October 16, 1998

Ms. Courtney C. Wiercioch
Program Manager
MCAS El Toro Master Development Program
10 Civic Center Plaza, 2 nd Floor
Santa Ana,, CA 92701

Dear Courtney:

             This letter is written on behalf of the airlines serving Orange County in reference to the impending Notice of Preparation (NOP) planned for the conversion of the El Toro Marine Corps Air Station to a commercial airport. It is our understanding that the NOP process is scheduled to begin very shortly and the airlines feel it important to restate our position with respect to this matter.

             As we have indicated before, the airlines are supportive of any initiative to provide additional cost-effective airport capacity in Orange County. However, as a result of airline meetings with the County, and after reviewing the information we have received, we would like to make you aware of some very serious concerns regarding the El Toro master plan. While it must be recognized that each airline may have individual requirements or issues related to developing an airport at El Toro, the concerns identified herein are shared by all of the carriers serving Orange County.

            The County has been directing the master plan toward a two-commercial airport system, but the carriers question how a system in which both John Wayne and El Toro operate as commercial airports can be financially justified. Operating two airports that essentially serve the same market in such close proximity creates an inefficient use of airport and airline resources, will unnecessarily drive up costs, and could adversely impact the air service being provided to the community. As long as aviation demand can be met at one airport (according to the master plan, this can be  accomplished at John Wayne in an unconstrained environment in the near-term. and at El Toro in the long-term), operating two commercial airports simultaneously would not appear to be a viable economic option,

         The proposed rail link between the two airports that is part of the County's preferred option likewise creates an unnecessary cost burden. The costs of constructing and operating such a system  would be excessive, and the carriers question its feasibility. Further, we do not fully understand the rationale for the landside connection between the two airports, since it is unlikely we'll have connecting passengers between the two airports, and we do not believe that there are any  operational benefits associated with it.
 
         The perimeter rule, also part of the preferred option, is a major concern, The carriers acknowledge the County's responsibility to provide airport capacity, but that responsibility does not extend to dictating the markets that may be served from its airport(s). The imposition of a perimeter rule would create an inefficient utilization of airport capacity, and restrict competition among the airport users. As proposed, the perimeter rule would actually force most of the carriers serving John Wayne, should it remain open, to discontinue service there.
 
         On a separate subject, we are extremely concerned about potential flight restrictions that might affect our ability to respond to market demand, This issue is crucial to the viability of El Toro as a commercial airport in any capacity, As you are aware, the current restrictions at John Wayne Airport have severely limited capacity at that airport, and we are concerned that, at El Toro, limitations may be placed on flight scheduling, including nighttime operations that could similarly constrain capacity there. The airlines consider any such restrictions unacceptable.
 
         A critical issue for the airlines remains the operational scenario proposed by the County. Although we understand the environmental implications involved in developing any new airport, we would like the planning to reflect the impact of the prevailing winds and the adjoining mountainous terrain, factors that will ultimately determine what type of operations we can safely conduct. We can then work together to develop procedures that will support reliable, economically viable air service while meeting the noise abatement     needs of the surrounding communities.
 
         The airlines appreciate the County's efforts in planning for additional airport capacity and we would like to see these issues resolved so that the project can be brought to a successful conclusion. We would welcome the chance to address these issues in more detail with you and your staff, and have formed a steering committee for that purpose, This committee will consist of Dennis Olson (Chairman of the Airline Airport Affairs Committee), Kelley Brown (a consultant representing the airlines serving Orange County), Kristine Fitzgerald (Government Affairs, ATA) San Chang (United Airlines), Leslie Carr    (Southwest Airlines) and myself   We will be contacting you soon to set up a meeting.

                                                                         Sincerely,

                                                                         Neil Bennett
                                                                         Regional Director

cc: El Toro Reuse Steering Committee
      E. Merlis, ATA
 

The Airport Capacity and Noise Act makes night time curfews unlikely without airline approval.