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Northwest Florida Group P.O. Box 4907 Seaside, Florida 32459-4907 January 25, 2005 |
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Virginia Lane Federal Aviation Administration Orlando Airports District Office 5950 Hazeltine National Drive Orlando, FL 32822 Comments Regarding the DEIS for the Panama City-Bay County International Airport The Northwest Florida Group of the Sierra Club respectfully submits the following comments. In short, we find the DEIS to be very inadequate for its purpose—to give the FAA a basis for decision making regarding the proposal to relocate the Panama City-Bay County International Airport. It lacks the studies that are needed to assess adequately the potential impacts on the environment and community of Bay County, Florida. It has given inadequate consideration of other alternatives that would be far less damaging to the environment. We do not find it to be objective; information has been left out or seems to be skewed to enhance the probability of approval of the alternative favored by the Airport Sponsor. Specific comments: 1.2.2 NEPA Documentation. By only considering impact years 2008 and 2018, the EIS has not fulfilled its obligation to evaluate the proposed project at build-out, as well as cumulative impacts. 1.7. Aviation Activity and Forecasts. Suggesting that FAA may use the sponsor’s passenger enplanement and operations forecasts rather than the TAF numbers is completely without merit. There is no basis in fact for these projected enplanement numbers. To base them on increases that MIGHT take place due to the new location, that do not also include an estimate of the decreases that might also take place due to the increased distance from the county’s population center, and the booming Gulf County market, as well as a likely drop in the General Aviation users, is not valid, and is contrary to the supposed objectivity of the DEIS. The FAA put out its own, very good report on projected national airport capacity needs last year. It looked forward for twenty years, and saw absolutely no need for increased capacity in northwest Florida. If FAA does indeed use the imagination-based numbers of the sponsor, it will be acting contrary to its own, fact-based study. Ref: FAA and Mitre Corp. 2004. “Capacity Needs in the U.S. Air System.” FAA, Washington. 3.6.4. and 3.9.10. Extend Runway with EMAS. The lack of consistency with the newer FAA RSA standards has often been given by airport proponents as the reason FAA should approve relocation of the airport. However, the DEIS states in 3.6.4 that this option would meet the FAA RSA standards. Then why does the DEIS drop consideration of it in Level 2? In 3.9.10 it states the option is being dropped because it would cause impacts 1.3 acres of seagrasses! Incredibly enough, the preparers would have us believe that impacting 1.3 acres of seagrasses is more harmful than impacting 2000 acres of wetlands, impacting and fragmenting over 4000 acres of wildlife habitat, including that of listed species; causing severe and permanent damage to entire creeks and feeder streams that carry freshwater into West Bay. Merely occupying 9.3 acres of Florida sovereign submerged land is not a strong reason for rejecting this option. It is allowable to do so if it is being used for a public purpose. The kind of relatively minor incursion into bay bottom in order to use EMAS materials is totally incomparable to the massive filling and seagrass destruction proposed in 1999 for a runway extension into the bay at PFN, which was eventually rejected by FDEP. By rejecting out of hand an inexpensive and much less environmentally harmful solution to the RSA issue at PFN, the DEIS has created an issue that could cause approval of the sponsor’s preferred alternative—a new airport—to be rejected by a judge in a courtroom of law, where they take credibility a lot more seriously than the preparers of this DEIS. 3.9.2. West Bay Site- Natural Environmental Impacts - Seagrasses There are no fill impacts, but there are many other forms of impacts to the seagrass habitat, including runoff pollution and loss of freshwater inflow. The DEIS has failed to review those in detail, but has stated elsewhere in the DEIS that there will be impacts to West Bay due to increased runoff carrying pollutants downstream. For example, the southwest portion of West Bay has lost most of its seagrass beds due to, most local scientists believe, from impacts due to the City of Panama City Beach’s treated sewage outfall that runs from a creek into that portion of West Bay. 3.10. Findings The DEIS has failed to identify a preferred alternative, per requirements of FAA Order 1050.1E), merely narrowing them to four choices in addition to the No-Action alternative. According to Order 1050.1E: “The EIS identifies the agency-preferred alternative or alternatives in the draft EIS if a preferred alternative exists” (Ch. 5, 500a). This is adverse to the public’s right to know which option they need to address in their comments. 