LATS (Long Term Air Transportation Study)
Update: July 31
(Warning: get ready for an "alphabet soup" of acronyms!)
The Puget Sound Regional Council (PSRC) is working on a Transportation 2040 Draft Environmental Impact Statement (DEIS.) This will become a regional planning document to coordinate our overall transporation infrastructure.
PSRC proposed that the DEIS include the LATS study, opposed by SOC. (There's your alphabet soup!) SOC submitted public comments to the PSRC opposing the inclusion of LATS into the DEIS. Click here for a complete copy of our comments.
Here's a brief summary of our comments:
1. LATS. We vigorously oppose the incorporation of the Long Term Air Transportation Study (LATS) into the PSRC's Transportation 2040plan. The LATS study is highly unsuitable as a planning document for the reasons we set forth below. The LATS report would serve only to contaminate the DEIS with faulty models and flawed conclusions.
- The LATS panel's report is a high-level summary of the status of all 600airports in Washington State.
- The analysis was based on coarse, discredited, outdated assumptions.
- The modeling was similarly outdated, relying on static models. It should have used more accurate and flexible queuing theory (for terminal capacity) and demand management modeling to arrive at capacity figures that reflect changes due to our recession, improvements at Sea-Tac, and technology improvements from NextGen.
- The 2005 projections for Sea-Tac in no way reflect the actual 2009 numbers.
- The LATS report is completely unsuitable as part of a large-scale transportation planning effort. The LATS enabling legislation did not design LATS for, or contemplate its use in, the PSRC's transportation planning efforts.
Our region, State and federal government have invested billions of dollars in Sea-Tac for the 3rd runway, in our Sound Transit rail and bus transportation systems and in other ground and air transportation facilities. Poor analysis for the ground/air transportation connection at Sea-Tac will lead us to incorrect and costly conclusions such as shifting demand from Sea-Tac to other reliever airports thus cannibalizing the investments made in Sea-Tac. We may even decide to build a new international airport with ever more finite dollars at astronomical expense. If we are going to pursue costly development or cannabilization of our current investments, we should go forward with the best available analysis rather than that provided by LATS.
For all of these reasons, the LATS report should not be included in the 2040Transportation DEIS. The LATS report would serve only to contaminate the DEIS with faulty models and flawed conclusions.
2. MPP-DP-51. Incompatible Land Uses: "MPP-DP-51 Protect the continued operation of general aviation airports from encroachment by incompatible uses and development on adjacent land." We take issue with this language, as it is inconsistent with the Transportation 2040's goal to create coordinated,integrated transportation plans with the local community.
3. FlyAway Bus. We recommend that the PSRC consider the "FlyAwayBus" model developed by the city of Van Nuys, California.
What a terrific outpouring you all provided to the LATS survey in April. Snohomish County responded 4:1 over those in King County! That's the "law of large numbers" at work.
Remarkably the LATS panel chose to dismiss our volume and consistency of comments as, some-how, "not representative of the public's opinion"! Now that panel is about to release its final report, due to the Governor on July 1st. LATS has based its recommendations on an outdated and inaccurate finding that Sea-Tac will reach "capacity" by 2030! Given that flawed assumption, federal law requires the State to identify new commercial airport capacity immediately, e.g. Paine Field.
But the LATS analysis is highly flawed and ignores reality. It uses faulty, outdated capacity models and obsolete growth rates that ignore the huge downturn in air travel. It fails to recognize additional capacity that the entire nation will gain by implementing NextGen, a highly efficient new air traffic control system; they ignore the capacity gains that result from the 3rd runway at Sea-Tac ($1.3 billion investment), from light rail ($1.2 billion) and from improvements to Sea-Tac's terminal capacity ($400 million). It fails to consider higher seat utilization and more efficient use of aircraft. The LATS panel also fails to consider passenger terminal throughput modeling, and as a result, LATS ignores higher capacity gains from e-ticketing, kiosks, improved parking, ground transportation management, etc.
Please tell Governor Christine Gregoire that the LATS panel failed to fulfill their duties. Click here to send her a note.
Sea-Tac is doing many of these things now to increase capacity. Conveniently, LATS fails to recognize the positive effects of Sea-Tac's efforts. The capacity problem isn't with Sea-Tac; it is with the LATS analysis.
