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KEEP Perspective 2
on “Risk Analysis for the
Proposed Relocation of the Bowling Green-Warren County Regional Airport” June 2002
Prepared by: Landrum & Brown, Inc. 11279 Cornell Park Drive Cincinnati, OH 45252 KEEP
Karst
Environmental Education and Protection Coalition P.O. Box 8 Oakland, KY
42159 Tel. (859)
255-8216 October 24,
2002 Executive Summary of Review
of Financial Risk Analysis for Proposed Bowling Green-Warren County Regional
Airport Introduction. In 1998, the InterModal Transportation Authority (“ITA,” a private corporation serving as development agent for Warren County) was provided a $6 million grant by the state of Kentucky to get the proposed Kentucky TriModal Transpark moving forward. Four years later, nothing substantive has been achieved, and the money is almost gone. To date, there are no businesses recruited; no airline commitments; and no private investment in evidence. For the past two years, the ITA has, via elected officials, asked the federal government for project development funding, which is the next stage in the process of building a new airport. Background. The Federal Aviation Administration (“FAA”) provides up to 90% of the cost of airport planning studies across the U.S., but only about 25% of the total public investment in airports.* It funds financial risk analysis studies for what it considers “large speculative” projects, so that local governments can understand that they may be left with the funding obligation if there are cost overruns on a new airport or there is not enough business to provide revenues. The FAA does not approve or disapprove a risk analysis study; it simply acknowledges that the study has been completed. In this case, FAA awarded about $133,000 to the ITA to hire a consultant, Landrum & Brown, Inc., to do such a study for the proposed, new Bowling Green-Warren County Regional Airport. This study, “Risk Analysis Study for the Proposed Relocation of the Bowling Green-Warren County Regional Airport,” has to date not been vetted or critiqued. There has been no public disclosure or dialogue. Only the Executive Summary is available on the ITA Web site, and no public hearings have been held. There has been no information about this report made available to the public beyond a predictably positive press release from the ITA and a single article in the Bowling Green newspaper. Have the city, the county, and the other local governments that have signed on to support the KTT, been invited to public meetings hosted by the ITA about this study? Have there been formal presentations about this study at regular meetings of governing bodies? Have these governing bodies been encouraged to respond to this document with their own concerns and questions? This public obligation by the ITA has been finessed, at best. Hence Karst Environmental Education & Protection (“KEEP”) is providing the public with a review and response to the Landrum & Brown report (“Risk Analysis”), including the full peer review response, which was intentionally omitted from the Risk Analysis and had to be obtained from the ITA via open records act requests.
3. Inviting investment on the basis of
4.
Dodging the question of who is going to pay for this project. KEEP
has been asked to not reveal the name of the real estate peer reviewer; and in
fact, “The ITA has no written record of
this review, however, the consultant has indicated that the expert’s review was
offered verbally and indicated that he found the concepts and assumptions
acceptable for planning purposes.” (Trisha Lawrence, letter to Ouida Meier,
July 1, 2002). See Appendices E and F for the unedited, full peer review comments from karst experts Tom Aley and Dr. Barry Beck. See Appendix C for May 2002 comments from Dr. Ralph Ewers on problems with the 1981 dye trace research by Quinlan, Ewers and Ray, upon which lie many assumptions about the siting of the airport and TriModal Transpark. As examples of the information that was omitted from the Risk Analysis, Dr. Barry Beck stated that the ITA’s own studies of the risk and hazard of sinkhole collapse are “grossly abbreviated” and “totally inadequate,” and that the hazard of sinkhole collapse is “significant” (Beck, 2002, Appendix F, pages 4-5). Tom Aley commented that sinkhole collapse could result in “injury and loss of life,” chided the ITA for treating the problem as being as simple as fixing a city street (Aley, 2002, Appendix E, p. 11), and noted that “sinkhole collapse is a common and expensive problem in this region of Kentucky,” contrasting it with other, less collapse-prone karst areas (Aley, p. 4). Aley also noted that “no runway could be threaded through the assemblage of buffer zones” needed because of the presence of substantial and numerous sinkholes throughout the proposed runway area (Aley, p. 5). Aley stressed that, until the issues of potential flooding on this site are understood and resolved, the financial risk assessment is incomplete (Aley, p.1). Beck concluded: “An accurate estimate of the cost of mitigating these hazards must be factored into the cost/benefit analysis, or the final decision based on this ratio will be invalid!” (Beck, p. 8). Additionally, in his full peer review comments, the Vice
President and Deputy Director of Research for the Federal Reserve Bank in St.
Louis warned that the capital requirement assumptions of building a new airport
should be modified to account for “bad” cases of higher costs and lower
proceeds from selling the existing airport (Landrum and Brown 2002, peer review
comments). Conclusion. The FAA funded this Risk Analysis with the intent that it be an “unbiased risk assessment study in order to obtain an independent and well-informed opinion regarding project feasibility” (Larry Kiernan, Manager, Airport Capacity Branch, Office of Airport Planning and Programming, FAA. Memo, June 6, 2001. Appendix D). The ITA has avoided public dialogue about this Risk Assessment and, indeed, withheld the most damning of comments until forced to turn them over. KEEP believes that the gross inadequacies found in the ITA’s studies is unconscionable, especially given the fact that the private corporation has spent almost $2 million in Kentucky taxpayer dollars for consultants to do this deficient work. The ITA and its leaders, elected and appointed, are suppressing information about the airport and TriModal Transpark project that could lead to injury and death. This information is revealed in the following pages. The ITA and its leaders, elected and appointed, are
presenting false information as truth: at the Cabinet for Economic Development
Web site, the aerial view of development site 227-010, the Kentucky TriModal
Transpark, represents 2,439 acres as being vacant and ready for development (www.thinkkentucky.com). This is an
example of the many misrepresentations and falsehoods discussed in the
following pages. The new airport and Kentucky TriModal Transpark are risky proposals, so risky that the federal government cannot be counted on to bail out this project. Ultimately, local taxpayers and governments and the Commonwealth of Kentucky will be left holding the bag. Table of Contents
Fatal
Risks in the Risk Analysis page Introduction 6 Fatal
Risk #1
6 Fatal
Risk #2
8 Fatal
Risk #3
11 Fatal
Risk #4 14 Conclusion:
Very Risky, Indeed! 16 Appendices
Following after
page 17
A.
Roger W. Brucker, KEEP steering committee, “Vocabulary and Meaning Unique to the Risk Analysis: Reader Beware!” B.
Photographs of potential for flooding and collapse: KY TriModal Transpark airport area, Bowling
Green, and Dishman Lane. C.
Dr. Ralph Ewers, karst expert. Comments on Quinlan, Ewers, Ray dye trace
research. D.
Larry Kiernan, FAA. Memo, June 6, 2001. E.
Tom Aley, karst expert. Comments in full from “Risk Analysis.” F.
Dr. Barry Beck, karst expert. Comments in full from “Risk Analysis.” Fatal Risks in the Risk Analysis
Introduction. The Risk Analysis advises accepting an enormous amount of economic and environmental risk in order to proceed with the airport replacement project. There are at least four fatal risks in the Risk Analysis, each of which will end the project, should its proponents be so unwise as to proceed. These fatal risks are discussed, below. In order to develop this list of Fatal Risks, these documents were reviewed: the Landrum & Brown “Risk Analysis Study,” and the products of a separate peer review panel made up of representatives of these disciplines and occupations: airline officials, real estate, geology/hydrology, geology/sinkholes, airport manager/airport official, and economist. Problems were encountered in obtaining the full peer review comments, which should have simply been appendices to the Risk Analysis. Instead, these comments had to be obtained via two open records act requests. The real estate consultant did not provide
written comments and had his name suppressed from the peer review list (it was
obtained via the open records request). This real estate consultant is the
principal of a realty advisory company that Kentucky’s Secretary of State lists
as inactive and not in good standing. Further checking reveals his direct
association with KY Gov. Paul Patton, President Dan Cherry of the ITA, and
through business connections, to a relative of the ITA’s lead attorney. Additionally, the highly critical comments from the two karst expert reviewers, Tom Aley and Dr. Barry Beck, also had to be obtained via an open records act request. Their comments are provided in full in Appendices E, F. Fatal Risk #1: Building the airport in a karst
floodplain, contrary to FAA regulations and local ordinances. KEEP asks the ITA: Should the FAA authorize
building a greenfield replacement airport in a flood-prone area on unstable
ground where the potential for rapid pollution has been demonstrated? Airports
should not be built on floodplains. Beyond the illegality, floods pose safety
hazards to air operations. Tom Aley, President of the Ozark Underground
Laboratory, and Expert Review Panel member for the Risk Analysis, discusses
this fatal risk at length in his report submitted to Landrum & Brown, Inc.
for inclusion in the Risk Analysis. The
substance of this distinguished karst expert’s report on the risks involved in
building a replacement airport was omitted from the Risk Analysis, and had to
be obtained by KEEP through an open records request. It is reproduced in Appendix E because it is based on scientific
evidence, familiarity with FAA requirements, and experience with at least one
airport built on a karst terrain with less sinkhole collapse and flooding potential than the sponsor’s
proposed site on the sinkhole plain west of Oakland. Aley
states that the Risk Analysis cannot be
completed until the
question of potential flooding problem is addressed and reconciled. He states
that there is a “major data gap” as to the potential for flooding at the
proposed airport site (Aley, p.1). He states “the ITA’s implicit assumption of
no flooding that would impact the airport has no validity whatsoever” (Aley,
p.1). See also Dr. Barry Beck’s comments on flooding (Beck, Appendix F, pp
7-8). The
Bowling Green, KY area has for many years been the recipient of chronic floods.
