March 19, 2002
 
 

Mr. David B. Kessler, AICP
Federal Aviation Administration
Western Pacific Region, Airports Division
AWP – 611.2
Post Office Box 92007
Los Angeles, California 90009-2007

Dear Mr. Kessler:

Thank you for the opportunity to review and comment on the "Draft General Conformity Determination, Proposed Civilian Aviation Reuse of Marine Corps Air Station El Toro" (Draft Conformity Determination). El Toro is located in the South Coast Air Basin, which is designated as nonattainment for the national ambient air quality standards for ozone, inhalable particulate matter (PM10), and carbon monoxide. The Clean Air Act and general conformity regulations (40 CFR Part 93, Subpart W) require that emissions that result from a federal action (like approval of the El Toro Airport Layout Plan) not interfere with attainment or maintenance of national ambient air quality standards in any area. This provision is an important tool in our collective efforts to protect the health of Californians from the harmful effects of air pollution. We do not believe that the Draft Conformity Determination adequately demonstrates that the El Toro Project would meet these requirements.

The primary issue is the approach used to determine the differential between emissions with and without the El Toro Project. This differential is then used to identify whether Project emissions would exceed the de minimis levels specified in the conformity regulation, which determines the need for comparison to emissions budgets or an air quality analysis. The Draft Conformity Determination assumes that operating El Toro would divert current and future air travel from existing airports throughout the Southern California Airport Service Area (covering multiple air basins and nonattainment areas) to the new facility. The Determination relies on emission reductions that would theoretically be achieved from less air travel outside the South Coast Air Basin (for example, in San Diego) to offset emission increases from more travel within the Basin. The Draft Conformity Determination evaluates the differential emissions impact across only this broad Southern California Airport Service Area; we believe it must evaluate the emissions impact in each nonattainment or maintenance area affected.

 Based on available information, we expect that comparing Project and No Project emissions within the South Coast Air Basin alone would likely result in differential emissions exceeding the de minimis levels for reactive organic gases (ROG), nitrogen oxides (NOx), and inhalable particulate matter (PM10). These differentials may also exceed the attainment emissions budgets for ROG and NOx in 2010 established for the South Coast in the approved State Implementation Plan (SIP) for Ozone.

Since there are no emissions budgets established for direct PM10 emissions, the Draft Conformity Determination presents a Local Air Quality Analysis of the impacts of the Project on PM10 levels. The serious health effects from exposure to particulate matter (including premature death, asthma, and other illnesses) demand a thorough evaluation of how the Project may affect levels of this pollutant. This Analysis appears to restrict the evaluation to PM10 emissions from construction only; it should include PM10 and particulate precursor emissions from all sources, including aircraft, ground service equipment, energy production and use, motor vehicles operating on airport roadways and parking lots, and airport-related motor vehicle travel on roads outside the airport. These other sources may be the dominant contributors to PM10 levels in some years. (For example, from the data in Tables 3-10 and 3-11 of the Draft Conformity Determination, we calculate that airport-related construction emissions in 2008 and 2009 would be only 19 percent and 27 percent, respectively, of total local emissions associated with El Toro.)

We note that many of the conclusions in the Draft Conformity Determination rely on analyses in the April 2001 "Draft Environmental Impact Report No. 573 For the Civilian Reuse of MCAS El Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County International Airport—Draft Supplemental Analysis." In prior comments to the MCAS El Toro Local Redevelopment Agency, we identified a number of concerns with the adequacy of this document. Because of the interrelationship between the Draft Conformity Determination and this document, we incorporate our June 15, 2001 comments and attach them for your reference.

For the reasons articulated in this letter, we believe that the Draft Conformity Determination does not demonstrate that the Proposed Civilian Aviation Reuse of Marine Corps Air Station El Toro would conform to the applicable SIP. We encourage you to require that the Determination be revised and reissued for comment if the property owners intend to proceed with the proposed El Toro International Airport.

 Thank you again for the opportunity to provide these comments. If you have any questions, please contact me at (916) 322-7236 or Mr. Gary Honcoop, Manager of the Strategic Analysis and Liaison Section, at (916) 322-8474.

Sincerely,

 /s/ Marvin Honcoop for

Cynthia Marvin, Chief

Air Quality and Transportation Planning Branch