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Last
year, we reported on WWA’s involvement
in a protracted fight to require the Wisconsin Bureau of Aeronautics and
Federal Aviation Administration to prepare an Environmental Impact
Statement (EIS) for the proposed West Bend
Airport expansion (Washington County) due to the substantial
impacts to wetlands and wildlife habitat.
With
federal and state law on our side, we won that fight, and work on the
critical EIS disclosure document kicks off October 11th with a process
called “scoping” (see below). Public meeting and comment period
details are posted in the adjacent sidebar. Background information on the
proposed impacts, the scoping process, and suggestions for how you can
provide meaningful input for this process are included below.
Thank you
to all of our members and supporters who spoke up last year to insist on an
EIS; who contributed financially to support WWA’s work on this effort; and now, for your responses to this
call to action.
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West Bend Airport
Expansion...What’s All the Fuss?
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 The City of West Bend would
like to expand its airport and has waged a long-standing campaign touting
the economic benefits the community will realize from the project (e.g.,
the promise of new and better jobs). They propose to construct a new
5,500 ft jet-capable runway and parallel taxiway, and to expand their
hangar facilities. These improvements would require the re-routing of
State Highway 33, a section of which would also be expanded to four lanes
if the project proceeds.
Wisconsin
Wetlands Association (WWA) opposes the expansion because it calls for the
direct fill of 60 acres of wetlands and the destruction of wetland
functions and wildlife habitat in 88 additional acres of wooded wetlands.
This would represent the largest single-site wetland destruction in the
state since the passage of the Federal Clean Water Act, in an area that’s recognized for its high functional values and
recommended for permanent protection! Click
here for more details on the proposed wetland impacts.
For the
state and federal government to even consider permitting wetland impacts
of this magnitude, a clear and compelling case must be made that the
project is necessary, that no alternatives exist to avoid or minimize
wetland impacts, and that the public benefits outweigh the ecological
costs. To approve a project without meeting these criteria would be an
egregious violation of federal and state environmental laws, and, to
date, we’ve seen little in the project record
to suggest that this project should be allowed to move forward. Done
correctly, the EIS should clarify the case for or against the proposed
on-site expansion. But this will only happen if the public actively
participates in the scoping process to send a clear and consistent
message for what the EIS must examine.
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What is “Scoping”
and Why is Input Needed?
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The fundamental
purpose of an EIS is to inform decisions on how to best minimize
environmental impacts while still meeting the project’s basic purpose and need. “Scoping” is
the first and most important step in the development of an EIS
because it defines the breadth and depth of issues to be examined in the
document. Substantive public input is needed on the scope of the West
Bend EIS, and the research methodologies that should be employed to
evaluate the environmental impacts of the proposed project, to ensure
that the document:
a.
Presents a clearly stated and adequately justified statement of project
purpose and need;
b. Includes an unbiased, comprehensive, and scientifically rigorous “hard look” at project
alternatives and the economic costs and environmental consequences of
those alternatives;
c. Fully explores opportunities to avoid, minimize and mitigate impacts
to wetlands, wildlife, water quality and other natural resource features.
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How you can help: General comments
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A
strong turnout at the scoping meeting or through comment letters is
needed to show that the public is engaged in this opposition effort and
expects a thoroughly researched and unbiased EIS. West Bend media coverage for the
project has been decidedly pro-airport, so your presence will also force
more balanced local coverage of the proceedings. Comments are needed to
insist that the EIS adequately examines:
1. Purpose
and Need: We know the city wants to expand their airport, but why is
the expansion needed? What functions will the expanded runway serve that
can’t be met through other facilities in the region?
If safety concerns are the driving factor, the EIS must document the
constraints and risks of not expanding. If the project is needed to
fulfill a role in the regional airport system, an independent analysis of
unmet demand should be conducted. Economic development is not an
acceptable basic project purpose because alternatives to improve the
local economy without destroying wetlands are abundant.
2. Alternatives
analysis: Once the basic project purpose and need is established, the
EIS must explore all reasonable alternatives to meet that need, including
consideration of expansion at other locations and a “no build” alternative. The economic and
ecological costs of each alternative must be fully explored, including
wetland mitigation costs, to provide an accurate comparison between
options. By law, cumulative impacts (based on previous fills in the
region) and secondary impacts (reasonably foreseeable subsequent
development) must also be considered and disclosed.
