(Note: This Guest Commentary appeared in the local papers of the four
Hanscom-area towns -- Bedford, Concord, Lexington and Lincoln.)

Bedford Minuteman
October 6, 2005

Commentary: MEPA decision is misinformed, biased

By Richard Canale and Julian Bussgang

With Massport's support, a company called Crosspoint has proposed
building a new general aviation terminal, with hangar space, at Virginia
Road in Concord which would greatly increase the airport's fuel-guzzling
corporate, private, and passenger jet traffic, introduce new, serious public
safety concerns, cause more noise, and generate more vehicular traffic on
the already overcrowded Battle Road.

Last week, the secretary of the Massachusetts Executive Office of
Environmental Affairs (EOEA) issued a ruling that this massive project does
not require an environmental impact review.

If left unchallenged, this decision would set a major precedent in
allowing Massport to greatly expand jet operations with no public
environmental review process and, hence, no opportunity for public input.

The citizen's group ShhAir (Safeguarding the Historical Hanscom Area's
Irreplaceable Resources) had submitted a formal request to EOEA to put the
project on hold until its environmental impacts were evaluated. This is
precisely what the Massachusetts Environmental Protection Act provides: a
new aviation terminal cannot be built without a full environmental review.
ShhAir's request, filed on Aug. 1, was supported by the citizen's group Save
Our Heritage, the Hanscom Area Towns Committee (HATS), and the Hanscom Field
Advisory Commission.

ShhAir's request should have gone out for a 30-day public comment
period. Yet EOEA took two full months -- until Sept. 28 -- to render a
decision, without setting a public comment period. This is particularly
disturbing in light of two key factors apparently underlying Secretary
Pritchard's ruling.

First: The Crosspoint proposal includes 13,000 square feet for
passenger services (more than double the passenger area of the Hanscom Field
Civil Air Terminal, which not long ago processed over 200,000 passengers per
year). Massport has never publicly questioned that 13,000 square foot
figure. Yet amazingly, when Massport's lawyer wrote to EOEA in response to
ShhAir's request for environmental review, he suggested that "only about
2,000 square feet" would be used for passengers. A public comment period
would have required Massport to explain this discrepancy publicly. It would
also have exposed many other contradictions, inconsistencies, and outright
misstatements in the Massport response.

Second: According to Secretary Pritchard's decision letter, he had
"personal communications" with environmental officials at the Federal
Aviation Administration and the Massachusetts Aeronautics Commission, who
both told him that they considered the Crosspoint facility to be a "hangar"
and not a "terminal." (As noted above, state law requires full environmental
review of a proposed new airport terminal.) There is no way to know whether
their assessment was based upon Crosspoint's and Massport's public
statements about the proposal or (as seems more likely) upon Massport's
letter that tried to make the proposal look like something it is not.

Furthermore, a public official's decision about a matter of public
concern should not depend upon private communications with other officials.
Making this case even more egregious is the fact that the federal and state
aviation agencies Secretary Pritchard consulted had their own reasons for
wanting projects of this kind to escape environmental review and therefore
were in no position to offer him disinterested advice. In short, their
advice was misinformed at best and biased at worst, and there should have
been a comment period to expose that advice to public review and critique.

As co-chairmen of the HATS Environmental Subcommittee, we have been
deeply involved in the analysis of Crosspoint proposal and the ensuing
effort to obtain environmental review. We believe we have documented that
the environmental impacts and safety concerns from the Crosspoint terminal
are real and warrant an environmental review. But, the MEPA public record
won't include this documentation because EOEA refused to allow public
comment.

In effect, Secretary Pritchard ruled in this case that a terminal is
not a terminal. It seems clear from reading his decision letter that he was
not properly informed of the facts of the case, and his failure to allow
public comment prevented him from basing his decision on a complete public
record.

The HATS Environmental Subcommittee co-chairmen have asked HATS to take
appropriate steps to overturn this decision. We urge citizens to tell Gov.
Mitt Romney that Secretary Pritchard has made a serious mistake and that the
Crosspoint project must not be allowed to proceed without the full
environmental review that it so obviously requires.

-- Julian Bussgang and Richard Canale are co-chairmen of the Hanscom
Area Towns Environmental Subcommittee.

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