Loading...
HomeMy WebLinkAbout26 AIRPORT STATUS RPT 08-01-94AGENDA.__ NO. 26 8-1-94 Inter-Corn DATE: AUGUST 1, 1994 TO: FROM: SUBJECT: WILLIAM A. HUSTON, CITY MANAGER COMMUNITY DEVELOPMENT DEPARTMENT AIRPORT STATUS REPORT - DRAFT ENVIRONMENTAL IMPACT REPORT FOR AIR CARGO OPERATIONS RECOMMENDATION Receive and file. FISCAL IMPACT Costs associated with this report and the review by City staff of environmental documents prepared by other agencies are covered by the City's general funds. BACKGROUND On July 5, 1994, Councilmember Thomas requested that the Tustin City Council be apprised of the pending proposal to initiate air cargo operations at John Wayne Airport (JWA) that will be considered by the County Board of Supervisors. The proposal has been submitted by United Parcel Service (UPS), a commercial air cargo carrier, requesting the authority to commence regularly scheduled commercial cargo service at JWA, Monday through Friday with one arrival time at approximately 4:30 p.m. and one departure time at approximately 7:30 p.m. Additionally, the County has also received a request from Federal Express, a competing carrier, to conduct one arrival/departure flight per day at approximately the same time. Based upon the direction of Council, staff has continued to monitor airport operations at JWA due to the direct noise impacts associated with the arrival of aircraft into the airport. Monitoring airport operations includes the coordination with the City's Noise Consultant, Van Houten and Associates, for review of quarterly noise reports published by the JWA Airport Director which are transmitted as available to the City Council. Staff also tracks and reviews any potential projects submitted to the County which would alter operations or require amendments to agreed upon policies. On July 7, 1993, the City received a Notice of Preparation (NOP) for a Draft Environmental Impact Report (DEIR) from the County's City Council Report DEIR Air Cargo Operations at JWA August 1, 1994 Page 2 Environmental Management Agency (EMA) concerning changes to the air cargo operations at JWA. Staff reviewed the Initial Study for the proposal and returned comments to the County on August 2, 1993. A copy of this correspondence is provided as Attachment A. Staff identified several issues including noise monitoring within Tustin's city limits, restrictions on flight times, potential changes to the air cargo operations at JWA related to the types of aircraft proposed, flight times, and the potential increases in overflights. Since the time that staff returned comments to the County on the Initial Study, preparation of the DEIR by the County was completed. On June 29, 1994, staff received a copy of the DEIR for review and comment with comments due back to the County on August 15, 1994. The following discussion is transmitted to the Council outlining the draft comments that are proposed to be returned to the County concerning the air cargo operations proposal. DISCUSSION Currently, JWA operations are required to be performed in conformance with the JWA Phase 2 Access Plan, which remains in effect through the year 2005. A principal element of the Access Plan is the restriction on the number of Average Daily Departures (ADDs) for certain types of aircraft. There are three classifications of aircraft which are distinguished based upon the noise levels associated with take-off. Two of the three classifications are restricted by a cap on the number of ADDs and are referred to as Regulated ADDs. Class A aircraft are regulated and considered the noisiest, followed by Class AA which generates less noise but is still regulated. Class E aircraft is considered the quietest classification and flights are not restricted. Currently, the overall Regulated ADDs are limited to a total of 73, and Class A ADDs are restricted to a maximum of 39, with the remaining Regulated ADDs attributed to Class AA aircraft. For this reason, the Class A ADDs are the most desirable by the passenger carrier industry because the classification gives the ability for the aircraft to be larger and hold more fuel allowing for longer non-stop flights. The principal element of the UPS proposal is an amendment to the JWA Phase 2 Access Plan, which would allow commercial cargo carriers using aircraft with a specified cargo-lift capacity to have the same preference in the allocation of Class A ADDs as passenger aircraft configured with 75 or more passenger seats. By virtue of the proposed amendment, commercial cargo carriers would then have regulatory status at JWA similar to the commercial City Council Report DEIR Air Cargo Operations August 1, 1994 Page 3 at JWA passenger carriers. Therefore, although UPS is only requesting one ADD at this time, Federal Express and other commercial