Sunday, April 15, 2012

Quack, quack

A recurring theme in the Public Comments submitted to the USACE regarding the permit application for the proposed Central Texas Airport is safety. Citizens are rightfully concerned that the Colorado River and a 26 acre ‘duck pond’ to be located 900′ east of the runway would attract large waterfowl that could possibly bring down one of those 737s or other aircraft that are slated use the airport.

Of course it’s dangerous. But thanks to the inclusion of an exemption to the 14 CFR Part 139 rules in the 381 Agreement (at County Engineer, Ronnie Moore’s suggestion) the CTA will not be required to follow safety guidelines outlined in the FAA Advisory Circular No. 150/5200-33 (Hazardous Wildlife Attractants On Or Near Airports). Mr. Moore confirmed that the County could have made adherence to the Advisory Circular mandatory but they either didn’t think of it or chose not to do so in order to secure the deal with the developer.

In the Hazardous Wildlife Attractants section of the revised Environmental information Document (EID) the Applicant, at the Corps request, finally owns up to the twisted logic that allows them to skirt FAA safety guidelines :

1. The proposed action is a privately funded GA airport.

2. The CTA will not accept any Federal grant-in-aid assistance.

3. Hence, CTA is not required to use the guidelines outlined in the FAA Advisory Circular No. 150/5200-33.

Then comes a clever attempt to justify the location and function of the ‘duck pond’ in order to characterize it as a non-issue:

4. Detention ponds hold water for short periods, while retention ponds hold water indefinitely.

5. Retention ponds are more attractive to hazardous wildlife than detention ponds because they provide a more reliable water source.

6. Because it’s a detention pond, it’s not going to be a problem.

What they fail to mention is that the planned detention pond is going to be maintained at a PERMANENT elevation. So in effect it will function as a retention pond. What are the chances that large waterfowl are going to respect the subtleties of this semantic sleight of hand? Not much.

The conclusion offers promises devoid of substance.

7. “The Applicant will implement Best Management Practices and wildlife hazard mitigation techniques relative to the hazardous wildlife attractant associated with the on-site detention pond.”

8. Then in the next sentence, “The Secured Airport Area will be protected by an extensive perimeter fencing and gate system.”

Just how is a fence going to deter to wildlife that’s on the wing? It’s not. It’s an empty gesture that we’re not buying.

If it walks like a duck and quacks like a duck, it probably is a duck. Or in this case, maybe a turkey . . .

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