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HomeMy WebLinkAboutRPT 5 J.W. AIRPORT EIR 12-18-84TQ: HONORABLE MRYOR AND CITY COUNC1'L FROM: COFI4UN'I'TY DI~VELOPFtENT DEPAR'~NT SUBJECT: ,IOHN HAYNE A'I'RPORT EIR, SECOND SUBM]'TTAL BACKGROUND: In August of this year, the County of Orange distributed a draft EIR (DEIR 508) detailing the expansion of the John Wayne Airport, for review and response by surrounding cities and community groups. The City of Tustin reviewed this document (two volumes) and responded to the County in a letter dated September 4, 1984. The Board of Supervisors anticipated holding hearings on the expansion in the month of October. Due to the overwhelming response to the draft EIR from numerous jurisdictions and organizations, the County decided to respond to each comment and redistribute the draft EIR, with the final date for comments being December 27, 1984. Along with a response to the County of Orange, the City can also address comments to the Federal Aviation Administration (FAA), since the document is a combination DEIR and DEIS, and the FAA is soliciting comments regarding the expansion of the Airport. The following is a synopsis of the City's September 4, 1984 comments and the County's response to them: 1. Q: The primary concern of the city was not only the additional single event and cumulative impact of mere overflights, but a noisier mix of aircraft than currently utilized. The City requested additional noise data and studies. A: The County has included mere data on noise upon arrival {see enclosed Fig. 4.15-13a) and the EIR basically discloses that all anticipated jet aircraft using the airport in the future will be noisier than the currently utilized MD-80. Since the major noise impacts (65CN£L or greater) are on the departure end of the airport and all of these jet aircraft are quieter on departure than the MD-80, the County does not see the impacts to the City of Tustin as significant, even though it will experience greater noise levels. 2. Q: As a mitigation measure, realign the ILS (instrument landing system) westerly of the Newport Freeway. JWA EIR page two A: The ILS is a precision approach and cannot be deviated from the 193° radial, which is exactly in line with the primary runway at John Wayne Airport. The VOR, non-precision, is oriented on the 180° radial, which is westerly of the Newport freeway. The VOR was established six years ago as a noise abatement measure. Altering the route would be difficult due to higher buildings in the area. Any changes to the route would be the responsibility of the FAA. 3. Q: Prepare a study examining a variety of descent patterns into the airport. A: The County agrees with the City and has included in the EIR in Section 4.15.6.7.2.8 this study as a mitigation measure. The County will request that this study be performed by FAA, the agency responsible for regulating aircraft approach procedures. (Note: In December 1975, Airport Management requested the FAA to increase the glide slope for the ILS and VOR approaches to Runway 19R from its present 3° to 4°. The intent was to decrease the noise impact on residential areas north of the airport. However, the FAA denied the request on grounds that the 4° approach would be a degradation of safety for turbine-powered aircraft. (DEIR 508; pg. 4.15-33) ¸4. Q: The EIR had an insufficient level of detail to include either MCAS E1 Toro or Santiago Airport as potential airport sites. A: The County basically felt their level of detail for each alternative was sufficient to meet the intent of the C£QA Guidelines. 5. Q: Potential of fuel dumping. A: The County was quite -adamant that no aircraft dump fuel over populated areas. Q: Include analysis that details the potential hazards of more overflights, and measures to reduce the impact. A: Additional overflights and their potential risk to people located under the flight path are covered in EIR Section 4.14.2.2. 7. Q: The elimination of all general aviation from the John Wayne Airport, as an additional safety measure. A: The County felt that the elimination of all general aviation would indeed lower the risk of accident. They did not, although, feel this was a feasible alternative due to the present activity of general aviation, and the inability to relocate these planes to either a new airport or one of the existing. Community Development Department JWA EIR page three 8. Q: The £IR should examine impacts on surrounding arterial highways outside of the immediate study area of the airport. A: It is the County's contention that traffic dispenses rapidly with distance from the project site. It is estimated that for the year 2005 only 1260 daily project trips (3.2%) would use Redhill Avenue north of MacArthur. The first draft EIR was a large, detailed two volume document. Considering the additions to the draft and response to comments, the