MY POSITION ON THE NSMTS REPORT

References:

(a) http://businesscenter.jdpower.com/news/pressrelease.aspx?ID=2010015 (b ) Improving Access to LaGuardia International Airport, Williams Aviation Consultants Report, 2010 (c ) Evaluation of North Shore Marine Transfer Station (NSMTS) and its Compatibility with respect to Bird Strikes and Safe Air Operations at LaGuardia Airport (draft), US DOT/FAA and USDA Animal and Plant Health Inspection Service - Wildlife Services, April 2010 (d ) http://www fly.faa.gov/Products/Information/information html

(e ) https://employees.faa.gov/org/linebusiness/ato/about/facilities/command_center/index.cfm?forceMyToo

ls=true

(f) http://www.fly.faa.gov/Products/NASDOCS/nasdocs.jsp

(g ) Web Site: http://csted.sri.com/content/envirotechnical

- program

- assist

- faa

- relocating

new

- york

- terminal -doppler- weather

- radar (h) http://www.infrastructurereportcard.org/fact- sheet/aviation (i) http://www.huffingtonpost.com/2009/11/23/new- york

- airports

- ranked

- _n_367512.html

My position is that the NS MTS s hould not be constructed based on the following

rationale:

LaGuardia Airport (LGA) is o ne of the busier United States airports in annual operations and passengers opened to commercial traffic in 1939. In 1947, it was leased to the New York Port Authority. The two main runways 4/22 and 13/31 are 7,000 feet long and 150 feet wide. A 460 feet safety overrun area was added to runway 13-31 to enhance safety. The four runway lengths total 28,000 feet (5+ miles) in contrast to JFK Airport’s four runways, whos e total length is about 9 miles. The New York metropolitan area (LaGuardia, JFK and Newark Airports) comprise more annual operations than any other nationwide metropolitan area. In a 2009 survey, LGA ranked 20 th in passengers and 14 th
in departures. In a 2010 survey done by JD Power and Associates, LGA ranked last out of 21 airports in passenger satisfaction (reference ( a )).

Williams Aviation Consultants provided a report (reference (b)) that reviewed and analyze d the proposed North Shore Marine Transfer Station (NSMTS) located 1,850 ft southeast of the Runway 31 threshold of LaGuardia airport (LGA). The purpose of the analysis was to determine how the proposed NSMTS would impact the usability of LGA during periods of inclement weather by preventing the implementation of a precision instrument approach procedure wi th 1⁄2 mile visibility minimums. During the process of conducting our review, it became clear that the NSMTS, presently under construction,will degrade airport access and efficiency while potentially increasing air traffic delays and associated costs to aircraft operators.

Currently, bu ilding obstructions preclude runway 31 (one of four LGA runways) from having a full Instrument Landing System (ILS). Short of a full ILS, there is a plan that could be implemented to allow a precision instrument approach procedure (IAP) on runway 31 as opposed to the current non

- precision IAP. Per reference (b), c urrent obstructions located on the LGA Runway 31 fina l approach course preclude the

establishm ent of a precision IAP with visibility requirements as low as 1⁄2 mile. Reducing the height of these obstructions will allow the LGA airport operator, in conjunction with the FAA, to establish a precision IAP to Runway 31 with improved visibility landing minima down to 1⁄2 mile from the current 1 3⁄4 mile limitation.

If satellite navigation based IAP such as a Localizer Performance with Vertical Guidance ( LPV ) was selected for implementation, the installation could be accomplished with

minimal cost. Referen ce (b) recommends that the two existing silos constituting obstructions on the final approach course to Runway 31 be reduced in height to facilitate the establishment of a precision IAP to Runway 31. Reference (b ) contains additional details regarding thi s proposal.

Failure to implement t his potential capability can impact LGA from fully achieving its maximum landing capability. Reducing the height or eliminating some of these edifices and not constructing the NS MTS are required to achieve the increased capacity, and these building changes are deemed to be feasible. However, building the proposed NSMTS would prevent the opportunity to reduce the current LGA runway 31 la nding requirements. This would not allow significant capacity improvements ( see reference (b )) to facilitate improved traffic fl ow at LGA. These improvements, if implemented,

c ould improve traffic flow in the highly congested airspace Northeast corridor (New York, New Jersey, Eastern Pennsylvania) by expanding the arrival capabilitie s at LGA runway 31 . This enhanced traffic flow is extremely important in today’s time frame, but becomes increasingly critical considering traffic flow projections i n the next two decades (approximate Next Gen era)

.

