Proposed Airport Expansion

Below are a few summary points about the new Environmental Assessment, developed by Andy McGill, CPCQ researcher for 15 years and Stonebridge resident.  Other resources are: 

 

Draft Assessment	Presentation on Environmental Assessment	Letters from Maple Creek HOA	Current Airport Layout
2022 DRAFT Environmental Assessment	Update on Environmental Assessment	Maple Creek Letters	Proposed Airport Layout

            The City of Ann Arbor proposes to extend the primary runway at Ann Arbor Municipal Airport from its current 3,505-foot length to a 4,225-foot runway, adding 720 feet to the western end of Runway 6 / 24. That plus the shift of 150 feet from the east to west end of the runway would bring aircraft 870 feet – the length of three football fields – closer to Lohr Road, where previous research shows aircraft would be landing only 93 feet above the rooftops of homes. 

 

            The proposal is dangerous and must be rejected!

 

 

            On November 10, 2022, ARB airport officials issued their third federally required Environmental Assessment (EA) in a dozen years. The first two EAs were rejected by the FAA. The 2022 Second Revised Draft Environmental Assessment (SRDEA) discusses ARB officials’ rationale for the expansion, claiming it would improve the “operational utility of the airport by meeting the takeoff and landing runway length requirements of aircraft that currently operate at the airport and are projected to steadily increase over time.”

 

            To support its claim, the SRDEA emphasizes the needs of four types “critical aircraft” – two classes of jets and two classes of turboprops. However, rather than supporting the need for an expanded runway, detailed aircraft performance charts provided in an Appendix to the SRDEA for each model confirm that three of the four classes of “critical aircraft” could operate year-round without penalty at full weight on the existing 3,505-foot runway, and that aircraft in the fourth class – dominated by the Cessna Citation Excel XLS -- could operate at full weight 90% of the time and at 100% capacity on most days.

 

            The SRDEA goes on to argue, however, that the extended runway is necessary because weather conditions – especially wet runways – can require longer stopping distances for aircraft, contending that such wet weather conditions existed at ARB an average of 192 days per year between 2010 and 2018. However, as the FAA made clear in comments on an earlier version of the SRDEA, reviewed under the Freedom of Information Act, wet runway conditions cannot be used to justify a runway expansion.

 

            “The inclusion of the contaminated runway length distances cannot be used to justify runway length under FAA funding requirements,” the FAA said. “Safety is maintained by the pilot adjusting their mission (payload, etc.) to the available runway length, not by the addition of a longer runway.” The FAA goes on to add that its Airport Improvement Program (AIP) “is not intended to provide sufficient runway length for ‘all’ normal considerations at an airport. . .in these circumstances, pilots are expected to calculate runway length needs and make adjustments needed for safety.”

 

            However, in a not-so-subtle affront to the FAA, stressing that its authority is limited, the SRDEA goes on to distance the project from the authority of the FAA, which has blocked the hard-to-justify project for more than a dozen years. The SRDEA states that as one of 10 State Block Grant Program (SBGP) recipients, once federal funds are received by the State of Michigan, except for approving Airport Layout Plan (ALP) components and navigational aids, the FAA “has no control, responsibility, or discretion for the use of SBPG funds” and “does not retain funding for or approval of SBPG actions.”

 

            In short, regardless of FAA regulations and opinions, once the federal funds are received as part of a block grant to fund the proposed ARB expansion, the Michigan Department of Transportation Aeronautics Division (MDOT-AERO) is free to ignore the FAA and award grants for the ARB project construction based on whatever unilateral criteria MDOT-AERO chooses -- whether the expansion is actually necessary or not, or whether the project’s Purpose and Need have been sufficiently justified.

 

            The danger of the proposed expansion, especially near the heavily populated neighborhoods surrounding the airport, presents a safety risk to residents that far exceeds the minimal benefits from the expansion that would be gained by the Citation XLS class of jets,  dominant among them, with 61% of the Citation XLS class operations, the operations of a single Cessna Citation Excel XLS operator, AvFuel Corp. Even worse, the expanded runway could – the SRDEA acknowledges likely would -- attract more larger and heavier jets, posing additional risks in an area heavily populated with Canada geese, which do not interact well with jet aircraft, as several prominent national accidents have showcased. 

 

            In addition, for the first time since the first ARB DEA was issued in 2010, airport officials finally acknowledged the significant presence of Canada geese in and around the airport. The SRDEA contains the report of an on-site U.S. Department of Agriculture inspector, who reported observing 75-100 Canada geese operating on the airport, feeding in a tilled fallow field. The inspector also reported that “flocks of 5 to 15 geese arrived on the airfield at different times. . .Geese were observed feeding within 10 yards of the runway.” As the Agriculture Inspector concluded, “Canada geese are a real and present danger, and will need to be managed for the foreseeable future. KARB is surrounded by ideal resident / migratory Canada goose habitat.”  The SRDEA, however, presents no plan for such mitigation. The SRDEA also makes no mention of any risks posed by the Canada geese.

 

            In short, the proposed expansion would primarily benefit the owner of a single Cessna Citation Excel XLS, which could be hampered by high temperatures, at most, 18% of the time, potentially affecting only 29 of its 161 annual operations – and representing only a miniscule .00038 of ARB’s total annual operations in 2019. In the process, the expanded runway would likely attract larger and heavier jets to the airport, posing greater risks to residents living around the airport, in an area heavily populated with Canada geese – adding to the danger. 

 

            As a result, objections contained in previous comments on the initial DEA and the revised RDEA remain unchanged: The risks of the proposed project far exceed any benefit that could result. The project poses serious risks to residents living around the airport, an area heavily populated by Canada geese, especially if the expanded runway attracts more jet traffic, as expected. The proposal also ignores the strong opposition by Pittsfield Charter Township, in which ARB is located, because of the risks posed by the project. In addition to which, sufficient Purpose and Need have not been established for the proposed expansion.