Questions and comments on the Department of Navy Draft Environmental Impact Study must be submitted by April 24, 2000.

Submit comments to:
Commander, Southwest Naval Facilities Engineering Command
Attn.:  Robert Montana, Code 06CM.RM
BRAC Program Office
1220 Pacific Highway San Diego, CA 92132-5090

For a copy of the EIS Executive Summary call Robert Montana at (619) 532-0942.

E-mail responses are not accepted.

The Following comments and questions were prepared from discussion with ETRPA's consultants and may be of assistance to you in preparing your own comments:

EIS QUESTIONS

THEME: Since 67% of the people have spoken against this process, and a majority of the populations opposes the airport alternatives, what are you, the Navy, going, to do to address this?

1) Why is the Navy declaring a preferred alternative (38 MAP) even though the LRA has already determined this is infeasible?  Why analyze an alternative that will never happen?

2) Why does the DEIS consider an alternative to the 38 Map airport as prepared by the county, but not the alternative non-aviation plan (MP2,) which is preferred by the community?

3) Why didn't the Navy analyze impacts of runway 25, west over Irvine?

4) The DEIS takes summary statements from the county EIR in some portions of the DEIS and in other portions claims that there is no data available (yet the data is in the County EIR). Please explain why the Navy only used selected portions of the County EIR, and why the Navy didn't conduct independent analysis?

5) Why didn't the Navy work in concert with the FAA and release the DEIS with the FAA analysis?

6) What happens if the FAA does not approve an airport with crossed runways that invite runway incursions?

7) What happens if the FAA fails to approve an airport with take offs that defy aerodynamics – up hill, with a tail wind into a rising terrain?

8) Why did the Navy give sketchy Aviation details making it difficult to analyze the plan?

9) Why didn't the Navy look at the airport system with John Wayne?

10) Why did the Navy ignore JWA in the economic analysis?

11) Why did the Navy recognize an LRA that excludes cities that share boundaries with the base, specifically Irvine and Lake Forest?

12) This is the first time in the base closure process that a city with part of the base within its city limits has been excluded from the base closure process.  Irvine is not part of the LRA.  Please justify this.

13) The financial information is not addressed in the DEIS, In the appendix it only talks about the preferred alternative -- why is there so little information on financial feasibility of the alternatives?

14) The airport plan has a lack of logic – the terminal is the same size in the 38 map and the reduced capacity.  The cargo tonnage is the same in the larger airport and the reduced capacity airport…Where is the logic in this?

15) How can the Navy claim that there will be takeoffs on Runway 7 in the Carbonyl aviation alternative, when there is no runway 7 in the Cargo plan?  That runway is removed in the cargo plan.

16) We have more jobs than housing in OC; so more jobs are an adverse impact. In this scenario, we will continue to have more jobs than housing so the airport becomes an adverse impact…how can the Navy justify the preferred activity if the base closure process is supposed to improve or help communities?

17) Since the Navy DEIS indicates that the Millennium Plan, non-aviation plan is economically superior, why did the Navy choose the airport plan which will have an adverse environmental impact and an adverse economic impact in terms of the county's current jobs/housing imbalance?

18) Why would the Navy choose a preferred alternative that the Navy will have to override negative impacts, when the non-aviation plan has superior economic and environmental benefits and will not require overriding negative environmental impacts?

19) To support the economic benefits of the airport system, the county accounted for economic benefit from JWA and visitor spending.  Why were these not considered in the DEIS?

20) Why cant the Navy identify the economically superior alternative as suggested by the DEIS economic analysis?

21) Why cant the Navy identify the environmentally superior alternative as suggested by the environmental analysis?

22) The DEIS does not choose the preferred alternative as the county plan, nor does it choose the non-aviation plan?  It appears that you have not identified a proper preferred alternative?

23) What is the best plan economically?

24) What is the best plan environmentally?

25) Since the airport is dead, why are we here?

26) Measure F clearly shows that the people of Orange County are disgusted with the process the county and Navy have followed regarding the closure of MCAS/El Toro?  What will the Navy do to correct this situation?

27) Please explain why the Navy or DOD will work with the LRA when they clearly do not represent the will of the community.

28) There is no evidence that the Navy has consulted with the FAA.  Please explain.

29) Since the Navy does not indicate FAA involvement in this process, how can you choose a preferred alternative that may be infeasible from an operations standpoint and an economic viewpoint?

30) Where will the people who work at the airport live?

31) What impacts on the county will result from the commuting of workers from other regions on a daily basis.

32) If the Navy has had discussions with the FAA why hasn't the Navy disclosed any documentation regarding these discussions?

33) What qualifications does the FAA have to manage the habitat reserve?

34) Why didn't the Navy analyze impacts on the habitat reserve?

35) Why didn't the Navy analyze the impacts resulting from the lack of a working fuel line?

36) The purpose of the Navy EIS is to establish a disposal and reuse at El Toro.  Why isn't the 975 acres in the habitat reserve part of the base reuse and disposal plan?

37) Why didn't the Navy analyze the public benefits and homeless issues?

