September 25, 1997

Ms. Peggy Kelly
Project Manager, Airports District Office
Federal Aviation Administration

Dear Ms. Kelly,

As a member of the Lexington-Fayette Urban County Council, I am vitally interested in the airport board's proposal for a 9,000-foot runway at Blue Grass Airport. I represent the residents of the 12th District, in which the airport is located. I also serve as a member of the Airport Task Force, but was unable to be present at the task force's meeting this week to discuss the runway proposal and the EIS process with you directly. Therefore, I would like you to respond in writing to the following questions, as they were not answered in this week's meeting.

1) Earlier this year, the Urban County Council passed Resolution 212-97, with which I presume you are aware. Yet the Scope of Services for the EIS makes no mention of this resolution, or the other two urban county resolutions concerning the runway proposal. In the entire document I do not recall seeing any reference to the Urban County Council, the only elected body representing the residents of Lexington-Fayette Urban County. Why is there no mention whatsoever of the Urban County Council's actions this past year? I will be happy to provide you with another COPY if one is needed.

Resolution 212-97 announces the strong opposition of the Urban County Council to any additional air carrier runway at Blue Grass Airport, and urges the FAA to confine its study to less costly alternatives. Yet, the Scope of Services for the EIS features the airport board's 9,000-foot runway as the "proposed action." Why is the FAA going forward with the EIS in the face of the Urban County Council's Resolution?

2) Resolution 212-97 was an exercise of the Urban County Council's statutory authorities over the airport board and airport development. It was drafted with the understanding that the FAA cannot legally approve any airport improvement project unless the FAA receives certain assurances from the airport. One of these assurances is that the project is consistent with local land use plans. Our resolution declares that the 9,000-foot runway would be inconsistent with local land use planning: Another assurance the airport must provide is that it has good title to the land needed for the project, or that it will acquire good title. Under Kentucky law, the airport board may not acquire property by condemnation without obtaining council approval. In resolution 212-97, we stated that we would not give such approval. If there is no way the airport board will be able to provide the FAA with the required assurances, why has the FAA decided to spend all this money on the EIS? More important, will the FAA approve funding for this runway over the objections of the Urban County Council as contained in resolution 212-97?

3) Another assurance the airport must provide the FAA is that enough money is available to pay the non-federal project costs. Our resolution states that we will not provide any funds or financial assistance in any form in furtherance of this runway project. I understand that you said, in the task force meeting this week, you were informed that the airport board did not need Urban County Council approval to pay for the local share. I do intend to review the tape and do want to know who told you that. What authority were you given in support of this statement? Are you aware of the airport board's financial status? Please provide me with a copy of with any material submitted to the FAA regard to funding of the local share for the proposed runway project.

4) I am concerned about the cost of preparing the EIS. The initial cost for the EIS was $500,000. As you know, the FAA approved funding of this amount through a passenger facility charge. I later learned that the airport has sought another $750,000 for the EIS. The airport board did not inform the Urban County Council before submitting a pre-application in December or the application in June. Has FAA approved this additional amount? If not, is the offer the FAA going to approve it? If so, why did the FAA approve it? Did the airport offer the FAA any justification for this more than doubling of costs, as required by the FAA order? A review of the Airport's pre-application and application contain no such justification. If there is such a justification, please provide me with a copy of it.

5) I am also very concerned about the objectivity and independence of the consultant selected to prepare the EIS. One of the members of the consultant team (PDR Engineers) is the author of the very master plan which recommends another air carrier runway. Don't you regard that as a conflict of interests? How can anyone expect that consultant to have an open mind about whether another air carrier runway at Blue Grass Airport makes sense?

6) The Scope of Services failed to note that actions taken by the Urban County Council opposing the 9,000-foot runway. Who drafted the Scope of Services document? Is this an FAA document, or was it drafted by the consultant? Has it been reviewed and approved by the FAA?

7) The Scope of Services document does not inspire confidence that the EIS will be a comprehensive consideration of the tremendous environmental effects a 9,000-foot runway will have on this historic and prime agricultural area. For instance, the discussion of the potential impact on horse farms leads me to suspect that the only impact the EIS is apparently going to consider is the economic impact to the horse industry. While these impacts are sure to be substantial, why doesn't the FAA see that what is at stake here is the very character of our community? What makes the Lexington-Fayette Urban County area so unique and rich is that this is the premier land for thoroughbred horse breeding in the world. Destroying at least six horse farms, as the proposed runway would do, would have an impact well beyond the financial cost of acquiring these properties. Does the FAA have any expert knowledge as to what a 9,000-foot would do to this area?

8) The Scope of Services describes a very limited survey of historic properties. Having chaired the Fayette County Historic Preservation Commission for three terms, I can assure you the proposed scope is inadequate. The Scope of Services assumes that the project would affect no more than four National Register-eligible historic properties and one National Register-eligible historic rural landscape. How did the FAA reach this conclusion at this time? Why did the EIS artificially limit its consideration to a predetermined number of properties? Also, the EIS does not mention any site-specific abrasion testing or archaeological testing to determine National Register eligibility. This was an important element in previous EIS studies, why not in this study as well?

9) Why does the Scope of Services refer to the master plan's capacity justification for another runaway, when the FAA and airport board have abandoned that justification? Is there any FAA document that you know of that suggests Blue Grass Airport currently suffers from a lack of capacity? Is there any FAA document that suggests Blue Grass Airport will need additional capacity in the next 10 to 20 years? If there is no such document, why is the Scope of Services focused primarily on building the proposed runway?

10) Why is the scope of the EIS limited to four runway development alternatives (other than no action alternative)? If, as I have been lead to believe, the FAA is concerned about taxiway separation and runway safety area standards, why wouldn't the EIS consider less costly alternatives that specifically address such issues, such as moving the taxiway or extending the runway safety area? Will this not need to be done to meet new regulations, whether or not another runway is constructed? And why is there no mention of building a new regional airport? The discussion of alternatives gives the impression that the decision has already been made to approve a runway, with the only questions remaining as to its length and location.

Are you familiar with the FAA's approval of the PFC to fund the EIS? The FAA approved the PFC for the sole reason of ensuring that Blue Grass Airport continues to maintain air carrier service consistent with current safety guidelines. The Scope of Service appears flatly inconsistent with the FAA's FFC approval. It should be clear that this community does not want another air carrier runway, if we can avoid it. Will you agree to revise the EIS Scope of Services to replace some of the runway development alternatives with non-runway alternatives?

11) The task force was told that two public workshops held during the preparation of the draft EIS would not involve public comment. I specifically and respectfully request the FAA allow members of the public and my affected constituents to be able to provide comment and to ask questions at these workshops. If this will not be the case, I must know why.

12) Are you aware the airport board does not own the airport property, but by an airport corporation created jointly by the airport board and the Urban County Government? Because of our ownership interest in the airport facility and because the Urban County Council is the only elected body that represents the Lexington-Fayette community, we believe the FAA should not approve any airport development projects without first notifying and obtaining the Urban County Council's confirmed concurrence.

At this time, I will request you please copy the Urban County Council on all written communications and inform us of all oral communications from the FAA to the airport concerning the EIS or any such airport improvements. If you do not intend to do this, please inform as to reasons why.

Further, the FAA should not approve any application from the Airport board relating to its runway proposal or other such improvements without first obtaining the views of the Urban County Council. Will you please agree to do this?

Thank you for your prompt attention to these questions. Please respond at your earliest convenience, as I am most anxious to be kept informed on behalf of my constituents on this most important issue in my district.

Sincerely,