AIR LINE PILOTS ASSOCIATION
635 HERNDON PARKWAY - PO BOX 1168 - HERNDON, VA 20170 - 703-689-2270
Mr. Brian Speegle
County of Orange
MCAS El Toro Local Redevelopment Authority
10 Civic Center Plaza, Second Floor
Santa Ana, CA 92701
RE: Comments on Environmental Impact Report 573
Dear Mr. Speegle:
The Airline Pilots Association (ALPA), representing 55,000 pilots who fly for 51 different airlines in the United States and Canada, appreciates the opportunity to respond to the El Toro Airport Environmental Impact Report (EIR). In our response we plan to identify safety and operational impediments that preclude El Toro/OCX from becoming a world class airport. We will show that planning shortsightedness will lead to a broad spectrum of daunting systemic safety problems.
Delays and cancellations will be prevalent
with the slightest hint of inclement weather. Poor planning, poor
design and less than desirable topography will haunt this airport indefinitely.
El Toro/OCX has very few redeeming qualities if any at all. Put another way, El Toro/OCX is the antithesis of what one would expect from a state of the art facility.
Unfortunately, the county has ignored a 1996 ALPA recommendation to realign the runways. East departures begin a takeoff roll on a runway with an uphill slope and lift off into rapidly rising terrain. There is a documented propensity for tailwinds that county planners expect users to tolerate to at least 7 knots. The grading improvement to runways 7L/R does little to satisfy ALPA concerns, nor does it satisfactorily meet a target level of safety. Under such circumstances ALPA would be required to advise its membership that departures from runways 7L/R would not be recommended. Rather, the runway of choice will be 25 L/R. Under FAR Part 91.3(a), "The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft." A request for runway 25 would exercise a pilot’s option to use the safest and most appropriate runway available.
Loma Ridge is an impediment for northbound departures. Flying over the ridge instead of around it defies common sense. The performance numbers for runway 34 operations initially proposed are based upon a procedure for a climbing left turn immediately after takeoff to turn the aircraft away from the Loma Ridge. A departure procedure based upon a straight out climb would call for minimum climb gradients that exceed those expected for the left turn procedure, and would dramatically reduce aircraft payload capability. ALPA has repeatedly voiced its concerns for this problem with the county, only to be told that they will not lose votes over noise propagation. The county will apparently ignore safety concerns by placing a premium on noise and votes.
Wildlife issues also require mitigation. In particular, landfills 2 and 17 in the habitat area, if my information serves me correctly, falls within five miles of the proposed departure corridor for runways 34L/R. FAA Advisory Circular 150/5200-33 HAZARDOUS WILDLIFE ATTRACTANTS ON OR NEAR AIRPORTS, provides guidance on locating certain land uses having the potential to attract hazardous wildlife to or in the vicinity of public-use airports. The Advisory Circular is attached for your information.
Gulls top the list as the bird most commonly struck by aircraft. If a daily migration pattern exists to the landfill areas noted above, the probability of an engine failure on take off dramatically increases. This only adds fuel to the fire when debating the issue of engine failures on take off. Aircraft engines can sustain certain amount of damage caused by bird ingestion, but they remain susceptible and vulnerable and are by no means bullet proof. As the Advisory Circular describes the problem, birds profoundly affect the aviation industry. Lost lives and billions in damages have resulted because our fine-feathered friends wish to share the same airspace. Ingestion of a small bird may only cause a minor stutter or fluctuation in engine rpm. However, it may also cause an engine to fail. Large and or multiple bird ingestion will, in all likelihood, impede or destroy one or more engines. The bigger the bird the greater the damage. Gulls, although not as large as Canadian Geese, have the size to independently destroy an engine, and to collectively even down an aircraft. The NTSB considers the threat so great that it recently sent 9 different government agencies lists of recommendations aimed at reducing the risks to aviation posed by the increasing threat of bird strikes and other wildlife hazards. The FAA later announced that it and the U.S. Department of Agriculture (USDA) Wildlife Services were issuing a manual to help airports combat wildlife hazards. Until such time as that manual is available, we suggest references to the attached AC.