As the photos in Appendix B suggest, flooding is a chronic problem at and near
the replacement airport site. Sinkholes near the proposed runway location flood
during high rainfall. For detailed information about sinkhole flooding
occurrence and flood events in the Barren River area, go to
www.kyclim.wku.edu/BRADD/sinkholes/sinkholes.html Can
this flooding at the replacement airport site be remediated or mitigated? The answer is NO, or Bowling Green would
have solved the problem years ago. The city of Bowling Green has drilled more
than 600 injection wells to drain away damaging storm waters into the
underground rivers below the surface. The maintenance department employs a
dedicated drilling rig to keep the injection wells open, because they plug with
brush, soil, and trash. Stormwater runoff, flooding, and stormwater quality
issues are major unaddressed problems for Bowling Green that it is now facing,
due to looming federal deadlines (EPA Storm Water Permit due March 2003). . The
ITA’s karst consultant, Dr. Nicholas C. Crawford, describes mitigation and
remediation measures that will eliminate flooding (Crawford, N., 2002. “Site
Evaluation and Design Assistance for the Proposed Kentucky TriModal Transpark
Preliminary Report (Based Upon Existing Data Only).” Center for Cave and Karst
Studies, prepared for the ITA). However
Aley refutes the idea that stormwater retention ponds lined with impermeable
membranes will solve the problem. He states that “failure of liners due to
various processes including subsidence or collapse is a common occurrence in
karst areas. Maintenance and repair costs of such liners are commonly
substantial” (Aley, p. 9). Beck states that “detailed geotechnical exploration
of the area” must take place prior to any liner use (Beck, p.5). The
weight of retained water and other liquids to be stored at the proposed airport
has not been calculated, and is likely to cause profound collapse (see also
Laura Carbó Maldonado, “Hydraulic characterization of sinkhole filters,”
mayaweb.upr.clu.edu/inge/FLAB/RESEARCH/research.htm). Cut and fill grading operations
will open new sinkholes, as has happened in most site development projects
around Bowling Green (see Lovers Lane and Dishman Lane photos in Appendix B). Conclusion:
The high cost of flooding and the virtual impossibility of preventing
flooding, with disastrous implications for airport function and for stormwater
problems in Warren County, create Fatal Risk #1. Fatal Risk #2: Postponing the consideration of major
financial risks by categorizing them as mere environmental risks to be
addressed later in an Environmental Impact Statement (“EIS”). KEEP asks the ITA: Will all environmental risk assessments be postponed until later phases? Already-identified environmental risks (see KEEP Perspective # 1, May 2002) add millions of dollars to the project cost, and the fatal risks identified herein will inevitably make the project fiscally impossible. Environmental risk assessments should be done now, because these are also economic risks. Is it fair to issue general obligation bonds to finance a construction project where no competent field checks have been made of the risky geology and hydrogeology, and where every environmental scientist except the sponsor’s consultants have decried the sponsor downplaying and misrepresenting the cost of the environmental risks? Collapse is a chronic problem around Bowling Green and the proposed replacement airport site. The risk of collapse is described in vivid detail in Beck’s comments. According to Dr. Beck, “the risk and hazard of sinkhole collapse is inadequately addressed in the Preliminary Karst Evaluation (Law Gibb Group) and it is hardly mentioned in the Risk Analysis Study” (Beck, p. 4). Further, Beck states “the detailed planning studies of the engineering geology of the site must adequately evaluate and mitigate the hazard of sinkhole collapse, which will involve detailed investigations” (Beck, p.5). Aley states that “subsidence or sinkhole collapse could interrupt aircraft use of the facility for a period of time necessary to make repairs. Such repairs … could require up to several months… Sinkhole collapse during a landing or take-off could result in injury or the loss of human life” (Aley, p. 11). According to published accounts, the cost of a single collapse – Dishman Lane in Bowling Green, which took place in February of 2002 – carries a repair price tag of $800,000 to $1,000,000 (see photos, Appendix B). The combination of possible injury or loss of life, business interruption, and subsequent claims of negligence for building on unstable karst doom this project. The Risk Analysis argues for postponing all considerations of environmental risk, such as collapse, until the formal EIS investigation is set in motion by federal authorities: “Environmental risk, based on several existing studies, is not present or can be mitigated, but this tentative conclusion will be further analyzed in future studies including an Environmental Impact Statement required to be prepared by the FAA. Thus, the full extent of potential environmental risk is not addressed in this report, but will be studied in subsequent analysis and is allowed for, to some degree, in the financial allowances” (Landrum & Brown, 2002, p. 2; see also p. VI-9). These environmental risks are economic risks. These risks have been repeatedly identified and presented to the ITA and to local, state, and federal authorities, and in public hearings and meetings held by the ITA and other entities (KEEP Perspective #1, May 2002; www.stoptranspark.org; www.rogerbrucker.com; www.WCCMG.org ). For the Risk Analysis to be valid, these environmental issues with very high price tags must be considered in full, now. Postponing an assessment of environmental risks is unconscionable. A fair and unbiased assessment of the economic impact of these fatal risks would indicate that the airport and Transpark projects should be immediately abandoned. If karst is as widespread as claimed in the Risk Analysis (40% of the U.S. land east of Oklahoma: Landrum & Brown, p. 3), then this site on the Central Kentucky sinkhole plain is at the top 1% level of risk due to flooding, instability and collapse, and pollution. One would be hard pressed to find a more vulnerable – and thus expensive – site anywhere else. A 1988 map, “Karst Hazard Assessment of Kentucky: Sinkhole Flooding and Sinkhole Collapse,” illustrates that Warren County is in the “Highest Risk” area of the state for collapse. A look at this map is also instructive because other Kentucky airports cited by the ITA as being built on karst, are located in less risky karst areas. This map, prepared by Nicholas Crawford and James Webster for the WKU Center for Cave and Karst Studies, can be viewed at the Web site of the Warren County Planning Commission, www.warrenpc.org The ITA’s consultant claims that “a storm water system which the ITA is committed to providing will greatly reduce the risk of groundwater contamination, sinkhole flooding, and regolith collapse sinkholes.” (Crawford, N., 2002, p. 3). To this, the ITA adds, “Utilizing proper engineering technology and construction methods, both industrial development and environmental protection can be accomplished.” (ITA, Vision promotional direct mailer, p. 4, 2002). Every karst remediation project requires costly investigation, individual engineering and planning, and special construction techniques. This consultant recommends construction of rubber-lined stormwater retention ponds, without regard to the weight of water as a contributor to collapse. As was the recent case in Alachua, Florida, lined ponds collapse with catastrophic effect and pour their contents underground before anyone can respond (“New craters in detention pond at Dollar General,” Heuss, Constance S., Alachua Post, April 19, 2002, p. 737; copious other references in the Gainesville Sun and Alachua Post from 1999 - 2002). The consultant also recommends (Crawford, 2002, p. 42) the use of sand and peat moss filters to “treat” stormwater runoff, without regard to the fact that sinkholes swallow sand, soil, trees – yes, and peat moss. Additionally, peat moss filters are inherently high maintenance structures because they plug with sediment, and the sphagnum moss must be replaced every two to five years, assuming it is still in place (Geerts, S.M. and Barb McCarthy, 1996, Wastewater Treatment by Peat Filters, Vol. 10, No. 1, Small Flows, Small Flows Clearinghouse, U. Minnesota). None of the costs of these special measures has been factored into the project budget, except for a catchall contingency allowance that may be an order of magnitude too low. Other environmental risks with high price tags that were ignored or downplayed in the Risk Analysis:
Conclusion: Fatal Risk #2 says it loud and clear: The economic costs of environmental problems are being ignored until it is too late. Investors, beware! Fatal Risk #3: Inviting investment on the basis of:
KEEP asks the ITA: Will the Risk Analysis adequately warn
investors and concerned local governments of the fatal risks, the expensive
secondary risks, and the cost of failure? Or will the ITA press ahead with
unconventional borrowing, land acquisition, engineering planning, construction,
and legal sunk cost commitments? Is it wise to invest in attempting to
stimulate aviation demand at a location where the only justification is a
forecast of demand made by the FAA, based on no market research? Is the assurance by local government
officials -- that they can commit taxpayer funds to underwrite the entire
project -- enough to offset the risk posed by the low-growth outlook for
general and commercial aviation? Is
it prudent to allocate general obligation funds to underwrite replacement of a
city/county airport (operating at 26% of capacity, according to E.P. Systems
Group, P. Meyer, letter to FAA and Warren County executives, August 3, 2001;
Haarstad, Havard, “Independent economic group finds fatal flaws,” p. 5 of Our
Backyard Journal, April 2001 ) in order to provide a sales feature for an
industrial park project? Is it sufficient to justify replacing an
excellent airport that can continue to serve the community, because of
anecdotal concerns about noise and security? Do unlimited government resources exist to
fund construction of a project where the costs of new adverse environmental
consequences are sure to exceed already-known, already-ruinously expensive
environmental risks? Will hidden contingent fees for contractors mask low construction bids, since the sponsor will underwrite the construction surprises in this karst terrain? terrain (cf. Flyvbjerg et al., 2002, Underestimating Costs in Public Works Projects - Error or Lie?: Journal of the American Planning Association, v. 68, no. 3, p. 279-295 (specifically p. 281 where geology is mentioned)? Plans for
the sale of the present Bowling Green airport: Discussion
Note the repeated warning in the Risk Analysis that the present airport must be sold and funds be made available before land acquisition and construction of the replacement airport can begin (pp. 6-7, III 5, III 7, III 13, V 3-5, VI 7). One of the Airline Experts on the peer review panel for the Risk Analysis stated with some urgency that for this project to go smoothly, development of the new airport must take place “fast,” and the present airport “has to be sold as soon as possible to recover the funds for the new Airport” soon (Landrum & Brown, 2002, unnumbered page). The only scenario by which this can happen is for the South Central Kentucky Regional Development Authority (SCKRDA) to issue promissory notes to buy the present airport. It is difficult to see how that will be carried out by this unincorporated group of individuals, without obligating the local government general revenue stream. However, this group was able to negotiate a $6 million “bridge loan” from a consortium of banks based on first mortgage deeds on unimproved farmland (anticipated) and in anticipation of the approval of bond issuance (still pending on appeal). The financing risks should be evident to all prudent observers. This house of cards is held together with the thin glue of a promise that the money for the replacement airport will come from a combination of revenue from the sale of the present airport, plus “State,” “tenant,” and “local” funds (Landrum & Brown 2002, pp. 2, 3, III 17, and V 3-4). No justification of the estimated revenue from the sale of the present airport is provided in evidence, except a real estate appraiser’s estimate. Where are the facts? Where is a rigorous study of comparable situations nationwide, which would provide real data for decision-making? It needs to be stressed that the FAA is not going to rescue this situation from failure. The Risk Analysis points out several times that the “FAA share” of the funding for this project is limited to the proceeds from the sale of the present airport, “with no new FAA funds assumed” (Landrum & Brown, 2002 p. 2, III 3). Any additional FAA funding would be only available through competition with other airports; thus “the level and timing of additional FAA funding, if any, is unknown” (Landrum & Brown, 2002, p. 6). Previous studies by the sponsor have “validated” that the present Bowling Green-Warren County Airport is being used to only 26% of capacity (see discussion of the misleading use of this term and others in Appendix A, Roger W. Brucker, “Vocabulary and Meaning Unique to the Risk Analysis: Reader Beware!”). Due to the adverse economy, present airport use is presumably even less than that modest figure. Out of this relatively light load of aircraft operations, 92% of this demand is training flying or pleasure flying (Landrum & Brown, 2002, p. I 6). An aircraft operation is defined as one takeoff or one landing. A student pilot performing five touch-and-go repetitions accounts for 12 aircraft operations! It appears that real demand at the present Bowling Green airport is low, and does not justify investment of taxpayer funds in a replacement just to meet hoped for, possible future demand. The FAA’s annual forecast for 2002 states that, barring business/corporate flying, “discouraging” is the word that best describes the general aviation outlook. Passenger traffic is forecast to begin recovery during or after 2004 (Paul Lowe, “Business aviation is the only bright spot in FAA GA forecast,” AINOnline, April 2002). The assertion is made that there are no “brownfields” – environmental contamination – problems with the present airport that would diminish or eliminate sales proceeds (Landrum & Brown, 2002, pp. III 1, 3). Airports are notorious spillers of toxic pollutants, and this one has a tank farm. Where are the facts? Where is the research, the comparisons with other similar situations, the environmental historic track record of the present airport? This is not the right time to be building a new airport, with aviation in a slump, investment and Wall Street confidence low, a history of profound underperformance and lack of demand at the present airport, and a decidedly shaky strategy for obtaining the funds necessary for the replacement airport. The present airport requires an annual subsidy of more than $100,000 from local government funds. Future needs for airport services: DiscussionThe most
significant quote from the Risk Analysis on the topic of the need for future
services at a replacement airport is found on page I 1: “the [present] airport
currently has no passenger service.” Other uses of the present airport
are similarly underwhelming: Commercial flights consist of three single engine
FedEx Cessnas daily, and “ad hoc” charter planes (p. I 7). Military use is
constrained to “transient helicopters,” perhaps three a day (p. I 8).
