GARY SIMON, EXECUTIVE DIRECTOR
MCAS EL TORO LOCAL REVEVELOPMENT AUTHORITY

July 7, 2001

Mr. Paul L. Galis
Deputy Associate Administrator for Airports Federal Aviation Administration
800 Independence Ave. SW
Washington, D.C. 20591

Re: Airspace Determination for former MCAS E Toro

Dear Mr. Galis:

Thank you for returning my call on June 2 8 and speaking to Mark Mispagel in my absence. We understand that the Federal Aviation Administration (FAA) is continuing to work diligently on the County of Orange/El Toro Local Redevelopment Authority's (LRA's) proposed flight procedures for a commercial airport at former MCAS El Toro (OCX). We appreciate the need for the FAA to review the proposed flight procedures and airspace safety thoroughly and objectively - and to take the time necessary to resolve all relevant issues.

As Mark stated, we are aware that individuals, groups and elected officials have submitted letters to the FAA commenting the LRA's Draft Airport System Master Plan (ASMP) and the proposed OCX terminal procedures and airspace determination issues. We understand that these letters and past or present FAA officials have proposed alternatives to the LRA's proposed procedures for OCX.

Recently, Williams Aviation Company (consultants) made a presentation to the Orange County Regional Airport Authority (OCRAA) that purported to summarize the Mitre Corporation's analysis and the consultants' view of the FAA's current thinking on the Airspace Determination for OCX. The consultants' summary of the Mitre Corporation procedures appeared to be different from the LRA's proposals, and in some cases the consultants presented alternative procedures proposed by others as if these procedures were the LRA's proposals,

While we are not suggesting that the consultant has insight into the FAA's airspace determination, we do want to be very clear that there is sound rationale behind the LRA's proposed procedures for the airport that the LRA is planning for former MCAS El Toro.

We recognize that the FAA may be required to analyze alternative procedures or modifications of the LRA's proposed procedures, but we assume that the FAA will clearly identify these differences or modifications in the Airspace Determination including quantifying bow these differences would potentially affect capacity in the Southern California system.

The LRA, as a long time airport proprietor, is familiar with the purposes and use of FAA airspace determinations and knows how to read them. The general public, which has a great deal of interest in this important project, likely, does not. It is vitally important, therefore, that the airspace determination discuss FAA's conclusions in a manner that will not create confusion due to its technical nature. The context of all of the LRA's ASMP proposals is very important because the LRA went to great lengths to avoid and minimize any potentially adverse impacts of the OCX project in the communities of Orange County.

SUMMARY

In summary, the LRA's proposed arrival procedures for Runway 35 and departure procedures for Runway 8 at OCX are similar to the former Marine Corps arrivals and departures for the 35 years from the mid-1960's to closure in 1999. The only difference from the Marine Corps' procedures is that the LRA's northerly departures from Runway 35 would continue north for about 8 nautical miles DME and then all aircraft capable would turn right. The TERPS analysis prepared by the LRA determined these procedures to be feasible in conformance with FAA standards.

These procedures were planned so that OCX flights avoid airspace conflicts with other regional airports (i.e., OCX flights would use the airspace formerly used by the Marine Corps operations wherever possible). In very limited situations, which are projected to comprise only 5% of all 2020 flights from OCX, northerly departures from Runway 35 that are not able to turn right (and only these departures) maybe subject to some delays. The flights that we are referencing are not projected to occur until approximately 2010, and even then, are projected to occur at times when potential impacts would be minimal or non-existent.

PRECISION APPROACHES:

Nearly all arrivals to OCX (96%) would be from the south to Runway 35, which is the only available runway for which precision approaches for all classes of commercial aircraft will meet current FAA Standards. Precision approaches to Runway 8 or Runway 16 are not proposed because of airspace, land use and/or terrain conflicts.

Missed approaches to Runway 35 would be a climbing left turn to 170 degrees similar to the route of the former Marine Corps departures from Runway 35. Since this approach is very similar to the previous military departure route from Runway 35 and therefore avoids the routes of other regional airports, little or no impacts are expected.

