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

planning effort which Chicago had now renamed the “ALP Update” was in reality the “Master
Plan Update” called for in the 1987 secret strategy memo, the same “Master Plan Update” that
Commissioner Franke spoke about in his September 1989 memo to Kruesi, 96 and the very same
“Master Plan Update” that Franke described in his January 1990 letter to DuPage County
Planning Commission Chairperson, Ms. Mary Eleanor Wall. 97
On April 3, 1991, Mary Vigilante, a Landrum & Brown Vice-President, wrote
Commissioner Franke as follows:
As we have discussed, Landrum & Brown will need a letter
authorizing our involvement in the O’Hare Master Plan/Airport
Layout Plan Update …. 98
On May 14, 1991, Mark Conway, a former Landrum & Brown official, made the
following proposal to assist the airlines in their participation in the new O’Hare Master Plan:
The majority of the program elements associated with the 1995
O’Hare Development Plan (ODP I) have been completed… It is
now time to continue planning the development necessary to
functionally balance the operational capabilities of O’Hare to
serve the next 20 years. The City of Chicago intends to pursue
consultant selection for a Master Plan Study which along with the
recently completed Chicago Delay Task Force, will serve as the
basis for defining the improvements necessary to increase the
operational efficiency of O’Hare. It is anticipated that a
development program (ODP II) will be the result of this study.
***
This study is intended to provide early airline input to the City’s
Master Plan Update Study. 99
capacity studies for the various Master Plan Update alternatives.
96 Exhibit C 12.
97 Exhibit C 15.
98 Exhibit C 30 (emphasis added).
99 Exhibit CBIN 9 (emphasis added). Note that Conway uses the euphemism “improvements necessary to increase
the operational efficiency of O’Hare.” (emphasis added). This is the standard euphemism adopted by Chicago and
the airlines to avoid mention of the fact that new runways and other changes are intended to increase capacity. In
other documents Conway acknowledges that the purpose of these “improvements” is to increase the operational
capacity at O’Hare.
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