The following letter was sent to the Board of Supervisors by Michael Ward in his dual capacity as Mayor of Irvine and Chairman of the El Toro Reuse Planning Authority (ETRPA). ETRPA includes representation from the cities of Dana Point, Irvine, Lake Forest, Laguna Hills, Laguna Niguel and Mission Viejo.
October 15, 1996
Chairman Roger Stanton and Members
Orange County Board of Supervisors
10 Civic Center Plaza
Santa Ana, CA 92701
Dear Chairman Stanton and Board Members:
The City of Irvine's comments on the MCAS El Toro Reuse Plan and Environmental Impact Report (EIR) as well as those of the El Toro Reuse Planning Authority are being transmitted to County staff under separate cover. However, I wanted to share some additional thoughts with you and the Board as we are about to embark on a series of decision making meetings that may lead to the certification of the EIR and submittal of a reuse plan to the Department of the Navy.
As you will recall, you and Supervisor Steiner negotiated to form an alliance with the Cities of Irvine and Lake Forest in the creation of the El Toro Reuse Planning Authority wherein the County of Orange and the two cities worked to craft a series of baseline documents that would have formed the foundation for a reuse plan for El Toro. I firmly believe that if we continued to work together, a reuse plan with the Navy's blessing would be in place today. However, in January of 1995, the Board of Supervisors withdrew from ETRPA and commenced the most divisive period in relations between the County and numerous South County cities. What was puzzling about this event is that there was no Measure A requirement to do this, as stated in two memos from County Counsel. Measure A says absolutely nothing about the local redevelopment authority.
The divisiveness is continuing to grow as evidenced by the turnout of over 600 peoples who attended the Board meeting on the Reuse Plan and EIR in Irvine on October 2, 1996. The public's frustration with the reuse planning process was evident at that meeting, with the perception being that no matter what affected citizens say or do, the majority of the Board is predisposed to building a commercial airport at El Toro, no matter what shortcomings may exist in the Reuse plan and EIR. The Irvine meeting did not alter the public's perception of the process, especially since many people in the audience were not given a chance to speak. Certainly we appreciated the Board's desire to meet in Irvine, but we could not understand the need to end the meeting, before all who wished to speak could do so. There was no obvious reason why everyone who wished to speak was not given a chance to do so, especially since this was the only Board Meeting sitting as the Local Redevelopment Authority outside of Santa Ana.
Those people who were given a chance to speak raised a number of significant issues with the reuse plan and EIR, which we share, including the fact that the entire process has seemed predetermined to achieve an airport, from the passage of Measure A with the drafting of reuse criteria that only an airport could meet. We believe that the EIR lacks a definitive project description of any of the alternatives considered, and lacks analyses that would provide meaningful information to the public on whether any of the alternatives are feasible. Moreover, nothing is provided for mitigation measures other than a list of choices, postponing consideration of all of the crucial project and mitigation measure details to some date in the future, and we cannot tell from the list of choices what measures are attainable over what period of time, and how much these measures will cost to implement. As a result, concerned citizens find it hard to know the impacts of the project, the extent to which successful mitigation of those impacts is possible, and the likely overall success for the reuse. Therefore, the EIR as a whole fails to provide meaningful analysis of the viability and potential impacts of the proposed reuse. According to a variety of technical experts, this EIR is incomplete and inadequate for such a major undertaking, and it even appears to have serious factual omissions and methodological errors. While I am not an expert on the California Environmental Quality Act, I cannot understand how the Board can even consider certifying a document that seemingly fails to answer the threshold questions of whether or not any of the three major alternatives are feasible.
The impact of noise, air pollution and traffic on the central Orange County area is not analyzed to any degree that would allow the reader to make a choice between the three alternatives; bold and unsubstantiated assumptions are made of a commercial airport being able to operate with the same flight patterns that the military uses; physical deficiencies of the runway, terrain, wind and other constraints associated with a cross runway configuration are discussed without adequate analysis; major assumptions are made regarding operational changes at John Wayne Airport which cannot be substantiated without analysis; major discrepancies exist regarding passenger demand and annual operations which cannot be reconciled; and of course if these questions cannot be answered, how can an economic impact analysis be undertaken that has any validity? We believe that even with a tiered EIR process, which the County staff purports to use, these and many other questions must be answered before a master plan and subsequent EIR for the base are undertaken.