4.1.2.3. Climate The DEIS fails to include information regarding an important climatic feature, fog. It is well-known to pilots in the area that the proposed project site experiences heavy fog, making air operations more difficult. The final EIS should investigate this issue, since it may pose a hazard to aviation. 4.2.2.1. West Bay Site The DEIS indicates that the proposed site is located “between” the Burnt Mill and Crooked Creek watersheds. In actuality, it is located “in” these watersheds. 4.2.2.2. Land Use Controls The DEIS seems to consider the West Bay Sector Plan to be a fixed and permanent land use plan. However, it may be amended at regular intervals. Also, Sector Plan property may be annexed into the city of Lynn Haven, and fall under that city’s land use rules. Therefore, it is conceivable that non-compatible development may occur in the future. 4.6. Environmental Justice The DEIS fails to address the negative economic impacts on the minority populations that use the current airport, do not have their own transportation, and cannot afford a 25 mile taxi ride. This includes not only minority airport users, but also minorities that currently work at the airport, or had hoped to work there. 4.8.3. Surface Water West Bay Site. Since the proposed airport is a site located at the headwaters of Crooked and Burnt Mill creeks which flow into West Bay, we are especially concerned about impacts of the these important creeks. The quality, quantity, and seasonal discharge of freshwater from the two creeks provide nearly all of the annual freshwater inflow to West Bay. Flow from these creeks is essential to the maintenance of the water quality and species diversity of West Bay and the creeks. Therefore, impacts of the proposed airport development on the surrounding water bodies and fisheries are of utmost concern. These impacts cannot be adequately assessed without basic information on these resources. Yet very little information on how this watershed functions is to be found in the DEIS. The DEIS even seems to shrug off this information as being inconsequential. It makes the statement, “The proposed 4,037-acre relocation site encompasses 7 percent of the combined Burnt Mill and Crooked Creek watershed acres.” This is untrue, and flagrantly so, since the consultant undoubtedly had this document available: “Response to the Department of Community Affairs Objections, Recommendations, and Comments: Panama City-Bay County International Airport Detailed Specific Area Plan, Item LPA-03-01A.” November 25, 2003. According to this report, which was issued by Bay County, “The ultimate airport build-out will occupy an average of 4 percent of the Burnt Mill Creek watershed and 14 percent of the Crooked Creek watershed.” This gives a total of 18%, not 7%. Once again, the DEIS has minimized impacts that should be accurately and thoroughly reported and reviewed. 4.8.3.2. Stream Flow Records One of the biggest failures of this DEIS is the lack of a hydrological study to discern the amount of freshwater inflow that will be lost due to the proposed airport project, and the impacts of that loss. A current study of the inflow should have been conducted, then a model used to project the water inflow loss. This 4,000 acre project at build-out will displace 18% of the combined watersheds of Burnt Mill and Crooked Creeks. Entire feeder creeks will be diverted or destroyed. Without identifying the loss, the FAA cannot evaluate the environmental impacts. This is particularly critical to a water body like West Bay, which flushes slowly (Rodriguez and Wu 1990). Its inflow is already very limited, and tidal influence is low. As a result, it is very sensitive to pollution inflow, excess nutrients and any decreases in its freshwater inflow. The final EIS should not be issued without a thorough investigation of the impacts of loss of freshwater inflow. Reference: Rodriguez and Wu. 1990. Initial analysis of circulation and flushing characteristics of the St. Andrew Bay System. Northwest Florida Water Management District, Water Resources Special Report 90-1. Fishery and hydrology information in and downstream of the proposed construction area is absolutely necessary in order for this DEIS to be a valid decision document. How would Crooked and Burnt Mill Creeks be impacted by being located in or next to a mitigation site discussed on page 4-27? The mitigation area map 5-73 is showing land that must be purchased by the state. If the state does not purchase the land, it may become developed. 