In addition to the capacity concerns, there exists a viable threat from large birds being ingested by aircraft engines; thereby, creating possibilities of decreased engine performance, stalls, or even complete engine failures . Refer to US Airways Flight 1549 on 1/25/09 taking off from LGA ru nway 4, which extends into a body of water between Queens and the Bronx and is close to runway 31. That aircraft collided with birds only two minutes into the flight. Fortunately, courageous action was taken to save the flight crew and passengers. That may not be the case if it happens again, particularly at a lower

altitude than 3,200 feet

.

In the reference (c ) report, it is indicated that mitigation oversight will be performed. This, in itself, is a form of admission that the proposed NSMTS will co nstitute a bird attractant. Efforts to alleviate that situation cannot effectively preclude birds from staying in dangerously close proximity to LGA (particularly runways 31 and 04). Thereis no l ogical rationale to allow the NS MTS to be constructed and immediately attempt to rectify ensuing problems that it creates. The country (particularly the Gulf of Mexico coastline) recently is experiencing the adverse effects of deep oil well drilling with no salient or viable plan for expedient corrective action. We need to learn from this incident and not allow other hazardous situations to exist. The impact of a bird strike is significant in terms of loss of life both on the aircraft and possibly the ground as well as massive propert y and equipment losses. T he oversight methods outlined in ref erence (c ) are questionable at best. There is no solid evid ence that the audit program will produce the necessary results. This poses a high risk that will likely not be sufficiently mitigated and the resulting residua l risk will remain high and uncontrollable. Reference (c ) page 22 illustrates that a high risk can be made low based on the cited modifications and the wildlife hazard plan, but there is no credible substantiation (failure recovery and corrective action) shown in the document. There is a voluminous area around the airpo rt where bird strikes can occur, a nd even if methods can shoo birds away, it is unwise to assume that they would be scattered beyond the danger area in proximity of the airport as

strikes ca n occur at variable (and not insignificant) altitudes and range from the airport.

Not making optimal use of runway 31 when visibility exceeds 1.75 miles (usually due to bad weather conditions), the terminal area does not congest more because air traffic

c ontrollers must maintain three mile separation regardless of weather or other

condit ions. C ongestion may form back at the outer range of the Terminal Radar Approach Con trol (TRACON) facility, and can backtrack into the En Route Airspace

sectors. If it is predictable bad weather, then the FAA's traffic management system is

made a ware of it based on airports providing reduced runway capacity rates due to bad

weather. In that case, traffic management can space the aircraft out evenly in the en route airspac e so there isn't excessive congestion. However, that doesn't prevent flights from being delayed. Given enough notice, traffic management will delay them on the ground

rather than in the air. This is a safer and more fuel efficient way as it precludes "holding"

patterns.

The bottom line of all this is that not making maximum use of all runway pavement is a problem, whether it manifests itself in congestion on the outer edges of the TRACON and in the en route sectors or it just delays planes on the gro und prior to take off. Either way, it's something you would like to avoid.

Since t he terminal final approach area requires terminal air traffic controllers to maintain

three mile separation regardless of weather or other conditions. What can happen is t hat congestion may form back at the outer range of the Terminal Radar Approach Control (TRACON) facility. It then can backtrack into the En Ro ute Airspace sectors. The Enhanced Traffic Management System ( ETMS ) is the system used by our traffic

m anagement p ersonnel to predict, on national and local scales, traffic surges, gaps, and volume based on current and anticipated airborne aircraft . The Traffic Management Personnel evaluate the projected flow of traffic into airports and sectors, and then implement the least restrictive action necessary to ensure that traffic demand does not exceed system capacity (reference (d))

. However, that doesn't prevent flights from being delayed. Given enough notice, traffic management will delay them on the ground ratherthan in the air. This is a safer way as it precludes "holding" pattern s. Monitor Alert (reference (c)) is a part of ETMS that analyzes traffic demand for all airports, sectors, and airborne reporting fixes in the continental U.S. It then automatically d isplays an alert when demand is predicted to exceed capacity in a particular area. Restricting LGA runway 31 to landing only when visibility/altitude requirements are met will at times back up the busy Northeast corridor and require the ETMS Monitor Alert to display an alert. This puts additional stress on the Traffic Management and ATC system and requires action to be taken by Traffic Management to apply the appropriate routes, metering and spacing to aid in controlling traffic flow.

The National System Strategy Team (NSST) also gets involved when weather is

forecasted to turn bad. The role of the NSST is to minimize the impact of severe weather on the airspace system by collecting meteorological information from various sources, and devise a suitable p lan with the other air traffic facilities and system users for routing traffic around the bad weather. This plan is revised dynamically as needed.

