Click dates below for additional ALPA letters regarding El Toro
October 11, 1996
Mr. Paul Lanning
Environmental Management Agency
Environment & Project Planning Division
County of Orange
P.O. Box 4048
Santa Ana, CA 92702-4048
Subject: August 1996 Draft MCAS El Toro Community Reuse Plan
Dear Mr. Lanning:
The Air Line Pilots Association (ALPA), representing 44,000 airline pilots who fly for 37 U.S. airlines, has reviewed and herewith offers comments on the subject reuse plan.
As we have stated previously, ALPA supports the concept of moving air carrier operations out of John Wayne Airport. John Wayne Airport is operationally and physically limited, and does not avail the desired margins of safety. Of particular concern at John Wayne are the required close-in noise abatement procedures and take-off operations which are conducted with just enough runway length to be legal, per the Federal Aviation Administration's (FAA's) minimum standards.
However, we are quite disappointed that the subject reuse plan has not addressed our profound concerns about the flaws inherent in its proposed runway configuration and usage plan, namely, Alternative A. To ensure clarity of our views, it should be understood that ALPA will steadfastly oppose the use of El Toro as a commercial airport if takeoffs to the east on runways 7L and/or 7R are a condition of its use as such a facility.
Further, we cannot give unqualified endorsement of any airport configuration at El Toro until such time as the FAA has performed a thorough study of terminal instrument procedures for all-weather instrument landings and departures. Also needed in such a study is an analysis of available emergency escape routes which could be utilized by the flight crew in the event of an engine failure.
The El Toro site offers the potential for an airport better than John Wayne only if its runway layout and operational usage are such that takeoffs and landings can be made with adequate safety margins.
Following are some general comments on areas of concern; specific comments on Appendix C of the plan are included thereafter.
The draft plan's primary alternative A proposes preferential easterly departures and closely-spaced runways which will greatly reduce potential airport capacity. Increasing the runway centerline separation for the two sets of parallel runways from 500 feet 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. Aircraft departing on IFR flight plans must track outbound on diverging courses. This situation will cause aircraft departing on runway 7L to fly towards rising terrain; this is an unacceptable situation for heavily loaded commercial airline aircraft, especially in the event of engine failure shortly after takeoff. Therefore, relocating an east-west runway would be a waste of resources and should not be given serious consideration.
Per the draft plan, arrivals on runways 34L and 34R will create the kind of undesirable situation which exists at San Francisco International Airport. When the visibility at that airport drops below five miles or the cloud bases dip below 2,100 feet, 50% of the airport's arrival capability is lost, which creates delays and scheduling problems. To conduct simultaneous visual approaches into SFO, the visibility and ceiling requirements need to be almost double that of standard VFR flight conditions (3 miles/1,000 ft. ceiling). Additional restrictions to simultaneous visual approaches exist at San Francisco due to wake turbulence considerations brought about from the mix of aircraft types which use that airport.
Ultimately, the four runways envisioned in the primary alternative will provide no greater capacity than two runways during standard prevailing VFR weather -- one runway will be used for arrivals and another for departures. Additionally, such problems as wake turbulence, aircraft turning belly-to-belly on approach, and overshoots (i.e., turning into the arrival path of the adjacent parallel runway) occur frequently in the San Francisco Bay area and must be expected for the El Toro draft primary alternative.
We believe the airport must be configured in such a manner as to eliminate, or greatly reduce, these problems. Our recommendations for doing so are discussed below.
FAA Advisory Circular 150/5300-13, Airport Design, sets a maximum of 1.5 percent change in longitudinal slope gradient for all parts of the runway, with the exception of the first and last quarters of the runway, which cannot exceed .08 percent. The gradients on runways 7L and 7R exceed these standards and must, therefore, be reconstructed if they are used in the current location.
Runway Length Analysis
The draft report acknowledges that the MD80 and Boeing 737-300/500 would be incapable of departing from runway 7R fully loaded and flying non-stop to Chicago or Dallas Fort Worth in a zero-wind condition. However, the report leads the reader to believe that the B757-200 and B767-300 appear capable of flying non-stop to the east coast (New York) fully loaded with a seven knot tailwind.
