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Luxury Jet Hangar Project Proponent Releases Flawed Environmental Report

April 2, 2024

The developer has submitted a Draft Environmental Impact Report (DEIR) on 3/15/2024 for the massive private luxury jet hangar project at Hanscom Field as part of a state environmental review under the Massachusetts Environmental Policy Act (MEPA).

Incredibly, the proponent asserts this 522,380-square-foot project will have no effect at all on private jet traffic which they claim is "projected to occur regardless of whether the project is constructed." The report has failed to follow FAA instructions pertaining to forecasts, which specifically require that proponents should “estimate how much increased hangar space would change predicted demand”.1 Instead, the proponent claims, contrary to the FAA, that private jet hangars have no effect on flights. This claim of "no effect on flights" cannot be reconciled with their own statement that the hangars are necessary to support future flights.

Such an assertion that aircraft infrastructure has no effect on flights is equivalent to saying that garages have no effect on auto traffic or pipelines have no effect on gas consumption.

By making this outrageous claim that hangars do not affect flights, which is contrary to both common sense and FAA instructions, the proponent neatly avoids any analysis of the greenhouse gases from flights generated by aircraft housed by the project.

The proponent does admit that aircraft at the airport today generate some GHG in Section 8.3.3 Table 5. However, the number claimed, 30,686 tons, does not represent the emissions of aircraft flights, but only aircraft emissions local to the airport. By including only local airport emissions, a distinction the proponent fails to disclose in the text, grossly misleads the public about private jet emissions enabled by the airport.

The proponent has admitted that this facility will dispense 15,000 gallons of jet fuel per day2 to the new aircraft sited there, corresponding to 5.5 million gallons per year. This directly corresponds to an enormous 220,000 new tons of CO2e per year.3 Yet, despite this admission, the proponent claims no new flights will occur, and that GHG emissions will decrease.

Not only does the proponent represent that hangars will not result in any new flights, but claims further that the hangars will reduce flights by “an estimated 3,500 per year.” They claim certain extra flights today are due to aircraft that cannot be based at Hanscom due to insufficient hangar space, which causes these aircraft to make empty flights (ferry flights) back and forth to another local airport where they have obtained hangar space. Yet by their own admission, they did not do any detailed analysis to identify such aircraft. Instead, they simply counted any aircraft that arrived from an airport within 350 miles and stayed at Hanscom for less than 18 hours. Their own consultant admitted at a hearing that this would include many types of short trips and taxi activity that are not ferry activity and would be unaffected by hangars, and that the number 3,500 was likely high and could even be zero. Regardless, they have continued to assert that their hangars will be a benefit by saving 3,500 flights.

Correcting the Record

To find a more accurate quantification of the effect of ferry flights and emissions, a recognized industry consultant, Industrial Economics Corporation (IEC), was retained to undertake a detailed independent study of the proponent’s claims.4 The consultant performed a analysis of detailed flight data for all aircraft using Hanscom over the prior year and identified the operating base for any aircraft exhibiting ferry flight activity. This analysis found only three aircraft that regularly ferry through Hanscom. It was found that those three aircraft, if they relocated to Hanscom, would save 75 flights, considerably less than the 3,500 avoided flights claimed by the proponent based on their superficial analysis.5

The proponent had access to the flight data and could have determined the actual number of ferry flights that would be affected by hangars at Hanscom, but deliberately did not do so, apparently because the facts did not fit with their misleading narrative. There is an important reason for the proponent to cover up impacts; the proponent is trying to construct a story to avoid the additional analysis and approvals that would would be required for a project creating more flights and emitting large amount of GHG.

The independent report concluded that the DEIR was fundamentally flawed and found that "Emissions associated with full utilization of planned capacity far outweigh any emissions savings." Further, the report summarized that "The DEIR errs in finding that the new hangar capacity will not increase operations or GHG emissions"

The hangar project can hold approximately 79 jets.6 Of these jets, only three are jets formerly exhibiting ferry flights, which will not add to new operations. The remaining 76 jets represent new operations. According to industry figures, each private jet will fly approximately 350 hours per year, which translates to nearly 200,000 new tons of CO2e per year. 7 This figure is consistent with the 220,000 tons estimated above via proponent's fuel consumption.

In violation of FAA instructions, the proponent has failed to admit impacts due to any new flights. The effect of the project on flights and greenhouse gases is clear: 1) The hangars will overwhelmingly house new private luxury jets. 2) The data shows savings due to ferry flights are insignificant and will not offset the huge growth in flights by newly housed aircraft. 3) The new flights generated will generate roughly 220,000 Tons of greenhouse gases per year, equivalent to those generated in a year by approximately 200,000 people in rural India.8

The amount of GHG generated by this project cancels out and negates the GHG benefits of 550 million Watts of solar panels.9 This is the largest known project of this type in the world and the largest GHG-generating project under consideration in Massachusetts. The project is in direct conflict with State law which requires the GHG of each sector of to decline over time.10 No public benefit has been established that would justify the public's acceptance of this pollution.

The report makes a claim that project is "net zero." These claims are specifically about the design of the buildings to reduce GHGs. and ignore the emissions of the aircraft altogether. These claims are misleading and are further discussed in a separate paper.

In 2005, over 100 coal plants were in various stages of planning and permitting in the USA. The proponents, as in this case, represented the proposed infrastructure as necessary in response to forecast and need. However, the country made a choice, and none of those plants was ever completed. The world is better for that choice. Changing direction here, and stopping this project, is a much easier choice.

In the case of coal plants, citizens and government recognized that coal would generate undesirable GHG. In this DEIR, the proponents, via subterfuge and misinformation, have made the incredible claim that the new aircraft enabled by their project will not generate any GHG. An independent report finds, consistent with common sense, that the proponents claims are false and that substantial increases in operations and GHG emissions will result from the project.

While there are many other shortcomings of this DEIR, it must be rejected for its complete failure to show the effect of increased private luxury jet flights.

1. FAA Master plan Guidance, section titled "Steps in the Forecast Process"
2. HFAC presentation by proponent, Feb 20, 2024
3. 5 million gallons generates 19.8 kg per gal of CO2e in a jet aircraft. Assuming round trips, with return trips using the same amount of fuel, 5.5 M x 19.8 x 2 gives 220,000 Tons
4. Analysis of the Greenhouse Gas Emissions Impact of Proposed Expansion of Hangar Capacity at Hanscom Field. Industrial Economics, Inc. April 4, 2024
5. The three aircraft had 132 ferry flights per year which would be eliminated. However, they also had 57 flights which did not route through Hanscom that would now be added if the aircraft relocated. The net reduction in Hanscom operations by moving these aircraft to Hanscom would be 75.
6. The project provides 395,000 sq ft of aircraft-capable space, which assuming and industry standard of 5,000 sq ft per jet corresponds with to capacity for 79 jets. The proponent has projected up to 55 jets, which must have assumed larger than average aircraft. Estimates of GHG based on aircraft are not changed if larger than average aircraft are assumed, because corresponding fuel consumption per aircraft will also be higher than average.
7. Assuming 350 hr per year for a based private jet, per industry standards, along with 330 gal per hour and 19.75 kg CO2e per gallon.
8. A rural person living in India is responsible for about 1 Ton per year.
9. Based on the Massachusetts rate of .3kg CO2 saved per carbon-free kwhr and 15% PV capacity factor.
10. Chapter 8 of the Acts of 2021, Next Generation Roadmap for Mass. Climate Policy

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