Mr. McMath has personal responsibility for environmental reviews for the SW Region of FAA and for the Georgetown airport.
Mr. McMath sent Wendy Dew, a Georgetown resident, an email designed to dismiss her and her challenges. Following is her response which shows the lies, half-truths and obfuscation being used. Fortunately, Ms Dew is not a dummy and through her research has exposed the FAA for its non-compliance with federal rules and for not protecting citizens living around airports in Texas.
From:
Wendy Dew
Subject:
Response to Dean McMath e-mail
Date:
November 7, 2017 at
10:34:19 AM CST
Cc:
Kelvin.Solco@faa.gov, Elaine.Chao@dot.gov, Winsome.Lenfert@faa.gov, Ben.Guttery@faa.gov, "Edward Boling- Assoc. Dir NEPA
CEQ" <Edward_A_Boling@ceq.eop.gov>, Rhonda.solomon@faa.gov, debra.richmond@txdot.gov
Dear Mr. McMath,
I apologize for the delay in responding to you, I have
had computer issues.
I have responded to some of your comments below.
Please read your comment and then my reply.
Your Statement:
Georgetown
Municipal Airport (GTU) is a public general aviation airport owned and operated
by the City of Georgetown, Texas. In the State of Texas, Federal funds for
general aviation airports like GTU are administered by the Texas Department of
Transportation's Aviation Division (AVN) under the State Block Grant Program
(SBGP). AVN is responsible for ensuring projects funded under the SBGP
are consistent with federal requirements, including the environmental review of
those projects.
As part of the
Federal Aviation Administration's (FAA) oversight role of the SBGP, we have
discussed AVN's processes for environmentally reviewing projects at general
aviation airports. We have specifically discussed projects at GTU and have not
identified any violations of the National Environmental Policy Act (NEPA) or
any other Federal resource laws. As per their contractual agreement with the
FAA, AVN will continue to be responsible for environmentally reviewing any
projects that airport owners may propose at such time as they are ripe for such
review.
————
Mr. Mc Math,
If what you say
above is true, why has there NEVER been an Environmental Impact Statement (EIS)
for any expansion of any airport in this state. I have done extensive research
and can find “nowhere” where an EIS has been executed for any airport for any
reason regardless of extent of expansion.
Without any EIS's for any Texas airport
grants how can FAA be fully aware of NEPA related issues and and their
resolution for any Texas airport grant?
In addition, in
your capacity as Regional Environmental Manager for the FAA SW Region you would
be totally familiar with the three past state and federal funded GTU master and
update plans and their respective three multiple million dollars, multi-project
“improvement” PROGRAMS over the past 37 years for development and expansion of
based aircraft fleets and aviation operations of the GTU as the principal
Reliever airport for Central Texas region. You would be aware of the
continuous public opposition to these planned programs in the heart of our city
and atop the Edwards Recharge Zone. You would also be aware that, except
for construction of the GTU air traffic control tower in the presence of strong
public opposition and completed with no environmental clearance, every GTU
design, construction and land acquisition grant was illicitly segmented from a
parent PROGRAM by FAA and AVN in violation of presidential Executive Orders,
DOT regulations, and FAA NEPA compliance regulations. Each of these
illicit segmented units was pretended to be a stand alone grant action with no
affiliation or connection with its parent planned program, determined to be
categorically excluded from the NEPA and any EIS preparation process by totally
ignoring applicable extraordinary circumstances by unelected, unaccountable
administration officials, totally removed and remote from the GTU and its
adversely impacted citizens, in secret, with no awareness of the general public
by the press, the city or AVN, and no formal, official review and approval by
the elected body of the Sponsor. The proposed grant actions may have been
“ripe” for review, but the NEPA environmental review practices used by ANV were
and remain rotten to the core. With this type unseemly record of NEPA
evasion including false testimony by local and state officials to the Texas Transportation
Commission to secure final grant approvals, it seems clear that such
environmental clearance practices deemed acceptable, supported and approved by
FAA could allow construction of a military munitions plant, a plutonium reactor
and a hazardous waste collection and distribution center all on the GTU
location site.