document has now grown to three volumes. Although the County has adequately responded in some areas, additional mitigating measures and controls are needed, and more questions have arisen due to the County's response. RECOI~ENDATION: Staff would recommend that a letter be addressed to both the County of Orange and the FAA, expressing the following concerns and potential mitigation measures. That documentation in the EIR conclusively shows that the City will experience additional single event and cumulative impacts from noise overflights from noisier aircraft. In spite of the fact that this impact is outside of the 65 CNEL impact area, the City considers this a substantial increase in the ambient noise level for these affected areas and therefore requires mitigation measures. The City proposes the following mitigation measures: The City supports a study performed by the FAA to alter the descent pattern to reduce noise levels in residential areas from jet aircraft, while still maintaining aircraft safety. The City supports a condition that the vast majority of arrival jet flights be restricted to utilization of incoming flight tract 8B, also known as the VOR, except at those times that the use of 8B could not be used due to weather conditions, or other such restrictions. That under acceptable conditions, pilots would be given the choice of using only flight track 8B, and could not utilize flight tract 8C, also known as the ILS. That the FAA severely restrict any structures that would further erode the VOR approach into the John Wayne Airport. The City's main concern is that the VOR approach (which is westerly of the Newport Freeway) remain as a viable route into the airport. Its removal would mean that all incoming flights would use the ILS,which is directly over the City of Tustin. That prior to consideration of penetration of imaginary surfaces by the FAA, the City of Tustin receive the request for review and input. Community Development Department JWA page four (Note: Over the last few years, the VOR has been restricted due to higher buildings in the area. The FAA is responsible for granting a "no hazard" determination onto these flight tract areas. Judging from the agresstve development nature of both Costa Mesa and Santa Aha, further intrusion could happen and could conceivably render the VOR so unsafe as to stop its use. That action would leave the ILS as the only available flight tract into JWA, and this would mean that all overflights would be over the City of Tustin.) 2. The City does not support the mitigation measure for the FAA consideration of a "Preferential Runway Program" and requests that it be removed. Documentation shown in the EIR under Section 6.6.1.1 shows that the Board of Supervisors has not supported this concept, and does not consider it as a viable solution for noise mitigation. Under the most recent noise variance (t982), it was not even included asa possible measure. (Note: The "Preferential Runway Program" is a noise mitigation measure that permits jet aircraft to take-off to the north, over Tustin, from 7:00 a.m. to 8:00 a.m. In reviewing the annual wind conditions that would permit this northern departure,, this program could take place approximately 315 days out of a year. This would enable up to 12 flights to depart over the City of Tustin from 7:00 a.m. to 8:00 a.m. before flights once again would depart to the south, over Newport Beach.) 3. Under Section 6.7.2, the EIR identifies the Santiago Canyon site as being "environmentally compatible with the area". Later in this same section, a SCAG report identifies the site as having "severe air space, environmental and infrastructure problems" and recommends its elimination. The City recommends that the County accept the recommendation of SCAG and eliminate Santiago Canyon as an alternative from the FIR. The C£QA Guidelines indicate that an alternative shall be capable of eliminating any significant adverse environmental affects or reducing them to a level of insignificance. The expansion of JWA is a regional issue, and the County has recognized this by considering alternatives over a wide regional area. A discussion of alternatives should center on reducing the number of significant environmental effects, instead of documenting an alternative that increases the number of adverse effects on the environment. 