Comments from a commercial airline pilot to the County of Orange regarding El Toro Airport EIR 573
Proposed Orange County International Airport.
Ladies and Gentlemen:
I am writing you concerning safety and transport category aircraft performance issues with respect to proposed air carrier operations at former MCAS El Toro as given in various Technical Reports and Appendices of the subject EIR.
Summary of Findings and Conclusions:
El Toro is surrounded by terrain obstacles requiring exceptionally steep climb gradients on all runways the County proposes to use. The intersecting runway configuration is inherently hazardous; no such runway system has been commissioned in over fifty years at a major airport for this reason. The County’s runway usage proposal for takeoffs is based upon a preferential runway system that is unsafe because of severely upsloping runways, rising terrain, prevailing tailwinds, an unorthodox low-altitude special procedure for engine-out situations, and a high potential for wildlife collision over a habitat preservation area and landfill in the immediate vicinity of the airport. For these reasons, easterly and northerly departures will be unacceptable to airline operators and their pilots under virtually all conditions. Further the County’s assumptions and conclusions on runway usage and flight patterns are in conflict with data in its own technical reports and are therefore invalid. If the airport is commissioned, there will be noise and environmental impacts that have not been accounted for in the EIR.
There were also errors in accident accounting at El Toro that appear to make the airport safer than it is. There are incorrect assumptions about circling approaches with large aircraft. The airport may not be usable during periods of rain and frontal passages due to exceeding tailwind limitations. The primary instrument runway to the north has man-made obstacles, a rail line and trains upon it, in the runway protective zone as well as terrain obstacles in the missed approach area. This precludes use of low visibility approaches. The impact of these issues is economic: the airport will not be able to be operated as an all-weather airport which will result in diverted flights, and consequent losses of revenues by air carriers.
Background: I am presently a Boeing captain for a major airline with 27 years of service and 21,000 hours of flying and have a particular interest in aircraft performance. Having served 34 years active and reserve duty in the Marines, retiring as a colonel in 1994, I am also familiar with El Toro. I flew from El Toro regularly as an aviator from 1966 to 1986 and was a fighter attack squadron commander there in 1984 -- 1986. I have no opinion as to the desirability of converting El Toro into a commercial airport as proposed in the Environmental Impact Report. I do, however, have a strong interest that operations conducted from such an airport be carried out safely and in accordance with Federal Aviation Regulations. The opinions I express here are my own. The comments and questions herein relate to the proposed commissioning of an air carrier airport at the site of former MCAS El Toro.
Issue: Intersecting Runway Operations
Comment: “X” Runway Configuration Hazard. The County proposes that future operations at El Toro will be in an intersecting or “X” runway configuration. This type of configuration with criss-crossing traffic is inherently more dangerous than parallel, non-intersecting runways by several orders of magnitude. Contrary to the County’s assertion that “[Such] runways are common at commercial airports throughout the U.S.” (Appendix M, Technical Report; Public Safety, p.51), they are not. The few air carrier airports that still have this configuration, notably San Francisco International and New York’s La Guardia, were laid out over half a century ago in the propeller aircraft era. These airports are consequently leaders in the list of traffic delays because good visibility is a requirement for their operation. They are also leaders in the category of hazardous airports.
As to the nature of the hazard, I will cite two recent examples. In 1999, there was a near mid-air collision between two airliners over the runway intersection in clear weather caused by a brief lapse of an air traffic controller. The aircraft passed within a few hundred feet of each other. The second example happened to me personally. Some months ago I was just about to land my Boeing to the west at San Francisco when I was directed to go around. A Boeing 757 was slow to accelerate during takeoff on an intersecting runway and as a result, we pilots had the highly unpleasant sight of the 757 filling our windscreen at an altitude of a few hundred feet over the intersection of the runways. Apart from the County of Orange, no knowledgeable person or organization that I know of argues that such unsafe relics of the past ought to be commissioned or built today.
Question: “X” Runway Configuration; Can the County cite any example of an air carrier airport designed or commissioned anywhere in the last 50 years with an “X” configuration?
