AIR LINE PILOTS ASSOCIATION
635 HERNDON PARKWAY - PO BOX 1168 - HERNDON, VA 20170 - 703-689-2270
                                                                                                                FAX 703-689-4370

Ms. Courtney Wiercioch
Manager
MCAS El Toro Master Development Program
10 Civic Center Plaza, Second Floor
Santa Ana, CA 92701

Subject: El Toro Airport Community Concepts and Terminal Instrument Procedures (TERPS) Report

Dear Ms. Wiercioch:

The Air Line Pilots Association (ALPA), representing 50,000 pilots who fly for 49 airlines in the US and Canada, has reviewed and discussed the subject documents at considerable length. We are most appreciative of your efforts and those of your colleagues to establish a good working relationship with ALPA and communicate with us as you have concerning the El Toro airport proposal. As you know, ALPA's interest in the airport proposal has its origin in the County's request for public input to the August 1996 draft El Toro Community Reuse Plan, on which we commented via letter dated October 11, 1996.

ALPA's motto. "Schedule with Safety," expresses quite clearly our limited focus on the subject airport proposal: namely, to determine what runway configuration will best enhance the safety of commercial aviation at the selected airport site. For that reason, we do not speak to other issues such as environmental impacts, capacity and so forth.

The County's recently concluded terminal instrument procedures (TERPs) study has helped us to make an objective analysis of the viability of a commercial airport at this site from a safety standpoint. The TERPs study is of particular importance for this proposed airport because of significant nearby terrain located to the north, northeast and east of the airport site.

Concept C, which is now the focus of Orange County as the build option of choice, envisions a two-airport system utilizing both John Wayne Airport and the new El Toro airport, connected by a passenger and baggage transport system. John Wayne Airport is intended to remain open to serve as a commercial airport for short-haul passengers, which ALPA opposes as explained in our previous letter.

Mountainous terrain surrounds three sides of the airport, with only the area to the west being completely free of such terrain. Loma Ridge, which is located directly north of the airport, rises to over 1,000 feet above airport elevation within four miles of the airport. To the northeast, terrain continues to rise to almost 6,000 feet above mean sea level only nine miles from the airport boundary. (The airport elevation is just under 400 feet above mean sea level.)

The air base has two closely-spaced parallel north/south runways (34-16) and two closely-spaced east/west runways (7-25), all four of which would be lengthened and minimally separated under Concept C. The extended centerlines of runways 34L and 34R intersect significantly rising terrain within four miles of the airport boundary which would make straight-out approaches hazardous for heavier aircraft under normal operations, especially during stormy weather or Santa Ana wind conditions, and for any aircraft experiencing an engine failure on takeoff. The extended centerlines of runways 7L and 7R intersect an upward sloping terrain mass within two miles, and insurmountable terrain for most straight-out easterly departures by transport aircraft within 10 mile. Runways 25L and 25R offer the best departure paths, would often enable takeoffs into the wind and are free of rising terrain, but these runways would not be used for takeoffs within the context of Concept C. Runways 16L and 16R have gently rising terrain along their departure paths, but departures would run counter to arrivals on the only current low-visibility instrument approach procedure to the airport.

In our 1996 letter, we made it clear that a realignment of the principal runways to a general magnetic orientation of 310-130 degrees would provide approach and departure flight paths relatively free of steep terrain. Further, we stated that such a runway alignment would provide all-weather approach and landing operations in both directions, and such alignment would provide takeoff and landing capability with a head wind (or calm wind) component virtually all of the time.

We recommended the construction of parallel runways having 130-310 degree magnetic orientation, separated by not less thin 4,300 feet, which would provide a simultaneous, independent parallel precision instrument approach and landing capability. In our proposal, these two parallel runways would replace all existing runways. Such a configuration would enable a very high level of flight operations.

Further analysis of the terrain to the north and northeast leads us to conclude that simultaneous, independent parallel instrument approaches are probably not feasible. This is so because ATC would be unable to vector an aircraft on the north-side approach to the east, (toward terrain) during an intrusion into the no-transgression zone by in aircraft on the south-side approach course. This situation dictates that dependent or staggered parallel runways be used, which will somewhat reduce the amount of available capacity compared to an independent approach capability.

ALPA reiterates its recommendation that El Toro be configured with two parallel 13-31 runways of at least 10,000 feet in length. Runway lengths of 10,000 feet would enable safe regional and transcontinental operations. For international operations and flights to Hawaii, one of the runways should be 12,000 feet in length.

Our second, less desirable alternative would be a three-runway configuration consisting of a 13- 31 runway located west of two parallel 34L and 34R runways with the parallels separated at least 700 feet to meet minimum standards for air carrier operations during terminal and visual weather conditions. Runway 13-31 should be equipped with a Category I instrument landing system (ILS) on both ends as should one of the runway 34 ends. Under normal wind conditions, approaches and landings would be made on runways 34L and 34R; takeoffs would normally be made on runway 31. With ILS approaches to runway ends 13 and 31, the airport would have a Category I precision landing capability for nearly all possible combinations of wind and weather conditions.

With this alternative. the existing 7-25 parallel runways should be removed because the addition of runway 13-31 would provide the airport's takeoff capability needed without the terrain problems which face takeoffs on runway 7L and 7R. Further, nighttime or marginal visibility daytime approaches and landings should not be conducted on runway 16L or 16R because of the proximity of Loma Ridge.

Takeoffs to the northwest on runways 34L and 34R should be limited to head wind or calm wind conditions and a turn should be made to the northwest promptly after departure to avoid Loma Ridge. We know of no other airport in the country where such a significant terrain mass is overflown within three (3) miles of takeoff by commercial aircraft. There is sufficient air space for IFR departure to turn northwest to avoid this terrain, however, and that is what the pilot community will expect to do.

The TERPS clearances over such a terrain mass meet minimum FAA standards, but they are inadequate to (1) prevent airborne terrain clearance warnings, by the aircraft ground proximity warning system (GPWS), and (2) satisfactorily mitigate the potential for a collision with the terrain. The El Toro TERPs study shows that a minimum climb gradient of just over 400 fact per mile would be required to clear Loma Ridge. We believe a climb gradient well in excess of 500 feet per mile is the practical minimum to consistently clear the ridge and not set off aircraft terrain warning systems. However, in the event of an engine failure at liftoff, a fully loaded B-757 on a 90 degree day would climb only 183 feet per mile in a calm-wind atmosphere. Thus, not only are turns to the northwest necessary for most normal operations, they are essential for an aircraft that suffers an engine failure on liftoff. Unless the pilot is required to turn during normal departures, he or she may very well forget to turn during the high-workload environment of an engine failure. In summary, straight-out departures from runways 34L or 34R should not be conducted by passenger-carrying commercial transport aircraft due to the terrain hazard posed by Loma Ridge.

ALPA supports the concept of moving air carrier operations out of John Wayne Airport due to its undesirable margins of safety. However, in our professional view, Concept C provides the same, or perhaps worse safety margins as John Wayne for the reasons given above. We recommend, therefore that El Toro be reconfigured to a parallel 13-31 runway operation. Less desirable, but acceptable to ALPA, would be a three-runway configuration comprised of a 13-31 runway and parallel 16-34 runways.

We trust that this letter provides you with a clear understanding of our views on the proposal for El Toro Airport. Again, thank you for including ALPA in the planning process to date and we look forward to further constructive dialogue.

Sincerely,

Capt. Jon Russell
Western Pacific South
Regional Safety Chairman

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