If you might want to be involved in the upcoming state environmental review process, it is important to send in written comments to the Pittsfield Conservation Commission by November 15th, 2007. Even if you are not sure which issues you most want to comment on, just picking one issue for now will keep you in the process. Some of general comments might be:

• Please protect the wetlands to the maximum extent possible. Remember these waters flow into the Housatonic River.
• If you allow the wetlands to be replicated, please require the proposed wetland replication areas to be monitored until they are showing growth of 75% of the planted native species for three years in a row - as opposed to just monitoring for three growing seasons. It is very important that the new growth is verified as being really established - with no invasive species growing in the replicated area.

Ideas for comments that are specifically mentioned in the Massachusetts Secretary of Energy and Environment's Certificate:

• The Certificate says that the airport commission has not demonstrated an overriding public interest, nor did they do any economic cost/benefit analysis. In fact, the airport commission states in the Notice of Intent on page 2.23 that this project is not based on an economic cost/benefit analysis. By the way precedence in airport expansion cases has already determined that economic development is NOT an overriding public interest.
• The public safety interest could be met with several of the alternatives. A cost/benefit analysis should be required to compare all the alternatives, not just the ones the airport commission wants - after all, the airport stands to gain substantial revenue particularly from fuel sales, with their "preferred" alternative.
• The plans only look at the larger planes taking off with "less than adequate fuel loads". BEAT believes "less than adequate" means the planes can't fly from Pittsfield to California, but would have to refuel part way. The airport commission should define what they consider adequate fuel loads. The analysis should be done based on what fuel loads they currently have to use. Perhaps a much shorter runway is perfectly acceptable if the aircraft is 40% loaded. The bother of having to stop once to refuel on a cross-country flight should be judged agaisnt protecting the people and environment of Pittsfield and Berkshire County. This sort of analysis should be required.
• The airport reports are all based on guesses of airport usage. The airport does not keep track of who or even how many aircraft use the runway. They should have been gathering this data for the last several years, but at least they should be required to start gathering this data now.
  
• The citizens of Pittsfield would be paying for this project not only financially, but also in noise pollution, water pollution, and air pollution. What actual benefits would they receive? The local paper suggested that the benefit would be having "John Travolta and Steven Speilberg" be able to fly in.
  
• The Notice of Intent lists impacts of 183,000 cubic feet to Land Subject to Flooding where the Final Environmental Impact Report listed impacts of 81,760 cubic feet. This is a substantial difference and one reason a Notice of Project Change should be required to be filed with the Massachusetts Environmental Policy Act office.
• The alternative analysis is incomplete. The airport commission analyzed the Obstruction Removal Alternatives alternatives only for the different methods of obstruction removal, not for each of the different expansion alternatives.
• The alternative analysis is incomplete. The airport commission analyzed the Instrument Landing System options only for the different types of landing systems, not for each of the different expansion alternatives.
  
• The proposed runway extension and new taxiway appear not to be safety related.
• Slopes of 1:1 from an area of high potential pollutant loads (an airport runway) directly into wetlands is an unacceptable risk. If this drastic a slope is allowed, there must be some protection provided on this slope to stop pollutants from entering the wetlands.
• Water quality monitoring before, during, and after construction should be required on all three brooks - not just for sediment, but likely pollutants including VOCs and heavy metals.

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