Comment: El Toro Historical Runway Use, Preferential Runways, and Captain’s Authority: From the various EIR documents it is apparent that the County believes that future operations at El Toro Airport with respect to runway use must conform to what the Marine Corps did from 1969 to 1999, no matter how ill-suited and unsafe they might be for airline operations. In late 1968, I was Operations Officer of a Marine F-4 fighter attack squadron at El Toro when the Commanding General, 3d Marine Aircraft Wing and the Commander, Marine Corps Air Bases, Western Area directed that tactical jet departures be henceforth conducted to the east on Runways 7L and 7R.
As I recall, we were not given explicit reasons for this new policy, but we generally understood that this was to mitigate noise over the new city of Irvine. Up to that time, jet departures had been conducted in the safest direction, which was normally to west on Runways 25L and 25R into the prevailing wind, downhill, and away from terrain. Although every aviator recognized that easterly departures violated basic rules of flying by taking off with a tailwind into rising terrain on severely upsloping runways, the directive had the force of a military order, and we complied. The directive did not apply to airline charters, military airlift transport operations, or even tactical jets if they were heavily loaded. Transpacific flights of tactical jets invariable took off to the west. As for charters and airlift flights, after the tragic Air Force C-135 crash on Loma Ridge to the north in 1965, all of these aircraft without exception so far as I am aware, landed to the north and took in the opposite direction to the south. The reasons for this were simple: they were the only safe and practical directions, and so it remained until the base closed.
The County asserts in its EIR that new airliners are more powerful and have better performance, and therefore, are not constrained to the runways that were used in the past. This reflects a basic lack of knowledge about the subject of aircraft performance and regulations regarding civilian transport category aircraft. It is true that over the past 46 years since jet airliners have come into service, engines have gotten more powerful and airframes have gotten somewhat more aerodynamically efficient. However, these improvements have been accompanied by steady increases in aircraft gross weights rather than by increases in aircraft performance. The net effect on engine-out performance, the standard to which, unlike the military, all air carriers must conform by federal aviation regulations, has not changed very much. In fact with the advent of two-engine jet aircraft, now overwhelmingly the most common type being produced, net engine-out performance has actually decreased compared to earlier three- and four-engine aircraft. This fact must be considered in any analysis of runway use at El Toro, and may be confirmed in the two volumes of Jeppesen Analyses that are part of the ASMP.
In Appendix E, Technical Report: Noise Analysis and Appendix M, Technical Report: Public Safety, the County justifies its use of adversely situated runways by promoting a Preferential Runway system. Perversely, the least two favorable takeoff directions from a safety standpoint, east on Runways 7 and north on Runways 34, are the designated preferred runways. Both directions have prevailing tailwinds, upsloping runways and rising terrain immediately ahead. Each of these factors violates safe flying principles. Both sets of runways require some of the steepest climb gradients in the world and mandatory unorthodox and hazardous engine-out special procedures. It has never been the intent of any civilian preferential runway program that I know of to promote less safe operations. Rather the program is intended to help pilots select runways that are the least noise sensitive when there are no other operational factors to consider. Unfortunately, El Toro has many obstacles to a safe airline operation.
Yet the County gives a strong emphasis in its EIR and technical reports that pilots will somehow adhere to preferential runways with statements like: “The noise modeling program assumes civilian aircraft will use the existing flight corridors as much as possible.” (Noise Analysis, p. 60), “The pilot normally does not have the discretion, in practice, to choose a runway that is counter to the existing flow of traffic.” (Public Safety, p.55), and finally, “…large air carrier airports typically operate at maximum tailwinds of 6 to 10 knots.” (Ibid. p. 53) and lists California and Arizona airports that allegedly operate with such tailwinds (Ibid. Table 21, p. 54).
The first statement’s assumption cannot be supported by the data in the EIR’s Jeppesen Analyses and the Instrument Flight Procedures Analysis (TERPS). On the contrary, both of these studies both explicitly and empirically indicate which runways are safest for takeoff: to the west on Runways 25 and south on Runways 16. The entire history of jet transport operations at El Toro support this statement as well.
