omalley-response-071701

July 17, 2001

Mr. Paul L. Galis
Deputy Associate Administrator for Airports, APP-2
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591

Dear Mr. Galis:

We received a copy of Mr. Gary Simon’s July 7, 2001 letter to you in which he attempts to reassure you that the LRA has a "sound rationale" for the procedures proposed for the planned commercial airport at former MCAS El Toro. Unfortunately, Mr. Simon’s letter is replete with the same inaccuracies about fundamental operating aspects of the proposed airport that have, since inception, generated criticism of the plan as profoundly unsound by the widest spectrum of respected aviation professionals.

We trust that the FAA, at this late stage of its review of the operational aspects of the proposed El Toro Airport System Master Plan, (ASMP), is more than aware of the significant operational weaknesses in the plan and clearly will identify them is its forthcoming report. Nonetheless, some of the statements in Mr. Simon’s letter force us to respond for the record.

The ASMP is at Odds with Marine Corps Flight Operations History

Mr. Simon’s letter asserts the ASMP uses the same approach and departure procedures as those used by the Marines. For example, he states that the "LRA’s proposed procedures would maximize the use of available airspace in the region by reusing the former Marine Corps procedures." Of course, there are two major problems with this logic: (1) the plan deviates in significant ways from the Marine’s use of the base, and (2) heavily loaded commercial transport aircraft cannot maneuver in the same manner as Marine fighter jets.

As you know, local flight restrictions due to the combination of urban encroachment and terrain constraints led to the closure of the base. Before the base was closed, Marine base operations for years were constricted in the following ways:

A self-imposed night curfew was established which prohibited flights between the hours of 10 PM and 7 AM Monday through Thursday and between 7 PM and

Due to growth of the City of Irvine, the main departure was changed for high performance aircraft from Runway 25 to the west to Runway 07 to the east. This departure could be accomplished safely by high performance, tactical aircraft that have high climb rates.
Larger aircraft, such as transports without the necessary high climb rate capability, continued to use Runway 25 to the west and Runway 16 to the south over Laguna Woods and Laguna Hills.
Departures to the north on Runway 34 were seldom, if ever, conducted because of terrain and airspace conflicts. The Standard Instrument Departures (SIDs) for El Toro required a mandatory left climbing turn to a "hard altitude" of 4,000 feet within 1.3 NM of the departure end of Runway 34, a maneuver possible with high performance jets, but not commercial passenger aircraft. These departure procedures were necessary to avoid the hazardous mountains to the north and the commercial traffic en route to John Wayne, Long Beach and Los Angeles International Airports.
Arrivals to Runway 34 crossed the coastline at approximately 4,000 feet above MSL.
As precisely observed by the Executive Vice President of the National Air Traffic Controllers Association (NATCA) in a June 22, 2000 letter to the LRA: "Apart from the slower tempo of operations, the aircraft departing from and arriving at El Toro in years past typically were fighters and attack aircraft of rapid climbs, equally rapid descents, and occasional maneuvering well beyond the capabilities of passenger-laden airliners."

The proposed ASMP contrasts sharply with the Marines’ circumscribed flight operations at the base:

The proposed airport would have no curfews and calls for 824 operations a day, 24 hours a day, 7 days a week.
Departures on Runway 25 would be prohibited under all circumstances, regardless of wind conditions, aircraft capability, and pilot safety preference. However, the ASMP states there will be arrivals from the West, over the cities of Tustin and Irvine for approach and landing on Runway 07.
Approximately two-thirds of planned departures would use Runway 07. To make this departure at all feasible for commercial aircraft, the plan projects massive regrading of the runway by raising the approach end 37 feet above present grade and lowering the departure end 18 feet lower the present grade. Even if this improves the runway grade, it does not change the inescapable presence of mountains in the immediate face of the departure route and the prevailing westerly winds from the coast causing tailwinds for departing aircraft that, for most of the year, are above 7 knots. During the summer months, with accompanying high ambient air temperatures, the winds from the coast exceed 10 knots.
As ALPA has observed: "Runway 08, with its upslope gradient, upslope terrain, and prevailing tailwind component, would be payload-limited under many circumstances. Its use for departure would cause greater noise impact on the public than departures from Runway 26. Further, because of the onerous close-in obstacle environment just to the east of Runway 08, takeoff minimums are limited to not less than a 500-foot ceiling and 2 miles visibility. These are extraordinarily high takeoff minimums for a primary departure runway at a major airline airport, and would be both economically inefficient and a potential hindrance in the flow of traffic in the national airspace system."
Approximately one third of planned departures would use Runway 34 despite the terrain and airspace conflicts that minimized its use by the Marines.