Why does the Department of Transportation and FAA condone
such NEPA avoidance practices? Who’s job is this to clean up this mess
and why are they and you NOT doing their job??
————-
Your Comment:
The airport is
not undergoing an expansion at this time. Ongoing projects, like
rehabilitating the runway pavement, are intended to meet current operational
and maintenance demands. We are aware that the City of Georgetown has
expressed interest to AVN for other future actions, such as strengthening the
runway, but AVN reports they have not been presented with adequate
justification by the city to consider such actions at this time. At such
time as adequate justification has been presented, AVN will consider the city's
proposal. This consideration will include the preparation of appropriate
environmental analyses and documentation to assist AVN in making an
environmentally informed decision regarding the proposal.
——————-
Mr. McMath,
You are knowingly
wrong stating no airport expansion is underway at this time. You are
aware that grant action, 1514GRGTN, is under construction despite public
opposition and demands for EIS preparation process for the action as it is an
illicitly segmented unit from its parent 2005 GTU master planned update PROGRAM
for expanding based aircraft from 256 to 405 and operations from 127,700 to
202,025.
There is no
justification for strengthening the runway.
Without any engineering needs,
justification and NEPA level environmental review for increasing the strength
of RW 18-36 from 30,000 to 60,000 lb single wheel load design as requested by
the Georgetown city manager letter dated June 30, 2015, both the city and AVN
have included the project on their current CIP schedules for FY 2018 and
FY2019. This is directly contrary to all grant eligible requirements.
Surface rehabilitation of RW 18-36 to correct “cracking” and retain its current
30,000 lb single wheel load design can be accomplished for about 10% of the
current strengthening budget. Although currently included in both the city and
AVN's Annual CIP budgets, this project is totally excluded from consideration
of impacts on aviation operations in the new GTU 20 year master plan update,
16MPGRGTN.
On the
Georgetown City website there is an FAA inspection, indicating that there was
some cracking, that FAA inspection states that everything at the airport passed
inspection and the runway condition was “good.” That inspection at the airport
was done three months before the letter was sent to AVN asking for funds to
redo the runways because of cracking. And on the FAA website it states that
cracking is common on runways and doesn’t compromise the integrity of the
runways. So why do both the city and AVN have this project currently
budgeted for receipt of state and/or federal grants for construction of
unjustified doubling of pavement strength in lieu of rehab of surface treatment
for 10% of the cost?
———————
Your Comment:
GTU prepared a voluntary noise study in 2004-2005. They
have not chosen to update their noise study to date and are under no regulatory
obligation to do so, largely because aircraft operation numbers have gone down
at the airport since the noise study was prepared.
Mr McMath,
This new GTU master plan, projects new based aircraft and take off and
landings operations substantially in excess of those studied in the 2001 Part
150 Noise Compatibility Study. A new noise study is essential. AND – such
a study must be made using a system that tracks actual movements of aircraft on
the ground and in the air - not a stationary sound emitter at the intersection
of the two runways. Those planes buzzing and shaking the walls and foundations
of our homes, schools and churches are not located at the intersection of the
two runways.
The
GTU noise study was prepared by an appointed board of random citizens, I have
read all their minutes from all their meetings and it was very obvious that
they had no idea what they were doing. All they wanted is to push this thing
through so they could go home.
The prior noise study was funded in 2001 and completed by Coffman
Associates in November 2004 all under the direct oversight of the old AAB
composed of unelected, appointed citizens with no federal structured public
hearings for review and comments.
WHY do I hear more planes every day and see big enough
planes to blow leaves off my roof if what you say is true.
Also if aircraft traffic is down???? Why in the world
would AVN and the FAA put 10 million plus dollars into a declining airport??
———————
Your Comment:
GTU is finishing a Master Plan update which offered
opportunities for public input. I cannot say why you were unaware of
these opportunities.
