EAST HAVEN – The environmental nonprofit Save the Sound, and the Town of East Haven, are pushing back against a federal environmental study that found a proposed Tweed New Haven Airport expansion would have little impact on the area, calling the conclusions “fundamentally flawed.”
On Monday, both groups submitted extensive comments on the Federal Aviation Administration’s draft environmental assessment of the expansion, which would include an extension of the runway, a new terminal, additional surface parking and a parking garage in East Haven.
Save the Sound’s response was 13 pages long and highlighted six reasons why the FAA should require an environmental impact statement – a more detailed study of the expansion’s impact. East Haven hired airport counsel Pullman & Comley, LLC and Daniel S. Reimer LLC to assist with its near 100-page response, which included independent ecological, environmental, stormwater and traffic reports by three consulting firms.
Of the many deficiencies asserted in the responses, two problems were made especially clear – both the town and nonprofit believe the environmental assessment’s finding of no significant impact was based on a “fundamentally flawed” projection, and said the study piecemealed an environmentally significant project, which is inconsistent with federal law.
The assessment, released in March, projected the same number of passengers boarding planes at Tweed by 2031 – 1,222,551 – both with and without the expansion. By extending the runway an additional 639 feet, the study explained, Tweed could accommodate larger and newer Boeing 737-800 airplanes, increasing passenger capacity and decreasing the need for additional flights.
Roger Reynolds, senior legal counsel for Save the Sound, told CT Examiner on Thursday that the conclusion is “frankly incredible.”
“The assertion that flights will actually decrease because enplanements will basically remain constant is frankly incredible, and inconsistent with every statement the airport and New Haven and others have made about this,” Reynolds said.
In Save the Sound’s written response, Reynolds provided specific instances in which Avelo CEO Andrew Levy said a lengthened runway “certainly opens up to more aircraft and economic capability,” and then-Interim Tweed Executive Director Matt Hoey discussed future increases in airport activity given interest from Allegiant Air.
Reynolds said the idea of equivalent passenger counts contradicts the entire need for expansion.
“If this was just going to maintain the status quo, there wouldn’t be so much urgency and so much support around this,” Reynolds said.
In its written comments, the town said the passenger projections are “implausible,” especially considering that the financial success of Avports, an airport management company under a 43-year lease with Tweed, is dependent on running as many flights and passengers through the airport as possible.
“These assertions in the EA [environmental assessment] cannot both be true: Either the existing facilities are inadequate to handle projected passenger traffic increases – and therefore will constrain the amount of future traffic (and, critically, environmental impacts) – or the existing facilities can handle the projected passenger traffic increases, and the new facilities are not really needed,” the town wrote.
The town and Save the Sound maintained that because flight activity projections are “flawed,” the study understates impacts on issues like air quality, traffic and wildlife.
Reynolds said the impacts on tidal wetlands were also understated, as the environmental assessment did not evaluate the “inevitable” extension of a taxiway – a path servicing the runway.
The 2021 Tweed Master Plan Update outlined a timeline for capital improvement projects over the next 20 years, grouping them into four phases. Later phases, Reynolds said, include an extension of Taxiway B, which runs parallel to the expanded runway and neighbors “absolutely critical” tidal wetlands.
Reynolds said the failure to study the future taxiway extension’s impacts on tidal wetlands – which improve flood control, water quality and support habitats – is inconsistent with the National Environmental Policy Act.
“Under the National Environmental Policy Act, that’s called segmentation,” Reynolds said. “You can’t divide one project into four smaller projects and say that, ‘Well, each one doesn’t have a significant impact, so there’s no significant impact.’”
Reynolds explained that NEPA requires environmental assessments to consider all actions connected to the expansion which, he said, includes the taxiway extension.
“I think it’s very directly and transparently for the purpose of avoiding doing a full environmental impact statement,” Reynolds said.
The town’s response also said the assessment fails to study the impacts of the complete project.
East Haven’s comments ranged beyond issues with passenger projections and segmentation, including discrepancies with the study’s traffic, flooding, stormwater and inland wetlands analyses.
Town attorney Michael Luzzi told CT Examiner that a tremendous amount of time and effort went into the “exhaustive” review of the study.
“[T]he Town gathered significant resources including hiring specialized legal counsel and a team of experts in the areas of ecological and environmental impacts, stormwater and hydrogeology, and traffic,” Luzzi wrote.
At a recent meeting of the South Central Regional Council of Governments, Mayor Joseph Carfora said he had spent $250,000 in taxpayer money to hire experts to review the documents.
Luzzi said the town’s response details why a more accurate study is necessary to “truthfully evaluate this once in a generation project.”
According to East Haven’s traffic impact study by VN Engineers, Inc., the environmental assessment failed to analyze peak evening hours around the airport, left out seasonal traffic as it was conducted in December 2021 and did not include several nearby intersections.
If the FAA allows the airport expansion, traffic to and from the new terminal would also move from residential New Haven neighborhoods to more impoverished East Haven neighborhoods. These areas are designated environmental justice census block groups, which have additional regulatory protections when it comes to federally funded projects like Tweed.
“Shifting the burden of environmental impacts from non-Environmental Justice neighborhoods to Environmental Justice neighborhoods is contrary to environmental justice principles,” the town’s comments said. “In an era in which the Biden Administration has recently announced a new commitment to environmental justice principles, it would not be appropriate for the FAA to participate in shifting such burdens to an Environmental Justice neighborhood.”
The town’s response also included reports by consulting firms Davison Engineering and Trinkaus Engineering, LLC, which explored the challenges to stormwater maintenance, flood mitigation and inland wetlands, given a proposed increase of almost 22 acres in impervious surface and the airport’s coastal location.
In addition to the 1,128 existing parking spaces to be used for a shuttle service, Tweed proposed 4,000 parking spaces adjacent to the new terminal. The increased impervious surface, the town said, could contribute to stormwater pollution.
“The primary source of metals and hydrocarbons in stormwater runoff is motor vehicles,” the town wrote. “[T]here is a planned significant increase of motor vehicles using the site that will also generate higher pollutant loads impacting coastal and tidal wetlands.”
To address potential flooding at the flood-prone airport, the FAA study said Tweed officials planned to utilize about 61,300 cubic yards of fill to displace the water. But the town’s study determined the fill would only raise flood elevation by 1.2 feet over 31 acres – the approximate expansion area.
“Frankly, it does not appear that the stated volume of 61,300 cubic yards will be adequate for this project,” the town’s study concluded.
Both the town and Reynolds said they are not opposed to the expansion, but rather want to explore all potential environmental impacts to the fullest extent.
Following the release of the environmental assessment, the FAA opened a 45-day comment period which it eventually extended to 60 days. Once the assessment and comments are reviewed by the agency, it can make one of three determinations: Approve the expansion by issuing a finding of no significant impact, approve the expansion but require additional analysis or require an environmental impact statement.
Reynolds told CT Examiner that the FAA often takes controversy surrounding a proposed action into account when issuing their determination, and that the Tweed expansion was “highly controversial,” citing the many legislators, organizations and nearby residents who have called for an environmental impact statement.
“We’re almost unanimously in favor of a more detailed environmental impact statement,” Reynolds said. “So, this level of controversy around this is about as big as it gets.”