AIR LINE PILOTS ASSOCIATION
635 HERNDON PARKWAY - PO BOX 1168 - HERNDON, VA 20170 -
Retyped from the original
February 11, 2002
Dear Mr. Withycombe:
ALPA understands that meetings between Orange County and the FAA may ensue to develop a Preferential Runway Use Program for the proposed El Toro Airport (OCX). As you may know, the development and conversion of OCX for commercial use has been contentious. Positions regarding safety and performance differ substantially between the Orange County Board of Supervisors and many of the potential users of the new airport. As a consequence, we respectfully request that ALPA representatives be among the users included in any discussions for a runway use program at OCX Our participation is essential to ensure that the pilot safety perspective is considered. ALPA has participated in similar discussions at many other venues and would expect the opportunity to do so for OCX.
ALPA has previously been on record stating that OCX operations should
not be considered under the configuration suggested by Orange County EIR
573. Our argument, addressed in FAA Order 8400.9, makes two points.
Second, under waiver requests, in accordance with paragraph 8 and Appendix 2, FAA Order 8400.9 reads, in pad, "Flight Standards personnel must consider the operational impact of the following factors when providing a safety analysis to support alternate criteria", and Appendix 2h lists two questions. "Is runway slope a factor?" If so, does it impact aircraft performance?" The answer to both questions, in our opinion, is YES. Therefore, for that reason alone, a waiver must be questionable.
ALPA would appreciate FAA feedback to these items and an invitation to participate in any future meetings to discuss an OCX Runway Preferential Use Program.
Captain Jon Russell
Western Pacific South
Regional Safety Chairman