The following is a summary of the extensive October 1996 comments on the Draft Environmental Impact Report, prepared by the El Toro Reuse Planning Authority. ETRPA is comprised of representatives of the Cities of Dana Point, Irvine, Lake Forest, Laguna Hills, Laguna Niguel and Mission Viejo. The summary was prepared by ETRPA.
On August 8, 1996, the County of Orange released its Community Reuse Plan & Draft Environmental Impact Report (DEIR) for MCAS El Toro. The ETRPA Master Consultant Team has been assigned the responsibility of conducting a comprehensive analysis of the information contained in the aforementioned documents, and forwarding comments to the County of Orange on behalf of ETRPA by the comment period deadline of October 15, 1996. In addition, staff from each of the ETRPA agencies are also reviewing the Reuse Plan and DEIR.
The County of Orange El Toro Community Reuse Plan and DEIR identify 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. A number of issues have been identified regarding these proposed uses and the accompanying DEIR. Each area of concern is discussed below.
Aviation Demand
The County of Orange has failed to respond to previous comments
on the Preliminary Aviation Market Demand Assessment (PAMA) and the Notice
of Preparation (NOP) regarding the total demand for air passenger service
in the Southern California region and demand for a 38 million annual passenger
(MAP) airport at El Toro.
The County's air passenger demand analysis is based on only three variables; population, per capita income, and air fares. The DEIR does not identify sources for the assumed values of these variables, nor include a sensitivity or risk analysis which identifies and discusses their tendency to fluctuate significantly, nor include an analysis of other factors such as employment, household income, disposable income, household size, age, licensed drivers in the household, etc. Consideration of these additional variables would result in the generation of more accurate passenger demand forecasts. In addition, the DEIR's future population projections are inconsistent with accepted South Coast Air Quality Management District (SCAQMD) regional, socio-economic data. Similarly, the air fare projections are inconsistent those provided by the Federal Aviation Administration (FAA).
When the more authoritative projections of the SCAQMD and FAA are used, the County's methodology predicts a reduction in the regional air passenger demand from 175 MAP to 146 MAP. Based on the County's own assumptions, this level of regional air passenger demand can be accommodated by other area airports without air passenger service at El Toro.
The County's efforts to validate its air passenger projections based on comparisons to other air passenger forecasts are inconclusive. The greatest discrepancies between the forecasts occur in the period from 2010-2020. Only one other projection addresses this period, and it was prepared by the County's previous consultant. In fact, the County's effort to plan facilities up to the year 2020 contravenes FAA guidelines which emphasize planning for the initial 5-10 years.
The DEIR anticipates a significant number of passengers from outside Orange County, including persons from the Inland Empire, and Los Angeles and Ventura Counties. The DEIR should substantiate this information as well as why no analysis of business and employee attraction from outside Orange County was provided for Alternative C.
Number of Flights
The County projects the need for 447,000 annual flights to accommodate the
projected 38 MAP. However, the methodology for determining this number of
flights is not adequately addressed within the DEIR. Based on the County's
estimates, the ratio of total flights to million annual passengers is the
lowest of the thirty busiest airports in the nation. As a further example,
the average number of passengers per flights is estimated to be 85. In contrast,
eight of the ten largest airports in the nation have passenger to flight
ratios in the 50s, 60s, and 70s. Only John F. Kennedy in New York and San
Francisco International have higher passenger to flight ratios than projected
for El Toro. Therefore, a more conservative estimate of the number of flights
necessary to accommodate the projected demand is somewhere approaching 650,000
flights per year. Such an increase in the number of flights will, of course,
increase the impact of flight delays, noise, and air pollution among others.
Airport Capacity
One measurement of an airport's capacity is its Annual Service Volume (ASV),
the level which allows for an average delay per flight of up to four minutes.
The County has determined the ASV of Alternative A to be 350,000 annual
flights. This estimate appears to be based solely on the existing configuration
of the runways at MCAS El Toro as the only limiting factor. SCAG's estimate
of the ASV of El Toro is only 250,000 annual flights. It is possible that
the County has not considered other limiting factors such as taxiway capacity,
airspace capacity, aircraft safety procedures.
The County correctly notes that it is not uncommon for busy airports to operate at 1.2-1.5 times their ASV and have average delays in excess of four minutes. Based on the County's projection, El Toro would operate at 1.28 times its ASV. It should be noted in the DEIR that this would result in average delays of 8.5 minutes per flight at a total cost of $98 million per year (based on the 1987 actual average aircraft operating cost of $1,587 per hour as quoted by the FAA). However, if the actual ASV is only 250,000 annual flights as suggested by SCAG, and the actual number of annual flights is 650,000, El Toro would operate at 2.6 times its ASV. The average delay would exceed 24 minutes per flight (the rate for facilities operating at 1.5 times ASV) at a cost well in excess of $412 million.
