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

admitted in another internal document produced by Chicago in discovery. 36 Indeed, the code
phrase adopted by Chicago and its consultants to speak about increasing “capacity” — i.e., the
ability to add more flights — is “increased operational efficiency”.
This game of characterizing measures to provide capacity increases — such as new
runways — as simply “delay reduction” started in 1988. In 1988, Chicago, the FAA and the
Airlines started what they called a “delay task force.” In reality, the effort was part of a
“capacity enhancement” program funded by FAA to develop “capacity enhancement plans” for
many of the nation’s airports. Because the concept of capacity increases or “capacity
enhancement” was political anathema in Chicago — the City having promised only a few short
years earlier to halt capacity expansion at O’Hare — Chicago and its public relations consultants
claimed that they were not planning ways to increase capacity but simply studying ways to
reduce delays at O’Hare or to “enhance operational efficiency.” The concept of increasing
capacity was never mentioned.
Yet internal documents for the development of the so-called “Delay Task Force Study”
show that, in reality, the purpose of the so-called Delay Task Force effort was to develop
methods to increase the capacity of O’Hare. For example, on December 6, 1988, Chicago’s
Aviation Commissioner wrote the FAA outlining Chicago’s proposal for a “Delay Task Force.”
His letter spoke of discussions to “enhance the operational efficiency of Chicago’s airports:
For several months members of our staffs as well as the airlines
and other parties have discussed options to enhance the
operational efficiency of Chicago’s airports. 37
But the letter from Chicago’s Aviation Commissioner attaching the proposed Scope of
Work openly acknowledged that the product of the so-called “Delay Task Force” will be a
“Capacity Enhancement Action Plan”:
36 March 10, 1993 memo by Mary Vigilante, Vice President of Landrum & Brown and Chris Young, Chief
Operating Officer for Landrum & Brown to Deputy Commissioner Robert Repel, Department of Aviation. Exhibit
C 89.
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