Furthermore, we have to wonder how enough information can be given to the Department of Navy, using this EIR as a fact finding tool, for the Navy to issue its record of decision. When the community that has lived with MCAS during its 50 year history is asking so many critical questions about the reuse plan and its environmental review process, how can Navy officials in Washington, D.C., be asked to make an intelligent decision, knowing less about reuse issues than the residents of Orange County. We believe that this EIR will do nothing to further educate Navy officials in Washington, D.C., to make an informed decision.
On October 8th, the Irvine City Council provided its input on the Reuse Plan and EIR. The most significant discussion dealt with a desire to find an alternative site from either John Wayne Airport or MCAS El Toro for a new airport to meet Orange County's future needs, if in fact existing airports in the region cannot accommodate this need.
Converting El Toro to a commercial airport is fraught with obstacles that have been highlighted in many comments which have been forwarded to the County from the Southern California Association of Governments , the Air Line Pilots Association, the Air Transport Association, ETRPA, and numerous professional airline pilots have spoken at public meetings on constraint factors associated with the use of El Toro's runways for commercial operations. Assuming all of these other obstacles can be overcome, what is the likelihood that El Toro will be able to attract 38 million air passengers a year by the year 2020? The major airlines are spending money to upgrade facilities at LAX and a master plan is underway to expand LAX's passenger capacity to 98 m.a.p. Ontario Airport and Long Beach Airport are operating below capacity, and closed or realigned bases at Norton AFB (San Bernadino International Airport), George AFB (High Desert International Airport) and March AFB are all anxious to acquire commercial passenger service. Not only do these former active bases desire commercial service, they are not surrounded by an urban area of 2.5+ million people, so their conversion to a commercial facility would not be opposed to the extent that it is at El Toro. And the County's EIR states that if El Toro is not converted to a commercial airport, commercial demand would be absorbed at other area airports, including the former active military bases. Additionally, one has to wonder how El Toro with the highest anticipated cost of enplaned passenger as compared to other airports in the region, would be able to compete with other area airports which will likely have lower ticket prices commensurate with lower operating costs.
But let's assume that the demand for 38 million air passengers exists and the demand cannot be met at any of the existing or future (military) base airports. Why can't we work together with the federal government, County's cities and business community, and identify a site near El Toro, such as a portion of Camp Pendleton for a future airport, or even explore the options that may be available at the Los Alamitos Armed Forces Reserve Center? Even under the best of circumstances, development pressures will continue around El Toro even if an airport is built there, making its long term viability questionable. The military has continuously opposed encroachment at El Toro, but has largely been unsuccessful, whereby jets now fly predetermined paths because of urban encroachment. This is the situation a commercial airport will inherit at El Toro - a facility that is obsolete because of land use conflicts that will only increase because of the area's strong economy. What we will likely inherit is another Stapelton Airport (Denver) situation which was closed because of urban encroachment. What we should consider doing is what Denver did before deciding to close Stapleton; find a site and build an airport in an area that will serve Orange County's needs (as well as those of San Diego County - because of constraints on Lindbergh Field) into the 21st century and beyond, and where parallel runways of adequate length, which can be designed with ambient wind conditions, and within gradient guidelines are achievable without disrupting existing development areas. That is the kind of airport we will need in the next millennium and beyond, with flexibility to accommodate aircraft which have yet to be designed. With the City of Denver, which has a population of approximately 500,000 and a metropolitan area population of approximately 2 million, now being served by Denver International Airport, a state of the art facility with room to grow, why can't Orange County think the same way and plan for its long term rather than looking for short term solutions?
We urge you to review the comments of ETRPA and its individual member cities, and all others received, and respectfully request that you restore a credible and inclusive planning process which will result in documentation where the argument will not be about a lack of facts and information, but about what decisions to make regarding the reuse of El Toro - where everyone agrees on the facts and information.
For those of you leaving the Board, we look forward to working with you on the reuse plan and EIR for your remaining tenure. We also look forward to meeting with the new Supervisors who, hopefully, will work with us to restore a credible process which is not tainted by the perception of a predetermined outcome. Our resolve is firm. Only if we begin to work cooperatively will we avoid a situation where the future of the reuse of El Toro is placed in the hands of the courts and is taken away from those of us who should be working with you to plan in a cooperative manner.
Sincerely,
MICHAEL WARD
Chairman, ETRPA
Mayor, City of Irvine