As we move into the 21st century, the antiquated concept of closely spaced crossing parallel runways needs revisiting. The El Toro/OCX runway design is virtually identical to San Francisco International (SFO). However, El Toro has more limitations. SFO operates by sequencing arrival and departure aircraft. Aircraft land together and depart together. Landing aircraft fly in a pseudo formation. Departing aircraft receive their take off clearances simultaneously and fly away from each other on diverging headings. The terrain at El Toro/OCX precludes simultaneous departures. The only option is to stagger the take off clearances. However, with staggered departures, aircraft cannot land. Using both runways 7L/R in the capacity the county intends is highly improbable. El Toro/OCX will be relegated to a single departure runway. Arrivals fare a little better than departures, but the flow would fall apart in poor weather. The two-runway operation will be reduced to one with even minor weather infractions. The plan lacks a comprehensive explanation of the traffic procedures to be implemented that will vector aircraft to the final approach course for arrivals on runways 34L/R.
We’ve seen a developing trend around the country with airports that have closely spaced parallel runways. The escalation in runway incursions has driven the FAA to make this issue a top priority. An incursion occurs when an aircraft or vehicle crosses, or encroaches on, an active runway without a clearance. For example, let's assume that a landing aircraft exiting an outside runway fails to hold short of the inside parallel runway after acknowledging the hold short instructions. As the landing aircraft crosses onto the inside parallel runway, a departing aircraft on the same runway could strike that aircraft. Many scenarios can unfold, but the net result is an accident waiting to happen. For more information, research recent runway incursion history at LAX. A recent flight carrying Senator and Mrs. Dole, was forced to rotate and takeoff early to avoid a certain collision under such conditions.
Wind & Weather
"The dominant daily wind pattern is an onshore
8 to 12 miles per hour daytime breeze."
Santa Ana winds and winter storms manufacture conditions the proposed airport is not equipped to handle. Winds in excess of twenty knots can shut down the airport. Recent storm winds blew from west to west-southwest as hard as 35 knots. When crosswinds exceed 20 knots north departures will cease. Runway 7 departures are not available either, because of the 10-knot restriction. If north, south and east departures stop, runway 25 becomes the only viable departure runway. Without it, airport operations cease. The similarities between El Toro/OCX and SFO are more than just coincidence.
If winter storms produce south or southwest winds, low ceilings and poor visibility, the airport faces severe operational constraints. A south wind exceeding 10 knots eliminates the use of runways 34L/R. With the same south wind and basic visual flight rule conditions of 1,000 feet and 3 miles the airport is closed for landings. The county has proffered a circle to land procedure in lieu of the ILS approach for such conditions. Flying a precision approach to runway 34 left or right with a circle to land maneuver will not work and has no functional practicality. El Toro/OCX, with high terrain obstructions like SFO, will have ceiling and visibility requirements in the range of 2,100 feet and 5 miles instead of the standard 1,000 feet and 3 miles. A circle to land approach is an instrument approach procedure followed by a circle-to-land maneuver. It is an approach in two parts. The instrument approach portion may be conducted in IMC to authorized minima (not less than 1,000//3). The remainder of the approach (the circle to land maneuver) must be conducted clear of clouds, and terrain, in visual flight conditions. Like SFO, the minimums will be much higher than the standard 1,000 and 3. A circle to land maneuver cannot be substituted for landing on runway 34.
Now, if we consider the terrain implications, it makes it even more unlikely. Compare any Boeing or Airbus transport category aircraft to a FA-18 and one thing quickly comes to mind. The hornet is nimble, maneuverable and tight turning. Commercial jets are not. To suggest commercial jets can fly the same patterns as an F-18 hornet is ridiculous.
Another Achilles heel for the airport is the lack of Category II and Category III approaches. On days when the visibility drops below ½ mile (2,400 Runway Visual Range/RVR), landing operations will cease. The inability to fly Category II (1/4 mile/1,200RVR) or Category IIIA (1/8 mile/RVR600) auto landings exemplifies once again the inadequacies of the airport. Not to sound rhetorical but someone should pose this question to the airport pundits. Why does El Toro/OCX only have Category I approaches to the two parallel runways? Once again, with visibility less than ½ mile, the airport shuts down. It is unprecedented for modern airports to cease operations as a result of very reduced visibility.
