evidentiary appendix in support of plaintiffs' partial motion for ...

P. O’Hare Master Planning Continued — 1998 Chronology.
1. January 16, 1998. Landrum & Brown publishes executive summary of new 2020
forecast— contains dramatically lower numbers than January 1993 Master Plan 20
year forecast and January 1995 2020 forecast; no mention made of earlier forecasts.
On January 16, 1998, Landrum & Brown produced an Executive Summary of a new
aviation activity forecast which had dramatically different numbers from its prior long range
forecasts. The hidden January 1995 unconstrained forecast said 69 million enplanements and 1.4
million operations in 2020. This January 1998 forecast — also by Landrum & Brown — had 49
million enplanements and 1,038,000 operations.
The existence of the 1995 unconstrained forecast was never revealed to the public. Nor
was there ever an explanation for the huge difference in the two forecasts. Indeed, as shown
below, even the newer 1998 forecast for 2020 was hidden from public view because it showed a
level of traffic that exceeded Landrum & Brown’s statement of the capacity of O’Hare without
new runways. 293 As Chicago did in 1993 when it deliberately shortened the forecast period from
2015 to 2005 to avoid disclosing the capacity shortfall, Chicago in 1998 shortened the 2020
forecast to the year 2012 294 so as to avoid public examination of the consequences of that
shortfall.
This manipulation of the forecast time periods — here from the private January 1998
forecast for 2020 to the public June 1998 forecast for 2012 — has enormous significance. Even
if this Court accepts the huge unexplained change between the hidden 1995 forecast for 2020 and
accepts the later 1998 forecast for 2020, the 1998 forecast for 2020 encompasses the period from
2012-2020 and shows that Chicago will have to build new runways to meet that demand. 295
293 Note that Thomas had said in 1995 that with significant advances in Air Traffic Control (ATC) technology —
advances which have not yet come to pass — O’Hare might (with a reduction in peak month traffic) have the
capacity for 946,000 operations. (No data to support that claim has been presented.) But even accepting that claim
of 946,000 capacity, the January 1995 2020 forecast showed a demand of over 1,400,000 and even the January 1998
forecast showed a demand over 1,000,000 operations for O’Hare.
294 Exhibit C 223 at p. I-1, et al.
295 The more than 1,000,000 operations exceeds even Thomas’s claim of a 946,000 flight capacity.
136