4.8.3.3. Surface Water Quality Classifications. West Bay Site and the West Bay Site Mitigation Parcels. The DEIS has made an error so egregious, that it calls into question the credibility of the entire report. On page 4-28, last paragraph, it indicates that shellfish harvesting is not authorized in West Bay. This is not true. Some portions of West Bay are not authorized, such as in the southwestern corner, but most of this water body is available for harvesting on the typical conditional basis. See map at: http://www.floridaaquaculture.com/PDFmaps/08w.pdf. Given the airport operations and their water quality impacts, the Florida Department of Agriculture may indeed have to place some of the shellfishing areas adjacent to the new airport off-limits, thereby reducing the shellfish resource in these Class II waters. 4.8.3.4. Black Water Streams The DEIS does double-speak by first stating that no black water streams on the West Bay site, then saying that Burnt Mill and Crooked Creeks “could potentially be classified as black water streams.” It is not difficult to determine this. A simple boat trip of the creeks would quickly reveal the tea-colored waters that give the name to these rare, imperiled streams, and a simple pH test would reveal the characteristic acidity. Indeed, on p. 4-36 of the DEIS, the water quality section points out the acidic and “tannic nature of the water.” The DEIS should be corrected to recognize that these creeks are indeed black water streams. The DEIS, page 4-29 states that secondary and tertiary tributaries to Burnt Mill and Crooked Creeks are located within the proposed relocation site and would be impacted by the Proposed Project. The DEIS fails to state how these tributaries will be impacted and to what extent, or what can be done to mitigate these impacts. 4.8.3.5. Use Support Ratings and Impaired Surface Waters The DEIS used old information (1998), rather than more recent information (Sept. 2004) available. The Statement, “There are no water bodies on or adjacent to the West Bay Site or the West Bay Site Mitigation parcels that were listed as impaired water” is misleading. On September 27, 2004, the Florida Department of Environmental Protection issued its revised draft verified list of impaired water bodies for Choctawhatchee and St. Andrew Bay. West Bay is listed for fecal coliform and chlorophyll (an indication of excess nutrients). The priority given is “Medium”. http://www.dep.state.fl.us/water/tmdl/docs/verified/group3/revised/ChoctawDraftVerified_9_24_04.pdf The DEIS mentions an earlier draft list, but should be corrected to reflect the revised list. 4.8.3.6. Water Quality Sampling Data Temperature, salinity, conductivity, dissolved oxygen and pH measurements were taken. However, the DEIS study should have also included chlorophyll, turbidity and fecal coliform counts. Without those, this is not a good baseline study, so that future water quality degradation can be determined. The report notes that dissolved oxygen values were low in Burnt Mill and Crooked Creeks, yet makes no mention of how the proposed project will affect this already environmentally sensitive situation. According to the Florida Fish and Wildlife Conservation Commission, in early January 2005 an extensive fish kill took place in Burnt Mill Creek. Dissolved oxygen was very low, only 1 ml/l on the bottom. Over 1,000 dead fish were seen by one observer on January 8 (Jim Barkuloo, personal communication). In light of this fish kill, and the frequency of low oxygen conditions in both creeks, the FAA should require NO impacts to these creeks for the proposed project. 4.10. Biotic Communities West Bay Site The DEIS indicates it is only evaluating impacts for the initial phase of the airport development, 1,378 acres. We believe that this sectioning of the project DEIS is illegal under NEPA. According to http://www.aee.faa.gov/aee-200/1050-1E/Chapter5.htm: “500c. An EIS is required when impacts of the proposed action, including mitigation, remain significant. Cumulative impacts of the proposed action must also be considered in determining significance (see 40 CFR 1508.7, 1508.8, 1508.25, and 1508.27(b)(7) and CEQ guidance for Considering Cumulative Effects Under the National Environmental Policy Act, January 1997). A series of actions, when assessed on an individual basis, may each have a limited environmental impact. However, the same series of actions may have a significant cumulative impact when assessed with other Federal and non-Federal actions that are ongoing or are reasonably foreseeable (40 CFR 1508.7 and 1508.27(b)(7)). (1) Connected actions should be considered in the same EIS. Connected actions are closely related actions that: (a) automatically trigger other actions which may require environmental impact statements; (b) cannot or will not proceed unless other actions are taken previously or simultaneously; or (c) are interdependent parts of a larger action and depend on the larger action for their justification (40 CFR 1508.25(a)(1)). Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts (40 CFR 1508.27(b)(7)). Proposed actions or parts of proposed actions which are related to each other closely enough to be, in effect, a single course of action shall be evaluated in a single impact statement (40 CFR 1508.25(3)).” Invasive Species, West Bay Site DEIS indicates that no invasive species were documented. It is simply not believable that, given their abundance in Bay County, not a single popcorn tree (Chinese tallow) can be found on the West Bay site. The final EIS should include a field survey of invasive species. 4.12. Endangered and Threatened Species West Bay Site Detailed analysis is limited to only the initial development phase 1,378 acres, rather than 4.037 acres. As we have stated earlier, we believe this “tiering” of impact consideration is contrary to NEPA and your own rules. Please instruct your consultant to do detailed analysis on the entire project. Wetland Mitigation Parcels for West Bay Site In a show of internal inconsistency, the DEIS is considering the entire impacts associated with the 50-year development scenario, thereby negating any argument that this cannot or should not be done for all impacts. 4.12.2. Methodology 4.12.2.2. West Bay Site - Specialized Survey Methodologies The fish survey as described is completely inadequate. There are no existing fishery studies of Burnt Mill and Crooked Creeks. There are other streams in the area where inventories have been conducted. These were the Econfina, Bear, Cedar and Bayou George Creeks, which flow into North Bay. Gulf sturgeon and alligator gar were collected in those surveys, so could possibly occur in BM and CC. The sturgeon is listed as a threatened species and the alligator gar is very rare in Florida. Bluenose shiner inhabits blackwater streams such as Burnt Mill and Crooked Creeks, and could possibly be found there. Since there have been no fishery or hydrological studies on these streams, there is no way to determine impacts of the airport development on fisheries because there is no way to know the type and degree of management needed. An inventory of fishes is a basic need to address impacts of airport development on freshwater and estuarine species diversity and your EIS will be incomplete without it. The description of your contractor’s field surveys for fish and the resulting list of fish species indicate a total lack of experience and training necessary to inventory fishes in these streams. The sampling design, number of samples, techniques used to collect samples, and length of study, are all, unfortunately, woefully inadequate and scientifically flawed. More importantly, dependence upon that data to guide management strategies will not protect coastal resources and species of West Bay and its creeks. The ecological risk of using this inadequate information is very high. To take such a risk, when proper studies can and should be completed is extremely negligent. Methodologies described on pages 4-64 and 4-65 are ineffective in acquiring fishery information needed. Aquatic biologists experienced in a variety of collection techniques would be necessary to do an adequate survey. It appears from the description of the surveys that only streams directly in the area of construction were surveyed. There was no attempt to survey the downstream portions of the streams which would be directly and indirectly affected by the proposed development. Also, only Burnt Mill Creek, not Crooked Creek was mentioned in this survey description. So even this flawed study was not even performed on a creek that will be directly impacted by the proposed project. Page 4-64 states that specialized surveys were made for certain species, but little information on how those surveys for the Gulf Sturgeon, shoal bass, and bluenose shiner conducted. The DEIS should have used aquatic biologists experienced in fish collecting techniques to conduct the surveys. What are the qualifications of those identifying the fish and what species were actually collected? The list of preparers and consultants on pages 7-1, 7-2, and 7-3 does not include fishery specialists. There is no excuse for a study of this importance not to use professionals with specialized education and experience to do these surveys in a scientifically valid manner. Fishery and hydrology information in and downstream of the proposed construction area is absolutely necessary in order for this DEIS to be a valid decision document. 