cargo carriers would be eligible to receive other flight allocations for use at JWA in the future. The proposed project entails consideration of the following four components: The Board of Supervisors would be required to adopt amendments to the Phase 2 Access Plan, which would be required to allow an allocation by the County of one or more Class A ADDs to UPS under the present operational circumstances that exist at JWA. The withdrawal of one or more Class A ADDs from passenger carrier use, and the reallocation of one or more Class A ADDs to UPS, resulting in a diversion of one or more Class A ADDs from current passenger carrier use to non-passenger~serving commercial cargo use on a one-for-one basis. o The County would need to reconsider the current operating leases with its passenger airline tenants, which presently prohibit them from engaging in commercial cargo service comparable to that proposed by UPSI The approval of specific groundside operating plans proposed by UPS, Federal Express, or any other commercial cargo carrier requesting permission to operate at JWA for its operations. The DEIR also considered three project alternatives, which included the (1) the No-Project Alternative resulting in no change to existing policies, (2) a New Air Cargo Classification adding 2 ADDs for a total of 75 Regulated ADDs, and (3) Joint Use of MCAS, E1 Toro which would potentially only provide operations until 1999 unless the reuse plan under preparation includes continued air operations. While the No-Project Alternative is of course determined the most environmentally superior, it would not address the air cargo industry needs. The reallocation of either two Class A or Class AA ADDs to commercial cargo carriers from passenger carriers would require mitigation measures. These measures include limiting groundside operation locations, establishing operational times and flight times, requiring compliance with existing noise requirements, and implementation of additional public health and safety requirements. Although the DEIR finds that the project does not result in significant environmental impacts, staff finds that it would be appropriate to advise the County of items that continue to affect the City of Tustin. Provided as Attachment B is a draft of staff's comments which are proposed to be transmitted to the County. City Council Report DEIR Air Cargo Operations at August 1, 1994 Page 4 JWA CONCLUSION Staff is proceeding with formalizing these comments for transmittal to the County. Staff will continue to monitor and report to the Council as applicable those changes to JWA operations as they affect Tustin. Associate Planner Christine A. Shin~eton Assistant City M~h~ager Attachments: A - August 2, 1993 Correspondence B - Draft Comments CA~ :AB\jwaacol .eab ATTACHMENT A Community Development Depadment August 2, 1993 Mr. Robert W. White, Manager Environmental Planning Division Environmental Management Agency P. O. Box 4048 Santa Aha, CA. 92702-4048 City Of Tustin 15222 Del Arno Avenue Tuslin, CA 92680 (714) 544 8890 FAX (7~4) 832-0825 SUBJECT: NOTICE OF PREPARJ~TION FOR DI~AFT ENVIRO19~4ENTA3~ IMPACT REPORT - JO}{NWAYlqEAIRPORT UPS AIR CARGO ACCESS PROPOSAL Dear Mr. White: The City of Tustin appreciates having the opportunity to review and comment on the draft initial study prepared for the John Wayne Airport UPS Air Carge Access Proposal. As you may know, the City of Tustin has historically pursued an active role in the planning for access into JWA. There are several items that the City requests clarification on concerning the proposal. However, there are two items transmitted to the County in previous correspondence on prior amendments to the Phase 2 Access Plan that again become relevant especially in light of the County's consideration of air cargo carrier operations at JWA. Since the principal element of the proposed project includes amendments to the Phase 2 Access Plan, it is important that the City again request analysis and mitigation that parallels the concerns expressed in our previous correspondence. The following two items have been repeatedly included: A maximum Single Event Noise Equivalent Level (SENEL) should be established at RMS-7 located within Tustin tc monitor the individual noise events triggered by arrivals, the event causing the most significant negative impact to Tustin. Currently SENEL maximums and monitoring occur for departures south of the airport, but there is not similar consideration given for arrivals. This is an even greater concern for Tustin due to the anticipation of air cargo carrier operations. 