Air Transport Association

October 15, 1996

Mr. Paul Lanning
County of Orange
Environmental Management Agency
P.O. Box 4048
Santa Ana, CA 92702-4048

Dear Mr. Lanning:

The Air Transport Association (ATA), representing the 21 major airlines serving the Southern California area, appreciates the opportunity to respond to the recently completed MCAS El Too Community Reuse Plan and the associated Environmental Impact Report (EIR). It is our understanding that the EIR comments are due by October 15, 119, and that the County will make a decision on the preferred reuse alternative by December 15, 1996.

In general, the airlines support the addition of capacity in the air transportation system, if that capacity is, in fact, necessary, and if it can be added at an affordable cost. With the availability of El Toro as a possible commercial airport, the citizens of Orange County may have a unique opportunity to provide for that capacity. However, the airlines have several concerns about the use of El Toro in this manner, and those can be summarized into four areas: operational feasibility, environmental impact, forecasted demand and cost.

The issue of operational feasibility is obviously of prime concern. The new El Toro Airport must be determined to be operationally unencumbered with respect to scheduling and payload requirements. Military aviation activities are not necessarily comparable to airline operations; there are serious terrain issues to be considered and air traffic delays in the Southern California area are already significant. We are, therefore, concerned that a new commercial airline scenario at El Toro be operationally sound with respect to these factors.

To address the environmental impact of this proposed airport, the airlines are aware of the sensitivity of the communities surrounding the El Toro facility. It is important, however, that we make clear that noise mitigation procedures, such as those at John Wayne Airport, have an economic impact on the airlines and restrict out ability to meet the market demand for timely and efficient air travel. The airlines believe that this demand should be the sole factor in determining commercial airline schedules. We understand that there will be substantial local comment on this issue, and we will, therefore, be monitoring the development of those procedures carefully to ensure that they are reasonable and necessary to provide measurable benefit to the community. To that end, we expect to participate, from the beginning, in any and all discussions regarding noise mitigation matters.

The projected demand for air travel in the Orange County area is another issue that must be carefully reviewed. Should the County proceed with the further study of El Toro as a commercial airport by initiating an Airport Master Plan, the airlines will ask to be an integral part of that process. In addition, any analysis of projected demand should be on an area-side basis, undertaken in association with neighboring entities to assure that a truly comprehensive plan is developed. This effort should include other existing ongoing efforts to assess future air travel demand in Southern California such as the Airport Master Plans now in progress at San Diego Lindbergh and Los Angeles International Airports.

Finally, the airlines have been attempting to control escalating airport costs throughout the country, and we are very concerned about the cost of developing El Toro, particularly with the limited financial information that we have been provided. While there is a significant infrastructure in place at El Toro from its previous function, the development of facilities at a level that would support commercial air travel will be extremely expensive and should be developed only as our requirements demand such facilities. We cannot pay for airport facilities unless they are justified by actual market demand.

Airlines are further concerned about supporting an operation at El Toro while we continue to maintain our facilities at John Wayne Airport. We cannot afford to pay for two facilities simultaneously, and if El Toro were developed as a commercial airport, we would need a resolution to the issue of the future of John Wayne Airport. Additionally, any costs for improvements at El Toro and/or John Wayne Airport not directly required or utilized by the carriers must be recovered from the beneficiaries of those improvements.

To restate our position, sufficient airport system capacity to meet market demand is obviously desirable. We are, however, concerned that any effort to meet market demand is obviously desirable. We are however, concerned that any effort to develop that capacity be operationally viable and fiscally sound.

The Air Transport Association member airlines again thank the County of Orange for the opportunity to comment on this very important issue, and we will always be available for further discussion of this very important matter.

 Sincerely,

Edward A. Merlis
Senior Vice President  

Air Transport Association

May 15, 1996

Mr. Paul Lanning
County of Orange
Environmental Management Agency Environmental and Project planning Division
P. O. Box 4048
Santa Ana, CA 92702-4048

Dear Mr. Lanning:

The Air Transport Association, which represents the major Air Carriers serving the Southern California area, respectfully submits the following comments on the Notice of Preparation (NOP) of Environmental Impact Report No. 565. We understand that the NOP serves as a statement indicating that an Environmental Impact Report (EIR) is being prepared as part of the process to facilitate the transfer of the El Toro property in the County of Orange. We notice that contained in the NOP is a comment by the County indicating that the NOP provides a higher level of detail than actually required. The Air Carriers, in these comments, are doing the same, specifically in the hope that we can more clearly define and explain the airline industry's views on the proposed redevelopment of MCAS El Toro as an Air Carrier airport.