4.12.3.2. West Bay Site- Listed Wildlife Species Given the faulty methodology of the field surveys, little credence can be given to failures to find listed species. Some tabular data is incredulous, such as the claim that the bald eagle and brown pelican have a “low” probability of occurrence in an area where they are commonly found. In Appendix one, wildlife “observed or inferred” omit species such as the bald eagle, flatwood salamander and bluenose shiner, even though their habitat occurs in the study area. Chapter 7, List of Preparers shows not a single wildlife or fishery scientist. Not to have adequate expertise to perform a quality study, despite the many millions of dollars that FAA may expend for this proposed airport project, is a disgrace to the agency. 4.13.2. Study Area- Background The DEIS is misleading on p. 4-78, 2nd paragraph. It claims that the 37,000 acres in the WPCA will serve to conserve and protect the environmentally sensitive habitats in West Bay. It states this as if it were a certainty. However, about 7,000 of these acres are state submerged land. Of the 30,000 remaining about 15,000 acres will have to be bought by the state in order to obtain them for this purpose. Given the enhanced value of this land due to the proposed airport relocation, that purchase is highly doubtful, and should not be considered as an environmental benefit. The 9,718 acres being offered as “compensatory mitigation” for the proposed airport will not make up for the filling and other impacts to wetlands in the study area. Not one acre will be created, so all of the wetland acres filled will be lost. Preserving wetlands do not make up for filling others in, even if the remaining acres are “enhanced” in their functioning. 4.13.3.2. Methodology for Wetland Determination- West Bay Site Given their ecological importance, the DEIS should indicate how many acres of wetlands were determined to be “isolated wetlands”, or non-jurisdictional, by the Corps of Engineers. These wetlands should be considered as part of the environmental impacts. 4.19. Light Emissions 4.19.1.2. West Bay Site There is no analysis of the environmental impacts of lighting and light structures on migratory birds. 5.4.2. Transportation Patterns 5.4.2.3. West Bay Site Alternative The DEIS fails to address the transportation impacts of airport relocation to the project site. A trip of from one to five miles for most county citizens to and from the present airport will now become a trip of five to 25 miles. Increased costs for fuel, taxicab fares, costs to operate motor vehicles, increased time of travel, and also increased exposure to traffic accident risk should be analyzed and included. 5.4.4 Business Relocation 5.4.4.4. West Bay Site The DEIS totally ignores the tremendous impacts of moving the airport to West Bay upon the General Aviation industry. Many of these users will either undergo much greater expenses due to the increased distance from the city, or close their businesses entirely. 5.5. Socioeconomic Impacts 5.5.3. West Bay Site Alternative The DEIS states, “The relocated airport would serve as a catalyst for the economic development of the West Bay Area.” The FAA is not supposed to use large sums of taxpayer funds to help communities pursue pie-in-the-sky economic fantasies of “build it and they will come,” or to enable urban sprawl. New airports are supposed to be built only in order to meet airport capacity needs. And we have seen from FAA’s own study, there are no capacity needs in Bay County—not now, not for at least 20 years or longer. (Ref: FAA and Mitre Corp. 2004. “Capacity Needs in the U.S. Air System.” FAA, Washington.). What the FAA would be doing by funding this proposed airport is enable extensive environmental impacts, including large-scale wetland destruction, destruction and fragmentation of wildlife habitat, impairment of two important creeks and West Bay itself, and in the process create a fiasco similar to the Mid-America Airport, deridingly called “The Gateway to Nowhere.” From: “Empty Sky at Instant Airports,” by Judy Pasternak. The Los Angeles Times, Feb 20, 1998, p. 1 MidAmerica--the first commercial airport built in 24 years, aside from a replacement facility in Denver--and other proposed airfields have set off a debate over the shape of American aviation in the 21st century. Although the growth in air travel is undisputed, the question of how and where to increase capacity is a touchy one--involving small communities with grand ambitions, airlines with a preference for known quantities, existing airports scrambling to build additions, politics and, of course, money. ‘Building airports is in many ways the S&L scandal of the 90s,’ said Denver-based aviation consultant Michael Boyd. ‘It's not a question of, If you build it, they will come.' Not a single airline has signed up to provide any service to the nation's newest airport, a $313-million