The official DEIR comment submitted by the city of Laguna Beach.
October 11, 1996
Paul Lanning
EMA/Environmental and Project Planning Division
County of Orange
300 North Flower Street, Room 321
Santa Ana, CA 92702
Dear Mr. Lanning:
This letter contains formal comments of the City of Laguna Beach regarding the draft EIR #563 for the El Toro Marine Corps Air Station Community Reuse Plan. If there are any questions regarding the comments in this letter, please contact our City Manager, Mr. Kenneth Frank, at 497-0704.
In short, the City of Laguna Beach believes that the Environmental Impact Report as drafted is inadequate for numerous reasons. The report should be revised and recirculated with adequate time for affected communities to analyze the document.
Our primary concerns are as follows:
NOISE
1. The noise report appears to ignore topography and the way that hills and valleys affect sound waves. This is extremely important to residents in Laguna Beach because residents in our hilltop communities already are more adversely affected by noise from planes and that problem would be exacerbated with a commercial airport at El Toro. Noise testing should be conducted with real airplanes.
2. The report ignores the duration of noise impacts. It attempts to compare the noise from military jets, which fly infrequently near our community, with the noise from a 24 hour, round the clock commercial operation. In particular, the noise at night and in the early mornings would be much more harmful to our residents than noise which occurs during the normal work day. Hence, the EIR has substantially understated the adverse noise impacts which would be associated with the commercial airport at El Toro.
3. The EIR attempts to compare noise from a commercial airport with noise from military operations at El Toro. However, the Federal government has already decided to close the Marine Corps Base at El Toro. Hence, the comparison to military noise is not pertinent. The comparison should be a commercial airport versus no airport at all. The EIR is deficient in that it uses a false baseline, i.e., the El Toro Marine Base since that Base will no longer be in operation.
4. It does not appear that the noise analysis quantifies the number of people living within the 65 CNEL contour who would be impacted by the proposed operations. We believe that many of our residents would be impacted particularly when topography is taken into account and particularly when the 24 hour a day operation is considered.
5. The noise analysis does not consider any alternative flight patterns which might further exacerbate the adverse noise impact on our residents particularly during the nighttime hours.
TRAFFIC
1. The EIR is deficient in that there is no analysis of traffic impacts on the City of Laguna Beach. Without question, Laguna Canyon Road and El Toro Road within our City boundaries will receive additional traffic because of a commercial airport. Already roadways are operating far in excess of accepted capacity. The EIR needs to extend this analysis to encompass Laguna Canyon Road and El Toro Road through our community. This is particularly important for our tourist oriented business community.
2. The EIR does not consider the joint impact of the Eastern Tollroad and a commercial airport on Highway 133 (Laguna Canyon Road).
3. The EIR does not appear to analyze peak hour intersection capacities which is extremely important to Laguna Beach given several areas where peak hour traffic is already gridlocked.
4. The EIR assumes that the commercial airport will apparently not generate any additional vehicle trips but instead will simply divert drivers from other regional airports. That does not seem realistic. Certainly the proximity of an airport will engender additional traffic within the immediate vicinity of that airport as people shift from other modes of transit to air travel. While there may be an overall benefit in the Southern California region, the traffic in the vicinity of a new airport would be further aggravated.
5. The EIR is unrealistically optimistic about travel assumptions for high occupancy vehicle use.
6. The EIR is inconsistent with the techniques of the Orange County Congestion Management Program which has been adopted by all of the cities in Orange County and the County itself.
7. The EIR fails to identify funding sources for construction of additional roadways to adequately mitigate the additional traffic that will emanate from the new commercial airport.
AIR QUALITY
1. The EIR totally ignores the localized impacts of air quality issues from the proposed commercial airport. Instead the EIR tries to analyze air quality only on a regional impact basis and then determines that there is no significant impact. This is absolute nonsense for people living in South Orange County.
2. There is no justification for the EIR to use the existing military use of El Toro as a baseline for air quality analysis. The Base will be closed and the analysis should start assuming the closure of the Base.
3. The pollutants study which identifies 80,000 pounds of particulates per day does not address the long term (25 or 50 years) impacts on the environment.
CONTAMINATION
1. The time frames in the EIR are unrealistic because they do not include adequate cleanup of contaminated sites on the Marine Base. This is particularly true if the Navy proceeds with its proposed natural plan to clean up ground water contamination in order to reduce overall costs.
FINANCIAL FEASIBILITY
1. The EIR does not clearly demonstrate the financial viability of constructing and operating a commercial airport at El Toro. The cost projections for construction appear to be substantially less than costs to construct other airports.
2. The financial impact analysis does not include the costs of protracted litigation to the County, to the various cities adversely impacted by the project and to private organizations and individuals.
3. The EIR does not adequately address the impact of a commercial airport at El Toro on the existing bonds which are outstanding for capital improvements at John Wayne Airport. Attempting to construct a commercial airport at El Toro could subject the County to extreme financial pressures if all of the optimistic projections of the consultants are not realized. This could exacerbate financial problems for all of the cities in Orange County as occurred when the County declared bankruptcy.
4. There is no consideration in the EIR for reimbursing property owners for decreases in home values because of the airport. Because the airport would degrade property values, the EIR should estimate those losses and propose a compensation plan.
REGIONAL PARKS
1. The EIR totally fails to address impacts of the commercial
airport on regional parks in South Orange County. We are particularly concerned
with impacts on Aliso and Wood Canyons Regional Park and on the Laguna Coast
Wilderness Park. Both of these facilities would be impacted by air pollution,
noise and traffic emanating from a new commercial airport at El Toro. These
valuable County resources need to be protected and the EIR needs to address
ways to accomplish that protection.
OPERATIONAL CONSIDERATIONS
1. The existence of Lomas Ridge has not been adequately addressed by the EIR. Instead, the consultants have put forth extremely optimistic statements about the ability to operate a commercial airport at El Toro. The report should identify the deficiencies in the location, including the inability of airlines to take off fully loaded.
2. As I indicated earlier, the EIR fails to address alternative flight paths which might be required when airlines decide that the existing configuration is unsuitable.
3. The EIR does not have mitigation measures to guarantee that flight patterns proposed at this time will not be altered in the future. Thus, possible impacts to our residents are not fully analyzed.
While we appreciate the extension of the time period to comment on the EIR,
this process is being rushed to meet unrealistic deadlines. There has not
been sufficient time for our residents to fully analyze the documentation.
This is particularly discouraging given the apparent attempt by the consultants
to prepare an EIR that is biased in favor of a commercial airport at El
Toro. We urge the County to conduct a more extensive, unbiased environmental
impact process so that the community has adequate information on the impacts
related to noise, air quality, traffic, parks and other issues that may
be identified.
Sincerely,
Wayne L. Peterson
Mayor
cc: City Council