We investigated this information and determined that the B757-200, powered with Pratt & Whitney or Rolls Royce engines, should be capable of flying to the east coast fully loaded only under ideal circumstances both at origin and destination. If poor weather exists at the destination, the fuel load must be increased to account for holding and/or diverting to an alternate. In this scenario, the aircraft is very near its maximum gross weight takeoff limit -- although the aircraft is capable of carrying more fuel, because of the slope, wind and terrain, that is not possible. If it is determined that more fuel is required because of these factors, a commensurate weight penalty (i.e., removal of passengers and/or cargo) must be assessed.
Further, the use of the more powerful Rolls Royce engine's performance capability in this calculation is misleading. Of the four major carriers, United, Delta and Northwest operate their Boeing 757-200s with Pratt & Whitney engines. The fourth major, American, uses Rolls Royce engines. United's B757-200 Pratt & Whitney engine produces 75,000 pounds of thrust. American's B757-200 Rolls Royce engine produces 86,000 pounds of thrust. The significance of these facts is that, instead of assessing the safety of aircraft takeoffs to the east with less powerful engines, a less conservative assessment has been made using the more powerful aircraft, which skews the results away from day-to-day reality. As regards the B747-400, reaching Tokyo from El Toro is a possibility, but Beijing may not be possible under certain atmospheric conditions.
The draft report's use of alternative A calculates that 69.8% of the flights will depart from runways 7L & R. It also indicates that all eight airlines surveyed condone a tailwind operation of up to ten knots. Of the airports listed in this report, which purportedly operate routinely with tailwind conditions, we are unaware of one which lands or departs with a tailwind stronger than five knots, with the exception of LAX. (During the riots a few years ago, LAX landed aircraft to the east and departed to the west to avoid gunfire.)
ALPA is strongly opposed to the concept of opening a new airport which plans to depart aircraft with tailwinds of up to 10 knots. The judgment of any pilot who would knowingly take off heavily loaded, uphill, with a 10-knot tailwind, and towards terrain is suspect, to say the least.
As is indicated in this report, air traffic sequencing could have a negative impact on capacity at both John Wayne and El Toro. One has only to examine the difficulties of sequencing traffic at J.F. Kennedy, LaGuardia, Newark and Teterboro Airports to understand the potential for problems between John Wayne and El Toro; under certain weather conditions, Teterboro shuts down. Although the John Wayne and El Toro situation has some differences from the East Coast example, potential conflicts will exist and be exacerbated with the necessary preclusion of easterly takeoffs. John Wayne should shut down all commercial passenger and cargo operations if El Toro is opened as a new commercial airport.
SPECIFIC COMMENTS ON THE REUSE PLAN
ALPA offers the following criteria which we believe should be included in the development of any airport plan in order to capture the maximum benefits of both capacity and safety. ALPA contends that safety and capacity issues are so closely aligned that consideration of either without the other is not only impractical, but unrealistic. Obviously, physical constraints and environmental factors may restrain the implementation of every ALPA design goal, but a comparison between the proposed El Toro design and the major ALPA criteria is a means of measuring the relative merit of the proposal.
Major ALPA Airport Design Criteria
Page 3, Alternative A. As noted above, ALPA has a number of serious concerns with the proposed runway configuration, which include:
Rising terrain east of the airport.
As we note above, the north-south and east-west parallel runways are proposed to have only 800 feet separation, which is only 100 feet greater than the minimum separation permitted by the FAA for simultaneous visual approaches, and 1,700 feet less the minimum FAA standard for wake turbulence independent runways. The possibility of an inadvertent wake turbulence encounter by a smaller aircraft approaching or departing behind a larger aircraft on these closely spaced parallel runways is a significant safety concern.
Parallel landing operations on runways 34L and 34R, both of which intersect the proposed 7R and 7L departure runways, would add considerable complexity for both pilots and ATC. We oppose the concept of planning a new airport which relies on conducting land and hold short operations in order to reach desired capacity.
Due to the terrain around the airport, it is not possible to create ILS approaches to the parallel runway 16's, even though winds during IFR conditions would favor landing to the south.
Runway slopes exceed 1.5%
The plan relies on departures having tailwinds of up to 10 knots.
Page 5, Alternative B. ALPA does not support this alternative since it does not provide for scheduled air carrier operations.
Page 7, Figure 1.2-3, Runway Configuration of Primary and Secondary Aviation Reuse Alternatives. ALPA proposes a different airport configuration from any of those shown on this page. We recommend removing the two 16-34 parallel runways and 7-25 parallel runways and replacing all four of them with two parallel 13-31 runways. We believe this configuration could successfully address several problems:
The ability to develop precision instrument approaches for runways 13L and 13R would be almost a certainty and instrument approaches in the opposite direction (runway 31) quite likely.