Remarkably, these stark facts accompany a fanciful discussion of potential scheduled airline activities at the proposed new airport, among them a projected annual 42,700 emplanements on 30 – 50 seat regional jet aircraft by 2009. This is a startling figure for a city of 50,000 (Landrum & Brown, 2002, p. I 3). These and other numbers of possible future aviation activity at this proposed replacement airport appear to have been invented, or borrowed from other equally unsubstantiated “validations” printed by the consultants and their sponsor, the ITA. Where is the market research, the solid historical documentation, the rigorously-tested evidence that there will be any real demand for this proposed airport? Can the replacement airport be justified on the basis of “security”? The Risk Analysis argues thus (pp. 2-3, IV 3). However, careful reading reveals that the sole testimony on this topic is a comment by the airport manager that “the closeness of airport neighbors may result in increased noise complaints or increased concern over safety issues” (p. IV 3). Anecdotal remarks about as-yet unvoiced complaints do not make a compelling case for “security” problems! Have any measurements or objective data been collected according to rigorous standards, to validate these claims? Apparently, no noise measurements have been made. If the present airport is unsafe, why has the FAA not shut it down? The Risk Analysis asserts that a longer runway would be desirable to accommodate larger aircraft, and that acquiring land at the present airport site to lengthen the runway is impossible, due to the presence of luxury residences (p. IV 1,2). Where is the data to verify these assertions? Many existing airports lengthen their runways through acquisition of adjacent properties because it is generally more financially prudent to use the invested capital with incremental spending than it is to start over. For example, Lambert Field in St. Louis was expanded after a huge cemetery was moved. Meanwhile, the Mid America Airfield (Transpark) less than 30 miles away sits nearly vacant. Following are summary points regarding numerous other remarkable or questionable assertions in the Risk Analysis: ·
The forthcoming
Eclipse 500 business jet needs only 2,500 feet of runway. ·
Most of the
training demand could shift to competitive airports. ·
Base case is
artificially low. ·
Contrary to the
ITA’s assertion, the public was not included in project planning. Critical public comments are omitted
entirely. ·
The assertion
that there is no risk to the FAA is false. ·
Scheduled
airline 3-plane per day operation with 35-50 seat jets is unrealistic even at
40% load factor. Wishful thinking for a town of 50,000, predicted by the 2000
Census to grow by 4% in 10 years. ·
If there is
real demand for airline service, wouldn’t scheduled limo service to Nashville
or Louisville be offered now? ·
No fire station
is planned for the new airport – must drive out from BG. No control tower and
no cross runway are planned. Safety and security? Conclusion: It is not
justifiable, nor even logical, to state that a surrounding industrial park will
benefit if and when the airport is developed. A new airport should meet real
demand, not serve as a sales talking point for industrial sites. This is just
one example of Fatal
Risk #3: Inviting investment on the basis of sketchy
plans for sale of the present airport; the likelihood of a major cash shortfall
during the replacement process; a fictitious demand scenario; and a deceptive
risk analysis based on wishful thinking, baseless projections, and marketing
hype. Fatal Risk #4: Dodging the question of who is going to
pay for this project. The Risk Analysis identifies private investment as a major source of money for constructing the new airport (Landrum & Brown, 2002, pp.7, V 4-5). Who do they have in mind? As noted above, the FAA will not bail out this project. Local and regional governments will have to pay for it, if there is little or no private investment. Consider these points: The present airport has to be sold at
just the right moment, and at the right price, for this chain of events to work
smoothly and not collapse mid-way. The local governments that have agreed to
support this project have been assured that they do not have to pay anything
until 2007. The ITA’s sanguine yet
undated timetable (p. V 6) is unrealistic, given the community uproar, which is
downplayed. A decision to stop is not considered, with sunk cost implications. Surely it is past
time for this project to be brought to a halt, before economic damage develops,
locally and regionally. In October, 2002, KEEP called for business and political leaders to release a marketing consultant’s study that casts serious doubt on the feasibility of the Transpark project. Dated September, 2002, the report raises concerns about the county’s ability to adequately finance the proposed 4000-acre industrial park and airport. KEEP filed an open records request to obtain a copy of the report. However, ITA denied the request. The ITA admitted they possessed a preliminary draft and preliminary memoranda of ongoing market analysis work commissioned by a third party. The ITA refused to provide those documents, claiming them to be exempt from public disclosure. This new study of market demand was believed to have been commissioned by the Bowling Green Area Chamber of Commerce. It was presented to the ITA board last month by Margaret Grissom, CEO of the Chamber of Commerce. Allegedly she criticized ITA officials for buying land for the project, given the adverse findings. A further allegation is that the parties to the secret meeting agreed to keep the report hidden until after the election. If true, implications of this attempt to conceal the bad news about no demand could seriously affect the willingness of the consortium of local banks to extend their $6 million “bridge loan” to purchase unimproved farmland. The original plan was to create an unincorporated land buying agency of the ITA and government, the South Central Kentucky Regional Development Authority. The banks loaned the Authority funds to tide them over until the court approves the $25 million bond issuance. Presumably, the loan was secured by conditional deeds to purchased land. The collateral value of the land now may be in question if there is no market demand, and the risk is unacceptable to loan portfolio examiners or risk insurance providers. The ITA reported that most of the $6 million is spent, but has refused to release its federal income tax statement until after the election in November. The bond issuance appeal filed by Joey Roberts continues to work its way through the court of appeals. Curious financial maneuvers and critical information holdback by the ITA and its supporters raise challenging questions: · Why does the ITA follow a pattern of hiding the economic bad news and promoting purely speculative projections of hoped-for Transpark demand? · Is the future of the Transpark and its airport to be characterized by past dodging, denying, downplaying, and deceptive dismissal of all adverse risks repeatedly detailed in scientific and economic expert reports? · Can demandless marketing work when precedent from similar multi-modal industrial parks on even more easily developed non-karst terrain in North Carolina and Illinois clearly warn of a bottomless sinkhole of risk, debt, and financial failure? · Would any company relocate to the Transpark and its airport, given the fatal environmental and economic risks that prudent investigation reveals? · Can dividing the Transpark project into successively smaller phase “bitter pills” justify the expenditure of $100 million or more of public funds, or even $25 million of bonded indebtedness? · Isn’t it cynical and dishonest to stick the taxpayers by funding an airport to replace an underutilized airport in which no private enterprise would invest, and for which no revenue stream can be identified? Conclusion: Very
Risky, Indeed!
The proposal to build a replacement airport eight miles from Bowling Green to enhance the sale of Transpark properties is an unjustifiable expenditure of scarce public funds at a time when the U.S. economy is in a tailspin. KEEP has identified four fatal risks to the project. Each alone condemns the project as unrealistic, unnecessary, financially unjustified, and probably illegal. Airports should not be built on flood-prone land, Airports should not be built on unstable land. Airports should not be built where the threat to a major national park looms and the threat to the aquifer is demonstrated. Airports should not be built with taxpayer funds when there is no demonstrable demand, nor even anticipated demand based on market research. KEEP believes that the Transpark project and its airport are economic wishful thinking. It is one more boondoggle, like the $90 million North Carolina Global Transpark which has yet to attract a single industrial job. Indeed, the FAA is asking North Carolina to return its $33 million, because the project has no demand and is unfinished. Some political leaders in Warren County support the replacement airport project, but the general public does not. There is insufficient demand to justify any scheduled passenger air service, even using “uneconomic” small feeder aircraft, according to past history and the Risk Analysis. Political leaders decry the unsafe absence of a control tower at the present airport, but make no provision for one at the proposed new airport. Fire safety at the proposed new airport is all but ignored. The expert consultant’s warning that a runway collapse is far more serious to life and property than a Dishman Lane collapse was omitted from the Risk Analysis. The ITA’s attempts to make the Risk Analysis appear favorable continues the pattern of disregard for public safety, arrogance and greed in financial irresponsibility, and overt engagement in investor deception that created the four flaws described above, fatal to plans for an airport and Transpark at this location. Appendices A. Roger W. Brucker, KEEP steering committee, “Vocabulary and Meaning Unique to the Risk Analysis: Reader Beware!” B. Photographs of potential for flooding and collapse: KY TriModal Transpark airport area, Bowling Green, and Dishman Lane. C. Dr. Ralph Ewers, karst expert. Comments on Quinlan, Ewers, Ray dye trace research. D. Larry Kiernan, FAA. Memo, June 6, 2001. E. Tom Aley, karst expert. Comments in full from “Risk Analysis.” F. Dr. Barry Beck, karst expert. Comments in full from “Risk Analysis.” Appendix A
Roger W. Brucker, KEEP steering committee
“Vocabulary and Meaning Unique to the Risk Analysis:
Reader Beware!”
Vocabulary and
Meaning Unique to the Risk Analysis:
Reader Beware!
Roger W. Brucker The authors of the Risk Analysis use ordinary words, such as demand, reasonable, risk, and validate in non-dictionary ways that may confuse readers. It is useful to examine some of the words for insight into the thoroughness and validity of the Risk Analysis. In theory, the purpose of a Risk Analysis is to provide prudent readers and potential investors with a dispassionate and realistic understanding of proximate and potential financial uncertainties, both fatal and secondary. Absent realism, a Risk Analysis becomes a sales promotion document, lulling even prudent readers into a false sense of security. Our KEEP review indicates that the sales function is paramount in the Risk Analysis for the replacement airport. Demand. Demand is an economic and marketing term used with rigor in those disciplines. Not so in the Risk Analysis. In the business world, demand is widely understood as needs plus wants coupled with the ability to buy: demand for a product or service is the demonstrated willingness for buyers to pay for it. The measurement of actual past and present demand is accomplished through financial accounting. A fiscally responsible company asks, “How much did we sell and how many dollars did we receive?” This process helps to measure and anticipate demand. However, the Risk Analysis lumps together real demand and possible future demand, without distinction. Thus in fact it is speaking about hoped for revenues, anticipated money, expected funds, and projected results. These are forecasts, educated guesses. To make educated guesses, economists and marketers combine historic demand data with market research to try to reduce the risk that predicted future revenues will be no more than wishful thinking. It is widely understood that past performance is not indicative of future results. There is no indication in the Risk Analysis that even this basic level of research has been carried out in support of the very optimistic demand and revenue statements claimed for a replacement airport. For example, some of the cost-benefit data accepted in this Risk Analysis is based on U.S.-wide trends of 20% increased demand per year, experienced during the halcyon economic days of the 1990s, never achieved since, and never at the present Bowling Green Airport. Of course, most financial and business experts will admit that they have never seen a pessimistic spreadsheet from someone seeking funds. Reader – and investor – beware! The result of lumping real and future possible demand in the Risk Analysis is that unsupported and generalized hopes for a now bygone era of U.S. economic growth are presented as real demand for the Bowling Green area. No competent company builds a plant on the basis of informal guesses about possible future demand! Instead, such a company requires that future demand be predicted using a methodical investigation of actual customers’ future needs and wants. No market research has been undertaken by the ITA to justify the proposed $100 million Transpark or its $34 million airport. The pages of KEEP Perspective #2 examine the shaky foundation on which some of the reported demand hopes rest, and the folly of relying on unsupported trend projections when making major financial decisions. Reasonable. Several members of the Expert Review Panel selected to comment on the Risk Analysis termed it reasonable. The generally understood meaning of this word is, “based on fact or logic,” or sometimes, “not expensive”. However, a reading of the Risk Analysis shows that this document’s use of reasonable is defined as “reasons were provided by the sponsor”. There is no regard for the facts or logic. Risk. Any analysis of risk is a study of potential losses. This is the case in the Risk Analysis, where the concern about potential loss is focused on the money that would be lost in the event of circumstances that prevent or restrict the desired final outcome, and that would result in unanticipated expenses or investment loss. Some risks can prevent achieving any part of a final outcome. They are called fatal risks because any one of them can kill a project. Other secondary risks can result in sub-optimum attainment of desired project objectives, or can increase costs beyond the budget.