The second statement is false. The pilot-in-command always has the discretion to choose a runway based upon the pilot’s assessment of operational factors and safety. This happens every day hundreds of times at airports with preferential runway programs. Although requesting a non-preferential runway may result in a delay, as the County acknowledges, “Air traffic control will honor such requests…” (FAA, Air Traffic Control, manual, section 3.5.1).
The third statement is false. Over the past 28 years I have flown hundreds of times from all the airports listed in Table 21, Public Safety, p. 54, none of which have such adverse runway slopes and terrain as does El Toro. I have never knowingly performed, or seen performed, a takeoff with a tailwind exceeding about three knots, nor have I seen or performed a landing in a tailwind exceeding about five knots at any of them with the exception of Los Angeles for landings after midnight. Regardless of what is shown in Table 21, the reality of airline operations is that tailwinds of only a few knots are acceptable to pilots for takeoff on an occasional basis, as opposed to the continual basis that the County is proposing. Even then, there must be no complicating factors like short runways, terrain, or slope. With any of these factors present, it is not unusual for pilots to refuse tailwinds as light as a single knot. On this issue I believe any experienced line pilot or tower air traffic controller would give essentially the same answer.
It seems to me that the County’s EIR writers do not fundamentally understand the difference in the authority of a military aircraft commander and the pilot-in-command (captain) of a civilian aircraft. When I served in the Marine Corps as a pilot, and the wing and base commanders ordered us to carry out the easterly takeoff directive despite its being contrary to basic principles of flight safety, we obeyed the order. Military commanders have the authority to order pilots to take risks. The reverse is true in civilian flying. Federal Aviation Regulations give final authority as to the operation of an aircraft to the pilot-in-command (captain). No matter how badly the County of Orange wishes it weren’t true, as captain no one can compel me to take unnecessary risks.
To amplify this further: at the most basic level, airline operators and their pilots are managers of risk. My airline likes to teach its pilots to assess risk using the analogy of an imaginary “risk-o-meter.” Takeoffs to the east and north basically involve maximum performance situations for virtually every takeoff. There is little or no margin for error. Therefore, the “risk-o-meter” would be pegged into the red sector. When safer alternatives exist, as they do in these situations, a reasonable and prudent pilot will take them. As a practical matter, the decision will likely be taken out of the hands of the pilots because a major airline as well as the two largest pilots’ unions – representing a large majority of north America’s airline pilots -- have already informed the County that they the risks entailed are too high.
Question: Does the County dispute any of the forgoing comment?
Question: Given that the pilot-in-command is the final authority in the operation of an airliner, and in view of the responses of the writer, airlines, and pilots’ unions so far, on what basis does the County believe that preferential runways will be used to any extent?
Issue: Easterly Takeoffs by Transport Category Aircraft on Runways 7L and 7R
The Airport System Master Plan (ASMP) postulates that about 62 per cent of all departures will be to the east at El Toro after the runways are rebuilt to conform to federal standards for runway slope as set forth in FAA Advisory Circular 150/5300-13 (with revisions): "Airport Design."
Question: Interim Operations from Runways 7: As far as I am aware, El Toro’s current east-west runways are the steepest sloping (more than 1.5%) of any used by jet aircraft in the world and exceed federal standards for air carrier airports. Until Runways 7 are rebuilt, does the County propose that they will be used for takeoffs and landings? If so, what written assurances does the County have that the FAA will certificate them under 14 Code of Federal Regulations (FAR) Part 139? Further what assurance does the County have that any air carrier will certify them for use under FAR 121?
Comment: Rebuilt Runways and Climb Gradients: The County proposes a massive rebuilding of Runways 7 to a gradient – depending on the document one reads – of 0.89% to 1.1%. This takes the runways from the category of “steepest in the world” to that of “one of the steepest in the world”. As far as I am aware, the steepest runways in North America in regular use by air carriers are at Las Vegas McCarran International in Nevada and have slopes of approximately 1.00%. It should be noted that, unlike El Toro, there are no terrain obstacles immediately near the airport and that Las Vegas has one of the longest runways in the world at 14,505 feet to cope with adverse slope. Moreover, despite a preferential runway program in place, they are not routinely used with tailwinds.
