Thursday, November 1, 2012

Oh, so green

Eco-merge may have been unmasked but ‘green’ hype is still very much a part of the proposed Central Texas Airport’s marketing strategy.

In the previous post, Exposing the hype, we learned that the Corps suggested that the applicant should give themselves credit for work they had done for energy and “green elements. ” Item 13 of the October 25, 2011 conference call also addressed the “green” aspects of the project:

13. Energy requirement and conservation potential, including information on the “green” elements of the proposed project.

Steve Paulson [aci] asked what we meant by this.

[The Corps] explained that they discuss “green” aspects of the project in their EID and website but never say what they are. For example, are they using solar arrays? If so state it in the EID.

In response to these suggestions, three sections of the revised EID touch on green aspects of the project. The most extensive presentation begins on page 43. It is brimming with lots of ideas and generalizations but the specifics still seem to be missing:

4.18 Natural Resources, Energy Supply, and Sustainable Design

Executive Order 13123, Greening the Government Through Efficiency Management (64 FR 30851, June 8, 1999) encourages federal agencies to expand the use of renewable energy within their facilities and activities and requires a reduction of petroleum use, total energy use, air emissions, and water consumption by federal agencies in their facilities. It is also the policy of the FAA to encourage the development of facilities that exemplify the highest standards of design including principles of sustainability.

The proposed CTA is designed to be a green airport demonstration project, conceived and developed to achieve balance between technology and nature. The proposed CTA is designed to provide a privately owned and operated business facility and environment that recruits third-party businesses to demonstrate new and emerging technologies in alternative renewable energies; patent-pending energy management and communications applications; and integrated environmental design and development standards. The proposed CTA is designed to provide convenient, safe, and efficient general aviation accessibility to the Central Texas region.

The proposed CTA plans to implement unique environmentally compatible design features, and utilize demonstrations by other parties with renewable energy generations and management capabilities and scalable smart grid communications infrastructure.

The smart grid network proposes to provide secure and efficient infrastructure connectivity for the airport buildings and businesses, offering real-time, point-source energy consumption data collection and management capabilities for individual buildings or the entire airport.

A local Bastrop County company has been recruited to utilize the roof surface areas of the hangars and other structures on the airport for rainwater collection and harvesting for commercial reuse and bottling. Airports such as the proposed CTA do not have high water requirements so utilizing gray water systems for irrigation and other uses offer a potential model for sustainability.

Landscape planners propose utilization of certain trees, plants, and grasses for carbon mitigation and deterrents to undesirable bird species. CTA will consider these proposals and may implement testing areas to determine the effectiveness of these practices. Many airports utilize vegetation and mowing practices that attract wildlife species that are not suitable for airport environments. CTA is not bound by governmental guidelines or practices for such activities and plans to utilize best management practices.

The “green” aspect of the airport is mentioned briefly in two other places in the revised EID - one on page 53 under 4.21.21 Natural Resources, Energy Supply, and Sustainable Designand the other on page 1 of the Compensatory Mitigation Plan.

Private ownership and freedom from regulation are the pillars on which this project is built. The CTA has made it very clear that their private funding status exempts them from FAA regulation and that they are NOT an FAA project yet here an FAA policy comes in very handy.

Renewable energy is a good thing but weren’t the “patent-pending energy management and communications applications” and “smart grid network” connected to Tiga Energy Services? On August 08, 2012, eight months after the revised EID was submitted, Tiga Energy Services filed for “Securities registration termination” with the SEC. What does that mean for the project’s master energy plan? Is Tiga toast?

Rainwater collection is also a good thing but would you want to pay a premium for bottled water that was collected in a toxic airport environment? How green is that?

And finally the idea of deterring ‘undesirable bird species’ with vegetation while constructing a permanent level pond that will be a wildlife attractant is just plain ludicrous.

All this ‘green’ talk seems like just a lot of hot air to us.

Tuesday, October 30, 2012

Safety be damned!

Safety concerns regarding the proposed Central Texas Airport have been a recurring theme on this blog and elsewhere in the media. In addition, many of the comments responding to the CTA’s Permit Application to the USACE highlighted the inherent dangers of not only building an airport on the banks of the Colorado River but on top of that, constructing a permanent elevation pond only 1000 feet from the runway.

