HomeMy WebLinkAboutMiami International Airport Airline Liaison Office memo to Miami-Dade County Aviation Department - Letter dated 04-08-2022Airline
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Miami Airline Liaison Office
Miami International Airport
To: Miami -Dade County Aviation Department (MDAD)
From: Miami International Airport Airline Liaison Office (MIA ALO)
Date: April 8, 2022
Subject: Freedom Park Assessment from FAA Determination Letter — Update to the ALO letter
dated December 10, 2019
The MIA ALO has reviewed the documents provided from the FAA and there isn't any specific analysis we
can perform that would provide any additional information than what the FAA has included. As we
interpret these documents the FAA has determined that the proposed light poles on the stadium which
are the highest penetration to the PART 77 and other surfaces at the MIA do not represent any hazard to
air navigation, other than requiring certain conditions relating to lighting them etc. The FAA has identified
that some of the proposed light towers on top of the stadium do violate some Part 77 surfaces, specifically:
• The MIA Horizontal Surface by 1 foot (for 9 of the proposed lights)
• MIA Runway 9/27 Transitional Surface by 1 foot (2 of the 14 lights)
They also identified an obstruction to the TERPS criterial that increases minimum instrument flight
altitudes and specifically the Departure Surface. In their further analysis they state these obstructions
would not increase the departure minimums and specifically no increase to the ceiling, visibility or climb
rate. Typically, the airlines can best advise on the degree of impact to their operations from an obstacle
particularly as it relates one engine out departure surface impacts (sometimes the required climb gradient
can result in payload reductions or affect the range of the aircraft when using that runway). Where we
have seen this before such as at ORD we typically have passed the obstruction information onto the
airlines themselves for their subject matter experts and engineering departments to run through their
models and determine how significant the impact would be.
There are some other items that could be issues in the future once the stadium is in place or during its
construction, issues we have previously raised with MDAD and the BCC with our first letter of concerns
dated December 10, 2019. First related to traffic during stadium events since the location is directly
adjacent to the primary public entrance to the airport which likely will increase congestion and from an
environmental standpoint could result in increased emissions that could reflect negatively on the airport
in future EA/EIS type analysis or drive additional mitigation measures. Lighting — depending on the
orientation of the lights, materials used in construction of the stadium etc. there is the possibility that
even though the lights would be aimed down into the stadium they could have reflection or other issues
that would be distracting to pilots on approach to Runway 27 and possibly other runways as well. Potential
temporary impacts during construction — The FAA has analyzed the completed final points of the
structure, there will be a separate airspace analysis required to evaluate temporary impacts due to
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construction. It is likely that construction of the stadium will require the use of cranes whose height will
exceed that of the final lights. Depending on the location of these cranes there could be impacts to
operations at MIA and on Runway 9/27 from the cranes that would be more significant than what results
from the completed building. These are difficult and/or challenging to identify or assess at this time,
without more specific information on the height and locations of the cranes.
Our recommendation is effectively for the airlines to socialize this issue with subject matter experts
related to operational procedures that may need to be modified based on the FAA's determination letter,
MDAD's concerns, and the ALO's initial assessment.
Respectfully,
Sandra Cisneros
MIA ALO