The problem posed by terrain to the east of the airport would be eliminated.
The 45-degree turn anticipated for departures from runway 34L would be reduced to a shallow bank.
Building a runway on the western boundary of the property on a 310 degree heading would parallel the Interstate 5 freeway. This is an ideal routing from an aircraft noise standpoint. Runway 31R could be used strictly for departures if desired.
FAA currently requires 4,300 feet of separation between parallel runways in order to conduct simultaneous IFR approaches; this number may be lowered to 3,400 feet in the future if Precision Radar Monitoring (PRM) and associated procedures are effected. (NOTE: ALPA has not yet accepted any approaches using the PRM, but continues to work with the FAA toward that goal.) With 4,300 feet of separation, a terminal location between the runways is feasible and practicable. Passenger terminal access from the street would be streamlined.
Additionally, a dual runway operation with 4,300 feet of separation will allow simultaneous independent IFR operations and, thereby, function more efficiently than the four runway operation proposed in this report. With minimum cloud coverage or a reduction in visibility, the four-runway configuration will be effectively reduced to two intersecting and dependent runways -- a poor configuration for the capacity desired.
Page 15, 2.3.1 Comparison of Airfield Facility with FAA standards. ALPA believes that FAA minimum airport construction standards, particularly with regard to objects, roadways and railroads inside the RPZ, do not provide adequate protection for persons on the ground or in the air, as is the intent of the RPZ. We note that auto parking is proposed inside the runway 34L/R RPZs, contrary to FAA guidelines that auto parking not be permitted in the Object Free Area (OFA) extended, out to the far end of the RPZ.
ALPA supports reconstructing the runways as suggested to bring the runway ends into compliance with a maximum .8% grade and reducing the maximum longitudinal grade to 1% along each runway centerline.
The present 500-foot parallel runway centerline separations operationally reduces the parallel runways to single runways. Constructing new runways with centerline separations of only 700 or 800 feet is imprudent from both capacity and operational safety standpoints.
Page 16, 2.3.2 Runway Length Analysis. While the text in the first paragraph states that, "All relevant factors were considered," we believe several critical issues were omitted in an attempt to justify the consistent downwind departures on runway 7R/L, such as:
No mention is made of the effects of wet runways as a consideration in runway length requirements.
No mention is made of pilot opposition to operating from an 8,000-foot up-sloping runway (with numerous obstacles in the departure corridor) when a 10,000-foot runway is available, especially when the use of the shorter runway may be predicated on departing with a known tailwind. The pilot has the ultimate responsibility for the safety of the aircraft. The pilot may potentially expose himself to criticism and/or legal action if an aborted takeoff leads to a runway overrun when another runway, 2,000 feet longer, is available.
Takeoff performance was based on average temperatures. Peak daytime, summer temperatures will be higher than those cited and will further degrade performance.
The use of an 8,000-foot runway will, in many cases, provide only the minimum margins of safety (i.e., the runway length required and runway length needed are virtually the same). In the case of runways 7R/L, acceptable aircraft performance may provide the minimum obstacle clearance in the event of an engine failure, again reducing the margins of safety to the bare minimum.
Page 17, 2.3.3 Airfield Capacity. We believe the Annual Service Volume (ASV) is extremely optimistic for the following reasons:
Advisory Circular (AC) 150/5060-5 indicates an ASV of 225,000 for two intersecting runways, and an ASV of 295,000 for two sets of parallel runways, which is far short of the 350,000 ASV calculated in the study for Alternative A. Based on a 295,000 ASV, the 447,000 annual operations considered in the year 2020 would be more than 50% greater than the available ASV. According to Figure 4.3-1 of the Reuse Plan, the average delay per aircraft at 50% over ASV is between 13 and 24 minutes. AC 150/5060-5 also states that delays of individual aircraft may be 10 times the average.
ASV, by definition, does not consider surrounding airspace complications and effects. The potential interaction between north departures (significantly greater than alluded to in the reuse plan because of pilot-initiated preference for the longer runway) and traffic at John Wayne Airport will further reduce the effective capacity of the airport. John Wayne Airport should be closed if El Toro is opened as a commercial service airport to avoid this problem.