The Operational Safety and Efficiency Problems Can’t be Explained Away

The LRA has been advised by virtually every potential aviation user group, including proponents of a commercial airport at El Toro, that the ASMP is significantly flawed. Many of these comments, including those already quoted, have been detailed and shared with the FAA, so we do not need to repeat them here. In addition to the points made above, we do, however, want to highlight just a few of the significant operational problems that Mr. Simon’s letter attempts to minimize or avoid.

Wind Conditions

With mountains immediately facing the only two planned departure runways, the LRA airport proponents’ plan is especially dependent upon wind conditions. Yet, the planners have played a shell game with wind statistics. The record shows that Orange County’s airport planners deliberately used a calm (less than 5 knots) tailwind assumption in their feasibility analysis for Runway 07 and 34 departures, because of "pilot concerns with taking off into rising terrain with a tailwind." In fact, the proposed ASMP assumed zero wind velocity at the surface for runway performance.

Yet, wishing for calm winds doesn’t make it so. A careful reading of the County’s EIR reveals conflicting wind assumptions, with some sections acknowledging the occurrence of westerly wind conditions at above 5 knots, and other sections acknowledging 8-10 knots. The Marines’ historical weather data shows average westerly winds above 6 knots 8 to 12 months of the year, frequently at 8-10 knots, and often exceeding 10 knots. Mr. Simon’s assertions that "westerly winds at OCX are not substantially more prevalent than easterly winds during an average year (and westerly/easterly winds rarely exceed 7 knots") is inconsistent with the historical weather record. The actual wind data strongly suggests that the plan’s projected frequency of departures from Runways 07 and 34 will not be able to occur as planned due to unacceptably high tailwinds or crosswinds, forcing different departure procedures or closure of the airport.

In essence, the LRA airport proponents have planned an airport perhaps uniquely vulnerable to frequent and major flight disruptions due to wind conditions. As ALPA has observed: "The present County of Orange proposal, with only one ILS approach to Runway 35, and one marginal, effectively visual flight rules (VFR) RNAV approach to Runway 17, would force air carrier arrivals to cease anytime the weather drops below basic VFR minimums and the tailwind component for Runway 35 exceeds 10 knots.
ALPA submits that this may occur often enough to cause this airport to be uneconomical for airline operations, and El Toro could become a choke point in the national airspace system (NAS)."

North Departures over Loma Ridge and Air Traffic Conflicts

As long ago as 1996, the FAA reportedly noted these problems with the LRA airport proponents’ plan to use Runway 34 for a significant percentage of departures:

FAA staff agree that the preferred procedure for departing Runway 34 would be to initiate a left turn within 1.3 nautical miles of the departure end of the runway and stay within MCAS El Toro airspace. . . .It is unlikely that MCAS El Toro Runway 34 departures would be allowed to continue northward due to the amount of traffic that already exists to the north. The proposed ASMP, nonetheless, is predicated on the feasibility of a straight-out north departure. Now, Mr. Simon states that, "whenever possible", "capable" aircraft departing on Runway 34 will execute a right turn at 8 nautical miles DME. It is obvious the LRA has not considered the critical concerns of the FAA Administrator and her program to reduce CFIT accidents.

The County’s airport planning consultants noted in 1998 that the climb requirements for an airplane departing on Runway 34 are "greater than at any other primary departure runway at a major international airport in the United States." Making a planned airport departure artery with this kind of climb gradient, vulnerable, in addition to the vagaries of winds in excess of assumptions, to "whenever possible" and when "capable", seems to us to be an extraordinary planning weakness.

Aircraft that cannot make the right turn will conflict with air traffic into John Wayne, Long Beach, Los Angeles International Airports, as well as Ontario International Airport. Even those aircraft than can make a right turn will conflict with JWA traffic. According to the County’s EIR 573 ("the EIR"), conflicting air traffic is impacted as close as 5-8 NM north of El Toro. In the vicinity of these intersection points, JWA arrivals are at altitudes of approximately 2,000 to 6,000 feet MSL. At about 13 NM north of El Toro
departing aircraft from El Toro are confronted with LAX arrivals from the east that have blocked altitudes from 8,000 to 13,000 feet MSL. The EIR states:

