Envmtl. Impact Statement

Ask the FAA for an Environmental Impact Statement of the Tweed Expansion.

State senator Christine Cohen

Senator Cohen also chairs the Connecticut General Assembly's Environment Committee

State Senator Christine Cohen, who represents parts of Branford, North Branford, Guilford, Killingworth and Durham. Her jurisdiction will include part of East Haven which runs alongside Tweed Airport after new districting come into effect following the November 8 election.

Read the full statement online here.

Her main points:

>> "I fear that an Environmental Assessment (EA) for Tweed Airport does not go far enough to study the full extent of the impact on our communities. An Environmental Impact Statement (EIS) is a more detailed and rigorous examination compared to that of an EA and given the scope and impression of this project, is the only way to proceed. We must delve deeper and perform due diligence to truly understand both the short- and long-term implications of this planned expansion,"

>> "Additionally, the increase in activity and change in flight paths has put neighborhoods directly in the line of flights at a much higher frequency"

>> "[In September], the U.S. Secretary of Energy announced the release of the Sustainable Aviation Fuel Grand Challenge Roadmap which called for a plan to develop new technologies to produce sustainable aviation fuels (SAFs) across the U.S. airline industry."

>> " As you may be aware, Connecticut has not been meeting its GHG emission reduction goals, and we have failed to comply with national standards for ozone, in fact we were just recently downgraded to severe nonattainment"

The full statement is online here.

Senator Cohen notes that Connecticut is already in "Severe Nonattainment" of it's committment to mee

East Haven Mayor

Information missing, inconsistencies in the proposal submitted by the Tweed Authority to the FAA

On October 7, 2022, East Haven Mayor Joseph Carfora sent a formal letter to the Federal Aviation Authority requesting that a full Environmental Impact Statement (EIS) be conducted before the expansion is approved. The 16-page, detailed request can be viewed in full online here.

Although called an "Environmental Impact Statement," an EIS is not exclusively about plants and animals, green-friendliness, or climate change. The analysis includes understanding how the proposed expansion would impact the community in and around Tweed Airport, and determining the true cost of such an expansion -- rather than the magical, handwaving, "good for business" explanation we've mostly been given.

Mayor Carfora notes that the documentation provided to the FAA, himself, and the rest of the public, are incomplete. He accompanies the letter with two prior communications sent to Tweed Airport Authority Executive Director (and candidate for comptroller) Sean Scanlon. One letter requested additional information about the expansion plans (view here), and another, filed under the Freedom of Information Act (view here), contained similar requests. A few examples of where the information formally offered to the public is misleading or possibly untrue:

>> The details provided to the FAA do not mention a reconfiguration of the runway, which magically appears as having happened in later phases of the expansion, but whose construction is not listed as one of the things for the FAA to review. The runway reconfiguration will change the flight pattern of the airplanes so they are closer to, and create more pollution on, residential communities.

>> There are 31 discrete line items of construction / changes to be made to Tweed Airport over four phases. At least 16 of them are not described and are omitted from the Public Notice -- meaning, our community doesn't have full information about what the Tweed Expansion will entail, and cannot effectively contribute to a decision about it.

The agreement summarizes (page 10): In this regard, we note there appears to be significant discrepancy between assumptions made in the Master Plan and agreements between the Authority and private airport management company, AvPorts, relating to projected level of passenger enplanements, which will affect estimates of both ground and air traffic. In short, the agreements appear based on far more aggressive assumptions about future activity levels than the FAA-approved forecast in the Master Plan. FAA has acknowledged the need for accurate forecasts as a basis for sound environmental analysis, and the agency should ensure that its environmental processing of the Project does not rely on faulty projections.

Mayor Carfora also notes the significant health and environmental impact that the proposed Tweed Expansion will have on the residents of East Haven and elsewhere. He emphasizes that Tweed Airport sits on both East Haven and New Haven property, but New Haven has been able to push the agreement through against East Haven's wishes. In an August, 2022 vote by the Tweed Authority to approve the proposed expansion plans, the representatives appointed by New Haven all voted in favor. The representatives from East Haven all voted against. New Haven had more votes than East Haven. The plan advanced.

Mayor Carfora notes several irregularities in the proposal to the FAA for Expansion Approval

Branford Conservation & Environment Commission

On June 8, 2022, The Branford Conservation and Environment Commission sent a letter to the Federal Aviation Authority (FAA) requesting that a full Environmental Impact Statement (EIS) be conducted before the Tweed Expansion is approved.

(A note on the confusing use of the term "Environment": an EIS uses the term "environment" to describe the combination of external physical conditions that affect and influence the growth, development, behavior, and survival of humans -- meaning, our businesses, our communities, our families, our children, etc -- as well as other living beings. But the Branford Conservation and Environment Commission's purpose is to protect the natural world in Branford and the surrounding areas, ie non-human world. As such, their letter details the negative impact of the Tweed Expansion on the non-human world.)

It reads:

Dear Deputy Administrator D’Alessandro,

We are writing to express our concerns about the planned expansion of the Tweed-New Haven Airport (“Tweed”) and to request that the Federal Aviation Administration (“FAA”) prepare an Environmental Impact Statement (“EIS”) as required by the National Environmental Policy Act (“NEPA”) for projects that may result in significant environmental repercussions. The Branford Conservation and Environment Commission (the “Commission”) is pledged to protect the environmental resources in our town and in adjacent areas that would affect our local environment. We believe that the proposed Tweed expansion will result in serious threats to those resources as outlined below.