The airlines serving the Orange County area have a significant investment in John Wayne Airport which presently serves virtually the same geographical area as the proposed airport at the El Toro site. The further fragmentation of airline activities and resources in the Los Angeles area that would occur if El Toro was developed as described in Reuse Alternative A (Commercial Passenger and Cargo use) would pose serious challenges for the airlines in terms of operational control and economic viability. Reuse Alternative B (All-Cargo and General Aviation Use) presents other difficulties that are addressed separately below. We have no comment on the remaining Reuse Alternatives, since these are non-aviation options.

The carriers are not convinced that the alternatives, as presented, adequately describe the various aviation related configurations that might be studied for the El Toro site. As part of the EIR process, we would be willing to discuss other alternatives, along with estimates of the overall costs involved in those options, including anticipated environmental impact mitigation expenses.

The flight track/operational scenario provided by the County is not supported by the FAA Air Traffic Control analysis. In addition to crosswind and payload limitation factors, we have significant concerns about operational conflicts with our present activities at John Wayne Airport. The airlines also have major reservations regarding integration of commercial aircraft operations from El Toro into the existing traffic flow in and around the Los Angeles Basin. Air traffic management and capacity in Southern California are serious, ongoing problems which are currently being analyzed by both the local air traffic personnel and the FAA Systems Command Center in Virginia. Any significant traffic numbers in and out of El Toro would obviously exacerbate this situation. It should be noted that no valid assumption can be made by comparing the military activity at El Toro with commercial Air Carrier operations at the same site.

Alternative B raises special concerns for the freight and package carriers because of their early morning and nighttime operations. These schedules make them particularly vulnerable to noise mitigation measures which are normally more restrictive during those hours. Any significant noise constraints would render El Toro undesirable for cargo operations. Restrictions limiting runway usage and/or a cap or slot allocation would also severely impair El Toro's utility as an air freight facility. The Cargo Carriers also have concerns about investment in a one (Air Carrier) runway operations, since, in addition to crosswind factors, any loss of that runway would constitute a service suspension. Thus, current forecasts of potential commercial use of El Toro may be overly optimistic. The spacing between runways will also be an issue, especially since freight carriers utilize wide body aircraft. General Aviation aircraft on the other runway would be subject to significant wake turbulence limitations.

The freight carriers are also concerned with aircraft performance and payload limitations in relation to the surrounding terrain. A full aircraft performance analysis of those constraints would be required, particularly if noise mitigation measures as described above are imposed.

Finally, the freight carriers would be hesitant to enter into a situation wherein the full burden of an airport's operating costs would be placed on the shoulders of a few operators. Therefore, an equitable airport system-based rate setting methodology would be essential.

To summarize, the airlines endorse efforts to evaluate options for additional system capacity and increased air transportation efficiencies. Limited capacity translates to increased delays and the inability to maintain a reliable schedule. Air traffic delays are also the largest single correctable airline expense. We are concerned that John Wayne Airport may not be adequate to serve the air transportation needs of the area beyond the year 2005. We also understand that the proponents of an Air Carrier airport at El Toro need the support of the Carriers to go forward.

For the record, the Air Carriers agree that further study of El Toro as a new commercial airport is warranted. Clearly however, we cannot commit at this time to supporting either Alternative A or B given our present John Wayne Airport obligations; the enormous expense of such an undertaking; the limited information and data now available to us; and the operational, safety, and economic concerns discussed above.

The Air Transport Association, along with our member airlines, would like to thank the County of Orange for the opportunity to comment on the Notice of Preparation. We look forward to providing additional views and information during the course of development of the Environmental Impact Report.

Sincerely,

J. Roger Fleming
Senior Vice President Operations & Services 

An FAA internal memo supports the conclusion that John Wayne and El Toro airports can not operate together in a two airport system for commercial traffic.

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