Eden Prairie City Staff Audit of Final Agreement with MAC
and MAC Commitments
March 2005

• In view of FAA changes to laws and policies in "General Aviation," we applaud city staff for their wise and prudent decision to conduct an audit and analysis of the final agreement with MAC – especially at this time.
  
  
• In regard to all the information related to the relevance of the "Relievers" from the FAA and the GAO (General Accounting Office) in GAO reports to Congress, it is appropriate for MAC to ask the question now and have a "core debate involving the very existence of the "Relievers." (Eden Prairie Sun Current, Feb 17, 2005).
  
  
• According to MAC’s own web site, "In 2003 Flying Cloud Airport experienced 155,837 takeoffs and landings, showing operations were down 11.7 percent from the previous year. http://www.mspairport.com/Reliever_Airports/Airports/Flying_Cloud. Though operations have decreased on an annual basis Flying Cloud Airport continues to be heavily subsidized by the public in the form of fees and charges at MSP. Diminished numbers and ample capacity at other relievers show the need for another reliever expansion is unwarranted.
  
  
• The audit of the Final Agreement and MAC’s commitments to the city is the most responsive action city staff could take on behalf of the residents/community of Eden Prairie. Unlike the Eden Prairie Chamber of Commerce, some council members and one of Eden Prairie’s legislators who conduct themselves as unquestioning advocates and lobbyists for aviation interests in Eden Prairie, the city understands that they must advocate on behalf of everyone’s interests with full knowledge of all the facts concerning the airport and its impact on the community. It would be appropriate to have all of Eden Prairie’s representatives speaking on behalf of the city and community – not just Flying Cloud Airport.

• New FAA policy which has the potential to force small airports to allow access to larger/heavier aircraft could result in cargo operations at FCM. The new policy would allow planes to land that exceed the weight bearing capacity of the runways. This policy has been strongly opposed by other "General Aviation" airports nationally. We oppose this policy because it opens up a variety of issues involving safety, pollution, economics and unregulated traffic.

• Heightened security risks affecting "General Aviation" airports have been in the news just this month. The report by the Homeland Security Department (March 14, 2005 Star Tribune) detailed particular vulnerabilities in what it called "the largely unregulated area of General Aviation, which includes corporate jets, private planes and other unscheduled aircraft." These risks call into question the existence of underutilized "General Aviation" (or "Reliever") airports. In the Twin Cities area there are 6 "General Aviation" airports, all underutilized. In light of heightened security issues and the economic subsidies necessary to keep these airports open, MAC must reevaluate the existence of the "Reliever System."

• With all of this information at hand, it’s important the city ensures that the letter of the law is upheld in every aspect of the agreement between the City and MAC. It would be very difficult for anyone to rationalize expanding Flying Cloud Airport if all of MAC’s commitments in the agreement were not upheld. Especially when Anoka and St Paul Holman Field, whose projects have higher priority, and have received some funding, will create more than ample capacity for "General Aviation" in the entire Metro Area.
  
  

Zero Expansion’s Position on Expanding FCM

While MAC was considering expansion at Flying Cloud Airport for the last 10 years plus, "General Aviation" was experiencing a down trend in operations. (In Testimony given in 1994 on the AIP, Airport Improvement Plan, the GAO reported to the Chairman and Members of the Subcommittee on Aviation Committee on Transportation and Infrastructure at the House of Representatives. The GAO looked at the "reliever set aside fund that was created to address reducing congestion at commercial airports, providing additional general aviation access— and came to the determination that the need for this set aside fund no longer existed." This report took into account the FAA’s Aviation Forecasts for Fiscal Years, 1994-2005. The FAA projected relatively little growth over the next 12 years from 1994 to 2005.)
The analysis in the 1994 report identified ‘a long and steady decline in general aviation traffic indicating that funding to relievers that are not in a position to play a prominent role in the nation’s airport system is wasteful when the reliever set-aside funds could be better used at public-use airports that could contribute to the national air transportation system.


The 2001 GAO report on long term capacity states that "FAA expected increases of about 50% in the number of cargo aircraft and the number of smaller general aviation jets, such as corporate jets, and jets operated by air taxi or charter services." (GAO-02-185 Long Term Capacity Planning Needed.) The reasons for this change are clear: the expense of owning your own plane, the price of gas, escalating fees and charges are a deterrent to single users even with the subsidies the public contributes through taxes, concessions, and fares at MSP.

The "General Aviation" environment is changing dramatically— future growth will not include use by owner operators, and hobbyists as was originally intended, but by multiple users— including a new era of fractional shares’ operations: "VLJs," Very Light Jets, called "Air Taxis," and small to medium cargo operations. And to accommodate these commercial operations the FAA introduced a new policy several years ago that would allow bigger planes to land that exceed the weight bearing capacity of runways at smaller airports. The final agreement between MAC and Eden Prairie stipulates a 60,000lb pavement weight bearing capacity.

What does this all mean for the community of Eden Prairie?