Another FAA organization that is involved with traffic management is the Air Traffic Control System Comma nd Center (ATCSCC) (reference (e )). This Command Center exercises command, control and oversight of air traffic activity within the National Airspace System ( NAS )

. This facility, located in northern Virginia, coordinates all air traffic movement, both civi l and military, in domestic and oceanic airspace. Its staff strategically manages air traffic to minimize delays and congestion, while maximizing the

overall use of the NAS. These management d ecisions are carried out in cooperation with airline personnel, traffic management specialists and controllers at affected facilities. Among other items, the ATCSCC (r eference (f )) provides documentation and a map of major U.S. airports with color coding showing each airport’s status as one of the following designati ons:

(a) General Arrival/Departure delays are 15 minutes or less. (b) Departures are experiencing taxi delays of 16 to 45 minutes and/or arrivals are experiencing airborne holding delays of 16 to 45 minutes.

© Traffic destined to this airport is being d elayed at its departure point. Check your departure airport to see if your flight may be affected. (d) Departures are experiencing taxi delays greater than 45 minutes and/or arrivals are experiencing airborne holding delays greater than 45 minutes

. (e) Th e airport is closed.

The point is when a runway, like LGA 31, is disabled for landing, it increases the

workload for all of the ETMS related teams /organizations , the air traffic controllers, meteorologists, and others as it puts additional stress on the A TC system. In addition, the flying public and the airlines are adversely affected by delays from runway closures.

The bottom line is that not making maximum use of a ll runway pavement is a problem as it backs up traffic in the TRACON a nd that in turn causes traffic to back

- up in the en route sectors. This may result in delaying airplanes on the grou nd prior to take

off. Being able to land airplanes on LGA runway 31 more frequently will benefit the airtraffic control by enabling more exp editious flow of air traffic through the very busy

Northeast corridor.

It is unfortunate that current limitations impact the ability to achieve maximum landing capacity effectiveness at LaGuardia Airport. These limitations include only having a full

ILS on three of four runways. Runway lengths are also constrained by geographical considerations. Allowing the proposed NSMTS would significantly hamper efforts or restrict potential improvements in achieving the capacity vital in accommodating projecte d inc reased traffic flows in the decades ahead (Next Gen era)

.

Regarding a different subject, it should be noted that the Terminal Doppler Weather Radar ( TDWR ) that services LGA and JFK is actually located at Floyd Bennett Field in Brooklyn. Floyd Bennett is actually further from LGA than JFK. The attached reference (g) web site contains an article regarding a proposed relocation of that JFK/LGA TDWR.

A brief search uncovered three major weather events in the New York City area. It is not as completely a rare event as people think. There was the June 24, 1975 Eastern Flight 66 Boeing 727 (pre

- TDWR) , which crashed onto runway lights on the final approach to

JFK. A total of 112 passengers and crew were killed on that fligh t due to a concentrated microburst wind shear during a heavy thunderstorm. In addition, there was a serious wind shear type event that occurred in December 1999 causing many delays and missed approaches, and unplanned runway changes further complicated th e situation. In April 2002, weather caused a Boeing 767 to experience an uncontrollable descent of some 1,200 feet in less than 60 seconds (certainly a potential crash, but fortunately the aircraft

was above that altitude th r eshold at the time). This inc ident occurred on a final approach

to JFK. There are likely more incidents if a detailed searc h were performed. It should be

noted that TDWR supplemented by Low Level Wind Shear Alert System (LLWAS) has done a good job of warning against threatening weat her phenomena. The LLWAS provides wind speed and wind direction from several anemometers strategically located near airport runways. However, the LLWAS provides only low altitude information (generally up to about 100 feet) as the anemometers are located on poles. The TDWR uses its radial velocity and reflectivity measurements in attempting to locate potential hazardous weather, such as microbursts. However, the TDWR is 20.9 km or about 13.06

miles from LGA and consequently likely has some blockages and does not cover the lower altitudes. Since microbursts can be detected at higher altitudes, the TDWR is satisfactory, but not as good as if it were located at LGA, where it could produce weather

data at lower altitudes as well. Note that reference (h) ci tes that about 68% of aircraft delays are caused by weather and 5.8% of aircraft delays are caused by closed runways.

Reference (i) from 2009 cites the following related to traffic delays in New York City:

Despite some recent improvements, the Big Apple 's three major airports continue to be the country's worst air travel bottleneck. Through t he first nine months of 2009 , they ranked first, second and third worst in on

- time arrivals among the 31 major U.S. air hubs, according to federal statistics. The problem doesn't affect just New Yorkers. Becausesuch a large percentage of the nation's flights pass through the city sometime during any given day, delays here have a tendency to ripple elsewhere.