The proposed rebuilding of the runways is rather like “trading a headache for an upset stomach.” A pilot attempting a takeoff to the east is still presented with the triple safety threat of severe upslope, rising terrain, and prevailing tailwinds, each of which is a breach of basic flying principles. The proposed new runways amount to a superficial solution that does not fundamentally solve the safety issues involved here. In this case, it would slightly reduce the runway slopes, but at the same time it also would increase the climb gradients immediately beyond the upwind runway threshold.
As an airline captain with the final responsibility for the safe operation of an airliner, there might be circumstances where I could accept one of these decrements to safety. Only a reckless or a very inexperienced pilot would accept three. It is obvious from the Jeppesen takeoff performance analyses discussed below that any aircraft operating from Runways 7 will be at or very near the maximum runway allowable takeoff weight. There simply is no margin for even the slightest error such as a puff of additional tailwind or a misloaded overweight aircraft. In my experience, regrettably both of these circumstances do occur in the real world of airline flying.
As a veteran of hundreds of soul-searching takeoffs to the east at El Toro, each of which occurred as a consequence of a military order, I will cite just one example to illustrate how marginal takeoffs to the east at El Toro can be. In about 1992 a TA-4J fighter attack advanced trainer operated by the Naval Aviation Training Command failed to get airborne on a routine easterly takeoff from El Toro and crashed. As far as I am aware, there was nothing mechanically wrong with the aircraft. The TA-4J has a thrust to weight ratio that exceeds the Boeing 757-200 with both engines at full power by over a third, yet the 757 is one of the best performing airliners now in service.
Another hazard is a high potential for collision with wildlife, particularly birds, in a proposed 970 acre wildlife habitat area immediately adjacent to the east of the airport. Even though the County proposes to fence the airport to protect against ground collisions, this will be ineffective against large birds such as hawks and turkey vultures that typically congregate over such areas. In my opinion, wildlife habitats and major airports are not compatible land uses. This opinion is shared by the National Transportation Safety Board, the FAA, and the U.S. Department of Agriculture, Wildlife Services. The latter two agencies have recently collaborated in the production of a manual on this subject: E.C. Cleary and R.A. Dolbeer, Wildlife Hazard Management at Airports, (Washington: FAA/USDA, December 1999). The proposed El Toro airport does not appear to conform to these government standards.
Question: Does the County dispute any of this comment?
Question: Does the County intend to conduct a wildlife assessment in consultation with the U.S. Department of Agriculture Wildlife Services as part of its FAR 139 Airport Certification process as recommended by the National Transportation Safety Board?
If so, and the proposed 970 acre wildlife refuge immediately to the east of the airport is determined to be an incompatible land use, what does the County propose to do with respect to the El Toro airport?
Comment: TERPS, the Jeppesen Analyses, and Engine-out Special Procedure. The County commissioned Jeppesen Sanderson, Inc. to do two volumes of takeoff performance analyses for various jet transport aircraft from El Toro. As far as they go, the data appear to be correct. However the entire mass of this data for Runways 7L and 7R rests on the assumption that airline operators and pilots will accept a very unusual and extremely hazardous “Special Procedure” for engine out situations when departing to the east. For reasons noted below, I believe no airline operator or any airline captain will ever accept such procedures.
At the urging of the Air Line Pilots Association, the County also commissioned an analysis of El Toro using criteria set out in FAA Order 8260.3B, United States Standard for Terminal Instrument Procedures (TERPS). This became K & M Consultants’ Instrument Flight Procedures Analysis dated May 1998 and is part of the EIR. It appears to be a competent body of work. To give the authors of the EIR benefit of the doubt, the TERPS and Jeppesen reports are difficult for laypersons to grasp. In any case, however, the writers of the EIR have utterly failed to understand how badly this information impacts the kind of airport they are proposing.
