Regional Plan Association (RPA) appreciates the opportunity to comment on the Draft Environmental Assessment (EA) for the proposed Facilities Redevelopment Project at Teterboro Airport.
For more than a century, RPA has advanced policies to improve the economic competitiveness, environmental sustainability, and quality of life of the New York - New Jersey - Connecticut metropolitan region. We recognize the important role Teterboro Airport plays within the region’s aviation system in supporting general aviation activity. However, we also believe public investments and federal approvals must be evaluated within the context of long-term regional resilience, responsible environmental stewardship, and sound land use planning.
For the reasons outlined below, RPA opposes the proposed expansion and respectfully urges the Federal Aviation Administration (FAA) to prepare a full Environmental Impact Statement (EIS) rather than issue a Finding of No Significant Impact (FONSI).
Wetland Impacts and Localized Flood Resilience
The proposed project would permanently expand aviation facilities in one of the most environmentally sensitive and flood-prone landscapes in the region. The Draft EA acknowledges that the project would require filling more than 11 acres of wetlands and calls for the construction of substantial new impervious surfaces, including new aircraft aprons, hangars, parking facilities, and access roads. While the document asserts that these impacts will be mitigated through the purchase of off-site mitigation bank credits, it overlooks the unique flood mitigation, habitat, and ecological functions these wetlands provide specifically within the immediate Meadowlands ecosystem.
Off-site wetland mitigation may satisfy requirements of the Clean Water Act, but it does not replace the localized flood protection and resilience benefits that existing wetlands provide to surrounding communities. As climate change drives more frequent and intense weather events and accelerates sea level rise, preserving the remaining Meadowlands wetlands should be prioritized rather than treated as an afterthought addressed through off-site mitigation.
Inconsistent Climate Baselines and Deficient Flood Risk Analysis
The Draft EA also fails to adequately analyze the true impact of constructing permanent infrastructure in a location with documented and escalating flood risk. The EA acknowledges that the study area lies within the FEMA 100-year floodplain but does not account for projected sea level rise or the increased frequency of extreme weather events over the 20-year planning horizon the EA itself uses.
Infrastructure expected to serve the region for decades should be evaluated against the environmental conditions it is likely to experience over that same period. The Draft EA forecasts aviation demand through 2044 but does not apply an equivalent long-term lens to flood risk and climate resilience. This significant oversight warrants the more rigorous analysis that an EIS would provide.
Overly Narrow Purpose and Need Statement
The project’s purpose and need is defined too narrowly. The document frames the proposed action primarily as accommodating Signature Aviation’s projected business growth, centered on attracting larger aircraft and additional apron capacity. While these may represent legitimate business objectives, they do not necessarily establish that further depletion of wetlands serves public interest.
Because the purpose and need statement is framed almost exclusively around accommodating Signature Aviation’s projected growth, the alternatives analysis largely evaluates different ways to achieve the expansion rather than meaningfully considering alternatives that could avoid or minimize environmental impacts.
Specifically, alternatives involving the accommodation of future growth at other regional facilities or through operational changes appear to have been dismissed because they would not satisfy Signature’s specific objectives, rather than because they fail to serve the region. An objective alternatives analysis must evaluate whether forecast growth should occur at Teterboro at all given the airport’s escalating climate vulnerability.
Failure to Account for Induced Demand
Similarly, the Draft EA also assumes that expanding Signature’s facilities will merely accommodate forecasted demand but fails to acknowledge that it will also influence future aviation activity. Expanded capacity is likely to induce additional demand by making Teterboro more attractive to existing and prospective operators. While induced demand is frequently discussed in the context of highway expansions, the same principle should be considered when increasing the capacity of other transportation facilities. The EA must fully evaluate whether the proposed expansion would generate additional operations, and whether the associated environmental consequences have been adequately considered.
Inadequate Scope of Cumulative Impacts
Finally, RPA is concerned that the EA limits its cumulative impact review to Port Authority-initiated projects on airport property within an arbitrary five-year window. This narrow scope excludes reasonably foreseeable development and incremental wetland losses in the broader watershed. This project directly contributes to cumulative hydrological and ecological consequences that cannot be properly assessed by examining airport property in isolation.
NEPA regulations require that cumulative impact analyses consider the combined effect of past, present, and reasonably foreseeable future actions by any person, federal, or non-federal entity.1 The EA’s limited scope does not satisfy that standard, and an EIS is necessary to provide a genuine cumulative analysis.
Conclusion
The limited public benefits from an expanded Teterboro Airport are greatly outweighed by the long-term environmental and resilience costs of removing critical wetlands and increasing flood risk within the Meadowlands. This project involves permanent wetland impacts, expansion of impervious surfaces, long-term implications for flood resilience, and severe deficiencies in cumulative impact analysis. Collectively, these issues raise substantial questions that warrant the rigorous analysis, robust alternatives evaluation, and public review provided exclusively by an EIS.
For these reasons, Regional Plan Association respectfully requests that the FAA decline to issue a FONSI, prepare a full Environmental Impact Statement, and thoroughly evaluate alternatives that avoid additional wetland impacts while protecting the long-term resilience of the Meadowlands.
Thank you for the opportunity to comment.
Sincerely,
Zoe Baldwin
Vice President, State Programs 140 C.