Mr. McMath,
I was well aware
of these public meeting where they had numerous posters of what they are going
to do whether we like it or not. If we had a comment they responded with
what they want us to think and from there NOTHING. There was in no
opportunities for actual dialog with any member of the Planning Advisory
Committee including the two designated for representing the “public” or from
the city or Coffman and Associates where issues such as social, economical, and
human environmental impacts, mitigation for elimination or reduction of adverse
impacts and full examination of ALL practicable alternatives to the PROGRAM of
“improvements” being developed by this new plan.
We are allowed
to present severely time limited statements to the GTAB, or the City Council
but at no time are we allowed to actually have productive dialogue with city
officials in any public venue.
There have been
no city PIO or press articles describing the purpose of the new 20 year plan,
the environmental background of the airport, its setting in the city's master
plan nor impacts on the community both good and adverse by implementation of
the plan's proposed capital improvements program. The city has ignored
all requests for open public workshop meetings on this new 20 year plan.
The appointed members of the Planning Advisory Committee designated as “public”
representatives have refused to receive public comment concerns and coordinate
with or represent the general public in any meetings with the plan's
consultants. The general public has been gagged from effective input and
participation regarding the new plan.
————————-
Your Comments:
No projects at GTU to date have reached an environmental
threshold individually or cumulatively to require an Environmental Impact
Statement. The majority of projects at GTU qualified for categorical
exclusions under NEPA. Only one recent project at GTU for a new fueling
facility required an environmental assessment (EA) which was prepared in
2015.
Mr. McMath,
Are you not fully aware that FAA assured us that the Fuel Farm EA would
provide a full vetting, consideration and examination of our NEPA
concerns? Are you not aware that AVN intentionally and without our prior
knowledge and input limited the scope of Fuel Farm EA in order to determine
that our concerns and objections that involved at least eight of the 12
identified extraordinary circumstances in FAA Order 1050.1F were determined as
“irrelevant” and outside the scope of the EA? Are you not aware that AVN has
never justified its expansion of the Fuel Farm by 13,000 gallons or 60% for operations
fueling to the year 2056 or so despite the GRW-Willis GTU 2005 master plan
update clearly stating expansion was not necessary, and never considered
relocation of the GTU as a practicable alternative to adverse impacts on our
community's health, safety and human environment?
You say “The airport is not undergoing an
expansion at this time”. You sir are very uninformed! You obviously
have not read the current draft of the new 20 year master plan contracted by
AVN with Coffman Associates. Apparently, you did not read the past three
plans either of 1980, 1998 and 2005. They all planned for operations expansion
and this one does too.
In addition, apparently you are not aware that grant
1514GRGTN originally included the extraction and relocation of the Fuel Farm
without any prior planned and justified expansion consisted of 9 projects
illicitly segmented from the PROGRAM of “improvements” determined by the GTU
2005 master plan update. That 9 project action was illicitly
categorically excluded by AVN from the NEPA by ignoring known citizen
objections and concerns that included at least 8 out of the 12 Extraordinary
Circumstances identified in FAA Order 1050.1E. During the design phase of
1514GRGTN AVN unilaterally and without justification increased the number of
the grant's projects to 25 including the Fuel Farm which was increased in
capacity by 60 % without justification and increased the grant cost by about $3
Million with no official review and approval by the city Sponsor and the
general public. During the review and comment period of the Fuel Farm EA
the grant was provided a second illicit categorical exclusion again by
ignoring applicable Extraordinary Circumstances. It went from 9 projects
that were Categorically Excluded to 25 projects that were again Categorically
Excluded. How you and the highest levels of FAA can condone and approve
our human environment not being adversely impacted by the 25 project 1514GRGTN
and the balance of the program from which it was illicitly segmented and the two
prior planned GTU reliever airport development and expansion PROGRAMS is beyond
me.
Your detailed response to me would be sincerely
appreciated.
Kind Regards
Wendy Dew
Ms Dew is to be commended for her understanding of the issues, the relevant FAA and NEPA rules and for her willingness to "call out" government officials that are not doing their job. Her commitment to making Georgetown a better place to live deserves the highest recognition.
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