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« on: June 02, 2005, 09:39:11 AM »
Letter to Hon. Jon Corzine:
The Honorable Jon Corzine
United States Senate
August 27, 2003
Dear Senator:
Since April, 2000 I have been working with Congressman Steve Rothman regarding the numerous errors, inconsistencies and obfuscation in the FAA's "FINDING OF NO SIGNIFICANT IMPACT" that allowed the ILS on Runway 19 at Teterboro Airport (TEB) to open and allowed planes to fly dozens of feet over the high-rise apartment buildings in the Hackensack Heights and Hackensack University Medical Center (HUMC).
Congressman Rothman arranged with the FAA for planes to fly an eastern offset to Runway 19, taking them down the Hackensack River, when planes were not using the ILS during bad weather. With the appointment of new FAA Administrator Blakely, planes are once again flying directly over HUMC. With the August 5, 2003 crash of a corporate jet at a small Connecticut airport, North Jersey residents are terrified that a corporate jet, or soon the 737 Boeing Business Jet, will cartwheel through the Hackensack Heights and HUMC, killing thousands.
In 2002 you wrote to FAA Eastern Regional Administrator Arlene Feldman, asking her to respond to my letter asking about the "FINDING OF NO SIGNIFICANT IMPACT." With Congressman Rothman's arrangement there was no need for these questions to be answered. Now it is vital to the safety HUMC patients and staff that the questions finally be answered and that ILS-19 approach once again be directed away from the Hackensack Heights.
As you know members of the New Jersey delegation have been calling FAA Administrator Blakely and DOT Secretary Minetta about their concerns. Neither has returned the calls. Can you please help us at least get answers to our questions regarding the significant safety concerns of flights over HUMC? These are Administrator Feldman's responses to my questions on 2002:
1998 TEB Operations Exceed FAA Projection for 2007.
The FAA "FINDING OF NO SIGNIFICANT IMPACT" that allowed ILS-19 to open states:
• p3: "Recently, total activity levels appear to have stabilized at approximately 160,000 annual movements. Total activity has remained at or very close to this level since the end of 1989. Forecast data used for the Environmental Assessment noise analysis were predicted on three well established trends (including) Total airport operations remain under 170,000 annual operations. This leads to a total annual movement sum of 167,799 by the Year 2007." (page 2)
p7: "The proposal is not expected to increase traffic levels at TEB."
The FAA was asked for the actual number of total TEB operations from June, 1999 to June, 2000. Ms. Feldman refused to provide the total TEB operations data but instead reported operations only for Runway 19. She does apparently revise upward the TEB aircraft operations forecast, providing a 1999 number that is within 627 operations of the 2007 prediction:
"The projected total landings and takeoffs used in the noise analysis for the two-year period ending 1999 was 166,172 operations, or a 4.3% increase over 1996 operations. For the seven years from 1990 to 1996, there was a 0.5% decrease in traffic, however, the EA used an estimated 4.3% increase over the two year period ending 1999, as a conservative estimate.
In 1996, according to data provided by the airport operator, Johnson Controls, the specific mix of total operations using Runway 19 was 15,057 landings and 6,539 takeoffs. Johnson Controls also provided us with data relevant to the use of Runway 19 for the period of June, 1999 through the end of June, 2000. Specifically, there were a total of 47,177 flight operations (36,241 arrivals, and 10,936 departures) using Runway 19 during this period."
In a May 19, 2000 letter to me, Robert Helland, an aide to now Senator Jon Corzine, uncovered the fact that the FAA recorded 198,466 annual operations at TEB during 1998, a 10% increase over 1997 and an 18% increase over the "FINDING OF NO SIGNIFICANT IMPACT" projection for 2007.
Without even considering the numerous other errors in the application of data and inconsistencies in the ILS-19 "FINDING OF NO SIGNIFICANT IMPACT," if the report’s environmental impact conclusions were predicted on total airport operations remaining under 170,000 through the year 2007, the FAA's own record of 198,466 annual operations at TEB in 1998 violates the cumulative noise impact projection and alone invalidates the "FINDING OF NO SIGNIFICANT IMPACT." This data should force a restriction of flights using TEB to within 170,000 until a valid and unbiased environmental assessment can be conducted.
The data Ms. Feldman provided does show that there was a 118% increase from 1998 to 1999 in flights using Runway 19. While this number represents only a portion of total TEB flight operations, it is representative of the marked increase in traffic into TEB and contradicts the report’s statement that "The proposal is not expected to increase traffic levels at TEB." Most important, the 118% increase in traffic using Runway 19 explains the increased concern of those at HUMC. It is the flights using Runway 19 that are placing our lives at risk.
Elevation Danger in the Hackensack Heights not Addressed.
The FAA "FINDING OF NO SIGNIFICANT IMPACT" states: • p4: ILS-19 "moves the approach away from residential areas to the predominantly industrialized areas North of the airport."
ILS-19 is in actuality an approach directly over residential areas to the northwest of the airport, residential areas containing the tallest buildings in the area. On p 4-1, the report does note that "community areas to the west and north lie at much higher elevations than the airport. These include Wood-Ridge, Hasbrouck Heights and Hackensack." But the wisdom of aircraft flying over those "higher elevations" is never addressed.
The FAA was asked to address the report’s misstatement that ILS-19 "moves the approach away from residential areas to the predominantly industrialized areas North of the airport," never mentions the effect of noise and safety on these "much higher elevations" nor the implications of aircraft flying apparently 50 feet above numerous high-rise buildings and over a majo medical center. I also asked for FAA radar tape data documenting the minimum and average altitudes of aircraft flying over HUMC. Ms. Feldman did not address the misstatement, provided no data for actual aircraft elevations but provided the following calculation:
"An aircraft using ILS guidance will generally be at a 3 degree angle downward to the touchdown point on the runway. Therefore, by taking into account and adjusting for the height of a building such as the Hackensack University Medical Center (HUMC), as well as considering the physical terrain in the vicinity, we are able to determine that an aircraft using an ILS approach to Runway 19 at TEB would be approximately 400 feet above the top of that building."
Although we have no measurements or radar data, simple observation and photographs indicate that aircraft are consistently less than 400 feet above HUMC and less than 100 feet above the high-rise apartment buildings just north of HUMC.
(continued in next post)
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