First there is the matter of climb gradients. East departures require an initial climb gradient of 360 to 400 feet per nautical mile. Although the County believes this is “safe”, the fact is that these gradients are extraordinarily steep. By way of comparison, I did an analysis of the standard departures for all 167 airports that my airline is authorized to use in North America. The list includes virtually all of the most challenging airports presently used by American jet air carriers. Only two, Missoula, Montana and Eagle, Colorado, had steeper gradients in their departures. Both of these airports require special procedures for engine-out situations and both are characterized by severe payload reductions as a result. However, I am unaware of any special procedure anywhere that requires pilots to turn so low to the ground as does the one for Runways 7 at El Toro. As will be discussed later, the climb gradients for departures to the north are even worse.
However, as bad as these climb gradients are, the required special procedure for engine-out situations is much worse. Airline operators are required by FAR 121.189 to account for all obstacles in the takeoff path by doing a performance analysis for each runway they propose to use. In the case of El Toro there are significant obstacles to the east. To clear them, weight penalties in the form of reductions in payload and/ or fuel must be applied to the allowable takeoff weight. Because the obstacles directly east are so high and close, Jeppesen proposes that a mandatory takeoff “special procedure” be used.
The procedure requires a prompt right turn from Runway 7L at 0.8 nautical miles and from 7R at 0.9 nautical miles respectively from the NZJ VOR located at N33 40.6 / W117 43.8 to a magnetic heading of 170 degrees. To put this in spatial context, this means that an aircraft taking off from Runway 7L after an engine failure must begin turning at about 900 feet from the end of the runway at an extremely low altitude. The pilot must continue turning right for a total 95 degrees of turn. On runway 7R the aircraft must turn at about 1200 feet from the end. At the conclusion of the turn the aircraft will now be pointed at oncoming traffic landing to the north, the primary direction for landing. The track of the special procedure takes the aircraft over densely populated residential and commercial areas in Lake Forest, El Toro, and Laguna Woods at very low altitudes.
I note here for the record that my company, along with most if not all other major airlines, does not permit its pilots to make any significant turns -- i.e. - more than 10 - 15 degrees of heading change -- until reaching an altitude of 400 feet above ground level (AGL). This altitude is unobtainable at these distances from the end of the runway for this procedure.
From the pilot’s perspective, special procedures are created for airports located in difficult terrain like El Toro. They are used only to cope with one of the gravest emergencies any pilot can face: engine failure at takeoff. The most important thing about them is that they must work. They must work during an extraordinary stressful time, at night and in bad weather. The only alternative is disaster. The problem with El Toro’s special procedures is that they really can’t work. There are simply too many factors stacked against a successful outcome.
To help the reader better understand this statement as well as the minimum performance required by FAR’s, I offer the scenario of a Boeing 767-300 which experiences an engine failure at the “go no-go” point of the takeoff. Like most takeoffs from Runways 7, the aircraft will be at maximum allowable takeoff weight because of slope, terrain and tailwinds.
The captain elects to continue the takeoff. If the wind holds exactly steady and the aircraft is loaded exactly as calculated, the 767 attains 35 feet above the end of the runway, and transitions to a minimum of 2.4 per cent gradient, the minimum required for a two-engine aircraft. It is also close to the maximum attainable in this situation. Because the terrain at the end of the runway is rising at about 1.57 per cent, the aircraft's net climbing path is only 0.83 per cent with respect to the ground. At a point 900 feet from the end of the runway, the special procedure requires the pilot to make a 15 degree banked turn to the right to avoid terrain ahead which it cannot safely clear in this situation. However, turning an aircraft immediately after an engine failure violates a fundamental rule of multi-engine flying. An additional complication is that this maneuver must be carried out by reference only to instruments because the nose-up attitude will block the view of terrain immediately forward of the aircraft. The pilot cannot see what is ahead even if were daytime.