Well the Corps took our collective concern to heart. Items 14 and 15 of the October 25, 2011 meeting discussed safety and wildlife hazard issues related to the proposed Central Texas Airport. The Corps tried their best but encountered an immovable (and clueless) developer. Here’s a summary of the exchange:

[The Corps] explained that there needs to be a discussing [sic] on why the pond would not create a hazardous wildlife attractant. She explained that in our public interest review we need to address this issue. They need to explain why there is a need for a constant pool. Could do a small dry dam and eliminate the wildlife hazard.

The CTA’s response provides stunning insight into the arrogance and self-interest of the developer. The safety issue is something that can be conveniently side-stepped by avoiding FAA regulation (due to the CTA’s private funding status). This attitude will be no surprise to those familiar with the CTA issue but it’s still a shock to see it so bluntly stated:

CTA stated that the pool was for aesthetics and irrigation and that it should not be a concern because it is not an FAA project.

And there you have it. Aesthetics is their primary concern and safety be damned! How’s that for a shining moral compass?!

After that the Corps tried once more:

[The Corps] stated that we still have concerns because it is still a public safety issue. They should consider a dry detention basin.

The Hazardous Wildlife Attractants section on page 28 of the revised EID is a twisted sleight-of-hand response to the Corps well-founded concerns. Quack, quack provides a comprehensive analysis of that section. And the Detention Pond Layout included in Appendix A of the Compensatory Mitigation Plan can be seen in More quackery.

Making a difference

The lack of transparency and disregard for public input regarding the County’s decision to give its blessing to the proposed Central Texas Airport has proven to be a colossal miscalculation. Citizens were rightfully outraged that they had been given no voice in a project that could so negatively impact personal lives, public safety and environmental quality. Would the public ever have a say?

The first significant opportunity came when the USACE posted a Public Notice on March 25, 2011 which requested public comments regarding the Permit Application for the CTA. The initial comment period was for 30 days and then extended until May 9. This section of the Public Notice provided some encouragement to those who were overlooked in the County’s decision-making process:

PUBLIC INTEREST REVIEW FACTORS: This application will be reviewed in accordance with 33 CFR 320-331, the Regulatory Program of the U. S. Army Corps of Engineers (USACE), and other pertinent laws, regulations, and executive orders. Our evaluation will also follow the guidelines published by the U. S. Environmental Protection Agency pursuant to Section 404 (b)(1) of the CWA. The decision whether to issue a permit will be based on an evaluation of the probable impact, including cumulative impact, of the proposed activity on the public interest. That decision will reflect the national concerns for both protection and utilization of important resources. The benefits which reasonably may be expected to accrue from the proposal must be balanced against its reasonably foreseeable detriments. All factors which may be relevant to the proposal will be considered, including its cumulative effects. Among the factors addressed are conservation, economics, aesthetics, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shore erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations of property ownership, and, in general, the needs and welfare of the people.

The USACE is soliciting comments from the public; federal, state, and local agencies and officials; Indian Tribes; and other interested parties in order to consider and evaluate the impacts of this proposed activity. Any comments received will be considered by the USACE in determining whether to issue, issue with modifications, or conditions, or deny a permit for this proposal. To make this decision, comments are used to assess impacts on endangered species, historic properties, water quality, general environmental effects, and the other public interest factors listed above. Comments are used in the preparation of an Environmental Assessment and/or an Environmental Impact Statement pursuant to the National Environmental Policy Act. Comments are also used to determine the need for a public hearing and to determine the overall public interest of the proposed activity.

The most recently obtained document summarizing the October 25 meeting between the developers of the CTA, their consultants and the Corps confirms that the above paragraphs were not just empty window-dressing.

. . . an airport project is very different from a housing development and the public interest review is also different; that this project had more public interest than any project in recent district history with 60 comments and 50 plus requests for a public hearing; and that the EID/EA would need to [be] commensurate with the public interest review.

Preparing comments is not an easy task; one for which not many have the time or inclination. But the citizens of Bastrop County took the opportunity and it paid off.

Let this be a lesson that citizens CAN make a difference. Let the lesson for the County be that transparency and due diligence should be the highest priority in evaluating any future projects of this magnitude. Government should work for and consider its citizens first and not give priority to developers’ pipe-dreams.

Sunday, April 22, 2012


A passenger on a flight taking off from JFK last Thursday recorded a birdstrike event that destroyed one engine as it happened. This plane made it back to safety. But a smaller plane might not have been so lucky. Build that 26 acre ‘duck pond’ 900′ from the runway at the proposed CTA and this could be happening right here in Bastrop County over McKinney Roughs, the Hyatt and the Cedar Creek High School. And we might not be as lucky.

Monday, April 16, 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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