facility.This facility currently has only one commercial carrier and just a few destinations. The wealth and industrial growth that was hoped for never happened. Funding a new airport because it is wanted, but not needed, is a disservice to not only the taxpaying citizens of the U.S., but the community that will receive it. It will cause tremendous impacts on the environment and cause urban sprawl and an accelerated rate of development in a community poorly equipped to handle it. The Bay County community has already been impacted by this proposed airport. Land speculation in anticipation of getting approval for it has driven real estate prices sky-high. According to published reports, the average cost of a home in Bay County has nearly doubled in the last 3 years. The average home in Bay County now costs more than the same home in Tampa. New homebuyers have been priced out of the market. The higher cost of housing has also affected Bay County’s ability to retain its military bases, which are so important to its economy. Tyndall Air Force Base and the Naval Coastal System Station are important sources of high-paying jobs, which are hard to find in a county with a tourism base. From: “Area housing could hurt bases,” by Faith Ford. News-Herald, Panama City, December 10, 2004 A recent report released by a group now known as the Bay Area Partnership for Affordable Housing showed Bay County ranked last among Panhandle counties in affordable housing based on median income.Prices have skyrocketed especially in the beaches area, which are closer to the proposed airport. This is not good growth, that comes with time and planning; this is out-of-control, dysfunctional growth, and FAA should not enable it by approving an airport based upon the economic desires of those who will profit from it. The location of the new airport has been chosen to enhance the tourism sector, and will serve to increase what Bay County does not need—low-paying jobs. FAA would also be well-advised not to consider the West Bay Sector Plan as a control over this development. Cities are already jockeying to see how they can annex land in the Sector. Once annexed into their city limits, the land will assume whatever zoning designation the cities will choose to give it. Even if the land remains in the county’s hands, its designation can be amended upon request of the land owner. The DEIS should analyze all the socio-economic impacts of accelerated development, not just what the consultant felt were the positive impacts. 5.5. Environmental Justice The DEIS should address the impacts on low-income population of the loss of convenient job opportunities at the local airport, the increased cost of transportation to the new airport, and the increased cost of housing due to the accelerated rate of growth caused by the new airport. 5.6. Water Quality 5.8.2. West Bay Site Alternative. Surface Water Quality. Page 5.-105 describes tremendous impacts to Burnt Mill and Crooked Creeks. There would be “long-term impacts to water quality in Crooked Creek and Burnt Mill Creek from the fill of secondary and tertiary streams and wetlands.” “Impervious cover could be as great as 75%” (in just the initial phase). “The construction…would result in the permanent loss of the uses and water quality function of these systems.” Damage to downstream habitats is also noted and discussed. Such large-scale destruction of these ecosystems critical to West Bay is extremely unacceptable, especially given the lack of established need for this airport. While the DEIS mentions that air pollution enters aquatic food chains, it should review these impacts in greater detail. Air pollutants deposited in water bodies enter the aquatic food chain, affecting fishes and the humans that consume them. Often the pollutants may convert to other, more harmful molecules. For example, sulphuric acid originates from sulphur dioxide. Since aircraft using the new airport will fly directly over West Bay on landing and takeoff, the DEIS should address those impacts to a greater extent. Groundwater Due to the 585 acres of hard surface, the DEIS states that most of the recharge water will not infiltrate the soil post-construction. There should be a mitigation plan to direct this water back into the groundwater. Instead, the DEIS makes the ridiculous suggestion that removing vegetation will slow down transpiration enough to make up for the water infiltration loss. Incredibly, the DEIS argues for something that is seen by even high school ecology classes as destructive—removing natural vegetation buffer zones. 