Error in EA Baseline
Appendix 2


The National Environmental Policy Act requires that proposed airport operations be compared with reasonable forecasts without the proposed operations, and if the noise impact is significant an environmental impact statement must be done. [References 1 and 2].

In NASA's draft environmental assessment (EA), "For the purpose of establishing baseline conditions against which to compare project impacts, these recent, lower levels of activity [24,000] have not been used, since these flight operations could return to the historically higher levels [60,000] at any time". [Reference 3]. NASA is using the CUP and its EA as the baseline for the current EA. In so doing they are attempting to exploit the provision of NEPA that allows previously approved plans to be used as a baseline. That might be reasonable in the case of a recently approved plan that had not had time to be implemented before the NEPA process for a subsequent action was begun.

The conclusion of the EA is that proposed air cargo will result in "less than significant impact" in noise levels, compared to the baseline of 60,000 flights. Thus no noise mitigation measures are considered, and no environmental impact statement is to be made. [Reference 4].

However, the Director of Moffett Field, Dr. Ken Munechika, admits that the baseline forecast is unreasonable. "If we just stick to those two limitations (federal aircraft and federally sponsored) and not consider CRAF there's no way we could approach that [60,000 operations]." [Reference 5]. However, NASA has effectively stipulated that "the CUP is broken". Thus, it seems that in this case use of a previously approved but infeasible plan as a baseline flunks the reasonableness test of the NEPA law.

Reference 1
FAA Regulation PART 150--AIRPORT NOISE COMPATIBILITY PLANNING


B. In accordance with 150.21, the existing condition map must be based on current data as of the date of submission (i.e., year of submission) to the FAA regional or district office. The 5 year map must be based on forecast aircraft operations at the airport and on other reasonable planning assumptions (further described below in V.A.) for the fifth calendar year beginning after the year of submission

Reference 2
FAA Airport Environmental Handbook . Order 5050.4A . October 8, 1985


The FAA will determine, in accordance with paragraph 51, whether the action will be the subject of an environmental impact statement or finding of no significant impact.

Reference 3
CRAF Air Cargo Operations. Moffett Federal Airfield. Draft Environmental Assessment, National Aeronautics and Space Administration, June 17, 1996.
Existing Noise Environment. Page 46.


Historically, aviation activities at MFA have averaged about 80,000 annual operations. Of these annual average operations, approximately 60,000 have actually occurred on the airfield, while the remaining 20,000 operations were typically overflights by aircraft traversing the MFA airspace.

However, as a result of the transfer of MFA to NASA and the phase-out of active duty P-3 squadrons, overall aviation activity has decreased over the past few years. While there recently has been some growth in the number, size, and level of activities of government agencies at MFA, existing operations have significantly declined since the Navy transferred MFA to NASA. In 1995, approximately 24,000 annual aricraft operations occurred at MFA. CNEL noise contours have been prepared for those conditions, as shown in Figure 13 (using the FAA's Integrated Noise Model).

For the purpose of establishing baseline conditions against which to compare project impacts, these recent, lower levels of activity have not been used, since these flight operations could return to the historically higher levels at any time, whithout further environmental review, as long as noise contours remained within the 1994 CUP 2010 description. A projected activity level of approximately 80,000 annual operations serves as the 2010 forecast conditions, as defined by the MFA CUP.

Reference 4
CRAF Air Cargo Operations. Moffett Federal Airfield. Draft Environmental Assessment, National Aeronautics and Space Administration, June 17, 1996.
Noise. Alternative 2. Page 107.


Would the proposal result in increases in existing noise levels? Less than significant impact. Alternative 2 would result in an increase to existing noise exposure (Figure 13). However, Alternative 2 would not result in an increase in noise that would result in further exposure of residential land uses to CNEL 65 dB when considering 2010 conditions (Figure 25).

Reference 5
Moffett chief talks about air cargo. Interview with Dr. Ken Munechika, director
of the Moffett Field Complex. Mountain View VOICE. June 28, 1996.


KM: In 1995, last year, here at Moffett we flew less than 24,000. If we hit 60,000 that would pretty well take care of our deficit and probably even more than that.

Voice: Would you say that 60,000 (operations) is a goal you could achieve with the limitations you were talking about?

KM: If we just stick to those two limitations (federal aircraft and federally sponsored) and not consider CRAF there's no way we could approach that. The reason is, the whole Department of Defese is downsizing and because they're downsizing it's pretty hard to grow using DOD assets, you see. What we have done is look at the bases that are closing in our area and there have been a few, as you know. But we don't have any more here that we can draw on and we don't have any flying organizations that we can draw on. So the opportunities for that is fairly limited.