In the Risk Analysis, the final outcome envisioned by the study’s sponsor, the ITA, is a fully functioning airport eight miles from Bowling Green that not only replaces the present airport, but also offers additional capabilities. Among the desired improvements would be a longer runway to accommodate larger aircraft. Examples of fatal risks in the situation under review include the possible failure of the FAA to approve a greenfield airport on a floodplain, as prohibited by law. Other examples include encountering insurmountable bedrock collapse events that terminate air operations, and a major nationwide economic crisis that makes unavailable funds earmarked for debt service. Fatal risks do not simply diminish the desired outcome. They can entirely prevent achievement of any portion of the desired goals. If sinkholes develop in the runway during air operations, the loss of life and potential damage could result in closure of the airport to air operations and expose the sponsors to ruinous financial penalties through litigation judgments. The fatal risks found in the Risk Assessment are discussed in detail in KEEP Perspective #2. Secondary risks, listed as bullet points, can raise the actual cost above available revenues, and stretch out the project for years beyond the date anticipated for commencement of operations. For example, the FAA, in an internal memo (Appendix D) that led to the funding of this Risk Analysis, observed that the proposed replacement airport is more likely to cost $150 million, rather than the $30 million proposed by the sponsor. To further warn of looming fatal and secondary risks, it needs to be pointed out that that memo was based on comparable airport construction costs for an airport not located on karst topography. Validate. To validate, in the dictionary sense of that word, is to prove in a way that cannot be objected to because it conforms to law, logic, and the facts. A validated financial statement conforms to the generally accepted rules of accounting and has been subjected to audit tests of fact for verification. Even though this process is being reexamined in the wake of recent Enron, WorldCom, Tyco, Xerox, etc. wrongdoing, most people believe one should be able to trust audited financial statements. However, the word validate has a special meaning as used in the Risk Analysis. It means previously published. Various data are described in the Risk Analysis as being validated, when what is in fact meant is that these projections have appeared in previously published benefit analyses issued by the sponsor and its consultants. In other words, previously published guesses, often based simply on wishful thinking, are termed verified merely because they have been previously printed in documents printed by the consultant and sponsors! This astonishing use of the English language occurs numerous times throughout the document. Appendix B
Photographs
of potential for flooding and collapse: KY
TriModal Transpark airport area, Bowling Green, and Dishman Lane.
Fig.
1. Caution: “High water possible” sign located just east of the proposed airport
runway. 2002.
Fig.
2. Flooded sinkholes, near the north end of the proposed airport runway. 2002.
Fig. 3. Fred Madison Road
Landfill. The
south end of the proposed airport runway would extend from the landfilled area,
to the left (north). Note water-filled sinkholes in the immediate area, and the
surface drainage to a sinkhole in the upper left (to the east). Note numerous
other sinkholes in the area, wooded and cleared. 2002.
Fig.
4. Surface drainage to sinkhole in the field immediately to the east of that in the
previous photo. This area is proposed for industrial development as part of the
TriModal Transpark, and would be immediately adjacent to the airport runway
area. 2002.
Fig
5. “Danger
High Water Area”: Residents of the Bowling Green area are VERY familiar
with the problem of chronic flooding! Eastwood Baptist Church. 2002.
Fig.
6. Flooded Bowling Green shopping center parking lot. Fairview Plaza. 1990s.
Fig.
7. Following a heavy rain, the Bowling Green area is decorated with hundreds of flooded sinkholes,
neighborhoods, parking lots, homes, businesses, and roadways. 1990s. B. COLLAPSE
Fig.
8. Lovers Lane soccer fields, Bowling Green: Two drains in this new recreation complex
have collapsed and been refilled and reconstructed twice during 2002. A large
concrete slab has shattered, due to voids opening up beneath it.
Fig.
9. The tip of the iceberg at Lovers Lane: If these collapses cannot be controlled at
new facilities on a small scale, using the latest techniques, how can an
airport runway and industrial park possibly be contemplated?
Fig.
10. The Dishman Lane collapse of February 2002 on the south side of
Bowling Green is now notoriously synonymous with bad planning and high costs in
karst, and with the unpredictability of destructive and dangerous karst
collapses. 2002.
Fig.
11. The Dishman Lane collapse, February 2002.
Figures
12, 13. Details of the Dishman Lane collapse, February 2002.
Fig.
14. Dishman Lane repair work, August 2002.
Figures
15 and 16. State Trooper Cave revealed: Work on the Dishman Lane collapse, in early (above)
and late (below) September 2002.
Conclusion: There is no right way to do the wrong thing. Karst flooding, pollution and collapse cannot be foreseen, leading to expensive and dangerous outcomes. This high-risk site is not suitable for airport or industrial park construction. Appendix C Dr. Ralph Ewers, karst
expert Comments on Quinlan, Ewers,
Ray dye trace research. Statement from
Prof. Ralph Ewers regarding the basin boundaries dye trace research published
as Quinlan and Ewers (1981) and Quinlan and Ray (1981). Date: Wed, 29 May 2002
17:56:45 -0400 From: "ewc" ewc@mis.net To: "michael.may"
<michael.may@wku.edu>, "chris.groves" <chris.groves@wku.edu>,"kenneth.kuehn"
<kenneth.kuehn@wku.edu>, "fredcaver" <fredcaver@aol.com>,
"Lynn & Roger Brucker" <brucker@graphtronics.net>,
"strobus" <strobus@graphtronics.net>, "strobus101"
<strobus101@yahoo.com> CC: <nicholas.crawford@wku.edu> To all concerned, I was only made aware of
this evening's meeting a few hours ago.
I would appreciate having this e-mail message being made a part of the
record, and I request the opportunity to expand, at some future date, upon my concerns. I recently received from Dr. Crawford a copy
of his report "Site evaluation and design assistance for the proposed
Kentucky Trimodal Transpark, Preliminary Report." I have given this report a review and I am
formulating a formal written report.
The comments below are a brief summary of my principal concerns. I worked closely with Dr.
James Quinlan and Mr. Joe Ray during the tracing efforts that were the basis
for the Quinlan and Ray map. This is
the map and the data upon which Dr. Crawford based most of his "Preliminary
Report." My studies of the hydrogeology of Mammoth Cave region began more
than 25 years ago, and a number of my former graduate students have done thesis
research there. My principal concerns are
these: 1- The most important
question relative to the data underpinning Dr. Crawford's analysis has not
been asked. That question is: What is
the quality of the tracing data
on which the Quinlan and Ray map is based? Though this work is a
monument to Dr. Quinlan and to Mr. Ray, it must be born in mind that it was
collected in a pre-instrumental era of dye tracing by then state-of-the-art
methods. Visual determinations of dye
eluted from charcoal samplers were used.
If tracing were done today from all of the input points on that map,
using present methodologies, the results would undoubtedly be different. I am confident that the gross aspects of the
groundwater basins would remain, but many more inter-basin connections would be
revealed, and basin boundaries would change and become less distinct. Thus, the
reliance upon data from this era poses a special, and probably unacceptable
risk, where Mammoth Cave National Park is at issue. 2- There is a real
possibility that some of the traces shown on the map were completely
misinterpreted because of the nature of the two dyes that were most commonly
used in the study, fluorescein and rhodamine-WT. The rhodamine dye undergoes degradation by de-amino-alkylation,
probably through biological agencies.
When this occurs, the red rhodamine dye is changed to a fluorescent
green dye that is indistinguishable from fluorerscein except by the most modern
analytical techniques. This degradation
product was unknown at the time of the Quinlan-Ray study. Therefore, some of the basin boundaries may
be erroneous. 3- The Hagen well, which is
a pivotal point in Dr. Crawford's analysis of the potential for flow
reversals, was a private water supply well, not a well driven into the master
conduit system. The monitoring points
to the west in the Graham Springs Basin are so positioned. Thus, the Hagen Well gives absolutely no
assurance that it represents the true elevation of the groundwater divide. The true level may be significantly lower
and more easily overcome. Indeed, all
of the wells in the upper potions of the Graham Springs Basin suffer from this
same problem. They represent water
levels only in the immediate vicinity of the well. A thesis study by a former graduate student, David Johnson,
confirms the truth of my analysis. 4- The north boundary of the
Graham Springs Basin and the western boundary of the Turnhole Spring Basin are
completely unknown where they extend beneath the caprock of the Chester Cuesta
(Dripping Springs Escarpment). Without the most rudimentary knowledge of this
region it cannot be said that flow reversals created by even modest rainfall
events do not cause groundwater exchange between these basins, and into Mammoth
Cave. 5- Among the important
non-hydrogeologic considerations is the increased traffic of hazardous
materials that the transpark would cause through the areas that are known to
contribute groundwater to Mammoth Cave National Park. Frequent spills are a problem there already. Additionally, the presence of the transpark
will only engender similar development adjacent to its eastern boundary with
increased likelihood of groundwater contamination to the national park. The proverbial camel will have it's
proverbial nose under the tent. Ralph O. Ewers Ph.D.
Registered Professional Geologist Director, The Groundwater
Research Laboratory Department of Earth Sciences Eastern Kentucky University Richmond KY and Graduate
Faculty, University of Kentucky Appendix D Larry Kiernan, FAA. Memo, June 6, 2001.
Bowling Green Airport Proposal There is a problem
apparent in the financial statistics included in studies that have been done
for the proposed airport. The costs appear to have been grossly underestimated
and the sources of funds appear to be optimistic. The site evaluation
study called for a runway 11,500 feet by 150 feet, with a parallel taxiway 75
feet wide. The study estimated the construction cost as $15.5 million. However,
experience at other airports suggests that the cost should be closer to $100
million. The best comparable recent development was the new Northwest Arkansas Regional
Airport, with a runway 8800 feet by 150 feet, which cost $107 million. Much
higher costs were encountered in converting Bergstrom AFB to civil use ($585
million) and making Scott AFB available for joint-use ($313 million). In
comparison, the business plan indicates that the Bowling Green airport would
cost about $28.5 million to develop (page5-Surnmary Table). A plausible
estimate for Bowling Green airport would be $100 million to $150 million. The source of local
funds is largely based on land sales that are expected to generate $24.6
million from the industrial park and $17.4 million from sale of the existing
airport. There is no evidence that a buyer has been identified, so this appears
to be a very risky source of funds. The project is
intended to attract jobs and strengthen the local economy, but it appears that
it could have the opposite effect, generating huge debt and little revenue. We recommend that the sponsoring agency conduct an unbiased risk assessment study in order to obtain an independent and well-informed opinion regarding project feasibility.
Appendix E Tom Aley, karst expert Comments in full from “Risk
Analysis.” OZARK UNDERGROUND LABORATORY 1572
Aley Lane Protem,
MO 65733 (417)
785-4289 f
ax (417) 785-4290 oul@tri-lakes.net Landrum and Brown, Inc. 1279 Cornell Park Drive Cincinnati, OH 45242 RE: Risk Analysis Study, Proposed ITA Bowling
Green, Kentucky Airport Dear Mr. Arthur: Enclosed is a 14 page report on my investigations. I realize that the documentation is greater than either of us anticipated, but I think you will be able to derive the information you need. In preparing the material I became convinced that the level of explanatory information I have provided was necessary to support my conclusions relative to financial risk. There is a major data gap in the ITA reports in that they do not consider whether or not the proposed airport would or could be located outside of the 100 year frequency flood plain. FAA policy dictates that such a location is necessary. Sinkhole plain areas such as the proposed airport area are characterized by having substantial amounts of areas within the 100 year floodplain. The ITA’s implicit assumption of no flooding that would impact the airport has no validity whatever. In my opinion, our risk analysis cannot be completed until 100 year floodplain locations are identified and it is clear that an airport with federal funding could be built at the proposed location or one of the two identified alternates. The following comments relate to the First Draft, February 2002 document for expert panel review. Page 1, bottom two lines. Because of the flooding issue, pending the necessary data, the selected site may or may not be economically reasonable. My work indicates that some other project costs need to be increased. Page 2, second full paragraph. The wording of this paragraph needs to be changed to remove the words “is not present”. In addition, flooding is an environmental risk which, from a fiscal standpoint, mayor may not be mitigatable at the proposed site. A determination of this issue must be determined during the risk analysis and cannot credibly be deferred until work for an Environmental Impact Statement.
