Dear Editor, I am trying to get some publicity on a major change in aviation policy in the New York City metropolian area. This is the the letter I wrote yesterday to the NYSDEC Environmental Justice section. Although I do not live in the city anymore I am still involved in N.Y. City environmental issues, especially when it comes to airport expansion. Thank you for your help. My group, Friend of Rockaway web site, is at: Our objections (also listed below) to the FAA's Airspace Redesign Plan are below and color maps and other information can be found at: We ask your help in getting the FAA to use science and fairness in their plan instead of lies, obfuscation and politics. This is an outrageous environmental buttault on Rockaway's minority community and an example of governmental environmental injustice that must be stopped. Bill Mulcahy, Vice Pres. Friends of Rockaway Re: Environmental justice violations, deliberate distortion and misrepresentation of information in the New York-New Jersey-Philadelphia Airspace Redesign Plan DEIS The NY-NJ-Philadelphia Airspace Redesign DEIS, although cleverly crafted to look scientific, is actually designed to maintain many of the unscientific, politically influenced aircraft routes. It demonstrates the deep arrogance and contempt the FAA has for NEPA process and their lack of concern for environmental and health impacts of aviation on minority communities. While my comments focus mainly on JFK Airport, which impacts I am most familiar with having lived there from 1990 to 1997, I am sure they apply to many other communities in Airspace Redesign Plan area. The plan's intention to deceive can easily be seen by the way the language that the FAA uses to hide their real intent. The one word the FAA never uses in their routing rationales is fairness. This DEIS can only be described as a official con job designed to expand aviation at the expense of those least able to defend themselves. I request that the EPA condemn this severely flawed DEIS for not using science and fairness as its basis instead of the obvious political influence of wealthy, white communities that the FAA actually listed as "agencies consulted." My reasons for requesting that the FAA's DEIS be thrown out and-redone are: 1. Continued concentration of flights over poor and minority JFK Airport communities. The DEIS indicates that there will be no changes to JFK routing. In other words, projected increases of JFK Airport operations will be inflicted on heavily populated poor and minority areas, which already have flights concentrated on them. The reason this is being done is to not to change the unscientific, politically-influenced JFK routes that protect certain wealthy, white "noise sensitive" communities in Long Island at the expense of poor and minority communities in Rockaway, New York City. 2. Use of phony "Land Use" (see map below left) map instead of population maps to determine airport routing environmental impacts on people. This is another example of the FAA avoiding showing the actual impacts of noise on people. In the case of Rockaway what you see when you look at their map is not 14 story apartments full of people but large stretches of once vacant land. The purpose is once again to use the poor and minority areas as dumping grounds and to protect the politically connected. 3. Falsely portraying Rockaway populated areas as being "vacant" and single family dwellings. The JFK Airport "Generalized Land Use" (Vol.2, 3-08) map misrepresents vast stretches of land as being "vacant" (see grey areas on FAA JFK Airport Land Use Map on the left). The Arverne section of Rockaway consists of many apartment houses and the once vacant land is all built on or in the process of being built on (see West Arverne Project Map left above). Yet the FAA falsely portrays it as empty in order to divert flights over it. The land over Lawrence, Long Island is clbuttified as heavily "multi-family dwellings." 4. Major Air Safety Reduction Not Properly buttessed. In the Redesign Plan (ES.3.2) there is a proposal (see picture on the right) to reduce the separation between pbuttenger planes over New York City from five to three miles. This is a MAJOR safety change in airplane operations, yet I did not see any safety buttessment done in the DEIS. 5. Heavy use of technical jargon and charts unreadable to anyone but engineers involved in airspace planning. This is obviously an example of the FAA hiding impacts from the public in this plan. 6. DEIS "Environmental Justice" (Vol.4 Appendix I) Consists of a computer printout of census tracts. No other information was given, such as maps or comments on minorities significantly impacted. I guess the FAA thought it better to say nothing than detailing their environmental racism. 