AC 150/5060-5 has not been modified to reflect the recent wake turbulence reclassification which significantly increased the number of aircraft placed in the Small category. Page 51, Table 3.5-6 indicates that an average day of the peak month will see commuter and general aviation comprising about 25% of the total number of operations. Prior to reclassification, almost all of these aircraft would have been classified as Large. After reclassification, most of this group is now Small; this requires additional separation behind Large and Heavy aircraft and greater takeoff restrictions behind them. The reclassification has typically decreased capacity by 8 to 12% and increased delays as much as 30 % at major airports throughout the country.
While it may be theoretically possible to use closely-spaced parallel runways in visual conditions, ALPA is concerned that such operations are potentially dangerous from both a wake turbulence and potential collision perspective. Assuming any significant increase in ASV as the result of simultaneous use of closely spaced parallel runways is of questionable merit.
ALPA believes that the capacity of the proposed airport will reach a position of undesirable delays considerably before the year 2020 and prior to attaining 447,000 annual operations.
Page 17, 2.3.4 Runway Wind Coverage and Utilization. Much of the discussion in the report centers around justification for the use of the parallel 34 runways with up to seven knots of tailwind for arrivals and the parallel 7 runways with up to five knots of tailwind for departure. ALPA understands that this proposed runway use emulates the military use of the runways and places the noise in the same basic location for the commercial airport as it has been for military use. We are also cognizant that other airports occasionally operate in a downwind flow, and that most air carriers do not prohibit operations in a tailwind environment up to the maximum certified tailwind value, usually 10 knots. We do find, however, that planning an airport with a runway usage which relies on downwind operations is unacceptable because:
Many of the airports cited in this section as operating with eight- to 10-knot tailwinds have longer runways, particularly departure runways, than the 8,000 feet planned for El Toro, with fewer obstacles in the takeoff flight path and less runway slope.
Wind components reported at the ATCT may not accurately reflect the winds at the liftoff area on the runway, possibly understating the tailwind component.
Large military transport aircraft which use El Toro today DO NOT routinely use Runways 7 for departure.
While air carriers may not prohibit downwind departures, we do not believe that any carrier would favor continued downwind use, particularly in light of the other negative aspects of the runway, including length, slope and departure obstacles.
Not addressed in the study is opinion of air carrier, turbojet-operating line pilots relative to the use of downwind operations on a continuing basis. It is our belief that had such data been obtained it would have shown overwhelming rejection of the use of Runways 7 in favor of either Runways 34, 16 or 25 for most air carrier departures.
Page 19, percentage use table. ALPA does not subscribe to the validity and operational soundness of the runway percentage use as shown for reasons stated above.
Page 22, 2.5.2 Airspace Considerations. ALPA strongly supports an aircraft simulation as described in this section performed prior to deciding on an airport configuration to understand and mitigate to the greatest extent possible interactions between John Wayne's general aviation operations and those at El Toro. This is a particular area of concern in ALPA's evaluation since we believe that many more departures will use the 34 parallel runways than are alluded to in the reuse plan. We believe that there will be a need for adjusting the present airspace structure to accommodate north departures at El Toro.
Page 27, 3.2.1 Approach. The existing separation standard for simultaneous approaches is 3,400 feet using the PRM. The FAA has successfully tested simultaneous approaches to 3,000 feet using the PRM and will likely adopt this separation standard in late 1996. While ALPA currently does not embrace approaches using PRM for various procedural and training reasons, we continue to work with the FAA toward final approval of PRM operations. It is our view, however, that the need for simultaneous ILS approaches to closely spaced parallel runways offers little capacity increase over dependent, staggered approaches to those same runways. The need to share the arrival runways with departures, or, in the case of narrowly spaced, triple parallel runways, the arrival to departure dependencies, requires arrival separation which is only marginally better in an independent simultaneous operation than it is in a dependent operation. The ASV in AC 150/5060-5 for two independent parallel runways is 315,000, prior to the impact of the wake turbulence reclassification.
There is an apparent contradiction between a comment made in this paragraph and elsewhere in the document. This paragraph states, "Although it would be feasible to construct parallel runways with a 4,300 foot centerline separation, that configuration would not result in approach and departure areas falling within those areas protected from residential and other sensitive land uses." However, on page 18, paragraph 3, the report says, "An important objective in determining the most appropriate runway use patterns for civilian operations was to take advantage of the areas that have been protected historically from residential and other sensitive land uses due to military overflights. These areas are the approach corridor to runways 34 (landings from the south) and the Runways 7 departure area (departures to the east)." Question: is the intent to protect the area to the north or south from noise impacts? If the sensitive area relates to the area north of the airport, then international flights departing runway 34 would be jeopardized.