Page 2, bottom paragraph. “The community views a commercial/industrial setting for the new airport as a positive factor to eliminate future noise, safety, and other potential complaints...” Recognize that a commercial/industrial setting increases groundwater contamination risks to the groundwater in an area which can impact federally listed endangered species. Increased runoff from commercial/industrial settings also increase the risk of airport flooding problems. Page 6, fourth bullet. The developments will not necessarily be hydrologically compatible. Page 6, basic project requirements. Need to include runway settings that are fully compatible with FAA policy, and specifically, outside of the 100 year floodplain. This needs to be done before we can complete the risk assessment. Page 3 of Introduction. Notes on karst topography. This needs to
be replaced with a more accurate
description. Karst is a three-dimensional landscape developed on and in a soluble rock unit where there is appreciable groundwater movement along preferential flow routes which have been dissolved out of the bedrock by groundwater. A few karst areas, such as the region in and around the proposed airport, are sinkhole plains where most or all of the water leaving the area moves through the groundwater system and discharges from a spring or springs which may be many miles away. Karst areas commonly have unique environmental conditions which impact upon land use practices and construction activities. Groundwater contamination can occur readily in karst areas, and the subsurface commonly provides ineffective natural cleansing for contaminants which enter the ground. Some karst groundwater systems provide habitat for federally listed threatened and endangered species; the Kentucky Cave Shrimp is an example. Other karst groundwater systems are utilized by private and public water systems which lack any alternate water supplies. Many sinkhole plain areas are prone to flooding, especially when land use changes such as urbanization increase the quantity and rapidity of storm water runoff. Land subsidence and catastrophic sinkhole collapses occur occasionally in some karst areas and commonly in other karst areas. These collapses can damage or destroy structures, rupture water and sewer lines, destroy impoundments, and sometimes introduce large quantities of pollutants into the groundwater system. Approximately 20% of the United States is karst, and approximately 40% of the nation east of a line through Tulsa, Oklahoma is karst. Approximately half of Kentucky is karst. Many people live in karst areas, and much construction occurs in these areas. The sensitivity of karst areas to environmental problems varies dramatically, with areas around Bowling Green area among the more sensitive. Tailoring land use practices and developments to site-specific karst conditions is critical if natural resources, human health and safety, and man-made structures are to be protected. I hope these comments are of help. I have now expended my budget, and
the budget will need to be increased if I am to do any additional work. I will send you a
hard copy of this letter and the memo report by mail. Sincerely,
Tom Aley Ozark Underground Laboratory, Inc. OZARK UNDERGROUND
LABORATORY 1572 Aley Lane Protem, MO 65733 (417) 785-4289 f ax (417) 785-4290 oul@tri-lakes.net March 4, 2002 Memo to: Mr. Bob Arthur, Landrum and Brown Inc., 11279 Cornell Park Drive, Cincinnati, OH 45242
From: Thomas Aley, Hydrogeologist and President,
Ozark Underground Laboratory Inc. Kentucky Registered Professional Geologist
No.1541. Subject: Bowling Green-Warren County Regional Airport. Input to the Risk Analysis Study on Karst, Hydrology, and Endangered Species Issues. Introduction
For my work on this panel I have: s Reviewed all of the documents that were sent to panel members. s Reviewed other reports and studies conducted in the area, and particularly the results of groundwater tracing investigations conducted by Joe Ray and the late Dr. Jim Quinlan. s Visited the site and interviewed various persons including Mr. Dan Cherry, President of the ITA; and Dr. Nick Crawford, Dr. Kenneth Kuehn, Dr. Michael T. May, Dr. Chris Groves, and Dr. Albert Meiner of Western Kentucky State University. s Discussed records of endangered species in the area on the phone with Mr. Rob Tawes, U.S. Fish and Wildlife Service, Cookeville, Tennessee. s Utilized my previous karst experience in the region and elsewhere. Organization
of this report
This report is divided into the following four major sections: s Major data gap s Invalid and/or unreasonable assumptions and/or conclusions. s Actions to prevent or mitigate identified deficiencies and their costs. s Summary. Major
Data Gap
Prudent land use and public facility planning require that features such as airports not be subject to periodic flooding. In addition, FAA policy is that runways be located out of the 100 year frequency floodplain. In a sinkhole plain area, such as the proposed airport site, hundred year frequency floodplains comprise most of the area on the floors and lower sides of sinkholes. The Inter-Modal Transportation Authority, Inc. (ITA) reports fail to delineate any appropriate interval (such as 100 year interval) floodplains relevant to the proposed airport site. This is a major deficiency. Until such data are developed it is my conclusion that the financial risk assessment for the project cannot be completed. The proposed airport site is within a sinkhole plain. The karst groundwater system in the area is primarily a system of finite conduits which provide relatively little water storage. During storm events the only appreciable water storage in a sinkhole plain area is within the sinkholes themselves. Under most conditions floodwaters from the area enter the karst groundwater system through sinkholes and other karst features. The floodwater are then transported laterally through the subsurface in localized natural conduits (caves) to a spring or springs. In the case of the airport site the area drains through the karst groundwater system to Graham Spring (about six miles away) and a nearby (but relatively minor) spring (Quinlan and Ray, 1989). Under major stormflow and urbanized conditions backflooding from the Barren River and water introduced into the subsurface in the region between the airport and the spring must be expected to greatly reduce (or even preclude) the ability of the lateral karst conduits to transmit water from the airport site to the springs. In addition, under major stormflow conditions, water derived from areas upgradient of the airport site may discharge to the surface in the airport area through some of the lower elevation sinkholes and inundate the area even more extensively than might otherwise be expected. One way of mitigating sinkhole flooding is to construct surface stormwater channels which convey the stormwater to surface streams. The feasibility of such a strategy to serve the proposed airport could be investigated, but costs are likely to far exceed the ability of the project or the area to finance such construction. The impacts of urbanization on stormwater flows in sinkhole plain areas is often not well appreciated by the public until homes, businesses, and infrastructure features encounter periodic flooding. Aley and Thomson (1981) developed water budget data for a sinkhole plain area in Springfield, Missouri and found the following ratios for mean annual total water yield for various intensities of development. The ratios indicate how much more water per year each intensity of development yields as compared with forest and grassland conditions characteristic of the area. s Suburban housing; 1.48 to 1.69 (mean 1.59). s City housing (single family); 1.69 to 1.90 (mean 1.80). s Apartments with business; 1.90 to 2.27 (mean 2.08). s Industrial and commercial; 2.27 to 2.53 (mean 2.40). The suggestion that areas with minimal sinkhole flooding under rural land use conditions are probably not going to experience serious flooding is specious. This is effectively illustrated by the above data. Furthermore, stormwater runoff from urban areas yields much higher peak flows than those generated by rural land uses. This enhances sinkhole flooding problems. The data gap for the proposed airport should be addressed by delineating the areal extent of anticipated flooding in and around the airport site during a 100 year frequency storm event. I recommend that such a delineation be based upon the following assumptions: s At a minimum, precipitation should be equal to the 24 hour duration 100 year frequency storm event. For this area that would equal about 6.5 inches, but a value derived from National Weather Service records should be used.. s That the ground is saturated prior to the storm event, and that all precipitation is yielded as storm flow. s Due to down-gradient existing and anticipated urban development it should be assumed that the down-gradient karst conduits cannot transmit any of the stormwater runoff from the airport area. s That there is no available subsurface water storage capacity prior to the start of the storm. In addition, the possibility that water derived from up-gradient areas might discharge upward through sinkholes that would impact the airport area should be evaluated and appropriately addressed. Once the extent of flooding is delineated, the feasibility of constructing an airport where all facilities would lie an adequate distance above flood crest elevations would then need to be evaluated. My concern is that such an airport in the proposed area would require far more earth work and much greater expense than the initial cost projections envisage. The availability of adequate fill material within reasonable haul distances may also be a major project limitation with significant fiscal implications. Ensuring that airport runways are outside of the 100 year frequency floodplain may make alternate runway locations more viable than the one which has currently been selected. Until floodplain data are developed and integrated into the project cost estimates it is my conclusion that the financial risk assessment for the project cannot be completed due to the absence of fundamental data. Invalid
and/or Unreasonable Assumptions and/or Conclusions
The ITA studies recognize that the proposed airport is located in a karst area, and a statement is made to the effect that about 20% of the United States is karst and that about 40% of the United States east of Oklahoma is karst. Statements are made that much construction occurs in karst areas and that engineers are familiar with karst related conditions. These statements are true, yet the ITA reports do not appear to recognize the extreme diversity of conditions which occur in karst areas. As an illustration, many karst areas have very few sinkholes and have well integrated surface stream channels which transport most of the stormwater runoff. In contrast, the proposed airport site and almost all lands within several miles of the site have abundant sinkholes and lack a network of surface stream channels. As a result, flooding problems are much greater in areas such as the proposed airport than in most other karst areas. As another illustration, sinkhole collapse is a common and expensive problem in this region of Kentucky. In contrast, it is a much less significant problem in most karst areas. The proposed airport site sits in a sinkhole plain which is atop a karst aquifer characterized by rapid groundwater movement and ineffective natural cleansing processes. This hydrologic setting, combined with the proximity of the proposed airport site to Mammoth Cave National Park and to known habitat for aquatic species which are federally listed as endangered, places an enhanced burden of care on all facets of a development with federal funding. There is no evidence that such an enhanced burden of care has been recognized by ITA’s consultants in the work which they have conducted. It is noteworthy that much of the opposition to the ITA program appears to be rooted in the public perception of the necessity for this enhanced burden of care. Relative to issues in my field of expertise, there are seven invalid and/or unreasonable assumptions and/or conclusions made in the documents prepared for the ITA. Some of these are clearly identified while others are implicit. These assumptions and conclusions have the effect of under-stating the environmental risks posed by the proposed airport and therefore under-estimating the resulting financial expenditures which will be needed to prevent, minimize, or mitigate these risks. In the following numbered sections I have identified and discussed the seven invalid assumptions and conclusions (which I identify as “issues”). Strategies and costs for preventing, minimizing, or mitigating the identified issues are included in the third section of this report Issue 1. The ITA reports clearly demonstrate an inaccurate understanding of groundwater movement in the karst aquifer system of the region. Quinlan and Ray (1989) produced a map of groundwater basins in the Mammoth Cave region which showed, among other things, groundwater flow routes (alternately called flow paths or trunk drainage paths). The locations of these flow paths are based upon results of groundwater tracing studies and water level information from private wells. These are inferred and generalized locations rather than finite locations; this can readily be seen when one compares the flow routes with mapped cave passage locations on the Quinlan and Ray (1989) map. Unfortunately, the ITA reports use these flow paths as finite locations without due regard to their generalized, inferred, and diagrammatic nature. Of critical importance, the ITA reports assume that lands immediately over the flow routes have potentially greater impacts on groundwater quality and cave fauna than is the case for lands further from the flow routes. This is not a credible inference. As an illustration, page 6 of LawGibb report of February 2, 2001 recognizes that “any development plan must protect the primary surface connections of these flow-paths from impacts due to: s Potential releases from planned underground utilities; s Potential releases from surface sources; s Siltation (soil in-filling) and loss of cross section due to construction activities; and s Inundation due to excessive surface water inflow caused by change in surface cover and infiltration characteristics”. The surface connections of concern to LawGibb are karst features such as sinkholes. Page 12 of the LawGibb’s report says that significant “no build” buffer zones should be provided around any sinkhole or karst feature that is directly connected to any of the three trunk drainage conduit routes (as shown on the Quinlan and Ray [1989] map). They further state that “no build buffer zones” are expected to be 250 to 500 feet around the karst features. The karst groundwater system in the proposed airport area is a semi-dendritic system of natural underground conduits which have been dissolved out of the limestone by passing groundwater. The underground conduits generally converge in a downgradient direction, but reversals in flow directions and divergent flow in some conduits should be anticipated under some conditions (Quinlan and Ewers, 1981). Of critical importance is the fact that the conduits do not provide effective natural cleansing for the waters which pass through them, and conduits which may exist in one of the mapped flow routes are neither more nor less prone to contaminant introduction and transport than are conduits located more distant from one of the mapped flow routes. A major consideration that the ITA consultants used for locating the proposed airport was to keep runways and other structures away from any of the flow routes shown on the Quinlan and Ray (1989) map. As indicated above, this strategy has neither technical credibility nor technical merit. Furthermore, if “no build buffer zones” of 250 to 500 feet were to be established around the karst features which directly connect with the underground drainage conduits (as suggested in the LawGibb report), the vast majority of the proposed airport site would be in buffer zones and no runway could be threaded through the assemblage of buffer zones. The entire proposed airport area poses potential water quality threats to the groundwater system and to aquatic life dependent upon that water. The use of buffers around sinkholes in the area is not a viable strategy since it would preclude the construction of a runway. The most viable alternate strategy is to ensure that all waters derived from non-vegetated surfaces and entering the groundwater system are of adequate quality for protecting the aquatic fauna in the groundwater system and for protecting the aquatic fauna in Barren River downstream of Graham Springs (which drains the proposed airport area). Issue 2. The ITA reports fail to recognize crucial characteristics of
the Lost River Chert. Among other things, these characteristics are directly
related to risks of land subsidence and catastrophic sinkhole collapse. The Lost River Chert is an essentially insoluble rock unit which separates the overlying Ste. Genevieve Limestone from the underlying St. Louis Limestone. The thickness of the Lost River Chert in the vicinity of the proposed Alternate T runway aligrnnent is on the order of 5 to 10 feet. While water can pass through the Lost River Chert and enter the underlying karst groundwater system, the widths of the fractures within the chert are typically not great enough to permit the passage of most soil-sized particles. Areas such as Alternate T which are underlain at relatively shallow depths by the Lost River Chert typically have a more subdued sinkhole plain topography than is the case for areas where the chert is absent. A sinkhole study conducted by the ITA consultants divided the Yellow
Study Area into four quadrants. The majority of quadrants 1 and 2 were
underlain at shallow depths by the Lost River Chert while the chert was absent
from the majority of quadrants 3 and 4. The ITA study, which was apparently
based upon a study of topographic maps, indicated that sinkholes in quadrants 1
and 2 were laterally larger than those in quadrants 2 and 3, but that sinkholes
in quadrants 1 and 2 represented a smaller total acreage. Although not identified in the ITA reports, the Lost River Chert tends to impede the downward movement of water. As a result, water is perched on top of the Lost River Chert. This can be especially important during storm periods as it can result in surface flooding and/or appreciable water level fluctuations in the limestone, residuum, and soil overlying the chert. Such water level fluctuations can trigger sinkhole collapse. The ITA reports do not indicate elevations of the top of the Lost River Chert across the proposed airport site. Dr. Nick Crawford indicated to me during an interview that the distance from the land surface to the top of the Lost River Chert probably averages 20 feet at the airport site and that there is about a 30 foot variation in topography along the runway. The surface on the top of the Lost River Chert dips gently toward the north to northwest at the airport site. Issue 3. Consideration of federally listed threatened and endangered
species which might be adversely impacted by the proposed airport has ignored
some relevant aquatic species. Groundwater tracing in the area (Quinlan and Ray, 1989) has demonstrated that Graham Springs is the major groundwater discharge point for waters derived from the proposed airport site. The karst conduits which convey groundwater from beneath the proposed airport site to Graham Springs provide ineffective natural cleansing. As a result, most contaminants introduced into the karst groundwater system from the airport development will be discharged from Graham Springs into the Barren River. The Barren River downstream of Graham Springs provides habitat for at least three federally listed endangered species of mussels: the Rough Pig Toe, the Club Shell, and the Fan Shell (U.S. Fish and Wildlife Service data). Barren River is a tributary to Green River, and additional listed endangered aquatic species are also known from Green River. None of the ITA reports identify any of these species as issues which must be assessed and considered in an environmental impact statement; this is a significant omission. The ITA reports conclude that the proposed airport site would be very unlikely to impact any federally listed aquatic species. Potential impacts on the Kentucky Cave Shrimp will be discussed in Issue 4, but even if that species were not present at the airport site the mussels in the Barren River will necessitate compliance with provisions of the Endangered Species Act and will almost certainly require that any stormwater introduced into the subsurface at the airport be of better quality than now envisaged in the ITA reports. Issue 4. The ITA reports conclude that it is highly unlikely that the
Kentucky Cave Shrimp exists within the Yellow Study Area (which includes the
proposed airport). This conclusion is based upon limited data of questionable
relevance. A more reasonable strategy would be to conclude that the karst
groundwater system beneath the proposed airport site is presumptive habitat for
the Kentucky Cave Shrimp. The proposed airport site is located within the Graham Springs groundwater basin; this basin lies adjacent to the Turnhole Spring groundwater basin and these two groundwater basins share a common border for a distance of about eleven miles. The Kentucky Cave Shrimp is known to exist in the Turnhole Spring groundwater basin and in eight other contiguous groundwater basins in the region (Leitheuser, 1988). Groundwater traces have demonstrated hydrologic interactions between the Turnhole Spring and Graham Springs groundwater basins (Quinlan and Ray, 1989). In other words, some portions of the basins share water with both spring systems under some conditions. Leitheuser (1988) reports that the shrimp require deeper pools of water, as opposed to very shallow riffles, where the stream currents are minimal. The shrimp are free-swimming and unable to utilize cover such as rocks on the stream bottom. They are sometimes found in floodwater pools; they probably reach these locations when floodwater wash them out of their normal localities. Leitheuser (1988) reports that the areas inhabited by the Kentucky Cave Shrimp are typically large base level cave passages and associated tributaries characterized by slow flow, abundant quantities of organic matter, and coarse to fine grain sand and coarse silt sediments. While Leitheuser (1988) emphasizes base level cave passages, there is no reason that shrimp populations may not exist in more headward portions of the karst groundwater system where typical flow conditions and substrates are suitable for the species. The Environmental Evaluation Technical Appendix prepared for the ITA included a report by Commonwealth Technology which dealt with endangered species. Field searches for Kentucky Cave Shrimp were conducted in the vicinity of the proposed airport at Mill Cave and Wolf Sink and Cave by the Western Kentucky University (WKU) Center for Biodiversity. The Commonwealth Technology report did not document the man-hours of effective search time, number of search trips, or other similar information normally associated with professional biological investigations. Additionally, the report notes that typical substrates that were searched by the WKU faculty and students consisted of soft silt substrates which the authors suggested might be the result of farming in the overlying sinkhole plain. The cave passages searched by the WKU group are in portions of the St. Louis Limestone from which the overlying Lost River Chert has been eroded away. The Lost River Chert tends to protect underlying cave passages from the vertical influx of sediments. The proposed airport lies above the Lost River Chert, and karst groundwater system beneath the proposed site would be expected to have substrates more conducive to the Kentucky Cave Shrimp. This difference brings into question the credibility of concluding that a limited search of unfavorable habitat can be used to conclude that a species is “highly unlikely to be present” in more suitable habitat located nearby. As an illustration, not seeing any mountain lions during a few trips into downtown Denver does not indicate that such animals are “highly unlikely to be present” in the adjacent Rocky Mountains. To minimize financial and scheduling risks to the project the information summarized above indicates that the groundwater system beneath the proposed airport should be considered as presumptive habitat for the Kentucky Cave Shrimp. As a result, design and development of the airport facilities should be consistent with providing adequate protection for this species as well as for other listed species. The strategy of presumptive karst aquifer habitat for federally listed aquatic cave fauna has been used at the Northwest Arkansas Regional Airport near Fayettevi1le, Arkansas. A strategy in the ITA reports of concluding (based on limited data of questionable relevance) that Kentucky Cave Shrimp are highly unlikely to exist in the Graham Springs groundwater basin poses a significant risk to the proposed development if (or when) shrimp are found in locations which would be impacted by airport activities. Issue 5. Stormwater treatment plans as outlined in the ITA reports are
prone to failure and are likely to be viewed by the U.S. Fish and Wildlife
Service during the required Section 7 consultation as inadequate to protect
groundwater quality and associated aquatic endangered species. Treatment of stormwater drainage from the airport and adjacent commercial and industrial developments is discussed in general terms in the ITA reports. The reports envisage storm water detention ponds, possibly some constructed wetlands, and passage of runoff water through sand filters into sinkholes. Stormwater detention ponds in sinkhole plain areas often experience sinkhole collapses either in the ponds or sometimes on adjacent lands tens or sometimes hundreds of feet from the ponds. As an illustration, a stormwater detention pond at the General Motors plant in Bowling Green experienced numerous sinkhole collapses within the pond area. Sinkhole collapses during storm events can introduce very poor quality water which may cause mortality of aquatic organisms such as the shrimp in the associated karst aquifer. Mitigation of land collapse and water quality problems requires that the detention ponds be located on relatively stable sites which have received thorough site investigations; in a sinkhole plain, suitable sites are rare and are not necessarily located in convenient locations. The ITA reports do not indicate that stormwater detention ponds would be appropriately investigated and located. Karst areas are poorly suited for constructed wetlands due to the rapid movement of water from the surface into the groundwater system through localized flow routes. Liners are sometimes used in an effort to prevent this leakage, but failure of liners due to various processes including subsidence or collapse is a common occurrence in karst areas. Maintenance and repair costs of such liners are commonly substantial. Reliance on constructed wetlands for storm water treatment at the proposed airport is unlikely to be a viable option. The quality of stormwater runoff from airports and other commercial and industrial developments is similar in many respects to raw municipal sewage. Sand filters remove some of the suspended load in the stormwater runoff, but are of minimal value in removing other contaminants of concern such as hydrocarbons and deicing compounds. Strategies such as peat/sand filters and basins specially constructed to retain spills have been used along highways in karst areas of Indiana and Texas to provide better treatment for storm water runoff prior to permitting it to enter sensitive groundwater systems. Regardless of the strategy employed, reliance on constructed wetlands and sand filters for storm water treatment is unlikely to be an acceptable strategy for the proposed airport location. The recently constructed Northwest Arkansas Regional Airport is located in a karst region with few sinkholes near Fayetteville, Arkansas. The airport lies atop presumed aquatic habitat for the federally threatened Ozark Cavefish (Amblyopsis rosae). To ensure protection of the water quality for this species the airport has designed and installed a storm water system which collects the first half inch of stormwater runoff from paved surfaces and roofs and conveys this to containment ponds. Urban stormwater studies have commonly demonstrated that the vast majority of contaminants of concern are flushed from paved surfaces with the first half inch of runoff. The water in the ponds is tested to ensure that it is of adequate quality before it is discharged to surface stream channels which recharge the karst groundwater system. Issue 6. Under some hydrologic conditions part or all of the airport