3. Wetland,
wildlife and water quality impacts: All wetland, wildlife and water
quality impacts must be fully examined and disclosed. This includes
assessment of direct wetland fill and the wetland degradation from
tree-topping, changes to site hydrology, wildlife habitat degradation,
and more. The EIS must also disclose proposed wetland and wildlife
degradation mitigation measures (e.g., replacement ratios, type and
locations of wetlands to be restored, etc.).
See the sidebar at right for contact and deadline information for
submitting written comments.
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How you can help: Technical comments
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If you
have specific expertise in wetland delineation, hydrology, wildlife
biology, land-use planning, airport engineering, or other relevant
fields, we encourage you to submit recommendations on the types of
research and methodologies needed to ensure a comprehensive environmental
review with valid results. Expert input will carry substantial weight in
the decision-making process for what to include in the EIS, and
recommended methodologies are important to document in the project record
in the event that the research methods or findings need to be challenged
as “insufficient” down the road.
Recommendations
for research and methodologies in the following areas will be
particularly effective for ensuring the EIS addresses deficiencies
identified in previous disclosure documents (e.g., the draft
environmental assessment (EA)):
1. Wetland delineation and functional assessment: The record of
wetland impacts in the EA was incomplete (e.g., the wetland delineation
was conducted late in the growing season and some of the wetland area had
recently been mowed; the functional assessment was limited to the area of
direct fill, ignoring the 88 acres wooded wetland tree-topping);
2. Hydrologic impacts: The EA failed to evaluate the hydrologic
impacts of building in an area with high groundwater recharge functions,
or of destroying 88 acres of wooded wetland trees. Impacts to the Milwaukee River were also largely dismissed.
3. Wildlife habitat impacts: The EA did not include a fish and
wildlife survey to determine what species use the site and how the
project will degrade or destroy habitat functions. Analyses of impacts to
birds and herpetofauna are particularly needed.
4. Hazards of Wildlife Attractants: The increase in standing water
at the site may increase what is already heavy duck/geese use of adjacent
wetlands. FAA regulations may require a wildlife hazard assessment prepared
by a qualified damage management biologist to explore how management
activities to avoid bird strikes will further degrade wildlife habitat
values at the site.
We
invite you to submit comments independently (see sidebar), or to work directly
with us to draft recommendations that WWA can incorporate as an addendum
to our comments. For more information on specific aspects of the project
or to discuss options for how you can help, please contact WWA’s
Wetland Policy & Conservation Specialist, Erin O’Brien at 608-250-9971.
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Scoping
meeting and comment period details
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On Wednesday, October 11th, the Federal
Aviation Administration will host a public meeting to solicit public
input on the scope of the Environmental Impact Statement for the proposed
West Bend Airport expansion. The event will
be run in an “open-house” format. The public will have the opportunity to provide oral comments to a court
reporter and/or submit written comments at the meeting, but there will
not be a hearing-style opportunity to share your comments at a microphone
in front of an audience.
Despite the lack of a public hearing
format, a strong turnout and consistent message in the comments is
important to demonstrate the extent of public concern over the wetland
and other environmental impacts of the proposed expansion and to send the
message that the public expects an open and comprehensive EIS development
and review process. Important messages to convey in your comments are
outlined under the "How you can help" sections to the left.
Meeting details and information on how to mail written comments are
provided below.
Meeting details:
Date: Wednesday, October 11, 2006
Time: 4:00 - 8:00 pm
Location: Clairemont Inn and Meeting
Center
2520 W. Washington St
West Bend, WI 53095
Click
here for a map to this location.
Written comments and recommendations may also be
sent to the following address and must be postmarked no later than
November 13, 2006:
Mr. Daniel Millenacker
Federal Aviation Administration
Minneapolis Airport District Office
6020 28th Ave. South,
Room 102
Minneapolis, MN 55450
Click here to
download a public outreach document (pdf) with
more information on the scoping meeting/comment period format and goals,
and the purpose of an Environmental Impact Statement.
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