Page 45, Military Aircraft Operations. The total number of operations projected for El Toro in 2020 is compared to the 1995 John Wayne operations of 473,000. This comparison must be viewed in light of the data presented in Table 3.5-3 which shows that general aviation is estimated to account for about 6% of the projected 447,000 annual operations at El Toro while general aviation constitutes about 79% of John Wayne's 473,000 annual operations. Therefore, it is impossible to drawn any conclusions about the present John Wayne traffic and what that might indicate as to projected traffic handling capabilities of the El Toro airport.
Page 46, 3.5.7 Average Daily Operations. ALPA believes that the computation of the average number of departures may understate the normal demand. Dividing the total annual fleet by 365 days distributes traffic equally over each day of the week. Air carrier traffic on Saturdays is normally less than that of weekday values. Therefore, the average daily operations, which reflect weekday numbers, should be increased to account for the reduction in traffic on the weekends. Using this adjusted average should also increase the Peak Day Peak Month number to more accurately reflect the weekday demand and delay.
Page 61, Table 4.1-1. It is our understanding that simultaneous arrival and departure operations on parallel runways could be independent below the 2,500-foot number stated under separation standards. This can occur so long as the near threshold is used for landing and an additional 500 feet of threshold stagger is provided for each 100-feet reduction in runway centerline separation down to a minimum of 1,000 feet separation. Applying these criteria would allow for the consideration of more options in runway geometry.
ALPA does not believe that there are wake turbulence criteria established for operations to parallel runways separated by 3,400 feet as stated in the Table.
Page 64, 4.2.1 Runway Length Analysis, Factors Affecting Takeoff Runway Length. The effect of runway contamination should be included as a "important determinant" of required runway length. Performance computations should have also included analysis of peak summer temperatures, not just the average maximum.
Page 64, Runways Analyzed. The report admits that, "Runways 16 and 25 would be less restrictive for departures than Runways 34 and 7, respectively, due to the downhill gradients and lack of terrain obstacles for Runways 16 and 25." This admission clearly points out that there is less safety and operational capability in using Runways 34 and 7 than there are in using runways 16 and 25 for departures. Furthermore, examination of the prevailing winds indicates that departures on Runways 16 or 25 would experience head winds for takeoff considerably more often than would runways 34 or 7.
Page 66-75, Charts 4.21-4.2-7, Performance Tables and Significant Findings. The charts contain a lot of details, but upon examination, they may mislead the reader. The charts reflect commonality between runway data generated for John Wayne and El Toro. More specifically, the data for runway 19R at John Wayne and runway 7R at El Toro mirror one another to give the impression that virtually no difference exists between them. However, to accurately compare the two runways, the charts should reflect the actual daily surface wind conditions. Depicting runway 19R with 7 knots of head wind and runway 7R with 7 knots of tailwind would more accurately depict the actual situation. Comparing both runways with calm wind conditions and then with 7 knots of tailwind misleads the reader. Also, missing from the data are the assumptions as to what distance the destination is from the originating airport, whether IFR alternates were chosen or if the performance is based on VMC weather at the destination airport. Of considerably more importance is the pilot acceptance issue.
Page 78, 4.3.1, Explanation of Airfield Capacity and Annual Service Volume. We have already spoken to the issues surrounding capacity and ASV. We believe that as pilots select preferential runways which differ from those set out in the Reuse Report, the interaction between arrivals and departures will increase delays significantly. This factor, coupled with what we see as an overstatement of capacity, will yield average and peak delays significantly greater than indicated in the Reuse Report.
Page 81, Table 4.3-1. The examples of airports with greater than the airport service volume given in this section is a rogues gallery of delay-prone airports, none of which offer qualities that should be emulated in the design of an efficient air carrier airport.
Page 82, Table 4.3.-2. ALPA is concerned that the hourly runway capacity may be considerably overstated for the following reasons:
New wake turbulence classifications which were not in place at the time the Reuse Study were completed which increase both landing and departure delays.
Lack of multiple IFR arrival and departure tracks which restrict the runway operations.
Only a small portion (6%) of the total operations are considered general aviation (some of those will operate under IFR); the vast majority of aircraft using the airport will operate under IFR in all weather conditions. Hence the airport will operate as if the weather was IMC even when it is not. Assuming that the airport can capture a significantly greater number of operations when the weather is good appears flawed. ALPA is also concerned that the increased capacity in VFR weather assumes heavy use of arrival and departure runways separated by, at most, 800 feet with multiple intersecting runways. We believe continuous use of runways in this manner greatly reduces safety margins for all the operators.