Operational Constraints
The DEIR ignores several technical aviation constraints of the anticipated
operating patterns proposed for a commercial airport at El Toro. Specifically,
the Air Line Pilots Association (ALPA) and the Air Transport Association
(ATA) have cited that the gradient of the primary departure runway (Runway
7) exceeds FAA standards, departures on Runway 7 would be hindered by tailwinds,
and concerns about the proximity of Lomas Ridge. The result of these concerns
are that aircraft departing El Toro will not have the range necessary to
fly nonstop to destinations such as Beijing, China as cited in the EIR.
In fact, one airline pilot has calculated that he could not fly a fully-loaded
757 nonstop as far as Chicago, Illinois.
Other constraints not addressed in the EIR include the substandard separation of the existing parallel runways, and the inability to install and use accurate Instrument Landing Systems (ILS) at El Toro because of the surrounding terrain.
The County has attempted to address some of these concerns by comparing proposed operations at El Toro with the existing operations at San Francisco International, a 30-plus MAP international airport with a similar runway configuration. However, this comparison is neither accurate or valid because of the omissions from the comparison. For example, simultaneous departures on the parallel runways at San Francisco because the flight paths diverge immediately after takeoff. Similar diverging departure procedures are not possible from Runway 7 at El Toro because of the proximity of Lomas Ridge.
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 and 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 Irvine, from Runway 25.
Noise Analysis Baseline
Apart from the safety issues of the proposed aircraft operations, a significant
concern regarding the proposed airport is its noise impact on the surrounding
communities. As its baseline for analysis, the DEIR assumes that military
operations will continue at MCAS El Toro, if the site is not converted to
a commercial airport. The fact is that the U.S. Marine Corps will leave
El Toro in 1999. If commercial aviation uses do not immediately begin, this
site will not be an airport. As a practical matter, this alternative baseline
scenario should be identified and used in the DEIR in order to analyze the
real impact of converting El Toro to a commercial airport, if that alternative
is selected by the County.
Noise Impacts
The existing noise analysis does not identify the number of persons living
within the 65 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. While it is true that individual commercial aircraft may be quieter than existing military aircraft at MCAS El Toro, it is reasonable to expect that persons near the proposed commercial airport would be exposed to jet noise more often persons near a military air base. Further, the Marines cooperated with the surrounding communities to limit nighttime operations, limiting sleep disturbances. Nighttime curfews on commercial flights, such as those currently imposed by the County at John Wayne Airport, are not likely to be supported again by the FAA an any new airport.
Finally, because there is no discussion of alternative flight operations and routes, the DEIR does not identify or analyze the noise impacts of more departures to the north, or departures to and arrivals from the west. The use of these potential operations alternatives could have more serious noise impacts, especially on Irvine, than the flight paths identified in the DEIR. Staff believes that once an airport becomes operational, departure and arrival patterns are determined by air traffic controllers in consultation with the commercial pilots.
Traffic Study Level of Detail
The traffic study does not contain a sufficient level of detail to satisfy
CEQA requirements and to adequately address the potential impacts on off-site
roadway segments and intersections. The DEIR traffic analysis should also
include peak-hour link and intersection capacity utilization (ICU) calculations
to determine potential impacts on the surrounding roadway network, consistent
with the methodologies used by the County for significant, proposed Specific
Plans or General Plan amendments such as the Bolsa Chica development.
Traffic Study Assumptions
The areas not adequately addressed in the DEIR include:
1. The use of new demographic information in the traffic study which is inconsistent with regionally accepted projections.
2. Assumption of the completion of the Master Plan of Arterial Highways (MPAH), although there is no identifiable funding source for completing the network. The analysis of potential impacts should be in the context of existing and funded roadway capacity, not "future roadway capacity".
3. The omission of foreseeable growth based on build-out of the cities' and County's General Plans.
4. Assumption that a commercial airport will not generate additional vehicle trips, but simply divert existing trips from other regional airports.
5. Assumption that people will use the proposed vehicle access routes for the Eastern Transportation Corridor, a toll road, when free access is available from the surrounding arterial roadways.
6. The low assumptions of freeway truck traffic combined with optimistic assumptions for high occupancy vehicle (HOV) use.
