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

O’Hare Airports operational capacity during certain weather
conditions while reducing delay. 181
Again, the March 15, 1993 Demand Forecast report — like the January 27, 1993
report — demonstrated clearly that O’Hare’s existing runway system was out of capacity as early
as 1995 and that even with the two runways (which created triples not quads) recommended by
the Delay Task Force, O’Hare could not handle the future traffic demand. Thus, again this report
demonstrated that either quad runways (the full O’Hare buildout) was necessary or that a third
airport was needed.
13. March 17, 1993. Memo from Getzels, Special Assistant to Mosena, to Commissioner
Mosena.
On March 17, 1993, Petey Getzels, a special assistant to Commissioner Mosena, wrote:
LB’s report begins with an analysis clearly stating that what the
current ALP proposes will not accommodate future demand at
O’Hare. This is probably true — given continuation of present
trends and no radical changes in airlines business.
***
It [L&B’s March 15 Forecast] firmly states at the outset of the
report that by 1995 will not be able to accommodate 3.03 million
connecting enplanements that are predicted to be demanded —
and by 2015 O’Hare will fall short of accommodating the demand
(for connecting) by 8.73 million. This situation will occur if
O’Hare puts in place only the upgrades recommended by the Delay
Task Force … which in effect is what the ALP [Update] is
proposing.
This puts us in a box. The only response is to build out O’Hare
[the quad runways] or support a new airport. We are trying to
forestall this decision. 182
Here again, Chicago is trying to hide from the consequences of reality. Reality puts
Chicago “in a box.” According to Chicago’s own consultant, O’Hare is going to be out of
181 Exhibit MP 6 at p. II-5 (emphasis and bracketed text added). In handwritten edits on Page II-5 of the March 15
report, the phrase increase O’Hare Airports operational capacity is edited to say “enhance operational efficiency”
the standard euphemism developed by Chicago to hide capacity increases. (Exhibit MP 7 at p. II-5).
182 Exhibit C 90 (underlined emphasis in original, boldfaced emphasis and bracketed text added).
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