Page 85, 4.4.2 Runway Utilization. The runway utilization omits pilot preferences, safety margins and runway contamination, all of which are factors which ALPA believes are relevant to runway usage. The predominant winds of more than 6 knots for 75% of the year, according to historical data cited in this section, are from the west. Furthermore, "Winds over 6 knots from noon to 6:00 p.m. are relatively more frequent and are predominantly from the southwest through northwest." The FAA Air Traffic Control Manual (FAA Document 7110.65J, February 29, 1996, version) states that:
Except where a "runway use" program is in effect, use the runway most nearly aligned with the wind when [the wind is measured at] 5 knots or more, or the "calm wind" runway when [the wind is measured at] less than 5 knots, unless use of another runway:
1. Will be operationally advantageous or
2. Is requested by the pilot
1. If a pilot prefers to use a runway different from that specified, the pilot is expected to advise ATC.
2. At airports where a "runway use" program is established, ATC will assign runways deemed to have the least noise impact. If in the interest of safety a runway different from that specified is preferred, the pilot is expected to advise air traffic control accordingly. Air traffic control will honor such requests and advise pilots when the requested runway is noise sensitive.
It is ALPA's view that the use of a preferential runway for noise abatement was intended to be applied when all other factors between the two runways of possible use are very close to being equal. In the case of El Toro, the preferential runway for noise abatement is generally operationally inferior to the other runway. Therefore, ALPA contends that pilots would, on a continuing basis, request deviations in the name of safety from the preferential noise abatement runway, generating more noise than was promised and causing considerable ATC delays because of the frequent, yet unpredictable, pilots' requests for other departure runways.
Some airports do occasionally operate with higher than normal tailwind components, however, much of this use is during times of wind shift which occurs during high demand. ATC will continue to use the runways in a downwind scenario until the demand decreases, at which time the operation will be shifted to runways which operate more closely into the wind. During the normal operating day, few airports plan to continuously operate downwind, even though the aircraft certification limits may permit such operations.
Page 87, Table 4.4.-1. There is a very large difference between the "Maximum Tailwind Component Normally Accepted on Preferential Runway" as shown in the chart and the number of hours per year when that accepted tailwind is actually tolerated for takeoff operations. ALPA is opposed to continued downwind operations at any airport, not just in the planning of the use of El Toro.
Page 88-89, Table 4.4-2 and Figure 4.4-1. For the reasons stated in this letter, ALPA does not believe that the runway use percentages and arrival and departure flows shown are representative of the runway use that will be achieved at El Toro for safety, operational reasons and pilot preference.
Page 90, 7 Knot Tailwind Conditions on Runways 34. ALPA does not subscribe to the primary departure runway being runways 7, used approximately 69.8 percent of the time. We further believe that a much larger percentage of the departures would be conducted on runways 16 as well as both more arrivals on runways 7 and departures on runways 25 than is being considered.
Page 91, 5 Knot Tailwind Conditions on Runways 34. It is stated that, "The aviation alternatives evaluated in this report have been structured on the basis of operating with up to a 7 knot tailwind component." "To provide an airline perspective on tailwind operations, several major airlines which would potentially operate at MCAS El Toro were surveyed. None of the airlines have a policy against operating under tailwind components of 10 knots or less. The specifications of commercial aircraft provide for operations with a tailwind component up to 10 knots."
ALPA believes that while the airlines canvassed may not have policies against 10 knot tailwind operations, the more pertinent question would have addressed these airlines' opinions relative to continuous downwind operations on a runway with a positive slope with obstructions in the takeoff flight path -- particularly when longer, more operationally appealing runways were available. We are confident that the airlines, and particularly their pilots, would share ALPA's concerns in regard to these operations.
Page 93, Table 4.4-4. We do not believe that the runway use percentages shown in this chart accurately reflect the safest runway use, nor that which would actually be achieved based on pilots prerogative to choose a runway instead of the preferred noise abatement runway.
Thank you for the opportunity to comment on the reuse plan. We strongly encourage the County to reconsider its ill-advised proposal to adopt alternative A as the commercial airport operating configuration and, instead, adopt a configuration that will ensure both safety and capacity now and into the future.
Capt. Jon Russell
Western Pacific Regional Safety Chairman