4. The discussion of traffic impacts from a civilian/military use at MCAS E1 Toro has not been done in sufficient detail to ascertain the significant effects on the surrounding arterial system. The City is preparing a comprehensive transportation analysis program which shows that the City of Tustin along with the surrounding area will require extensive improvements to meet the traffic demand. This study was done without consideration of the impact of a regional airport capable ~' of 73ADD. EIR 508 must take into consideration the cumulative traffic impacts before E1 Toro can seriously be considered as an alternative. Community Development Department 3WA EIR page five The removal of upwards of 6,000,000 cubic yards of earth from surrounding hillsides represents a substantial demonstrable negative aesthetic effect, yet this must be done before jet aircraft can safely depart from the airport. Under Section 4.10.1.4, the largest percentage of trip ends on an Origin/Destination study utilize SE 55 north, at 38~. According to this study, the City of Anaheim is the destination point for these trip ends. Currently, the SE 55 freeway north is congested for AM and PM peak. When the freeway becomes congested, vehicles use Eedhtll Avenue and Newport Blvd. as alternate routes, creating congestion on these and other city arterials. The EIE discloses that the greatest percentage of airport traffic will utilize the SE 55 freeway north, and the City of Tustin feels this will result in greater impacts on not only the SE 55 freeway, but Eedhtll Avenue and Newport Blvd. as well. Yet, the only measure that EIE 508 gives for those cumulative impacts is that "affected jurisdictions in the study area should cooperate with OCTC in seeking methods to fund these major improvements". Essentially, traffic impacts created outside of the city limits are left for the City of Tusttn to solve.. The County should be more responsible for the traffic impacts it creates from this project, and the solutions to help mitigate these impacts. Associate Planner EK:do Community Development Department ~ ARRiVAJ~,. PROFILE AL?ITUOE vi D~STANCE FROM TOUCH DOWN I06 100 NOI~ vi OISTAN~E FROM TOUCH OOWN i COMMENTS OF THE CITY OF TUSTIN 80. Please see response to co--,ent N&.ISR. 81. A. The question is somewhat confusing in that the Instrument Landing System (ILS) approach is already east of the freeway. The ILS, or precision approach, must be aligned with the runway -- no deviations are possible. This means that the ILS approach has to be on the 193° radial, and exactly in line with the primary runway at John Wayne Airport. The VOR, non-precision, approach used by many of the airline aircraft is oriented at a 180' radial, and angles to the VOR (located on the north end of the airport) overflying a route slightly west of the Newport freeway and then crossing over the freeway close to Dyer Road. This radial was established six years ago when the VOR was relocated to its present position, and the 180' route was selected for noise abatement purposes. Since that time higher buildings have been constructed around the airport. Therefore, altering the route, or radial heading, would be very difficult if not impossible. The assignment of flight paths and headings is, however, an FAA responsibility, and sub~ect to the location of NAVAIDS themselves as well aa objects that could interfere with air navigation, and with the airspace requirements of adjacent airports and enroute traffic. " Bo Altering aircraft descent patterns could have positive noise implications. Consequently, we have revised the mitisation measures in Section &.15.?.7 to indicate that the County will request that FAA conduct 'a study to.determine the optimum descent pattern that ensures aircraft safety While reducing residential noise impact. We agree with the City that this should be a separate study, and not ' part of this EIR. There are several reasons for this. First, a =horoush study cannot be reasonably be conducted in a timeframe governed by EIR circulation and processing. Second, any operational chanse that misht result would not change the plans for physical facilities proposed in the Airport Haster Plan. And, finally, we would be reluctant to -126- 82. incorporate an operations change into the basic assumptions for EIR noise analysis, since this would eliminate the conservative natu:e of our analysis- In short, we agree that the proposed study can and should be a separate and distinct effort. 83. Please se~ responses to comments 279, 280, N6E, and N6JJJ, as they relate to adequacy of the analysis of alternatives generally, and the MCAS-E1 Toro and Santiago Canyon sites specifically. The E1 Toro and Santiago Canyon alternatives are addressed in some detail. However, it is acknowledged that additional environmental documentation would be required to implement one of these alternatives, if chosen in preference to the project. The County also acknowledges the City's recommendation regarding a potential off-shore airport. This is addressed in Section 6.6.8 of the EIR. The off-shore alterna~ive has been extensively studied by groups charged with that task (e.g. SCAC,'Blue Ribbon Regional Airport Advisory Committee) and has been relected as being infeasible. Additionally, thegroups mentioned above have found MCAS-E1 Toro and Santiago Canyon zespectively, to be sites appropriate for further