As the pilot commences the turn, the altitude above the ground is only 43 feet. The wingspan of the Boeing 767-300 is 156 feet. The regulations recognize that an engine failure at takeoff is among the most demanding maneuvers required of airline pilots, so they allow a 15-degree overshoot as a safety margin. At this point, my calculations show that the right wingtip is only about twelve feet above the ground. Worse, because the wings are no longer perpendicular to the ground, there is a loss of vertical lift, and the already minimal rate of climb will decrease further. The slightest gust of wind could cause the wingtip to hook the ground with an ensuing catastrophic cartwheel. At the completion of the turn, the aircraft is pointed to oncoming arrival traffic. The non-flying pilot attempts a radio transmission to notify air traffic control of the situation, but El Toro is a busy airport, and the transmission is blocked by other aircraft, unfortunately an all too frequent occurrence. The aircraft’s traffic alert and collision avoidance system (TCAS) detects the oncoming traffic and begins blaring a warning to climb or descend. The pilots can do neither. I leave the rest to the reader’s imagination.
A similar scenario was presented to the County in response to the previous EIR for El Toro. The answer in effect was “there is no problem with this.” On the contrary, there is a very big problem with this. I am not the only airline professional to take issue with this. In filings to the County, the Air Line Pilots Association as well as a major airline, American Airlines and its pilots union, the Allied Pilots Association, have all clearly indicated they will not consider use of easterly departures for substantially the reasons listed above. Yet despite these unambiguous statements, the County persists in its position that easterly takeoffs are safe and therefore possible.
Question: Does the County dispute any of the forgoing comment?
Question: If airlines and pilots reject use of easterly departures, what flight patterns and runway usage does the County anticipate?
Issue: Departures to the north on Runways 34.
Comment: Much of the comments about east departures also apply to north departures with respect to runway upslope, prevailing tailwinds, terrain obstacles, and a hazardous special procedure. The climb gradients are even higher at 410 feet per nautical mile. Even more problematical is the special procedure.
The County states that aircraft that cannot use runways 7 for takeoff will takeoff to the north on Runways 34. These generally will be larger, long-range aircraft such as the Boeing 747. Again the factors of upslope, tailwinds and terrain will place each of these takeoffs in the maximum performance category. Again engine-out situations require a special procedure to avoid impacting terrain immediately north of the airport property as well as Loma Ridge farther out. The aircraft must be turned to the left approximately 900 feet from the end of the runway for 130 degrees total turn. Assuming the aircraft reaches its required minimum of 35 feet above the end of the runway and transitions successfully to a 3.0% climb gradient, the minimum for a four engine aircraft, the aircraft will be about 62 feet above the ground when it begins its turn. The wingspan of a Boeing 747-400 is 211 feet. As far as I am aware, not even the Navy’s famed aerobatic team, the Blue Angels, bank their aircraft at less than a half wingspan above the ground. Neither will airline pilots. This special procedure requires a maneuver that is far too hazardous so close to the ground, especially with the aircraft in an already highly critical phase of flight. It therefore cannot be acceptable to airlines or to airline pilots.
There is an additional, even more serious, decrement to safety to north departures: the County of Orange’s Frank R. Bowerman landfill site, located about 11,000 feet northeast of Runways 34. The landfill attracts large numbers of gulls and other large birds such as the turkey vulture. The gulls migrate to the dump from Upper Newport Bay on a route that crosses the departure path of Runways 34 at a distance of about 8000 feet. Heavily loaded airliners will pass through this flyway with a high potential for collision with birds. There have been relatively few, if any, collisions with birds to the north of El Toro for the simple reason that virtually no jet aircraft have operated in this area since the tragic crash of the Air Force C-135 jet transport in 1965. Although the County downplays the risk in Appendix M, Technical Report: Public Safety, pp. 46, 74-76, it does not do so with any persuasive arguments. Further, the landfill site location is incompatible with the criteria set forth in FAA Order 5200.5A, Waste Disposal Sites on or Near Airports. One of the most frightening moments I have ever had in an airliner was the impact of a single gull on the captain’s windshield at low altitude at a fairly low airspeed. The prospect of flying through a flock of gulls just after takeoff at a critical phase of flight is a horrifying recipe for disaster and, therefore, is intolerable to airlines and airline pilots. I invite anyone who might dispute this statement to go to the Bowerman landfill on any winter day and watch the migrating and spiraling flight patterns of gulls extending into the sky
Question: Does the County dispute any of the forgoing comment?