An EIS is Required Adequately Measure Tweed’s Environmental Impact

An EIS is required because the lesser review offered by an Environmental Assessment (“EA”) fails to address the complex issues presented by the proposed project. First, this is a controversial and historic project. Tweed proposes to extend its runway and develop a new terminal area.[1] Expanding the airport has a fifty-year record of litigation and community opposition. A state law preventing the expansion of the runway at Tweed was overturned by a federal court in 2019. But, the decision of a federal court on the legitimacy of state law does not waive the FAA’s obligations under NEPA to rigorously assess the project’s threat to the local environment. Under Section 102(2)(C) of NEPA, major federal actions that significantly affect the “quality of the human environment require the rigor represented by an EIS. Tweed’s proposed expansion is a major action within the meaning of NEPA under 40 C.F.R § 1508.1(q)(3)(iv).

We believe that the Tweed expansion will have a major deleterious impact on the following:

1. Inland wetlands from both construction and hydrologic changes due to wetlands reduction and increased impermeable surface. Tweed has identified 22.74 acres of inland wetlands that would be adversely affected by the expansion. [2]

2. Tidal wetlands from direct development and hydrologic changes. The EIS should include an assessment of the project’s impact on areas adjacent to the study areas including the taxiway, which would be required for any runway expansion, as well as the impacts to nearby tidal wetlands. The assessment provided by Tweed does not do this.

3. Stormwater. Tweed is a flood management zone that protects the surrounding communities by acting as a catch basin for stormwater. Fewer wetlands and greater impermeable surface will challenge this scenario and put the surrounding communities at risk of flooding.

4. Local and migratory wildlife. The loss of habitat for migratory birds and the increase in bird strikes will greatly affect migratory birds. The airport borders on the most significant reporting site northeast of Cape May and is deemed important to both scientists and vast numbers of amateur birders.

5. Water quality. Runoff from stormwater and pollutants from Tweed threaten the water quality of both surface water and coastal resources. The history of Tweed reveals a record of noncompliance with water quality permits. Nothing in that history suggests that measures will be taken to address the increase in pollutants from de-icing, greater traffic volumes and intensive land use changes.

6. Greenhouse gas emissions. An increase in the air traffic at Tweed and the resulting additional ground traffic will increase CO2 emissions. The Commission supports the reduction of CO2 emissions as a crucial step in the effort to reduce global warming.

For these reasons, the Branford Conservation and Environment Commission requests that the FAA follow the rules established by NEPA and do the requisite Environmental Impact Statement on Tweed’s expansion proposal. The expansion of the airport without rigorous analysis of the project’s effects puts the local ecosystem at risk, an outcome that should not be tolerated by the FAA.

The Branford Conservation and Environment Commission

By:

Heather W. Sweeney, Chair & Karyl Lee Hall, Former Chair

[1] See https://www.tweedmasterplan.com.

[2]Even if this number were correct, (there is reason to believe that it is too low), it illustrates the need for an EIS: In 2002, when a prior expansion of Tweed was approved, the FAA did an environmental impact statement when only 9.89 acres of wetlands would be affected. The increased scale of the present proposed expansion should justify an EIS on those grounds alone.

Tweed airport is situated only 12 inches above water level in an environmentally protected area

civic association of short beach

Short Beach is a community in Branford, CT. It embodies the lifestyle that recently earned Branford a glowing review in the New York Times as a place to live. The pollution from a Tweed Expansion will make it less desirable to entrepreneurs & other business people, the types of people Greater New Haven says it wants to attract.

The letter, replicated in full here, was sent on October 21, 2022.

Dear Director Lattrell:

On behalf of the residents of Short Beach, Connecticut, we, the executive board of the Civic Association of Short Beach, write to share our community's serious environmental concerns raised by the planned transformation of Tweed-New Haven Airport (“Tweed”) into Southern Connecticut's Airport. Our main concern is to recommend that the FAA prepare an Environmental Impact Statement (EIS) as required by the National Environmental Policy Act (NEPA).

The Short Beach Civic Association in Branford, Connecticut, was established by the Connecticut legislature as a special taxing district in 1895 and was purposed "with protecting the property, health and morals..." of Short Beach residents. It is governed by an unpaid Executive Board, which residents elect. The Board is also charged with the day-to-day operation of administering our zoning regulations, and overseeing our parks, beaches and sidewalks.

Short Beach, just two miles from Tweed, is a shoreline community of approximately 2500 residents, covering about 32 acres wedged between the Long Island Sound and the Farm River. Our community lies directly under the pathway of flights to and from Tweed occurring at all times of the day and night. Our area abounds with estuaries and wetlands rich with wildlife, including Osprey, Blue Herons and Bald Eagles. Home to a diverse yet tight human community as well, Short Beach includes many multi-generational families still living in the same houses for over 100 years. In 2017, our unique fabric was listed as the Short Beach Historic District on the National Register of Historic Places administered by the National Park Service. Residents of all ages are active year-round whether fishing, boating, swimming, or walking, hiking, and biking. Route 142, called Shore Drive locally, bisects our community and sees a high volume of foot traffic accessing beaches, US Post Office, or Pizza Parlor and charming small Restaurant with outdoor seating. Rt. 142 is also a direct east–west route to Tweed; the proposed site for the new 6-gate terminal and 1500 parking spaces is 1.5 miles due west of us.

Because of our proximity to Tweed, and because of our desire to retain the quality of life that we enjoy and to protect shoreline wildlife, we urge the FAA to undertake an Environmental Impact Statement that will thoroughly review the environmental and public health impacts of the expansion of the Tweed New Haven Airport now underway. We believe that the public must be involved in establishing the scope of the EIS study; and that we, the local populace, along with regional, state and federal representatives must all be engaged in the full EIS review process.

Respectfully submitted:

CIVIC ASSOCIATION OF SHORT BEACH

Douglas Hanlon, President, Christine Collins, Vice President, Margaret Carpenter, Treasurer, Frances Clark, Clerk

The Case for an...