AIR LINE PILOTS ASSOCIATION
635 HERNDON PARKWAY - PO BOX 1168 - HERNDON, VA 20170 - 

Retyped from the original

February 11, 2002

 
Mr. William Withycombe
Regional Administrator, AWP-I
Federal Aviation Administration Western-Pacific Region
HQ P.O. Box 92007
Los Angeles, CA 90009-2007

Dear Mr. Withycombe:

ALPA understands that meetings between Orange County and the FAA may ensue to develop a Preferential Runway Use Program for the proposed El Toro Airport (OCX). As you may know, the development and conversion of OCX for commercial use has been contentious. Positions regarding safety and performance differ substantially between the Orange County Board of Supervisors and many of the potential users of the new airport. As a consequence, we respectfully request that ALPA representatives be among the users included in any discussions for a runway use program at OCX Our participation is essential to ensure that the pilot safety perspective is considered. ALPA has participated in similar discussions at many other venues and would expect the opportunity to do so for OCX.

ALPA has previously been on record stating that OCX operations should not be considered under the configuration suggested by Orange County EIR 573. Our argument, addressed in FAA Order 8400.9, makes two points.
 

First, under Paragraph 7d(2)(b) - "Runways Not Clear or Not Dry", the FAA Order stipulates "No tailwind component may be present except the nominal range of winds reported as calm (0-3 knots) may be considered to have no tailwind component." ALPA has learned from a review of historical meteorological data for OCX, that the tail wind component for Runway 8 will often exceed five knots. In fact, ALPA believes that the tail wind component could be much higher, if calibrated at the generally accepted elevation of 45 feet above the ground now used with FAA installed Center-field Wind Towers. We assume that FAA will install such a tower since it is the accepted mounting device for Center-field Wind Anemometers today. The point of wind analysis for Runway 8 has been argued by the County, but not to our satisfaction. ALPA feels that Runway 8 fails to meet the calm wind conditions required for a Preferential Runway Use Program.

Second, under waiver requests, in accordance with paragraph 8 and Appendix 2, FAA Order 8400.9 reads, in pad, "Flight Standards personnel must consider the operational impact of the following factors when providing a safety analysis to support alternate criteria", and Appendix 2h lists two questions.  "Is runway slope a factor?"  If so, does it impact aircraft performance?"  The answer to both questions, in our opinion, is YES.  Therefore, for that reason alone, a waiver must be questionable.


ALPA would appreciate FAA feedback to these items and an invitation to participate in any future meetings to discuss an OCX Runway Preferential Use Program.

Sincerely,

Captain Jon Russell
Western Pacific South
Regional Safety Chairman
 

Click here for additional ALPA letters