7. Use of low resolution pictures, especially "noise maps," with little detail, in extremely large files. In the online site the "noise modeling technical report" was 58 megabytes! Only people with a very high speed Internet connection could access this. I believe this was purposely done to reduce public access. Noisy Neighbour from Hell 600Your Name Here=Harvey LOL -- six of one or half a dozen of the other, Harvey. Anything else is hypocrisy. Right, which is why you felt compelled to note that "they conform to the stereotypes... 8. Use of aircraft routing "maps" that do not show airports, or even landforms, that could be correlated to the plane routes. Some of these maps are so incomprehensible that they look more like a Jackson Pollack painting than an aircraft route. The picture on the right is typical of how the FAA shows aircraft routing. This shows the contempt and arrogance the FAA has for the public and the NEPA process. 9. "Noise Sensitive" areas mentioned, but not identified. These areas are mentioned in the DEIS Executive Summary but not identified as to where they are, or what criteria is used to determine what makes one community noise sensitive and another noise tolerant. I suspect that this non-scientific "noise sensitive" term is used by the FAA to justify racist and politically influenced aircraft routing over minority communities. They don't identify which communities are noise sensitive as this would expose their favoritism to wealthy, white and of course politically-connected, communities. 10. Air Pollution Increases Not Addressed Or Analyzed. There seems to be a total ignoring of the air pollution impacts of the Airspace Redesign Plan on communities and the ozone layer and local communities from increased numbers of planes this plan will allow to be used at NY-NY and Philadelphia airports. 11. FAA used old, inaccurate maps to indicate land use. These maps do not reflect current or immediate future residential areas. This is especially true in the Arverne section of the Rockaway peninsula where there has been dramatic home building and population growth in the last few years. Many of these areas are clbuttified by the FAA as "vacant." The FAA made no attempt to reflect actual or future land use conditions. 12. Completely ignoring the JFK Airport noise impacts on minority communities from planned increased flights. The FAA has decided not to change the flight routes at JFK Airport. This means that they apparently intend to inflict increased noise impacts on poor and minority communities that have long had their flights diverted away from Lawrence, Long Island (the Lawrence Diversion) and over them. A homoloveual's "Socks ListOn Thu, 23 Feb 2006 11:19:40 GMT, the faaaaabulous supreme deity Tlahuizcalpantecuhtli, Ruler of the heavens and... 13. Falsely identifying Lawrence, Long Island as a JFK Airport 65 DNL high noise impact noise area. The FAA has falsely identified Lawrence, Long Island as a high impact (orange color map lower left) noise area. If the year 2000 "baseline" that the FAA used for their noise map is correct, which I doubt, that year must be a aberration to actual noise impacts. I believe this is a false representation as Port Authority (see picture above left) maps have always shown departure flights headed for Lawrence as being diverted over Rockaway (the Lawrence Divergence) putting Lawrence in a much lower noise contour. Also, JFK Airport is not even indicated on the FAA map. (Vol. 3, Appendix E, Sec. 4) 14. Listing of community lobbying groups as "consulting agencies" in Airspace Redesign Plan. The Town and Village Aviation Safety-Noise Mitigation (TVASNAC) organization is headquartered in Lawrence, L.I. and is a lobbying group for Lawrence and other nearby communities (the Five Towns). I think it is outrageous that they are obviously have an influence on FAA policies while other communities do not get the same privilege. Once again this demonstrates the cronyism and selective "community input" (AKA political influence) the FAA uses to route planes instead of scientific method and environment justice. 15. Details of poor and minority impacts not adequately dealt with. While one map shows "environmental study areas" impacted by projected impacts from Newark and LaGuardia Airports, the impacts on JFK Airport communities from the projected increased was not addressed. The FAA apparently is using the excuse that there will be no route changes for JFK Airport as the reason for avoiding dealing with environmental justice issues for JFK. However, it is my opinion that the real reason is that they did not want to expose their long history of favoring certain protected communities while dumping on poor and minority communities. The impacts of the increased flights that will occur over JFK Airport's poor and minority communities due to the airspace redesign project should be buttessed. According to the DEIS the Riker's Island prison is going to get a dramatic increase in noise pollution. This kind of selective analysis is typical of this DEIS where poor and minority communities, which also will get a dramatic increase noise pollution, don't get the same attention as convicts. Sincerely, William Mulcahy
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