site may contribute groundwater to springs other than Graham Springs. If
hydrologic work in progress demonstrates that this is the case,
additional risks posed by the airport development would need to be addressed. Western Kentucky University’s Center for Cave and Karst Studies is conducting groundwater tracing work to help determine if water from the proposed airport might occasionally flow to springs other than Graham Springs. This work was prompted by concerns that there could be water movement into Mammoth Cave National Park. Based upon the map by Quinlan and Ray (1989) such flow is unlikely. However, this map suggests that flow into the Poorhouse Spring basin might occur under some conditions. It is my understanding that this spring is used as a public water supply and may serve a population on the order of 1,000 to 2,000. If it were found that water introduced into the ground at the proposed airport site could at times reach Poorhouse Spring the airport impacts would be mitigated by ensuring that stormwater runoff was adequately treated prior to introduction into the groundwater system. Issue 7. The risks of land subsidence or catastrophic sinkhole collapse
at the airport site are great enough to warrant far more attention than they
have received in the ITA reports. The ITA reports recognize that land subsidence or catastrophic sinkhole collapse are common occurrences in karst areas. These problems are especially prevalent in sinkhole plain areas (such as the proposed airport site) and in areas where human activities significantly alter the water regimen by one or more of the following actions: s raising water table elevations, s lowering water table elevations, s increasing the extent and/or frequency of water table fluctuations, s increasing the extent and/or frequency of sinkhole flooding, s introducing appreciable amounts of water into the groundwater systems at locations where appreciable recharge did not previously occur, or s installing liquid product pipelines (including water and sewer lines) which will readily separate or break in the event of subsidence thereby inducing more extensive subsidence or collapse. . The ITA reports suggest that the strategy to be employed for dealing with land subsidence and catastrophic sinkhole collapse will be primarily focused on trying to stabilize sinkhole drainage points when they are discovered during construction. In some cases the reports suggest that pipes may be installed into the “throats” of sinkholes in such a way as to provide a sediment trap in the lower part of the sinkhole. Based upon a conversation with Mr. Dan Cherry of the ITA, the consultants dealt with the cost of land subsidence and sinkhole collapse by increasing the contingency factor in the construction cost estimate by 25 to 30% rather than a more conventionally used 10 to 15%. The ITA reports suggest that little in the way of geophysical surveys or test drilling will be done prior to construction. Dr. Nick Crawford of WKU did indicate in a conversation that he anticipates conducting some microgravity survey work as a part of his work for the ITA. The fundamental issue is the extent to which land subsidence or catastrophic sinkhole collapse risks must be minimized for a runway. Subsidence or sinkhole collapse could interrupt aircraft use of the facility for a period of time necessary to make repairs. Such repairs, even with adequate funding, could require up to several months depending upon the size and nature of the problem. Sinkhole collapse during a landing or take-off could result in injury or the loss of human life. As outlined in the present ITA report, the anticipated level of effort to identify unstable areas and mitigate them seems to be similar to the level of effort applied to city streets in Bowling Green. During the period of this risk assessment work a large sinkhole collapse destroyed both lanes of travel on Dishman Lane in Bowling Green on February 25, 2002. Based on a phone discussion with Dr. Nick Crawford, the collapse is about 200 feet by 200 feet and is about 20 feet deep at the deep end. The hydrogeologic setting of the Dishman Lane collapse is similar to the setting of the proposed airport. Pre- construction microgravity geophysical work was apparently conducted on Dishman Lane (Crawford, 2000), but based upon a recent phone discussion with Dr. Crawford this work did not include the road location where the collapse occurred. The extent of the collapse suggests that more extensive investigative and foundation stabilization work, in concert with careful stormwater management in the area, would probably have been required to prevent the collapse. It is my expectation that the FAA and the ITA will require a greater standard of care for detecting areas particularly prone to subsidence and sinkhole collapse than that normally applied to city streets in Bowling Green. After identification of problem areas such areas should be investigated and treated using approaches suitable for the discovered conditions. While street alignments can be adjusted to avoid severe problem areas this is not possible with runways. As a result, it will probably be desirable or necessary to conduct evaluations of an area or areas substantially larger than the envisaged runway. Finally, the evaluation (but not remediation) should extend beyond the present end of the proposed runway to ensure that the selected alignment will be suitable for future extension. Actions to Prevent or
Mitigate Identified Deficiencies and Their Costs For purposes of this risk assessment we must recognize that the entire proposed airport area represents water quality threats to the groundwater system and to aquatic life dependent upon that water. As discussed earlier, the use of buffers around sinkholes is not a viable strategy since it would preclude the construction of a runway. The most viable alternate strategy is to ensure that all waters derived from non-vegetated surfaces and entering the groundwater system is of adequate quality for the aquatic fauna in the groundwater system and for the aquatic fauna in Barren River downstream of Graham Springs (which drains the proposed airport area). For purposes of this risk assessment the estimated cost of implementing this strategy would be $750,000 with operation and maintenance costs of $75,000 per year. These costs are in addition to the costs envisaged in the present ITA reports. Since they are essential, the cost of geophysical investigations, exploratory drilling, and remediation of unstable areas should be a separate line item in the budget rather than a contingency percent of construction costs. For purposes of the financial risk assessment the budget for investigative and remediation work should be initially set at $2,500,000. This level of funding should permit the ITA to retain a highly experienced geophysical firm familiar with karst problems, conduct necessary exploratory drilling, and remediate minor problems and at least one major karst feature. Multiple major problems would increase investigative and stabilization costs. In addition, continuing costs for sinkhole inspections and repair should be budgeted at $50,000 per year. Contingency funds should be established to cover major karst problems associated with ensuring that only good quality water enters the groundwater system and that major new collapse or subsidence problems are promptly repaired. A recent spill of about 1,200 gallons of jet fuel at the Springfield-Branson Regional Airport, Missouri, entered a drainage sinkhole known to contribute water to a downstream population of a federally listed threatened species. The cost of cleanup and associated testing was probably in the range of$75,000 to $100,000 even though emergency response was rapid, weather conditions were favorable, and critical background information existed. Repair of major subsidence or sinkhole collapse which effected a runway could easily cost twice this amount. To permit prompt response to problems, an emergency contingency fund for major karst and/or water quality problems in the amount of $250,000 should be established with provisions to maintain the fund at this level as adjusted for inflation. The estimated mean withdrawl from the karst contingency fund is estimated at $25,000 per year . Summary
The absence of an assessment of whether or not the proposed airport will be inundated by periodic flooding represents a major data gap in the ITA reports. Periodic flooding in sinkhole plain areas often inundates a large percentage of the land area; this is especially true in areas such as the proposed airport site where the sinkholes are broad and relatively shallow. Periodic flooding may or may not be a major airport constrain at the proposed Bowling Green site or at alternate sites. However, this issue must be considered in a comprehensive site-specific fashion with due regard to the dramatic increases in water yield which accompany anticipated urbanization in the Graham Springs groundwater basin. It is my conclusion that this flood assessment must be completed before the risk assessment can be completed. The data gap must be filled with a credible quantitative assessment; generalized assumptions or the assignment of contingency cost values will not serve for a viable risk assessment. A series of invalid and/or unreasonable assumptions and/or conc1usions linked to water, water quality requirements for endangered species, and land stability issues were identified and discussed. Based upon these discussions actions necessary to prevent or mitigate identified ITA report deficiencies were made and their costs were estimated. The estimated increase in project costs over those outlined in the ITA documents totals $3,250,000. In addition, annual costs attributable to the identified actions would equal $150,000. All costs are based upon current dollars and are in addition to amount identified in ITA documents. The ITA cost projections reportedly included a contingency allowance in construction costs which was about 15% greater than that normally allocated for somewhat similar construction projects. Mr. Cherry of the ITA indicated that this increase in contingency percentage was designed to cover sinkhole problems which might be discovered during construction. My risk assessment concluded that costs associated with discovering, investigating, and stabilizing areas which might subside or collapse should be presented as a line item in the budget rather than as a contingency percent. Conditions in karst areas are characterized by great heterogeneity, and an increase in normal contingency estimates of 15% for the proposed site seems reasonable even if this contingency allowance does not include land subsidence and collapse issues. Submitted:
Kentucky Registered Professional Geologist No. 1541 Certified Professional Hydrogeologist No.179, American Institute of Hydrology References
Aley, Thomas and Kenneth C. Thomson. 1981. Hydrogeologic mapping of unincorporated Greene County, Missouri, to identify areas where sinkhole flooding and serious groundwater contamination could result from land development. Ozark Underground Laboratory contract report to the Missouri Department of Natural Resources with funding from the U.S. Environmental Protection Agency. 11p. + 5 map sheets. Crawford, Nicholas C. 2000. Microgravity investigations of sinkhole collapses under highways. Proc. of the First International Conf. on the Application of Geophysical and NDT Methodologies to Transportation Facilities and Infrastructures. St. Louis, MO. 13p. Leitheuser, Arthur T.
1988. Recovery plan for Kentucky Cave Shrimp (Palaemonias ganteri). U.S. Fish
and Wildlife Service, Southeastern Region, Atlanta, GA. 47 p. Quinlan, James F. and Ralph O. Ewers. 1981. Hydrogeology of the Mammoth Cave Region, Kentucky. IN: Roberts, T.G. (editor). Geological Society of America Cincinnati 1981 field trip guidebooks. American Geol. Inst., Vol. 3, pp. 457-506. Quinlan, James F. and Joseph A. Ray. 1989 (revised from 1981). Groundwater basins in the Mammoth Cave Region, Kentucky. Friends of the Karst, Occasional Publication No. 2. 1 sheet. Appendix F
Dr. Barry Beck, karst expert Comments in full from “Risk
Analysis.” P. E. LaMoreaux &
Associates, Inc.
Hydrologists, Geologists & Environmental
Scientists 106 Administration Road ─ Suite 4, Oak Ridge,
TN 37830 TELEPHONE: 865-483-7483 FAX: 865-483-7639
E-Mail: bbeck@pela-tenn.com MEMORANDUM TO: Robert C. Arthur, Director Landrum & Brown, Inc., Aviation Consu1tants Cincinnati, Ohio FROM: Dr. Barry F. Beck, Chief-of-Operations PELA, Oak Ridge, TN SUBJECT: Completeness Review of “Risk
Analysis Bowling Green -Warren County Regional Airport Bowling Green, Kentucky”
PELA No. 643900 DATE: March 25,
2002 Introduction
As per your request of February 25, 2002, I have reviewed the Risk Analysis Study for the Proposed Relocation of the Bowling Green-Warren County Regional Airport, Bowling Green, Kentucky (First Draft, February, 2002} and the important associated documents on behalf of P. E. LaMoreaux & Associates, Inc. A complete list of the documents reviewed appears in Table 1. I also conducted a site inspection on March 13, 2002; interviewed Mr. Dan Cherry, President of the Inter-Modal Transportation Authority (ITA); and consulted with Dr. Nicholas Crawford of the Center for Cave and Karst Studies at Western Kentucky University. According to your request, my expert role was to comment on the issues related to sinkholes and karst geology and hydrology, which I am qualified to do. I did not consider, nor make comments on, other issues which were outside of my area of expertise. Inasmuch as your request specified
that “extensive written answers or critiques of the documents themselves are
not necessary…the Airport Sponsor is seeking identification of issues they may
have missed,” my comments have been made as brief summary statements. It is understood
that the purpose of my review is to “identify any fatal flaws” or “insurmountable barriers to completion.” While very few barriers would be absolutely insurmountable, given
unlimited funding, each part of the planning, design, construction and operation
of the proposed airport has a cost/benefit ratio. In the final analysis, the
total benefits must balance the total costs. Therefore, if an item under
evaluation in the planning process is not adequately addressed, the corrective
action may be misstated, and the cost may be underestimated. While appropriate
mitigation of an individual item may not constitute an insurmountable barrier,
it could swing the balance of the cost/benefit ratio below an acceptable limit.