In the rare instances of southerly winds exceeding 7 knots (4%), visual approaches to Runway 17 would be accomplished by using a 14-degree westerly offset approach (i.e., approx. 150 degrees) and a right turn to a final approach at approximately two nautical miles north of OCX. The LRA recognizes that delays can be expected in the rare cases when this approach may be needed.

DEPARTURES:

Approximately 62% of departures would be east on Runway 8 along the same route as the former Marine Corps easterly departures for fighter jets, Since this departure is similar to the former Marine Corps' departures, little or no impacts are expected.

Approximately 36% of departures would be north from Runway 35. Commercial aircraft will depart north on runway heading and at eight nautical miles DME, as noted above, would execute a right turn whenever possible. This departure has been designed to avoid the routes of other airports. Straight north departures would be minimal and the LRA recognizes that such flights will be necessary-to help minimize noise impacts and community disturbance in communities to the northwest. Note however that commercial aircraft arrivals to John Wayne Airport are forecasted to decline by 35% with the development of OCX Therefore, the use of airspace to the north and east of John Wayne Airport by John Wayne Airport traffic would be reduced with development of OCX.

MISSED APPROACHES:

As noted above, the missed approach procedure for Runway 35 would be a left climbing turn to 170 degrees along a course approximately 2 to 5 miles west of Runway 35. This missed approach course would avoid aircraft approaching John Wayne Airport. Thus, little or no conflicts or delays are anticipated for ILS approaches where a missed approach procedure must be available for all approach operations.

ALTERNATIVE APPROACHES:

No precision approaches are proposed from the west to Runway 8 because they would conflict with incompatible land uses and with aircraft approaching John Wayne Airport or Long Beach Airport

Precision approaches are not feasible from the north to Runway 17 due to terrain. An RNAV approach may be feasible to Runway 17 for Aircraft Approach Categories A, B and C. The approach minimums would be very high and would not offer a benefit during IFR conditions.

ALTERNATIVE DEPARTURES:

No departures are feasible from Runway 26 to the west because they would conflict with incompatible land uses and aircraft approaching John Wayne Airport and Long Beach Airport Such departures would result in unnecessary impacts and delays at these other airports. Note also that no substantial wind advantage would accrue to westerly departures versus easterly departures because westerly winds at OCX are not substantially more prevalent than easterly winds during an average year (and westerly/easterly winds rarely exceed 7 knots).

Since approaches from the south to Runway 35 are the only feasible precision approaches to OCX, departures to the south on Runway 17 would not be efficient or practical when Runway 35 is in use. Departures from Runway 17 to the south would conflict with arrivals to Runway 35. This would result in severe delays except under very light periods of aircraft operations.

CONCLUSIONS:

As you can see, the LRA's proposed procedures would maximize the use of available airspace in the region by reusing the former Marine Corps procedures. For northerly departures from Runway 35, the LRA proposes to eliminate the northbound left turn the military used. This avoids overflights and helps to minimize noise impacts and community disturbance in communities to the north west of OCX that would oppose left turns.

The LRA's proposed arrival and departure routes for OCX would be similar to the existing routes for San Francisco International- (SFO) airport except OCX -would have about 40% fewer operations and considerably better weather and wind conditions than SFO. In addition, it is notable that most all projected OCX departures would be away from John Wayne Airport as opposed to SFO's departures, which are toward Oakland Airport (and vice versa).

For these reasons, the LRA concludes that OCX would greatly increase runway capacity in the region with little or no new conflicts with other airports.

None of the foregoing information should be news to the FAA, but we want to ensure that our proposal is clear. If you have any questions or comments on these procedures, please contact Bryan Speegle at (714) 834-3144,

Sincerely,

Gary Simon, Executive Director

cc: Member's, County of Orange Board of Supervisors
      William Withycomb, Regional Administrator, FAA Western Pacific Region

Note: This letter was obtained by the media and has been scanned by OCR software which may allow minor differences from the original.

Click here for the referenced Mitre report.

Click here for the rebutal from Tom O'Malley, Deputy Director of ETRPA

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