This page last updated on February 24, 2000.
Allied Pilots Association
APA represents over 9,800 American Airlines pilots.
The following letter was sent by APA's President as an EIR comment.
Click here for a related letter from
American Airline's top ranking operations officer.
Note: The air base's easterly runways are referred to
by some as Runways 07 and by others as 08. The northerly runways
are referred to as either Runways 34 or 35. The difference
in designation arises from the small variance between magnetic and true
north compass headings.
Mr. Brian Speegle
County of Orange, California
10 Civic Center Plaza, Second Floor
Santa Ana, CA 92701
RE: Comments on Environmental Impact Report 573
Dear Mr. Speegle:
The proposed EIR suggests using Runway 8 as the primary departure runway in the Formal Runway Use Program, and a straight out departure on Runway 35 as a secondary departure path. According to FAA Order 8400.9(5.b), concerning the National Safety and Operational Criteria for Runway Use Programs, a Letter of Understanding between Flight Standards, Air Traffic Service, the airport proprietor and the users (the airlines and their pilots) is required to establish a Formal Runway Use Program. The pilots of both ALPA and APA have publicly stated that they will not use Runway 8 at El Toro. Since the users (pilots) will not sign a Letter of Understanding, Runway 8 cannot be used in the Formal Runway Use Program. The pilots will also not agree to a straight out (canyon departure) on runway 35, which would have terrain on both sides of the departure path. The EIR also states that a 410 ft./nm climb or approximately 1200 ft./min. rate of climb is required for obstacle clearance. That rate of climb is unattainable with an engine failure. The straight out departure on runway 35 would not allow an escape maneuver in case of an engine failure between the terrain. The FAA would probably not approve of a primary runway that consistently has tailwinds in a direction toward rising terrain, or the straight out canyon departure between rising terrain anyway. But the FAA will not comment until they see a formal master plan.
Of course, it really does not matter if Runway 8 is approved under the Formal Runway Use Program, because FAA Order 7110,65J-ATC/Chapter3.ATC-Terminal/Section 5.Runway Selection/3-5-1 selection/Note 2 states that, "At airports where a 'runway use' program is established, ATC will assign runways to have the least noise impact. If, in the interest of safety, a runway different from that specified is preferred, the pilot is expected to advise ATC accordingly. ATC will honor such requests and advise pilots when the requested runway is noise sensitive."
The proposed departure paths at El Toro airport are completely unacceptable to the pilots, and no one has the authority to override the pilots' decision to use the safest runways for takeoff or landing.
Sincerely,
Captain Richard T. LaVoy
President
RTL/sh
cc: APA Board of Directors
Click here for related letters from the Air Line Pilots Association (ALPA)
Click here for earlier letters from APA
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