October 22, 2001
Orange County Board of Supervisors
10 Civic Center Plaza
Santa Ana, California 92701
RE: El Toro Airport Environmental Impact Report
The Allied Pilots Association (APA) would like to restate our objections to the conversion of MCAS El Toro to a civilian commercial service airport. The APA has long opposed this proposal as evidenced by our letter dated February 15, 2000 from Captain Rich LaVoy, APA President to Mr. Brian Speegle (see attached). Our fundamental position has not changed in the intervening 20 months, so I will not repeat the specifics of that letter. Rather, I will take this opportunity to outline the failures in the present discussion.
The proposed configuration for the El Toro departures imposes many hazardous restrictions that force air operations unacceptably close to the limits of aircraft performance. The primary departure runway 8 has a 1.53% slope and a prevailing tailwind departing into rising terrain. This places aircraft in a position requiring performance at or near certificated limits on runway slope (2%) with an additional decelerating effect of a tailwind. The projected velocity of these tailwinds is also a concern to us. One Environmental Impact Report (EIR) stated that the winds would be westerly at 8-10 knots. Another EIR stated that 44% of the time between 12 and 6pm winds would be westerly at 6.5 knots. Most commercial aircraft have a maximum certified tailwind limitation of 10 knots. Thus, the expected operating scenario of the airport places the aircraft dangerously close to its certificated limits regarding tailwinds while also placing it dangerously near the certificated limit for runway slope. Thus, flight crews will be forced to operate in an environment where wind gusts could easily place the aircraft outside its certified performing envelope departing into rising terrain. Simply stated, this plan is dangerous and unrealistically optimistic.
Our concerns are exacerbated by the fact that the wind measurements being used for this analysis do not reflect current standards. Wind measurements for the EIRís were taken at a 9-foot elevation instead of 10 meters (32.8 feet) as required by current regulation. Our engineering staff feels that an increase of up to 5 knots could easily be expected due to variations occurring within the surface boundary layer. This is significant enough to warrant another wind study using current standards. Even if a 3-knot variation is observed, the change would require a significant number of westerly departures.
Finally, the current plan also fails when considering the requirements of FAR 25.115, which states that aircraft must be capable of achieving specific engine-out climb gradients above the terrain. The required 450 feet per nautical mile gradient (7.4%) for runway 35 will require drastic reductions in payload to operate at FAR required safety margins. Meeting this engine out climb gradient will leave virtually no margin of error in pilot technique if and when an aircraft experiences an engine failure on takeoff.
In summary, the Allied Pilots Association opposes the use of eastbound departures and the use of runway 8, which would require pilots to take off into rising terrain with tailwind and runways with an uphill slope. In addition we oppose the departure climb requirement and departures to the north (runway 35) that would not allow pilots to turn to the south to avoid terrain. Considering that this runway will be used primarily by heavy aircraft, the situation mandates unacceptable risk to both aircraft and local residents. Finally, the wind data being used for this study is obsolete and should be re-evaluated using current FAA standards.
The Allied Pilots Association is committed to the safe operation of our aircraft. We appreciate the opportunity to point out the shortcomings of the El Toro conversion effort thus far, and will continue to be active as a strong and steady advocate of safety as the plan develops. In the final analysis, it is essential that safety, not politics, should define the departures and arrivals at this proposed airport.
Captain John Darrah President
Allied Pilots Association