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-relocatingnew-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 NSMTS should not be constructed based on the following 

rationale:

LaGuardia Airport (LGA) is one 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, whose 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 20th in passengers and 14th

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 

analyzed 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 with 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, building 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), current 

obstructions located on the LGA Runway 31 final approach course preclude the 

establishment 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. Reference (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 this proposal. 

Failure to implement this 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 NSMTS 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 landing 

requirements. This would not allow significant capacity improvements (see reference 

(b)) to facilitate improved traffic flow at LGA. These improvements, if implemented, 

could improve traffic flow in the highly congested airspace Northeast corridor (New 

York, New Jersey, Eastern Pennsylvania) by expanding the arrival capabilities at LGA 

runway 31. This enhanced traffic flow is extremely important in today’s time frame, but 

becomes increasingly critical considering traffic flow projections in 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 runway 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 constitute 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). There 
is no logical rationale to allow the NSMTS 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 property and equipment losses. The oversight methods outlined in reference (c) 

are questionable at best. There is no solid evidence that the audit program will produce 

the necessary results. This poses a high risk that will likely not be sufficiently mitigated 

and the resulting residual 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 airport 

where bird strikes can occur, and 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 can 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 

controllers must maintain three mile separation regardless of weather or other 

conditions. Congestion may form back at the outer range of the Terminal Radar 

Approach Control (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 aware 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 

airspace 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 ground prior to take off. Either way, 

it's something you would like to avoid.

Since the terminal final approach area requires terminal air traffic controllers to maintain 

three mile separation regardless of weather or other conditions. What can happen is that 

congestion may form back at the outer range of the Terminal Radar Approach Control 

(TRACON) facility. It then can backtrack into the En Route Airspace sectors. The 

Enhanced Traffic Management System (ETMS) is the system used by our traffic 

management personnel 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 rather 
than in the air. This is a safer way as it precludes "holding" patterns. 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 displays 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 plan 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 Command 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 civil 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 decisions are carried out in cooperation with 

airline personnel, traffic management specialists and controllers at affected facilities. 

Among other items, the ATCSCC (reference (f)) provides documentation and a map of 

major U.S. airports with color coding showing each airport’s status as one of the 

following designations:

(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 delayed 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) The 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 ATC 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 all runway pavement is a problem as 

it backs up traffic in the TRACON and that in turn causes traffic to back-up in the en 

route sectors. This may result in delaying airplanes on the ground prior to take 

off. Being able to land airplanes on LGA runway 31 more frequently will benefit the air 
traffic control by enabling more expeditious 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 

projected increased 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 flight 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 the 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 threshold at the time). This incident occurred on a final approach

to JFK. There are likely more incidents if a detailed search 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 weather 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) cites 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 the 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. Because 
such 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 number 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 planes 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 reduction 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 have 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 have 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 highspeed taxiways 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 spokesman 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 asked. 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 tremendous 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 primary 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 

meteorological 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 aforementioned reasons (bird strike threat, passenger dissatisfaction, 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 not 

be constructed 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 

density Northeast corridor, and potentially reduce the impact of severe weather. This will

reduce airport delays at LGA thereby helping passenger dissatisfaction, and help to 

reduce overall stress.