38) Why didn't the Navy analyze the impact on housing?

39) NEPA says the Navy needs to look at cumulative impacts…why hasn't the Navy considered other BRAC actions in the region? How can the Navy look at one without looking at the impacts of others – specifically, the Inland Empire needs jobs, and Orange County needs housing?  The preferred alternative for El Toro will make our housing crisis worse and will take jobs from the inland empire by impeding the success of the reuse of March AFB, Norton AFB and George AFB and adding to traffic congestion, air pollution in a non attainment area.  Isn't SCAG’s (Southern California Association of Governments) regional master planes goal to create a jobs/housing balance?

NOTE:  The economic modeling is much better than the county's …We can actually tell what they did to get to their numbers.  In most cases it was more favorable to the non-aviation scenarios than any document we have seen before. They took out JWA and Visitor expenditures which ETRPA did too and more closely resembles what the net benefit of the airport.

40) Since the analysis shows the Village Park is superior, why didn't the Navy choose it?

41) Why didn't the Navy compare the income from jobs against the cost of housing in Orange County?

42) (Asking it another way) What are the wages that will be generated by the jobs and how does that relate to the cost of housing in Orange County?

43) Of the alternatives which will create jobs that compare most favorably to the cost of housing in Orange County?

44) Since the Navy has used other county documents in this, how can the Navy state that this is an independent and objective review?

45) The Community Reuse Plan says direct jobs are 30,300; the master plan says 29,500 – roughly the same.  Why would the reduced commercial airport (county 28 MAP airport) have as many jobs as the 38 MAP airport?
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46) Why hasn't the Navy looked at regional demand issues besides just airport – why not include housing demand, job demand/supply, ground transportation, recreation, open space etc.?  Why hasn't the Navy thought of other alternatives?  This document provides a very limited range of alternatives.

47) The federal scoping meeting in 1996 mentioned an alternate airport site. This is not mentioned in the DEIS, why not?  Why is the DEIS only validating the airport without discussing regional needs?

48) The page indicating alternatives considered and rejected are missing from the EIR, (tables 2-19 and 2-20) why was it excluded?  Can the Navy distribute these tables?

49) How can air quality emissions be less in 2020 than 2010?  What is the Navy's basis for these assumptions?

50) DEIS claims non-aviation uses create less emissions than aviation uses.  There is no discussion of construction impacts, no operational impacts. Where did the Navy come up with the documentation for their emissions levels, as the Navy's sources not the referenced?

51) DEIS is supposed to include adverse affects that cant be avoided, the relationship between short-term uses of mans environment and the maintenance and enhancement of long-term productivity, an irreversible or irretrievable commitments of resources which would be involved in the proposal should the project be implemented.  Why hasn't the DEIS addressed these?

52) The DEIS fails to quantify the hazardous air pollutants from the assumed baseline year (1994) and does not identify hazardous air pollutants for any of the alternatives including the preferred alternative.

53) It appears the Navy has underestimated nitrous oxide by 1/3 using a 25% conversion but the national conversion is 75%.  Why didn't the Navy follow EPA standards?

54) CEQA has a mode of significance comparison of short-term increases in air pollution concentrations. Why didn't the Navy use this comparison?  If the Navy had, there would be significant times of adverse impacts.  This is not, as the DEIS claims, a faithful adherence to the CEQA handbook.

55) Why didn't the Navy consider on-road emissions?  Explain why these potentially significant impacts are not considered in the DEIS?  Why didn't the Navy take the onsite vehicles from the DEIS traffic analysis to develop the emissions impact from on road emissions? How does the Navy justify not including any of this when it is available from 573?

56) What led the Navy to conclude that there will or will not be significant impacts to air quality?  The document has no backup, data or analysis, for its conclusions, basis or justification.

57) Not all air quality impacts are quantified.  How can the Navy then draw conclusions?

58) Since the Navy does not quantify mitigation measures, how do we know how effective these mitigation measures will be?

59) The DEIS claims that the project conforms to the State Implementation plan for air quality but there is no backup for this claim. Please Explain? Or please state the regulations that allow it to be exempt?

60) How can the Navy make these claims about air quality and its impacts with no background information?

61) How many cancer deaths per year will result from increased pollution generated by air pollution from the airport?

62) The noise model is driven by runway utilization. Since the FAA has not stated that it will approve an airport plan with crossed runways and takeoffs north – and a prohibition on Runway 25, how can the Navy suggest that these noise models are even remotely related to the actual impacts from the proposed project?

63) Why didn't the DEIS address or acknowledge any possible deviation which may result from the utilization of other runways, or variations on the frequency of runway use?

64) There appear to be discrepancies between the claims that the SENEL (single event noise equivalent) noise impacts will be about 20 dB above ambient noise and the charts which show that the noise will be 38 dB above ambient levels. This is a four-fold increase versus an eight fold increase.  Please explain the discrepancy.

65) Why doesn't the Navy mitigation section discuss and compare the feasibility of any specific noise impact mitigation?

66) Why did the Navy not consider the no project or no action alternative in the DEIS noise analysis?