When using FAA growth rates for Sea-Tac and adjusting the LATS analysis to reflect 2009 data, it appears that Sea-Tac capacity is extended beyond 2050!
It's bad enough that the final report is riddled with flawed logic and analysis but considering the billions that have already been spent and the millions that will likely be expended to implement the recommendations, using the LATS Final Report as a planning tool would be blatantly irresponsible. In this era of huge budget deficits, we need to invest public dollars wisely. Let's not allow a flawed study to drive decisions that will mis-use those dollars and permanently, needlessly, impact our communities and our region.
Please show up at the LATS meeting and protest their report. Or click here to send an email to the Governor. Tell her the LATS Panel has failed to do even a reasonably good job. By failing to use updated and accurate capacity analysis, the LATS panel is undermining the very basis for the LATS law and the process.
Office of the Governor
PO Box 40002
Olympia, WA 98504-0002
"The final set of strategies will ultimately become part of the Washington Aviation System Plan, which supports the management of Washington’s public airports as an integrated system. The plan will guide the strategic investments necessary to preserve aviation capacity and provide facilities that effectively accommodate future demand. The Aviation System Plan will become the aviation portion of the Washington Transportation Plan (WTP), the blueprint for transportation programs and investment in Washington State" (from LATS questionnaire.)
SOC warned LATS about the need to conduct proper analysis. SOC supporters responded in numbers to the LATS survey. Yet the LATS panel dismissed these large responses as some-how "not representative" of the "public"!
To see SOC's completed version of the LATS questionnaire, click here. (After it opens, hit "ctrl-2" on your keyboard to see it in full screen view.) SOC has a number of concerns about the LATS process that we discuss in the answers given.
HERE ARE SOC'S MAJOR ISSUES AND COMMENTS:
At the very least, please send in these bullet points. You will need to “select” and “copy” these bullet points to your email or to a Word document.
- The LATS process and survey are biased towards airport protection and addressing airport expansion obstacles.
- Underlying this survey is a presumption that Sea-Tac will reach capacity by 2030 and other capacity throughout the State will also be constrained. We question the capacity demand analysis underlying this survey, for the following reasons:
- LATS has not clearly defined how capacity is measured. They are basing billions of dollars of decisions on state-wide aviation capacity, yet they are not clear or transparent about this critical issue.
- Why will Sea-Tac have capacity constraints when it has a new third runway, new NextGen air transportation management system, a mostly vacant South terminal, and new light rail starting up there? LATS needs to answer this before seeking solutions like new airports or pushing traffic to Paine Field.
- Why will Sea-Tac have capacity constraints when the FAA stated that the US experienced an 8% decline in air passenger service from March 08 to March 09? LATS is basing all of its capacity constraints on growth rates in 2005/06, and assuming straight line growth rates will continue. But this is false.
- LATS needs to look at ways to improve bottlenecks and other constraints in the system before looking at expensive solutions, such as converting Paine Field to a scheduled air service field, or building new airports. There are less expensive ways to improve throughput in our system without the expensive propositions put forth by LATS.
- LATS should emphasize a balance between airport needs and other GMA/land use decisions. Instead there is a clear effort to emphasize airport needs at the expense of GMA/land use decisions.
- The survey is designed to limit local input and shift it to the state to give local elected’s cover from community outrage – that is wrong. Even worse, the survey wants taxpayer dollars to “educate” the community. We fear this will give airport proponents our tax dollars to lobby against the communities and for the airlines.
- The LATS process fails to account for all the involved issues that would be considered in a truly comprehensive airport citing or airport use decision. Instead the myopic, airport centric process is biased towards airport use and expansion almost to the complete exclusion of other considerations no matter what they may be.
- The LATS process completely ignores identifying and considering highest/best use options for airports, communities and the associated land use decisions. By definition, if all viable options are not being considered the results are virtually guaranteed to be suboptimal – how does that kind of government decision serve the people? It doesn’t!
- The entire approach seems designed to protect airports, subsidize airlines, minimize other considerations, preserve ability to expand airports and centralize decision making to get away from locals, etc.
- In short, this is a bad way to make permanent public policy decisions that may destroy communities and high paying job growth opportunities. It does a disservice to communities and to the state.