which] would come out to be 3.4 million passengers a year,” said Wheeler, a figure which she said surpasses the proposed expansion’s master plan approved by the FAA.
With arriving/departing Avelo traffic over Branford already traveling under an altitude of 2,000 feet, “... there’s plenty of data that shows we are impacted by the volatile compounds [including] increases particulates, from emissions and ultra-fine particulates,” said Wheeler.
“These are issues that impact our health,” said Wheeler. “The area around the airport [is already] an ozone non-attainment area, with high levels of ground-level ozone...imagine the increase in ground-level ozone it’s going to have from emissions from cars and planes.”
Passengers using area roads to reach the airport are already increasing traffic levels, but should the 3.4 million annual passenger number come to pass, Wheeler surmised that would average 9,480 passengers daily using the main route to the terminal, Hemingway Avenue in East Haven. The road intersects with Shore Drive, which leads to Branford via Short Beach.
“The Town of East Haven is seriously worried; [and] where Shore Drive meets Hemingway is in a flood zone,” said Wheeler.
She said that with 4,500 to 6,000 cars a day coming through Hemingway, alternate routes would find their way through Branford.
Among air/noise monitors citizens have situated in the airport area, one placed in Branford Hills on Pompano Avenue captured a “small sample,” and “...that one sample would indicate that Pompano is registering a higher sound decibel level than Hyde Street, which is right next to airport, and similar or higher levels of toxins that are emitted than right next to the airport,” said Reiners.
Bubriski also noted that a Short Beach neighbor, Ken Engelman, has recorded Avelo airliners flying so low over his backyard that 91 decibels (dB) of sound was recorded.
According to FAA policy, the agency has adopted a day-night average sound level (DNL) of 65 dBA (dBA levels are “A” weighted according to the weighting curves to approximate the way the human ear hears) as the threshold of significant noise exposure. The metric reflects a person’s cumulative exposure to sound over a 24-hour period as the noise level for the average day of the year on the basis of annual aircraft operations. The policy states, “areas exposed to noise levels between DNL 65 dB and 75 dB are ‘normally unacceptable,’ and require special abatement measures and review. Those at DNL 75 dB and above are ‘unacceptable’ except under very limited circumstances.”
Reiners urged first selectman Jamie Cosgrove to advocate for the Town of Branford that there be an EIS.
“It doesn’t say stop everything at the airport. It says measure what’s happening, don’t just model,” Reiners said of the EIS. “There is a great impact happening from what exists already. Please join with Mayor Carfora, join with our state representatives [who] have all advocated for an EIS. Please advocate before the May 1 deadline.”
Even without expanding the airport, Wheeler said going to larger planes would increase exposure to sound, pollutants, and other endangerments.
Cosgrove asked for some clarification on the group’s statements, such as those regarding action-no action (expansion or not expanding), which the group said would still not stop the planned increase in commercial airline traffic; and would lead to increased air pollution, including nitrogen oxide emissions.
As Reiners had explained earlier, the number of flights predicted for 2031 would equal emitting 450 tons of nitrogen oxide, something she said is not reflected in the computer modeling in the EA.
“This computer model said it would not exceed a benchmark of 25 tons; and we are admitting 25 times that in actual quantity. That’s the hypocrisy of this model,” said Reiners.
Cosgrove asked Reiners, “If they take no action, you mean no expansion; but as you say, they’re not seeking approval to add additional flights because they can do that today... so if they were taking no action in terms of expanding the runway and building the new terminal, in 2031 the projection would be 68 flights a day, and that nitrogen oxide level would be 450 [tons]?”
“Yes, roughly,” Reiners answered. “But the difference between the two benchmarks is a small number, even though the base has grown 20 times.”
The citizens provided written information to the BOS on April 19 to review as part of their request. The full April 19 BOS meeting was live-streamed by BCTV and can be viewed at BCTV on Facebook.