Volume 1 Issue 1 |
The El Toro Reuse Authority Newsletter |
December 1996 |
Working together to ensure a viable quality of life for all Orange County residents
Municipal Member Agencies:
Dana Point, Irvine, Lake Forest Laguna Hills, Laguna Niguel,
Mission Viejo
Led by the City of Lake Forest, eight South County Cities are vigorously pursuing their litigation to set aside Measure A, the County measure which requires that MCAS El Toro be used as a commercial airport. While the airport supporters were assisted in their delay tactics by the Orange County bankruptcy, this lawsuit is now free of the bankruptcy proceedings, and while a San Diego trial court judge ruled against our efforts, there was no substantial record established to sustain that decision.
Therefore, the case entitled City of Lake Forest, et al. v. County of Orange, et al., No. D025946, Superior Court No. 6913 10 is now before the Court of Appeals. The cities' opening brief was filed last month and the County and pro-airport supporters Response is due in the first part of December 1996. The cities' have opposed several attempts to delay this proceeding, and we were successful in getting our case on the expedited court calendar for a hearing date which will probably be in March 1997. A favorable ruling would overturn Measure A and thus not require a civilian airport at MCAS El Toro.
On August 8, 1996, the County of Orange released its Community Reuse Plan & Draft Environmental Impact Report (DEIR) for MCAS El Toro.
The County's reuse plan and DEIR identified three primary alternatives: Alternative A, a passenger/cargo airport; Alternative B, a cargo/general aviation airport; and Alternative C, non-aviation uses including visitor-oriented attractions.
On October 15, 1996, ETRPA submitted its formal comments to the County of Orange regarding the proposed uses and the accompanying DEIR. Each area of concern is discussed below.
Aviation Demand
Will air travelers residing in the cities of Oxnard or Fontana, commute to the new El Toro airport as anticipated by the County of Orange? The DEIR assumes that a significant number of residents living in the Inland Empire, Los Angeles and even Ventura Counties will drive in excess of 60 miles to use the new El Toro airport. It should be noted that the analysis for the non-aviation alternative (Alternative C) did not provide employee or user attraction from outside Orange County. In other words, the DEIR provides an "apples to oranges" analysis in comparing the demand for aviation uses versus non-aviation uses.
Number of Flights
The County of Orange has projected the need for 447,000 annual flights to accommodate a staggering... 38 million air passengers (MAP), roughly the annual number of operations at San Francisco International Airport. This figure equates to almost one take-off or landing every minute, day and night, 365 days a year. However, compared to other airports, it is unlikely that 447,000 annual operations can carry 38 MAP, meaning that many more planes will be flying overhead than even the 447,000 analyzed.
Airport Capacity
Could the County have overestimated the Annual Service Volume for El Toro? One measurement of an airport's capacity is its annual service volume, the level which allows for an average delay per flight of up to four minutes. The County has determined the annual service volume of Alternative A to be 350,000 annual flights, while the Southern California Association of Governments (SCAG) estimate is only 250,000 annual flights. This is a major discrepancy.
Operational Constraints
The County of Orange continues to downplay several operational and safety constraints associated with Alternative A. The Air Line Pilots Association which represents 44,000 professional pilots and the Air Transport Association have cited that the gradient of the primary departure runway (runway 7) exceeds FAA standards, is subject to strong tailwinds, and is impacted by the proximity of the rising terrain to the east. Additional constraints not addressed in the DEIR include the substandard separation of the existing parallel runways, and the inability to install and use accurate Instrument Landing Systems because of the surrounding terrain. Can 44,000 professional pilots be wrong and the County's consultants be right?
Operations Alternatives
Although serious concerns have been raised about the feasibility and safety of the proposed flight operations, the DEIR fails to identify and analyze flight path alternatives. In particular, the DEIR fails to identify and assess the potential impacts of an increased number of departures to the north from Runway 34, arrivals from the west on Runway 7, and departures to the west, over the City of Irvine, from Runway 25.
Noise Analysis Baseline
The County's DEIR baseline for analysis assumes that military operations will continue at MCAS El Toro if the site is not converted to a commercial airport. Yet, the U.S. Congress mandated the Department of the Navy to close MCAS El Toro by July 1999.
Noise Impacts
How can I determine if my home will be impacted by aircraft noise? It's difficult to determine since existing noise analysis does not identify the number of persons living within the 65 Community Noise Equivalent Level (CNEL) contour who would be impacted by the proposed operations. Some estimates have placed this number between 30,000 and 100,000 people. In addition, the DEIR does not identify or analyze the issues of duration of noise exposure and the effects of nighttime exposure. Remember, current flight operations at MCAS El Toro start at 7:00 a. m. and cease at 10:00 p.m., with very limited operations on the weekend and holidays.
Traffic
The DEIR fails to provide a sufficient level of detail to determine the impacts on off-site roadways and intersections. This is a serious concern as many of the intersections within the vicinity of El Toro are almost gridlocked during peak morning and peak afternoon drive times.
Air Quality
Local air quality impacts will WORSEN as the DEIR fails to address the local impacts of the proposed commercial airport. The DEIR analyzed air quality impacts on a "regional" perspective in which the commercial airport is anticipated to have no significant impact; however, even this analysis is predicated on unsubstantiated assumptions.
Contamination
Clean-up of El Toro could hinder the "timely" transfer of the airport to commercial operations since the clean-up of contaminated sites is generally slow. The Department of the Navy has already extended the timeline for clean-up from the year 2000 to 2004. The projected cost of cleaning the site is in excess of $166 million but may increase in an era when funding for the clean-up of contaminated sites is diminishing.