A few questions must be asked regarding airport
efficiency. First, how will the traveling public be inconvenienced
during inclement weather? And secondly, how will bad weather impact
the hourly arrival rate? These litmus tests will gauge and quantify
the actual efficiency of the airport. El Toro/OCX like SFO and the
old Stapleton Airport in Denver will lose in excess of 50% of their hourly
arrival capability in poor or even marginal VFR weather. With the
minimum separation between runways only one of the parallel runways can
be used for landings. The reason more than 50% of your capacity is
lost is because the separation standards between
aircraft during instrument conditions increases. Greater separation translates into a reduction in the hourly arrival rate. This very reason was the impetus behind the construction of the new Denver Airport. Stapleton fell apart during bad weather. Delays ran rampant, planes diverted, and passengers were inconvenienced. SFO falls victim to the same systemic runway design flaws as Stapleton, and so will El Toro/OCX. Imagine what will happen during consecutive days of marine fog. Airlines design and tailor their schedules for fully functioning airports. An airport that implodes at the sight of bad weather costs money, destroys schedule reliability, and inconveniences passengers.
Air Traffic Control
The admonition that John Wayne and El Toro/OCX can coexist, but traffic between the two airports must be sequenced, says it all. Fairy dust and a magic wand will not cure the ATC issues plaguing El Toro/OCX. Routing traffic north generates a number of concerns. Once departures clear John Wayne, a myriad of new problems will ensue. ATC plans to keep departures at low altitude. General aviation aircraft use this airspace. Mingling with them opens the door for a midair collision. Examples of midair collisions in Cerritos and San Diego are still fresh in our minds, as is the fact that the Southern California airspace remains the busiest in the world.
As we transition to the Los Angeles basin,
north departures must fly underneath the arrival corridor for LAX.
This airspace is actively used by general, corporate and commuter aviation.
Additionally, traffic flying below the Class B airspace is restricted to
200 knots. A Boeing 747 loaded for the orient needs to maintain a
speed of approximately 270 knots in the clean configuration. Slowing
to 200 knots produces high drag. Low altitude and aircraft drag translates
into high thrust settings, increased fuel burn, and limited payload, both
passengers and freight. These detracting factors collectively may
preclude the viability of flights to the orient simply because of airspace
constraints. Additionally, once clear of the LAX arrivals,
El Toro/OCX departures must blend with all Ontario departures and maintain a stringent climb gradient that may exceed the performance characteristics of the aircraft. Modest and minor changes to the Class B airspace has historically taken years to accomplish and many will be necessary to make this master plan work. It is our opinion that north El Toro departures will restrict operations for airports in the L.A. Basin and in particular for the Ontario Airport.
ALPA does not believe that John Wayne and El Toro/OCX can synergistically exist. They are not compatible unless delays are acceptable. The flight tracks used at John Wayne will undoubtedly need to be employed for El Toro/OCX. Do not be disillusioned into thinking minor airspace changes merely entails a simple written plan that users willingly accept. Any airspace change will become a long protracted fight taking years to resolve.
The El Toro reuse proposal is extremely vague. Details are lacking for air traffic operations and safety enhancements. Instead, safety is diminished when purposeful plans expect routine operations into rising terrain despite tailwind conditions.
Safety must be inherent in commercial airport operations. Such airports must measure up to the stringent requirements of FAR part 139 for regulatory certification, and to the satisfaction of the users. It is not uncommon for an airport to have some minor problems. Unfortunately, ALPA feels the problems or safety fires at El Toro/OCX rage out of control. The attempt to mitigate these fires has led to an airport plan that ignores both safety and common sense. The architects call it safe, but ALPA believes that the forces in this plan working against safety could take life and limb. ALPA, therefore, can not, and will not, endorse the plan as it is presented. As always, the Association is available to consult with county planners on all of the troublesome issues in order to arrive at a satisfactory resolution.
Original signed by Jon Russell
Captain Jon Russell
Western Pacific Regional Safety Chairman
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