In 2007, nearly three

- quarters of all delays in the U.S. could be traced to a problem in New York, according to the Federal Aviation Administration. The log jam has received a lot of attention over the past two years, with mixed results. The FAA tinkered with takeoff and landing procedures and limited the numbe r of flights allowed at all three airports. Airlines adjusted their schedules. Air traffic controllers settled a labor dispute. The military even opened up restricted airspace off the East Coast. Improvements have

been modest.

On busy days, the lines of p lanes landing at LaGuardia Airport can still stretch unbroken in the sky for 40 miles, said Dean Iacopelli, an air traffic controller and union representative at the facility that handles approaches to New York. "All we can do is take them and space them out as close as FAA rules allow," he said. "It's not like you can put more aircraft in there. That's it. We're just maxed out." Getting planes off the ground is no picnic, either, he said.

With a takeoff or landing scheduled every 40 to 50 seconds during peak periods, controllers are sometimes so busy giving instructions that they can't get the words out quickly enough. "One guy just can't talk that fast," Iacopelli said. The little relief that has come recently has been due partly to a nationwide reduct ion in air travel, experts

said.

Flights were down 10 percent at LaGuardia and 9 percent at Newark Liberty International in the fiscal year that ended in July 2009. They were down nearly 5 percent at John F. Kennedy International Airport.

Fewer flights ha ve meant fewer delays. Through Sept. 20, about 66 percent of the arrivals at LaGuardia have been on time in 2009, up from an abysmal 58.6 percent during the same period a year ago. Newark's on

- time arrival rate improved from 60.8 percent to 64.1 percent. JFK's improved from 66.8 percent to 71.4 percent. Big improvements aren't expected anytime soon. Airports serving Atlanta, Chicago, Boston, Seattle and Washington, D.C., have all added runways in recent years to relieve stress, but no such expansion is in the works for New York or Newark, N.J. The FAA continues to work on a handful of other projects aimed at reducing congestion.

For two years it has been phasing in a reconfiguration of the complicated airspace around New York and Philadelphia. Airlines h ave been seeking an overhaul of the old, inefficient jet routes for years, but the plan has been opposed by some communities because of noise concerns. Implementation, scheduled to be complete in 2012, is now significantly behind schedule. "The sooner we get it, the better," said Tim Wagner, a spokesman for American Airlines.Meanwhile, the Port Authority of New York and New Jersey, which operates the airports, is now resurfacing one of the main runways at Kennedy. That project will also add high

speed ta xiways and extra waiting pads aimed at reducing backups.

Airlines worry that delays could get worse while the strip is under construction, but Port Authority officials say they have planned thoroughly to minimize disruptions. "I'm a

believer that sometimes it's worth it to take the pain in a short dose, and get it over with," said Susan Baer, the Port Authority's aviation director. The FAA for years has been pushing a $35 billion plan to modernize its air traffic control system, a project called

NextGen. Some elements of the new technology, which promises a significant efficiency boost, are already being deployed, but the government has hesitated to put the overhaul on a fast track, in part because of concerns over its enormous cost.

David Castleveter, a s pokesman for the Air Transport Association, an airline industry group, blamed the slow rollout of the project on "procrastination" and "complacency." "The economy will turn around, we all know that, and there will be growth. Will we be ready for it?" he a sked. In the meantime, air traffic controllers will try to get the most they can out of the equipment they have. Ray Adams, a controller and union official at the tower in Newark, said it won't be easy.

"Traffic has been down, and we are still running tr emendous delays," he said. "At some point, depending on controller skill level, you just get to the point where you can't jam anyone else in there."

The point that may be made is that LGA seems to get the short end in terms of capabilities. Not only does it not have a full ILS on each runway, but it also uses the Floyd Bennett Field/ JFK TDWR for its pri mary microburst related data. In addition, on days when runway 31 experiences Northwest winds (favorable for landing on runway 31), but that runway cannot be used because of reduced visibility, pilots are forced to land on runway 4/22 into crosswinds. If they experience an unforeseen significant

meteorolo gical storm, they will also have to contend with crosswinds. This situation may not occur frequently as much of the bad counter

- clockwise rotation weather is from Nor’easters, which normally result in a tailwind component on runway 31.

For all of the afo rementioned reasons (bird strike threat, passenger dis satisfaction , lack of full ILS on runway 31, lack of a separate TDWR located at LGA , significant delays at

LGA and other NYC airports , etc. , it is suggested that the proposed NSMTS should n ot
be constru cted and the changes

, as outlined in the Williams Aviation Report ( reference (b ) ), be enacted to reduce the visibility criteria for LGA runway 31. This will enhance capacity, reduce workload and stress on the ATC system, benefit traffic flow in the high

d ensity Northeast corridor, and potentially redu ce the impact of severe weather. This will reduce airport delays at LGA thereby helping passenger dissatisfaction, and help to

reduce overall stress.