2 o The operations per hour should be controlled requiring a steady decrease after 7:00 p.m. This is a critical element in reducing the overflight noise impacts to Tustin during sensitive evening hours. This becomes even more crucial since Robert W. White Re: NOP for DEIR - August 2, 1993 Page 2 JWA UPS Proposal the subject proposal would most likely result in a displacement of passenger carrier flights into the evening hours. The UPS Air Cargo proposal and the preliminary environmental documentation are cause for additional concerns as well and the City requests that the following items be addressed in the Draft EIR: The UPS proposal includes the request to utilize one of the regulated Class "A" flights. Tustin has a concern as to whether the fleet of any of the air cargo carriers is capable of meeting this classification (the least noise-restrictive). Prior County staff reports and drafts of the Access Plan have indicated that air cargo carriers do not currently ma'intain within their fleets any Class "A" type aircraft and that noise mitigating equipment would have to be installed to modify the fleet utilized at JWA. The initial study does not clearly discuss whether this is still the case. The draft EIR should clearly investigate the types of aircraft proposed for use by the air cargo carriers at JWA. 2 o The initial study contains a discussion concerning the alternative use of Class "E" aircraft by air cargo carriers. The discussion mentions that UPS maintains a sorting hub within proximity to Ontario Airport and flights by UPS could ensue utilizing the quietest and unrestricted classification type aircraft. Tustin has concerns with this alternative which include: Will the proposed UPS operations result in an increase in unregulated Class "E" flights between JWA and surrounding airports? If so, what is the likely increase, particularly if other cargo carriers are also permitted to use ~4A? Since there are no passengers on these all- cargo flights, will there be any restrictions on the number of these Class "E" flights? Will nighttime (10:00 p.m. to 7:00 a.m.) flights be allowed? bo If the air cargo carriers utilize Class "E" aircraft, what is the potential for aircraft within this type to generate excessive noise upon arrival, since the classification determination is based upon departure noise levels rather than arrival noise levels. Should Class "E" aircraft become the preferred alternative, a noise evaluation should follow for arrivals and Robert W. White Re: NOP for DEIR - August 2, 1993 Page 3 JWA UPS Proposal departures and corresponding mitigation should be imposed (Class "E" type aircraft that satisfy both conditions). 3. The project summary describes some of the characterJ, stics of the types of aircraft proposed and parameters for operations at O-WA. The following questions need to be addressed: a. Why is preference given to commercial cargo aircraft with a payload capacity of 50,000 pounds or greater? How does this weight related to a typical Class "A" passenger flight? b. What are the landing noise characteristics (e.g., maximum noise level, single event noise exposure level) of a fully loaded cargo plan relative to a typical air carrier? 4. Finally, the City of Tustin is concerned with the resultant cumulative impacts this proposal will have if approved. a. The proposed plan could eventually result in more cargo flights than passenger flights. What effect would this have on the noise contours? b. Cargo flights typically occur during the early morning or nighttime hours to accommodate the needs of the cargo companies. This will change the number and schedule of the passenger flights. What effect will this have on the noise contours? What steps will be taken to minimize the number of evening and early morning flights? will there be restrictions on the hours that the cargo planes can operate? c. What steps will be taken to ensure that the number and noise level of aircraft overflights will not increase in Tustin? will there be restrictions on the number of cargo flights that can occur at JWA (all classes, all operators)? d. What is the likelihood that additional ADDs will be negotiated? What is the likely number of these additional ADDs? What effect will this have on the noise contours? Thank you again for the opportunity to review the subject NOP. We would appreciate the opportunity to review the draft and final EIR Robert W. White Re: NOP for DEIR - JWA UPS Proposal August 2, 1993 Page 4 documents as well. Please contact myself or Anne Bonner, Planner, should you have any questions. Sincerely, Rita Westfield Assistant Director of Community Development Associate RW: AB: ab\j waups, hop cc: William A. Huston Christine Shingleton Anne Bonner ATTACHMENT B August 1, 1994 Mr. Robert W. White, Manager 0CEMA/Environmental Planning Division 300 North Flower Street, Room 321 P. O. Box 4048 Santa Aha, CA. 92702-4048 SUBJECT: DRAFT EIR NO. 552 FOR AIR CARGO OPERATIONS AT JOI~l~ WAYNE AIRPORT (JWA) Dear Mr. White: The City of Tustin appreciates having the opportunity to review and comment on the subject Draft EIR No. 552 to initiate Air Cargo Operations at John Wayne Airport (JWA). As you may know the City of Tustin has historically pursued an active role in responding to planning issues associated with access into JWA. Based upon our review of the document, there are several items of which the City has concerns with, particularly now that amendments to the Phase 2 Access Plan are being considered. The following summarizes the City's concerns: 1. The time restrictions that are proposed as mitigation for land use incompatibilities for this project will result in potentially increased noise impacts, due to the displacement of arriving passenger carriers, to the benefit of providing smooth groundside operations for the cargo carriers. The mitigation proposed will not permit cargo carriers to arrive any earlier than 4:00 p.m. Upon arrival the carriers will proceed to the southern "Remaining Over-Night" (nON) area for loading/unloading. Departure of the cargo carriers must occur by 7:45 p.m. the same day. This concentration of time to accommodate groundside operations will displace other arriving passenger flights into the more sensitive evening hours, particularly if a passenger carrier is anticipating to hold-over in the southern nON area, which has limited storage capacity. This resulting displacement of commercial passenger flights is Robert W. White Re: DEIR No. 552 for Air Cargo Operations at O-WA August 1, 1994 Page 2 undesirable and will result in increased noise impacts to City residents in the sensitive evening hours. Tustin has repeatedly requested that the County amend the Access Plan to provide for time restrictions on arriving aircraft, particularly between the 7:00 p.m. to 11:00 p.m. hours, whereby the number of arriving aircraft steadily decreases after 7:00 p.m. The DEIR indicates that while noise levels and corresponding ground contours may increase slightly, the levels will be insignificant. However, the fact that the Access Plan concentrates its responsiveness to departure noise still presents a problem for the City of Tustin and what we believe will be a negative impact. Arrivals are not necessarily restricted nor monitored for noise impacts and therefore, aircraft classifications are not defined by arrival noise. Tustin has repeatedly requested that arrival noise impacts be monitored and mitigation implemented, such as setting a Single Event Noise Equivalent Level (SENEL) for Remote Monitoring Station (RMS) No. 7, which is located in Tustin. Currently, Community Noise Equivalent Level (CNEL) monitoring is performed tracking airport arrivals. The County has indicated that establishing SENEL readings at RMS No. 7 is not necessary due to the fact that reverse take-offs (Santa-Aha Conditions) are infrequent. However, Tustin's noise impacts are just as greatly disturbing and are "single events" related to each arriving plane. By allowing formal air cargo operations to commence at JWA there is a definite potential for a cumulative environmental impact. Although the County's proposed Access Amendments limit the reallocation to two Regulated ADDs, once the air cargo carrier operations are established, the County will continue to receive pressure to either continue reallocation of Regulated ADDs or proceed with the process to increase them. While the proposal seems limited (or mitigated to a level of insignificance) at this time, its precedent and future implications concerning JWA operations and their impact to Tustin is great. Finally, the City of Tustin is opposed to the transfer or reallocation of any Class A ADDs to the commercial air cargo industry since this classification is considered the noisiest. If any decision is made towards reallocation of ADDs from commercial passenger carriers to commercial air cargo carriers, they should be restricted to operating at least at Robert W. White Re: DEIR No. 552 August 1, 1994 Page 3 for Air Cargo Operations at JWA the Class AA ADD classification. The County should take the initiative to phase out the number of Class A ADDs not perpetuate keeping them or adding to them. Thank you again for the opportunity to review the subject DEIR. We would appreciate the opportunity to review the County's response to our comments prior to any recommendation to adopt a final environmental report. Copies of subsequent hearing notices and staff reports should be forwarded to my attention. Please contact Anne Bonner of my staff or myself should you have any questions. Sincerely, Christine A. Shingleton Assistant City Manager Rita T. Westfield Assistant Director of Community Development cc: William A. Huston Christine A. Shingleton Anne Bonnet