Jet arrivals from the east to JWA Runway 19R pass to the north of OCX and intersect the extended Runway 34 Centerlines between 5 and 8 NM north of OCX. In the vicinity of these intersection points JWA arrivals are at altitudes of approximately 2,000 to 6,000 feet above MSL. The heavily loaded departures that are expected to use the Runway 34 system at OCX will be at altitudes between 3,000 feet and 6,500 feet above MSL. While some OCX departures will be able to climb above the JWA arrivals, there will be some aircraft that cannot. The EIR goes on to state: Since this interaction occurs only a short distance from OCX and involves aircraft that are at relatively low altitudes, it is expected that there will be little time or opportunity to maneuver the OCX departures to achieve separation. Accordingly, air traffic controllers will probably need to sequence OCX Runway 34 departures and JWA westbound arrivals. This sequencing may require controllers to occasionally "gap out" JWA arrivals to facilitate OCX departures and hold OCX departures to facilitate JWA arrivals. Both of these actions could result in aircraft delays at either airport. Further, Mr. Simon fails to point out that aircraft taking off on Runway 34 and within 10 NM of the airport will be especially vulnerable to airspace conflicts due to their low altitude. As has been pointed out by ALPA, APA, ATA, and NATCA in reference to north (and east) departures, the Minimum Vectoring Altitude (MVA) range for both the north and east of El Toro is from 4,000 to 7,000 feet. Air traffic control has difficulty directing aircraft below this altitude. As stated by the MITRE Corporation: "It is impractical to run aircraft below this altitude, since the controller has no flexibility to maneuver the aircraft to separate it from other traffic."

Mr. Simon’s offer of a right turn for chosen aircraft does not resolve the fundamental problems with Runway 34. A candid 1996 internal FAA memo from the FAA AWP Manager, Air Traffic Division Manager to the Manager, Airports Division, in our view, continues to capture the essence of problems with the proposed ASMP, and especially the planned use of Runway 34:

Two airports within seven nautical miles poses significant problems for air traffic. Overlapping airspace boundaries, crossing instrument approach and departure procedures and insufficient airspace capacity to manage a large volume or mix of heavy turbo-jet operations and general aviation traffic demand would surely result in gross inefficiencies at both airports and would serve no useful purpose to the National Airspace System. Western Departures and Airport Closure

Mr. Simon fails to acknowledge the consequences of the fundamental illogic of the runway use plan: Departures on Runway 25 are completely prohibited for noise reasons, therefore winds in excess of operating minima for the three remaining runways will result in closure of the airport. This is not mere speculation; the Runway 25 departure prohibition, historical wind data, FAA runway performance requirements, and FAA regulations and policy on preferential runway use plans will drive this result. Putting aside the terrible safety precedent of refusing to permit a pilot in any circumstance to take off over low terrain and into the prevailing winds, a major commercial airport that cannot reliably remain open will cause enormous inefficiencies to the national airspace system (NAS).

Crossing Runways

Mr. Simon also fails to acknowledge the runway incursion hazards inherent in the plan’s perpetuation of the former Marine base 1940’s crossed runway configuration. The recently released FAA survey of the national runway incursion problem demonstrated that the vast majority of reported incidents occurred at airports with intersecting runways. It would be a gross misuse of national, regional, and local resources to base a modern commercial facility on an outdated runway configuration that would guarantee, for this reason, as well as the many others, to place airport operations at a higher safety risk.

Conclusion

Mr. Simon’s letter, ostensibly written to "ensure that [their] proposal is clear", sadly, accomplishes its goal. It is abundantly clear that the LRA airport proponents, in an unsuccessful bid to circumvent the difficult public debate associated with a realistic operational plan for El Toro, continue to misrepresent the actual operational

consequences of its plan. Mr. Simon states, "the LRA went to great lengths to avoid and minimize any potentially adverse impacts of the OCX project in the communities of Orange County." This statement, true only with respect to the northern cities of Orange County, really says it all. The LRA airport proponents have sacrificed operational safety and efficiency to political expediency.

Our comments highlight only the inaccuracies about flight operations in Mr. Simon’s letter. The plan has other enormously important drawbacks, also downplayed by the airport proponents that would affect the community, including, only for example, the significant impact on air quality and the requirement for hundreds of fuel truck deliveries a day to compensate for the lack of an adequate fuel infrastructure.

We can appreciate the fact that much time and millions of dollars have been spent fostering this misguided proposal and that it takes courage to point out fundamental flaws at this juncture. Nonetheless, as we consistently have stated in our many conversations with you and your team, we encourage the agency’s thorough examination of every aspect of the proposed airport plan and trust that, with the FAA’s paramount safety mission firmly in mind, the agency will identify these flaws and help the LRA correct its course.

Sincerely,

Thomas F. O’Malley, Jr.

Deputy Executive Director