Financial Feasibility
The DEIR does not clearly demonstrate the financial viability of developing and operating a commercial airport at El Toro. The County estimates a capital cost of $93.1 million to strengthen two existing runways to accommodate commercial aircraft (rebuilding a quarter of one), construct two new parallel runways, and construct two full-length taxi ways with little back-up information to justify this cost projection. Compared to the cost of a new runway at $110.5 million, the County's figure seems to be grossly underestimated.
The DEIR does not address any contingencies if the actual airport revenue is insufficient to pay for its construction and operation, especially considering the fact that the revenue from an El Toro airport would be used to retire the County's bond commitment for John Wayne Airport, which would be downsized to a general aviation facility under Alternative A. We may be gambling with our future if the County's revenue projections fall short.
John Wayne Airport
Didn't Orange County taxpayers recently spend over $260 million improving John Wayne Airport? It is not readily apparent how the future of John Wayne Airport has been addressed in the DEIR. It is not clear what employment projections have been assumed for the facility if commercial operations are transferred to El Toro, how vehicle trips will be reallocated from John Wayne Airport to El Toro, or the economic impact on the area surrounding John Wayne Airport if commercial operations are relocated to El Toro.
Summary
The discussions above highlight in general terms the most significant areas of concern which arise from the review of the reuse plan and DEIR. While the obvious focus of these comments is on the potential conversion of MCAS El Toro to a commercial airport, the DEIR also fails to provide sufficient information to thoroughly evaluate the potential environmental impacts of Alternatives B and C. In short, the DEIR lacks an adequate description of a feasible project, contains insufficient analysis of the impacts of each identified alternative, and fails to provide details of mitigation measures and corresponding funding programs for their implementation.
In response to the County of Orange's MCAS El Toro Community Reuse Plan and Draft Environmental Impact Report, the Air Line Pilots Association, which represents 44,000 airline pilots, who fly for 37 U.S. Airlines, submitted comments to the County of Orange.
Although, the Air Line Pilots Association (ALPA) supports the concept of moving air carrier operations from John Wayne Airport to El Toro, they expressed their "disappointment" in the County's reuse plan, since it did not address ALPA's previous air safety and operational concerns with the proposed runway configuration.
ALPA stated that the closely spaced runways 7L and 7R would greatly reduce potential airport capacity at El Toro. Even "...increasing the runway centerline separation for the two sets of parallel runways from 500 to 700 or 800 feet may allow simultaneous visual approaches but it fails to address arrival and departure problems. Simultaneous departures from runways 7L and 7R may not be possible even with the added separation."
An additional limiting factor cited was the runway gradients associated with the usage of runways 7L and 7R. As outlined by ALPA, the gradients on runways 7L and 7R exceed FAA standards and must, therefore, be reconstructed if they are used in the current location.
ALPA also questions the County's ability to have approximately 70 percent of the flights depart from runways 7L and 7R due to tailwind conditions. ALPA stated that they are unaware of any airline which lands or departs with a tailwind stronger than five knots, with the exception of Los Angeles International Airport (During the L.A. riots, LAX landed aircraft to the east and departed to the west to avoid gunfire.) As such, ALPA stated that "...it is strongly opposed to the concept of opening a new airport which plans to depart aircraft with tailwinds of up to 10 knots.
Lastly, it should be noted that ALPA indicated that in order to avoid air traffic conflicts, John Wayne Airport would need to shut down all commercial passenger and cargo operations once El Toro is opened as a new commercial airport.
This position was also supported by a representative from the FAA as reported in the October 22, 1996, Orange County Register, "Not enough airspace for El Toro and John Wayne," representative states. Pacific Region FAA Air Traffic Division Manager Mr. George D. Williams, wrote an internal FAA memo indicating the John Wayne Airport would have to close as soon as the proposed El Toro Airport opens to avoid major air traffic conflicts and delays.
It has come to ETRPA's attention that an "El Toro Airport Info" web site has recently been established on the Internet. The address is: http://www.eltoroairport.org and it has a companion 24-hour hot line at (714) 521-0100 which carries excerpts from the web site. Information regarding the web site is provided here for public information only, and it is not affiliated in any way with ETRPA.
3rd Monday of Each Month, 5:00 p.m.
Lake Forest City Hall Council Chambers
23161 Lake Center Drive, Suite 100
El Toro Reuse Upcoming Public Meeting
Final Decisions-Local Redevelopment
December 10, 1996
Orange County Board Of Supervisors
(Sitting as the Local Redevelopment Authority)Hall of Administration
Board Meeting Room
10 Civic Center Plaza, Santa Ana
The County Board of Supervisors, will select a Community Reuse Plan to recommend to the Department of Navy. The Department of Navy will make the final decision. Call your local representatives and voice your position on the El Toro Reuse Plan.
John Dalton, Secretary of the Navy
1000 Navy Pentagon, Room 4E-686
Washington DC 20350-000
(703) 695-3131
Paul Galis Federal Aviation Administration
800 Independence Avenue S.W., Suite No. 600 East
Washington, DC 20591
(202) 267-8775
Orange County Board of Supervisors
Hall of Administration, 10 Civic Center Plaza
Santa Ana, California 92701
Supervisor Roger R. Stanton, Chairman
Chuck Smith (After January 5, 1997)
District Number 1
(714) 834-3110
Supervisor James W. Silva, Member
District Number 2
(714) 834-3220
Supervisor Donald J. Saltarelli, Member
Todd Spitzer (After January 5, 1997)
District Number 3
(714) 834-3330
Supervisor William G. Steiner, Vice Chairman
District Number 4
(714) 834-3440
Supervisor Thomas Wilson
District Number 5
(714) 834-3550
For additional information please call the MCAS El Toro Hot-line at (714) 461-3591.