67) Since noise is a significant issue to this community, why didn't the Navy make an analysis of the amount of time the noise exceeds significant threshold levels?

68) Why did the Navy use 1994 as a baseline for noise analysis, when the base was fully operational? The county's EIR 573 used 1998 (per court order). The base is significantly quieter now, consequently, the Navy operates under the assumption that the base would operate as a military facility until 2010…please justify this.

69) Why didn't the Navy analyze noise impacts from ground operations?

70) Why didn't the Navy analyze noise from trucks on largely residential streets such as Alton, Barranca, Sand Canyon, Jeffery, Trabuco, Irvine Boulevard, Bryan, Los Alisos, Rockfield, Muirlands, Bake Parkway and Alton?

71) Why didn't the Navy analyze noise from rail lines for cargo through the base and surrounding residential areas?

72) The noise study sites are not clearly identified and there appears to be no monitors North East of the base where the most significant noise impacts are expected to occur. Please justify this.

73) In the Navy analysis of aircraft noise, the FAA states that if data to model a MD-90 is not available, you must substitute a MD-80.  Why did the Navy substitute the Boeing 737, which is a much quieter aircraft?  If the Navy had correctly modeled the MD-80, how would this change your results?

74) The SENEL for the Boeing 747 is stated to be 10-20 dB higher than the ambient noise, however the tables in the DEIS state that it will be 38db higher. Please explain the discrepancy.

75) Table 8-9 Appendix J states that anywhere the SENEL was below the ambient noise level it is inaudible.  This is incorrect and not appropriate.  Please justify this.

76) Why is there no discussion of construction noise associated with the project?

77) Please explain why there is no discussion of the project impact on the Endangered Species Act

78) Since the base has closed, there has been an increase in the baseline species at the base, especially the habitat reserve.  Why didn't the government conduct a baseline analysis or survey of animal and plant species at the base to provide comparison of impacts?

79) Do the Navy know what endangered species are currently living at El Toro and the adjacent habitat reserve?

80) What provisions is the Navy recommending to prevent the killing of endangered species due to aircraft operations?

81) Since the DEIS recognizes that noise is a significant impact, why did the Navy choose a preferred alternative that has the maximum negative impacts on the community from noise, when other alternatives are economically preferable, environmentally superior and do not impose these negative, unmitigatible impacts?

82) NEPA says that the DIES should be prepared early to be included as part of the decision making process.  Why has this document come out seven years after the base reuse process began?

83) The BRAC order states that the Federal Government should work with state and local communities in a spirit of cooperation to facilitate the closure and reuse planning of the base.  Please justify why this process has deteriorated to the point where the local population has had to resort to the initiative process and has voted by nearly 70% margin to condemn the planning process.

84) There is no discussion of how the cleanup of toxic areas on the base will affect phasing of the project.  Please explain.

85) The DEIS states that the El Toro elementary school will exist until 2010. However, this is not compatible with the project phasing.  Please explain.

86) Please explain why the earth moving operation to change the runway gradient for Runway 7/25 on the west and 18 feet on the east is not considered an environmental impact.

87) Please justify the Navy's position on aviation demand since there is no supporting documentation in the DEIS.

88) Please explain the logic behind DEIS charts that claim that the average cargo tonnage on the cargo airport will be 24 tons per plane; 38 tons per plane with the 38 MAP airport; and 76 Tons per plane with the 28 MAP airport.  Since the cargo-only airport doesn't include passengers, logic would dictate that the cargo only planes would carry more cargo than passenger aircraft that also carry cargo in addition to people.

89) Why is the Navy accepting the county's preferential runway program when the pilots have said they will not support it?

90) How can the Navy keep the existing buildings on the west and East End of the base when the land underneath the buildings will be moved 37 feet?

91) The DEIS accident analysis claims that there will be one accident every 2 years.  How many people will die?

92) The Navy had 2 months to review the County's DEIR 573. Why didn't the Navy take that data into consideration in the DEIS?

93) The DEIS claims that the feasibility of the airport will be constrained by airspace problems. Why didn't the Navy do an air traffic analysis or wait for the FAA to complete its analysis so as to determine if the preferred alternative was even feasible?

94) The DEIS makes no analysis of impacts of the airport, however, the DEIS claims that there will not be any increase in risk to the public associated with aircraft activities, fire and explosions.  There are no mitigation's required.  With no aviation analysis how can the Navy justify this conclusion?

95) How can the Navy claim that all the existing runways will be used when two of the four runways will be torn up and moved?

96) Why didn't the DEIS consider the 1965 Loma Ridge crash in its safety analysis since the straight out north departures on Runway 34, are proposed in the various airport plans.

97) Please justify the traffic modeling program used for this project.

98) Please explain why the DEIS uses 1994 for the baseline traffic model since traffic in the area has changed significantly since then.

99) Bake parkway north of Muirlands is currently 26,000 trips.  The DEIS states that in 2010 there will be 26,000 to 34,000 ADT. Please explain.

100) Please explain why there is no supporting analysis of traffic studies, and no information on how the traffic planners distributed traffic.