A pivotal state agency wants the developers of a massive hangar complex on Hanscom Field to show why it can’t accomplish the same goals with a smaller or delayed project.
The secretary of the state Executive Office of Energy and Environmental Affairs – as expected – this week issued a requirement for the proponents of the hangar project to prepare a draft environmental impact statement.
A detailed “scope” specifies the content of the impact report, and much of the focus is in response to hundreds of comments submitted in response to the initial environmental notification form.
According to the agency, the report should “demonstrate that the proponent will pursue all feasible measures to avoid, minimize and mitigate damage to the environment to the maximum extent feasible.”
Thus, the scope is all-inclusive in its requirements, ranging from noise, air emissions, and land alteration to water quality, wildlife habitat, and ground traffic.
“I received over 350 comment letters from legislators, local officials, residents and community groups expressing significant concerns about the project,” wrote Secretary Rebecca Tepper. Most are about increasing flight capacity and the resulting greenhouse gas emissions, “in contrast to the climate goals established by the commonwealth and local communities.”
The environmental review is not a permitting process. Under state law, once the impact report is submitted there will be a 30-day comment period. If the content is not accepted by the secretary’s office, the proponents must prepare a supplemental report.
A spokesman for the developer said in an email Tuesday, “We anticipate it will take at least six months to prepare the draft in accordance with the scope.” Ken Schwartz, senior vice president with the consulting firm VHB, added, “We look forward to working with MEPA, Massport, and the reviewing public in undertaking a thorough analysis of the proposed project.”
“I encourage the proponent to request an extended comment period to facilitate its review by the public and by local, state and federal agencies, and to hold at least one public informational meeting prior to filing,” the secretary wrote.
The project consists of almost 500,000 square feet of hangars, of which more than 80 percent would be new construction on Massachusetts Port Authority land off Hartwell Road, called North Airfield. Renovation of the adjacent so-called Navy hangar would add another 87,000 square feet of storage. There are two limited-liability companies that are the proponents.
One rationale Massport has used to justify increasing overall aircraft storage space by 50 percent is to reduce so-called “ferry flights.” Airport management has said that there is no room for overnight storage, so passengers are often dropped off at Hanscom, with the planes then departing for other nearby airports for the night.
The scope demands that the impact report “provide data and analyses that support the proponent’s assertion that the project will reduce the number of flights at Hanscom.”
According to the scope, the developer also “should review a reduced-build alternative that achieves the goals of reducing the number of ferry flights by constructing fewer hangars and thereby minimizing land alteration.”
Also, the developer must consider “operational measures that could be implemented to reduce ferry flights without additional hangars,” such as restrictions on aircraft type, financial penalties, or shuttle buses from outlying airports.
State Sen. Mike Barrett led an effort calling for Massport to prohibit fossil fuels from the new space. The scope calls for reviewing “phased construction of the proposed hangars, with the later phase of construction being contingent upon the widespread availability of synthetic aircraft fuel or electric planes.”
And the proponent must also review the feasibility of waiting to finish until there is “a clear demonstration that the project achieves its goal of reducing ferry flights.”
The agency wants to know “whether the project will facilitate and accommodate an increase in flight activity, or whether it is intended to absorb existing demand,” and “how the project may affect future activity levels, based on detailed information.” It reads, “Discuss how expanding hangar capacity to meet potential future increases in customer demand would not result in a net increase in flights, even when accounting for a reduction in ferry flights.”
The report should “describe the number and type of aircraft to be stored in the hangars and provide a comprehensive explanation of ferry flights, estimate the number of ferry flights that are anticipated under existing and future conditions with explanation of how the estimates were generated.” The memo also differentiates between “aircrafts departing to serve additional customers” from planes “seeking parking spaces at another base location.”
Air quality is another key focus of the scope details. The proponent must “evaluate air emissions from takeoffs, landings, cruising, taxiing and idling.” There is also a list of seven contaminants that must be quantified, such as lead, carbon monoxide, and particulate matter.
The developer also has to “specifically review emissions from aircraft while they are on the project site and their potential impact on nearby receptors.” Carbon dioxide emissions must be quantified, along with efforts to minimize them. This includes buildings and vehicles.
Other requirements specified in the environmental scope include:
- “Discuss how the plan is consistent with Massport’s net-zero planning and the commonwealth’s emission reduction goal.”
- “Provide a comprehensive assessment of the air emissions impacts of the project,” and whether current and future flight patterns “are anticipated to disproportionately affect any particular neighborhood within a five-mile radius.”
- “Include a separate section on public health and discuss any reasonably foreseeable public health consequences that may result from the environmental impacts of the project.”
- “The forested portions of the site should be described with respect to species, composition and approximate age, size, and density.”
- Potential water contamination from washing airplanes and similar operations should be reviewed, with details on how possibly contaminated water will be “captured, contained, and/or treated prior to discharge into the sewer system.”
- An analysis of “noise produced by the operation,
“including aircraft driving around the site and idling, interior and exterior noise associated with maintenance, repair and starting of aircraft, and other noise-producing activities.” The scope also calls for proposed noise elimination or minimization options, such as orientation of buildings or hours of operation.
- A description of “any proposed fuel storage tanks at the site, as well as accommodation of the ongoing environmental cleanup taking place near the Navy hangar.
- The secretary questions the assertion of 13 employees making 194 daily vehicle trips from a 240-space parking area, and demanded that they “Describe the staffing level needed to operate 27 hangars and any fluctuations in the number,” as well as the type and number of non-employee trips, travel routes and time.”
There’s a separate section on construction impact, citing noise, air and water quality, and traffic impact, citing construction vehicle trips through residential areas. The scope calls for details on truck routes and the number of vehicles. The proponent must also review the feasibility of a construction vehicle route using the airfield and “clarify whether the route would also be used to deliver supplies such as fuel to the project site when the facility is in operation
.,” as well as the environmental impact of building the road.
Under state law, a copy of the impact report must be provided to every person or agency that commented on the environmental notification form.
The good old “we’ll say we need 50 then we’ll caave and give up on 30, this way they’ll be happy with the illusion they won the fight and we end up with the 20 we really wantd to begin with,” tactic…