AIR LINE PILOTS ASSOCIATION
635 HERNDON PARKWAY - PO BOX 1168 - HERNDON, VA 20170 - 703-689-2270
FAX 703-689-4370
Mr. Brian Speegle
County of Orange
MCAS El Toro Local Redevelopment Authority
10 Civic Center Plaza, Second Floor
Santa Ana, CA 92701
The Air Line Pilots Association, representing the professional interests
of more than 56,000 pilots flying for 52 airlines in the United States
and Canada, wishes to comment on the latest new instrument approach proposals
for the El Toro Airport submitted by Mr. McGowan and Mr. Griffin.
ALPA has reviewed both the McGowan and Griffin Plans. We commend
these gentlemen on their dedication to cultivate solutions to the numerous
problems surrounding the development of the El Toro Airport. However,
these plans are not without serious and specific limitations. It
appears that in the development of Mr. McGowan’s and Mr. Griffin’s individual
plans some misleading assumptions may have been made, and ALPA will speak
to those with a review of each plan.
First, however, we should ask whether or not an instrument landing
system (ILS) approach for landing to the south at El Toro is feasible?
A review of FAA Order 8260.36A provides criteria for all new Instrument
Landing System (ILS) installations. Those criteria of 8260.36A
are proposed to replace the ILS criteria in the current Terminal Instrument
Procedures Handbook (TERPS), FAA Order 8260.3B.
First, no restriction exists for any approach category provided the
commissioned glide path angle does not exceed 3.10 degrees. However,
the FAA/Industry preference is a 3.00 degree glide path, particularly at
Part 139 airports. Second, a glide path in excess of 3.00 degrees
requires the approval of FAA Flight Standards Service. With Category
C operations, comprising the majority of commercial aircraft, ALPA must
strenuously object to any glide path that exceeds 3.00 degrees. Third,
although Category C aircraft could be authorized to use a commissioned
glide path as steep as 3.6 degrees, penalties in both Decision Altitude
(DA) and minimum authorized visibility or Runway Visual Range (RVR) would
be assessed. Assuming the use of standard approach lights (ALSF),
but no Touchdown Zone (TDZ) or Centerline Runway Lights (CL), a glide path
angle of 3.11 to 3.30 degrees would result in Category C minimums of 250-foot
Decision Altitude (DA) and 4,000 feet Runway Visual Range (RVR).
If TDZ and CL runway lights are added, the Category C DA remains at 250
feet, but the RVR could be reduced as low as 2,400 feet. With a glide
path angle of 3.31 to 3.60 degrees, the minimums without TDZ and CL lighting
are a DA of 270 feet and an RVR of 4,000 feet. Assuming the use of standard
approach lights (ALSF), but no Touchdown Zone (TDZ) or Centerline Runway
Lights (CL) the DA remains at 270, but the RVR decreases to 2,600 feet.
These minima preclude Category II and Category III approaches altogether,
and Category D aircraft are prohibited from using the ILS when the commissioned
glide path exceeds 3.10 degrees.
Virtually every airport the size of El Toro has some type of Category
II or III approach. Category III operations enable aircraft so equipped
to land in weather conditions as low as 300 feet RVR. Category II
minima may be as low as 1,200 feet RVR with a DA of 100 feet. Both
Category II and III operations usually employ the use of the autopilot
with autolanding capability, with some rare exceptions. Compare that
capability with the limitations from the previous paragraph and you may
understand our concerns. Basically, as we stated in previous correspondence,
landing minimums necessary for operations to a south runway are too restrictive
to support reasonable low visibility operations. When deviating
from established standards, the limitations become more restricted.
Now, let’s examine each proposal. The McGowan plan makes several
assumptions. First, there is a suggestion that obstacle clearance
requirements over the precipitous terrain can be reduced, and ALPA feels
that suggestion sends the wrong message. The FAA is finalizing new,
highly complex and technical obstacle clearance criteria, and we expect
added conservatism once the new terrain clearance formula becomes available.
It’s hyperbole for Mr. McGowan to suggest that obstacle clearance reductions
are imminent. ALPA TERPs experts don’t have the necessary information
to make such a statement, so we don’t understand how Mr. McGowan can.
We feel that it may be misleading to apply criteria that probably will
not be used. In addition, ALPA has the same objections to this plan
as we voiced with the original county proposal for north flow operations.
ALPA simply cannot capitulate to a straight out departure over Loma Ridge.
Mr. Griffin’s plan focuses on moving the runway threshold to the
south sufficiently to permit a 3.30 degree glide path that will just clear
Loma Ridge by the required obstacle clearance. From the information
posted above you can see at 3.31 degrees weather minimums increase.
This plan deals another fatal blow because it would result in dismissal
of Category D aircraft and the elimination of Category II/III minimums
for virtually every other type of commercial aircraft. Further, the Griffin
Plan assumes absolute accuracy of obstacle data along the ridge line, which
is no small task to survey. To maintain the most favorable accuracy
codes for the obstacles, Mr. Griffin proposes that Orange County has absolute
control over the obstacle environment along the affected terrain and this,
in our opinion, is unprecedented.
ALPA must repeat the question: Is an ILS approach to the south feasible?
The ALPA TERPs experts doubt seriously that a glide path steeper than 3.10
degrees will be approved given the surrounding terrain. In our opinion,
the answer to such a request should be NO. With glide path proposals
at 3.30 degrees, both the McGowan and Griffin proposals are out of business.
Before anyone can claim victory, however, the FAA needs to perform a hard
TERPs analysis for all runway configurations because the FAA evaluation
is the official evaluation.
Up to now, Orange County has apparently ignored and discounted our previous recommendations. That is their prerogative. Rest assured though, the FAA will listen because the FAA must. ALPA will argue and make its case using FAA standards and criteria. We will strenuously object to any glide path in excess of 3.10 degrees because of the preponderance of Category C operations proposed for the airport.
ALPA remains in favor of a properly developed and safe plan for the El Toro Airport, one that maintains an acceptable level of safety. ALPA cannot accept an operational plan for El Toro that reduces the level of safety to less than that of the present John Wayne–Orange County Airport. As always, we offer our services to assist in developing a safe plan. If an acceptable and safe plan cannot be developed for El Toro operations, then we suggest that an acceptable expansion of the John Wayne – Orange County Airport be considered.
Sincerely,
Capt. Jon Russell
Western Pacific Regional Safety Chairman
JR:BP:as
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