Question: If airlines and pilots reject use of easterly departures and northerly departures, what flight patterns and runway usage does the County anticipate?
Question: Does the County intend to close the Bowerman landfill
prior to commissioning El Toro airport?
History of Aircraft Accidents at El Toro (Appendix M, Technical Report: Public Safety, p.2).
Comment: List incomplete, Terrain Accidents Missing. The research done for this list was incomplete. Six accidents that I am aware of were omitted. There are probably more. Interestingly, El Toro’s location in difficult terrain was a factor in most of them. They are:
Aircraft Type Location Approx. Date Custodian/Remarks
Late ‘60s MCAS El Toro; Military
airliner, Rwy 7 takeoff
F-4B Laguna Beach 1967 3dMAW, MAG-33, VMFA-122
F-4B W-291 1969 3dMAW, MAG-33, VMFA-531
F/A-18A off Dana Point mid-80s 3dMAW, MAG-11,
F-4N on base 1985 4thMAW, VMFA-134 Rwy 7 T/O
TA-4J on base 1992 CNATRA, Rwy 7 takeoff
Comment: Demonstration Flights, December 1999. I observed the demonstration flights at El Toro. These flights were conducted under FAR 91 basic flying rules rather than under the more rigorous FAR 121 regulations that govern air carriers. Contrary to statements by County representatives in the media, it was apparent to me that the aircraft were very light and not being flown at weights that were typical of normal airline operations. The operation of airliners at very light weights tend to greatly mitigate noise impacts because the climb gradients they attain is much greater than normal.
Question: Is it the County’s contention that the aircraft used in the demonstration flights were being operated at weights typical of those in normal airline service?
Comment: Railroad Obstacles in the Runway Protection Zone for Runways 34: The Instrument Flight Procedures Analysis (TERPS) report indicates that Category II and III approaches are feasible to Runways 34L and 34R. Category II and III instrument landing systems (ILS) are a standard facility at all major airports. Yet the same report on p.1-5 states that terrain in the missed approach area will limit the approach to that of higher minima of a Category I ILS. Therefore the airport will not be able to operate to Category II or III minima. An active rail line passes through the RPZ of Runways 34, which is both an obstacle and can disturb ILS signals at a critical stage of flight. The issue is not clearly addressed in the TERPS report.
Question: Does the County intend to commission Category II or III ILS at El Toro, and if so, what minima will be possible?
Question: An active rail line passes through the Runway Protection Zone, which is an obstacle and can affect ILS signal propagation. Does the County have plans to mitigate this hazard, and if so, what are they?
Issue: Circling Approaches to the South, Noise Impacts for Landings to the East.
Comment: El Toro’s runway configuration is particularly unsuited to approaches and landings during periods of rain and frontal passages when wind blows from the east through south. This condition occurred during the demonstration flights of December, 1999 when aircraft were unable to take off to the north because the tailwinds exceeded aircraft limitations. In these conditions the County proposes that aircraft will make circling approaches to land to the south in ceilings as low as 800 and visibilities of 2 ½ miles. For the record, my company, like other large airlines, does not allow circling approaches with ceilings of less than 1000 feet and visibilities of less than three miles. The weather is generally worse than this during rainy fronts. Because of Loma Ridge and the descent rates and tight turning radii required in such approaches, I do not believe airline operators or pilots will accept them. The TERPS report indicated that Category I approaches are “feasible” to Runways 7 although I note that the missed approach procedure is marginal due to terrain to the east. From a pilot’s perspective it is Hobson’s choice: Runway 7 or not at all. Appendix E: Technical Report, Noise Analysis, does not show the approach tracks and noise impacts for this approach, yet there will be noise impacts over Newport Beach, Costa Mesa, and Irvine.
Question: Does the County dispute any of this comment?
Question: If landings on Runways 7 are the only practical way to land at El Toro in the above conditions, what will be the consequent noise impacts?
I request a written answer to these comments and questions, and look forward to receiving your answers. Please feel free to call on me if I can be of assistance.
Charles J. Quilter II
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