Add it all up: a 5,000 runway, aircraft that exceed the weight limitation MAC committed to in the final agreement and the result is an open door to a bona fide commercial airport under the guise of the pseudonym, "General Aviation," which used to mean non-commercial aviation. The current character of FCM will forever change, from a sleepy little airport into a largely commercial airport, allowing access to planes weighing over 100,000lbs and more. MAC’s contention was that there can’t be cargo at Flying Cloud Airport because of the weight limitation. New FAA policymaking removes access restrictions and creates a commercial environment where it didn’t exist before in small airports around the nation.
1. New FAA policy which removes pavement weight based restrictions and allows larger aircraft to land at airports they were denied access to before.
2. A new FAA fractional rule classifies (charter or for hire) larger aircraft as non-commercial users of business aviation and allows them access to thousands of smaller airports.
Will MAC keep the 60,000lb commitment to the city of Eden Prairie: a signed, contractual, legal commitment? Ask them.

Zero Expansion is opposed to lengthening the runways and turning FCM, Flying Cloud Airport into what would essentially be a commercial airport, and, or, cargo facility. We are opposed to the increased risk from environmental pollution, from the use of jet fuel and toxic chemicals used for aviation maintenance, and the increased noise and safety issues that will cost our city the quality-of-life that makes Eden Prairie a livable and desirable community. The idea of residents subsidizing hobbyists wasn’t acceptable, but footing the bill for corporate, commercial, and or cargo operations is a tax/subsidy on the public for a service that is incompatible with our community’s best interests.

The time has come again to contact our city manager, council members, legislators, and MAC officials and tell them no expansion(s) at Flying Cloud Airport.

• In direct contrast to the FAA and the GAO, MAC’s contention is that relievers reduce congestion at MSP. According to the 1999 GAO (General Accounting Office) report to the Resources, Community, and Economic Development Division responding to a request from the Chairman of the Subcommittee on Transportation and Related Agencies Committee on Appropriations, United States Senate, the "FAA lacks information or data to determine if allocating funds to reliever airports actually reduces congestion or improves general aviation access."
  
  
• In a 1999 GAO report, General Aviation Airports Unauthorized Land Use Highlights Need for Improved Oversight and Enforcement, the GAO states that the FAA not only" fails to effectively implement its compliance programs as to land use for general aviation airports, it leaves the airports vulnerable to mismanagement, fraud, waste and abuse." The report cites a lack of "hands-on" monitoring and sufficient internal controls of general aviation airports."
  
• The GAO (General Accounting Office) 1999 report to the Resources, Community, and Economic Development Division responding to a request from the Chairman of the Subcommittee on Transportation and Related Agencies Committee on Appropriations, United States Senate, "recommended reducing the number of airports designated as relievers. FAA and General Aviation officials agreed that too many airports are in the reliever program. FAA officials say most relievers were designated years ago and continue in the program because it is the FAA’s only way to show priority over 2, 400 public-use general aviation airports."
  
  
• In Testimony given in 1994 on the AIP, Airport Improvement Plan, the GAO reported to the Chairman and Members of the Subcommittee on Aviation Committee on Transportation and Infrastructure at the House of Representatives. The GAO looked at the "reliever set aside fund that was created to address reducing congestion at commercial airports, providing additional general aviation access— and came to the determination that the need for this set aside fund no longer existed." This report took into account the FAA’s Aviation Forecasts for Fiscal Years, 1994-2005. The FAA projected relatively little growth over the next 12 years from 1994 to 2005.
  
  
• FAA projections at that time (for 1994 to 2005) for General Aviation traffic suggested that "the future of reliever airports in alleviating congestion and delays would likely remain small. Scaling back the number of relievers appeared to have wide spread support."
  
  
• The 1994 report stated that, "Officials at 22 reliever airports in the nation told the GAO that they considered reliever airports in their metropolitan area to be underused. The officials pointed to the shrinking size of the general aviation market as a cause and said the shrinking market was forcing them to compete for customers." Over and over again – the findings of the GAO and the opinions of FAA administrators show a diminished relevance of relievers.
  
  
• In this same report the GAO also stated that the "FAA did not consider general aviation to be a significant factor in congestion at commercial airports because of an overall decline in general aviation traffic. Also, the FAA and the aviation industry officials considered access to general aviation facilities sufficient where most reliever airports are located." The report also identified "excessive access for General Aviation operations in areas where relievers are located."
  
  
• The GAO comments and recommendations from the 1994 report were as follows: Though no one can predict future growth, the "FAA has not acted upon any of the information or changes reported, and they have not developed a means to assess overall general aviation access needs to determine how many relievers are needed." The only forecasted growth segment of general aviation, which is larger aircraft, could be included in a set-aside for funding. Another "option the GAO looked at was eliminating the designation of "relievers entirely and eliminating the set-aside altogether."
  
  
• Ultimately the GAO sees the future of aviation in commercial operations and not in General Aviation. In the 90s the legislature changed the reliever classification from a minor airport to intermediate; in the same way the relievers can be reclassified again, this time as airports that handle commercial operations, such as the new VLJs (very light jets that accommodate 1 to 7 passengers), also referred to as air taxis, or even cargo operations.
  
  
• MAC has acknowledged that "corporate aviation is changing" and the "current trend involves buying fractional shares of a single aircraft and using it according to an hourly charge or lease-related basis." (Eden Prairie Sun Current, Feb 17, 2005.) The article refers to "sport jets" which are correctly termed "VLJs," Very Light Jets, or Air Taxis which are essentially planes for hire. Most General Aviation airports around the nation objected to the new FAA fractional ruling classifying commercial larger aircraft as non-commercial users of business aviation that now have access to thousands of smaller airports around the nation.