Therefore, items that are inadequately addressed in the airport planning
documents will be noted and commented upon, even if they do not constitute an
insurmountable barrier. Table 1: Documents Examined
Commentary In summary, except for the floodinq issue, the various assessments and
planning documents that I reviewed were aware of and considered all the
significant karst problems, although almost all of them were inadequatelv
treated. It was obvious from these documents that a consultant with specialized
karst expertise should be involved in the detailed planning and design of this
facility, and that such involvement had not occurred to date. It must also be
noted that many of the negative comments on the airport siting invoked karst
issues with an equally inadequate understanding. It is repeatedly stated in these various documents, and specifically in the Risk Analysis Study (p. 3, Notes on Karst Topography) that “karst topography is not unusual,” “50% of Kentucky exists on karst topography,” “all the existing houses, factories, highways, airports, etc., in these regions co-exist with the karst topography, but special concerns and planning are required….” Although this statement does contain the final caveat regarding special concerns and planning, the total impact of the message is to minimize the karst hazard, because half of Kentucky is already built on karst. While that statement is true, it fails to enumerate all the associated
problems that arise in those areas constructed on karst. Major sinkhole
collapses, such as recently occurred on Dishman Lane in Bowling Green, are only
one hazard of building in karst areas. Unanticipated flooding, complex and
hazardous foundation conditions, and an extreme sensitivity to ground water
pollution are others. Certainly human development co-exists with karst, but the
price that is paid is much greater than it is in non-karst areas, and it must
be reckoned with. An accurate estimate of the cost of mitigating these hazards
must be factored into the cost/benefit analysis, or the final decision based on
this ratio will be invalid! To compensate for the uncertainty regarding the karst conditions, the estimated construction cost of the runway and associated taxiways includes a contingency fee of 25% of the total acquisition and construction costs (Risk Analysis Study, p. III-6). Given the difficulty of mitigating karst problems and the fact that there are several different types of problems to be considered (collapse, flooding, pollution), this figure may not be adequate. “…. the ITA has recently commissioned a topography and water drainage study to investigate the matter of karst topography, “ (ibid.) but the results of that study are not yet available and have not been considered. The final evaluation of the cost of these corrective actions can only be determined when a detailed geologic and engineering study of the site is completed. I. The risk and hazard of sinkhole collapse is
inadequately addressed in the Preliminary Karst Evaluation (Law Gibb
Group), and it is hardly mentioned in the Risk Analysis Study. In the
Preliminary Karst Evaluation, the summary of Geology and Topography (Section
5.0, p. 4) is abbreviated and totally inadequate. Whereas this section notes
that there are fewer sinkholes on the St. Genevieve Limestone, to the north of
the railroad tracks, as compared to the St. Louis Limestone to the south, and
that they are larger, shallower and more rolling, the report fails to explain
why. The presence of the Lost River Chert, a 5- to 10-foot- thick section of
insoluble, bedded chert at the base of the St. Genevieve, a1ters the nature of
the hydrology and the karst development above that stratum. It causes the
variation in the nature of the sinkholes, and it will exert other significant
impacts on the karst hydrogeology; yet the preliminary evaluation does not
mention it. Moreover, a more complete discussion of the nature and role of the
Lost River Chert would also treat one of the objections that was repeatedly raised (Comment C.1 , p. 11-12, Response to Comments). The preliminary evaluation does not explain or adequately consider the
complex origin of sinkholes or the difference between the large, broad
depressions and the smaller, catastrophic collapses. While the discussion of
sinkholes on page 9 of that report is not incorrect, it is inadequate
for a report that is specifically charged with evaluating karst. It is stated
that the railroad and the nearby interstate highway “have performed
satisfactorily with no significant problems.” That may be true if one considers
only the limited area in the vicinity of the site. Even in areas where the risk of sinkhole collapse is high, the actual
number of collapses is physically low, approximately one collapse per square
mile per year. Therefore, if one evaluates only a few square miles of land and
one looks only for collapses in the last few months or a year, it is very easy
to overlook incidents of sinkhole collapse. However, if one considers the
history of sinkhole collapse in Bowling Green, which is in a similar geologic
situation, it is obvious that the hazard of sinkhole collapse is significant.
When one considers the design life of an airport, the total risk of impact may
increase by two orders of magnitude. Moreover, a sinkhole collapse in a
commercial airport runway does have significantly more impact than a similar
collapse in a residential street. The detailed planning studies of the
engineering geology of the site must adequately evaluate and mitigate the
hazard of sinkhole collapse, which will involve detailed investigations. II. The reports and documents examined recognize that karst areas are highly susceptible to ground-water contamination. Airport design, and the design of surrounding development, must mitigate this hazard. While this issue is discussed extensively, the various measures proposed for mitigation of the ground-water contamination hazard may not be sufficient. The Environmental Assessment proposes to collect all stormwater drainage and direct it to a “sand filter-wetland treatment area” (p. 4-25) .In the site area, this may be impractical and inadequate without additional safeguards. For instance, the Preliminary Karst Evaluation (p. 12) says, “It is possible for new dropouts to occur, especially in areas of ponded water. “ In fact, it is this reviewer’s experience that it is not just possible, it is quite probable that dropouts will occur in areas of ponded water. Therefore, any treatment and filtration mechanism built into the design will be circumvented, and the contaminated water will drain directly into the karst ground water. It is not sufficient to repair such dropouts when they occur. All areas of ponded water should be underlain by an impermeable liner to prevent such dropouts. The design of such a liner requires detailed geotechnical exploration of the area. Further, it is next proposed to direct the treated water into the subsurface via a drainage well (EA, p. 4-25) after passing through a sand filter. Several state DOT’s have been utilizing peat filters to better clean-up roadway runoff draining into sinkholes, and the Federal Highway Administration is presently finalizing a multi-year study that quantitatively evaluates this treatment mechanism. Removal efficiencies for most contaminants are greater than 90% . Given the sensitive nature of the subsurface fauna and the direct connection to Graham Spring, it is advisable for the designers to consider the inclusion of peat or similar filters in the stormwater treatment system. The impermeable liner and the installation of a peat filter are both actions which will increase the cost of the stormwater treatment. It is suggested that the development of this site incorporate a three-tiered monitoring system. Stormwater, or any overland drainage, should be sampled and monitored to determine if potential contamination is occurring and to facilitate the elimination of the source of such contamination. Ground-water flow leaving the site area through trunk conduits should be monitored, which wil1 document whether the proposed treatment measures have been adequate in minimizing contamination. And, finally, Graham Springs should be monitored to determine the overall impact of this development. A statistical-evaluation plan should be prepared to adequately detect when the water quality at the springs has been impacted. While it is true that such monitoring will only detect a problem that has already occurred, it will make it possible to initiate corrective actions at the first possible opportunity. III. The various reports repeatedly refer to the “main channel” (EA, p. 3-15) or “central trunk drainage conduit” (EA, p. 4-54) as shown on the dye tracing maps for the area. Many of the design plans and corrective actions (such as buffer zones around sinkholes) are tied to the location of these conduits. The Preliminary Karst Evaluation (p. 6) correctly notes, “However, these locations have been hypothesized based on dye traces and a few water well locations.” Trunk drainage conduits shown on the maps are hypothetical. Extensive geophysical and dye tracing efforts will be required to actually delineate the path of such costs. The cost of such efforts will be significant. IV. Various comments stress the fact that the boundaries of the Graham Springs drainage area may change during high-flow conditions (for example, Comment D-2, p. 15, Response to Comments). The conclusion that is drawn from this is that contamination from the airport site could impact MCNP. It is certainly a documented fact
that karst drainage boundaries may vary depending on the flow conditions.
However, it is usually the upstream reaches of the drainage basin, near the
basin boundary, which may switch flow directions during high-water conditions.
It would be most unlikely for drainage far into the basin, at a downstream, “trunk” location such as the proposed airport
site, to reverse flow sufficiently to flow into a neighboring drainage basin.
While it cannot be stated that such an event is absolutely impossible, it is
extremely unlikely. V. Quantitative
dye studies should be conducted as part of the EIS. The EA states, “When federal involvement
occurs on this project and an EIS is prepared, additional geologic
investigations will be conducted, including dye studies, to determine the
actual groundwater flow paths and connections to critical sinkholes and potential
cave fauna habitat” (p. 3-15). Many of the dye studies that were used to
construct the drainage basin maps were conducted many years ago and done very
crudely. Large quantities of dye were used and detection, whether on charcoal
or in water, was generally visual. As a result, where positive traces were
obtained, the results can be assumed to be valid. However, a failure to detect
the dye may not be totally reliable. Moreover, most of these dye traces were done using charcoal “bugs” to detect the dye. While this technique is certainly valid, it provides only part of the possible information. The detection of the dye confirms a ground-water connection, but it does not provide any information about the nature of that connection. In understanding the complex hydrology of a karst basin, it is important to understand the nature of the ground-water connections, whether through a myriad of small cracks or tubules, or through a large, open conduit. Quantitative dye traces provide a breakthrough curve of the dye arrival. The shape of that curve is indicative of the nature of the ground-water flow. Quantitative dye traces can provide the type of information which is critical for understanding the impact of potential contamination on Graham Springs and on the subterranean fauna. However, the addition of quantitative dye traces will increase the cost of the investigation. VI. Potential flood damage is not adequately considered. The
EA, on p. 4-44, states, “There is no 100-year flood plain within the Yellow
Study Area [the site area].” Tom Aley,
in his letter and report of March 4, 2002, points out the error in this
statement and categorizes this as a “major data gap.” While Mr. Aley is correct
that there are undoubtedly flood-prone areas within the myriad of sinkhole
basins on the site, the EA is also technically correct within the definition
that they reference. Earlier in that same paragraph, the EA states,
“Floodplains are defined in Executive Order 11988, ‘Floodplain Management’ as ‘the lowland and relatively flat areas
adjoining inland and coastal waters, including at a minimum that area subject
to a one percent or greater chance of flooding in any given year.’ “ Obviously,
the areas on site are not “adjoining inland...waters.” However, invoking this
definition without considering the hazard of sinkhole flooding in a noted karst
area, where the city of Bowling Green is well-known for its sinkhole flooding problems, is a totally inadequate
assessment. Recognizing the inadequacy of this conclusion does not necessarily mean
that potential flooding is an “insurmountable barrier” or even necessarily a
serious problem. The design of the runways and the airport facilities will
undoubtedly not utilize the bottoms of sinkholes. These broad, gently sloping
sinkholes will not flood to as high a level as smaller, more steep-sided
sinkholes will, given the same inflow. It will be necessary to consider the
flood problem when designing the airport. However, a stormwater collection
system is already planned. Modifications to insure that flooding is not a
safety hazard or an economic impediment will not be too complex. However, as
with the other issues, they will necessitate increased costs. It is incorrect
to state that the flooding problem does not exist. Summary
In summary, the various assessments and planning documents were aware
of and considered all the significant karst problems, with the exception of
flooding, but the impact of almost all of them was significantly
underestimated. Certainly human development can and does co-exist with karst,
but the price that is paid is much greater than it is in non-karst areas, and
it must be reckoned with. The detailed investigations necessary to avoid
sinkhole collapse, ground-water contamination, and flooding will be extensive
and costly. Specialized experts should be involved in each component of these
tasks. An accurate estimate of the cost of mitigating these hazards must be
factored into the cost/benefit analysis, or the final decision based on this
ratio will be invalid! |