Traffic Study Consistency
The DEIR is inconsistent with the requirements of the Orange County Congestion
Management Program (CMP) adopted by all of the local jurisdictions in the
county, and the County of Orange, itself. The DEIR states that a level of
service (LOS) "F" on freeways is acceptable to Caltrans. However,
the CMP requires an LOS of "E", of no worse than 1990 conditions
if the roadway was at LOS "F", for its roadway network, including
the freeway system surrounding El Toro.
In addition, the level of significant impact identified in the DEIR is inconsistent with accepted level of significance identified in the Orange County Growth Management Program (GMP). The DEIR should identify all roadways which experience an increase in intersection capacity utilization (ICU) of 1% or more, once the ICUs have been calculated for existing conditions and existing plus project conditions consistent with the requirements of the GMP.
Traffic Mitigation
The traffic study mitigation program is insufficiently detailed to assure
that the impacts of Alternatives A, B, or C can be mitigated to a level
of insignificance. It fails to specifically identify all freeway and arterial
deficiencies, and the cost and funding sources for "augmented arterials"
where needed. The DEIR should identify all deficient roadway segments and
intersections, propose a phasing strategy consistent with development, propose
individual treatment for each deficient roadway segment and intersection,
and identify the necessary funding sources or programs. The DEIR also fails
to address the potential of public transportation, through the Irvine Transportation
Center, as a potential traffic mitigation strategy.
Air Quality
The DEIR does not address the local impacts of the proposed commercial airport.
Instead, air quality is analyzed on a regional perspective, on which the
commercial airport is anticipated to have no significant impact. However,
even this analysis is predicated on unreasonable, unsubstantiated assumptions.
There is no identifiable source for the assumption of vehicle trips associated
with air passengers, and the number of vehicle trips to El Toro is almost
perfectly off-set by a similar reduction in vehicle trips to the other regional
airports. In addition, the use of the "military" baseline for
the air quality analysis, as with the noise analysis, allows the emission
of nearly 8,000 tons of pollutants per day without a negative impact on
air quality, even though this figure is approximately ten times the SCAQMD's
threshold of significance.
Contamination
The feasibility of Alternative A is predicated on the "timely"
transfer of the airport to commercial operations. The DEIR does not address
the impact of potential delays resulting from on-site contamination. Yet,
clean-up of contaminated sites is generally slow. Already, the timeline
for El Toro has been extended 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.
The fact that this may be less of an issue for Alternative C, where the
site may be parcelized and phased development begun, is not addressed by
the DEIR.
Recently, the Department of the Navy proposed a "natural attenuation" alternative for the clean-up of ground water contamination in order to reduce overall costs. Therefore, the DEIR should analyze the impact of a delay to the clean-up of the base by the federal government, and the potential impacts of such a delay on the feasibility of developing a commercial airport or a non-aviation alternative.
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 taxiways with little back-up information
to justify this cost projection. By comparison, the construction of a single,
new 9,000 foot runway at Bergstrom Air Force Base in Austin, Texas cost
$110.5 million. Additionally, roadway improvement costs seem low in the
absence of substantiating the estimates.
In addition, the County appears to incorrectly assume that revenue from airlines is independent of costs. Under the terms of FAA grant agreements, fees for aeronautical use of airport facilities must be "fair and reasonable" based on the capital, operating, and maintenance costs of the airport. However, the County's projected operating and maintenance expenses, and the infrastructure debt payments are the same for two different revenue scenarios, and they are less than the projected revenue from airlines. Either the projected revenues include non-airline income sources or the airline charges are not fair and reasonable, and the revenue projection is inflated.
Another possible source of revenue is the lease/rent of existing building square footage. The DEIR projects $12.9 million in revenue from building lease/rent, approximately $4.3 per square foot. This figure is lower than the $5-10 per square foot stated in the Financial Feasibility Report.
In addition, 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.
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. It is not evident how vehicle trips have been reallocated from
John Wayne Airport to El Toro because the traffic study area does not include
the John Wayne Airport area. Finally, the DEIR does not address the economic
impact on the area surrounding John Wayne Airport if commercial operations
are relocated to El Toro.
Conclusion
The discussions above highlight 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. As
the first tier of a series of EIRs, this document should answer the question
of the feasibility of each of the three identified alternatives in terms
of their respective environmental impacts. 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. Staff
does not believe that the DEIR has accomplished this and, therefore, it
would be premature for the County to endorse Alternative A, B, or C based
on this document. It would also seem to be inappropriate to ask the Department
of Defense (DOD) to issue a record of decision on any of the three reuse
plans, especially when the next level of analysis, known as the Master Plan
with its own EIR, may result in a different project than the one the DOD
will be asked to endorse.