Mr. Matthew Beaton
Executive Office of Energy and Environmental Affairs
Attn: Page Czepiga, EEA No. 15434
100 Cambridge Street, Suite 900
Boston MA 02114
Dear Secretary Beaton,
Please review my comments below regarding the Logan International Airport Terminal E “Modernization” project Environmental Notification Form (ENF), EEA #15434, and its potential environmental impacts, lack of serious alternatives, inadequate mitigation measures, request for an Environmental Impact Report (EIR), Special Review Process and request for an extension on the ENF comment period.
In 2014 the Massachusetts Department of Public Health’s Logan Airport Health Study confirmed a direct association between airport pollution and chronic diseases. To date, it showed a 360 % increased risk of probable childhood asthma and nearly 200% increased risk of chronic obstructive pulmonary disease. Given this direct link and the potential serious health impacts, I strongly urge you to require an EIR in accordance with 301 CMR 11.06(7).
The project alternatives in the ENF, (§ 2.4.1, § 2.4.2) are wholly inadequategiven that the Port Authority could have studied economic, environmental and operational viability that would provide greater sustainable growth alternatives. The failure to address regionalized air travel as a common and widely viewed alternative demonstrates this need for further review. It is becoming increasingly clear that both for operational and public health impact reasons, Logan International Airport will not be able to fulfill its appetite for long term continued growth in a sustainable manner.
Massport has done an insufficient job of addressing mitigation and transportation matters in the ENF, particularly as it relates to managing traffic at Logan Airport. Given the expected increase in passenger traffic at Terminal E (§ 126.96.36.199), and the recent Massport community proposals in regards to lifting the long standing legal parking freeze, it should be assumed that demand for parking and vehicle trips will also increase. I suggest that MEPA further investigate this inconstancy of no new vehicle trips (§ 3.6.8) for an expansion project of this size in conjunction with its desire to lift the parking freeze. The lack of serious mitigation beyond a pedestrian walkway (§ 2.8) is also an affront to idea that a large increase in passenger and aviation capacity in international travel will have no further mitigating impacts beyond the scope of the project.
Based upon the risks associated with airport developments and their specific nature, I urge MEPA to develop a supplemental review process as outlined inM.G.L. c. 30, section 301 CMR 11.09. Massport proposals to expand or “modernize” Logan International Airport should require a MEPA special review process to help properly address the scope of potential public health impacts in assessments. In addition but not limited to, it should always require a thorough Environmental Impact Report, a more robust community engagement process, a longer comment period, and require an Environmental Justice Coordinator to promote thorough inclusion of these topics on all further MEPA related public processes.
Please consider extending the ENF comment period for the following reason: 6pm meetings held at the Airport’s Noddle Island Community room do not allow adequate time for people working traditional work hours to attend. The venue, its size, and its lack of amplified audio facilities was inadequate and it was very difficult to hear everyone’s comments also, many people had to stand due to the lack of seating. Limiting the comment period to just 30 days for large projects of this nature, especially during the winter and the holiday seasons, make it extremely difficult to gather the necessary information to make informed comments.
It is my hope that you will carefully consider these comments, concerns and recommendations, and act in the interests of the community.