5.11.2.3. Applicability- West Bay Site The DEIS claims that Pine Log State Forest will not be impacted. It will. In order to keep the forest habitat healthy, the park staff do prescribed controlled burning: “A widely used management tool on Pine Log State Forest is prescribed burning. The use of controlled fire in managing timber, wildlife and ecological resources is necessary for the Division of Forestry to fulfill its goal of protecting and managing Florida's forest resources.” (http://www.fl-dof.com/state_forests/Pine_Log.htm). Smoke from these burns may affect airport operations. The reverse is also true. In order not to interfere with aviation operations, the forest staff will have to cancel or delay needed burns, thereby impacting the health of the forest community, or set the stage for wildfires. 5.12.2.3. State-Listed Species For the bluenose shiner, the DEIS claims its habitat—environmentally sensitive streams—is not impacted by development. This is untrue. Steams such as these are very much affected by development. 5.12.3. Mitigation The “mitigation” for impacts to wetlands may sound good, but does not replace or make up for what has been lost. Not one acre will be required to be created, so there will be a net loss of wetland acres. Preserving wetlands does not make up for filling others in, even if the remaining acres are “enhanced” in their functioning. 5.19.1.3. Light Emissions West Bay Site: There is no analysis of the environmental impacts of lighting and light structures on migratory birds. 5.26.3.2.1. Wetlands- West Bay Site Alternatives. Repeats the same error made earlier, in 4.8.3. The site will occupy 18% of the combined drainage area, not 7%. Sector Plan Conservation Strategies. The DEIS once again relies strongly on a preservation plan based upon hope, not fact. At least 15,000 acres of the land in the plan is dependent upon state purchase, which may not take place. This land should not be considered as helping to make up for some of the damage created by the airport project. 6. Coordination and Public Involvement The workshops that were held used a format that precluded open questions that everyone could hear at the same time. Using the one-on-one approach, those in the audience with expertise could not elicit from the agency staff the information needed by the public. The DEIS fails to mention a very important form of public participation. A referendum vote was held during the Presidential Preference election on March 9, 2004. The citizens of Bay County were asked, “Do you favor future relocation of the Panama City-Bay County International Airport at no cost to the Bay County taxpayer?" The citizens said NO, by a margin of 54% to 46%. Before spending a great deal of public funds, and impact the environment and community of Bay County, FAA should take into consideration whether this new airport is even wanted. Even though the question was skewed in order to elicit a positive response, the majority said they do not want it, even if it is free. Some folks do want it very much, and some of them may have political power; however, they are not the majority of the citizens of Bay County. Other The DEIS contains no analysis of the potential for bird-aircraft collision impacts in the study area. Given that the site for the proposed airport is adjacent to water bodies, and many wetland acres, bird collision is a very real, predictable problem. The report mentions a management plan; however, the report does not consider whether property with so much water on and around it is an appropriate site for an airport. Conclusions The FAA should have high standards for an EIS, and it is clear to us that this DEIS does not meet these standards. We request that the FAA instruct its contractor to redo large portions of this DEIS, to include needed information, correct errors, and perform new field surveys using properly credentialed scientists. We also request that the FAA choose a less environmentally damaging alternative than building a new, unneeded airport in a highly fragile environment, and consider some alternatives that were wrongfully discarded. It is unfortunate that the FAA will not, or cannot suggest to the Airport Sponsor that it work on a long-range solution to air transportation needs in Northwest Florida; that it work with other counties to create a future Regional Airport in a more suitable location, on higher, dryer ground; away from sensitive water bodies; more conveniently located to population centers; and to merge some of the competing airfields. This would solve the central problem of air service in NW Florida—too many airports chasing too few airlines with too few passengers. There is plenty of time to do a better plan—over 20 years, according to FAA’s own national air capacity study. Thank you for your consideration of these comments. Sincerely, Sharon Maxwell Sharon Maxwell Chairperson |
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P.O. Box 19318 · Panama City Beach, Florida 32417
(850) 234.5071
cfbay@go.com