evaluation. Aircraft do not dump fuel over populated areas. None of the commercial Jets operating at John Wayne Airport have fuel dumping capability. Under moist air conditions, aircraft will exhibit vortex-generated condensed air that will stream off of the wing tip, or corners of flags or ailerons. This will generally happen in early morning or late evening, and only when air conditions are conductive. This is sometimes mistaken for fuel dumping by observers on the ground or even passengers in the aircraft. In fact there are no known instances at JWA. Accordingly this subject was found to be highly speculative. Additional overflight and their potential risk to people located under the flight path are covered in EIR Section &.14.2.2 8&. Elimination of general aviation operations at JWA would have a drastic effect on daily operation levels. The 1,254 average daily operations of -127- all aircraft types experienced in 1983 would dwindle to about 146 air carrier operations (73 departures) and 160 co~uter operations (80 depar- tures), for a total of 306 daily operations. This would be an average of one take-off or landing every 3.1 minutes, between the control cower operating hours of 7 A~ and 11 PM, as opposed to one every 46 seconds now. The result would be less density of air traffic near J~A with a resulting decrease in the risk of in-flight collision. It would also minimize any potential sequencingproblems related to different approach speeds for different types of aircraft. John Wayne A/rport, however, is one of the nation's busiest general aviation airports, with over 400,000 general aviation operations annually. In the past the County has concentrated its efforts on finding a location for an additional general aviation airport in the South County to take some of the burden off of John Wayne ~u~rport. Unfortunately, no suitable site has been found. Other existing airports in Orange County (Fullerton~unicipal and Meadowlark) do not have the facilities or capacity to absorb the general aviation traffic of J%/A. This subject was reviewed as an alternative to the proposed project in Section 6.6.3. The alternative fails to reduce any of the significant effects. 85. With regard to impacts on the regional roadway system, please see the response to comment number 155. Traffic impacts from a project such as the JWA/SAH disperse rapidly with distance from the project site. The impact area chosen includes facilities with significant traffic impacts. It is est~Jaatsd that for the year 2005 only 1260 daily project trips (3.2 percent) would use Red Hill Avenue north of MacArthur and only 980 daily project trips (3.9 percent) CO~TS TO ROBERT A. BYRON - BAKER INTERNATIONAL 86. The proposed General Aviation Noise Ordinance ("GANO"), which is discussed as a potential mitigation measure of the project in Section 4.15.7.7.1.1 of the EIR is intended to exclude from the airport the noisier general aviation aircraft, primarily general aviation Jet aircraft. The noise levels specified in the proposed General Aviation Noise Ordinance were selected because of their consistency with the maximum noise levels -128- 4.15 Q. 4.15 R. which the County can make regarding the fleet mix which might be expected to operate at JWA at those time periods, within identified regulatory constraints. In addition, the proposed and discussed mitigation measures would each act to further reduce noise impacts, as measured by CNEL values. Finally, the "single event" effects were not "ignored'' in this analysis in the EIR. Nevertheless the discussion and. analysis of single event effects, and single event metrics, has been further expanded in the revised EIR. The EIR does not "conclude that 73 ADD is not a significant impact" of the proposed project. An expanded analysis of its single event characteristics of various aircraft types, including the Boeing 7~7, both on approach and depar- ture is incldded in the Revised EIR. However, to characterize the Boeing 767 aircraft as "louder than aircraft previously banned from the aircraft because of noise" is misleading. As reflected in the EIR, the Boeing 767 aircraft is most likely significantly quieter on departure than the older aircraft types which historically have used JWA. The County has traditionally regulated primarily~based upon departure noise characteristics because it is departures which impact most signifi- cantly the "noise sensitive" co~munities in the vicinity of JWA. The land uses to the north of the airport, which are affected by aircraft landings (or "approach~ noise") are largely co~ercial or other compatible land uses, and residential areas to the north of the airport are much further removed from the airport's noise contours then resi- dential areas to the south of JWA. Nevertheless, revised single event information for both departure and approach has been included and discussed in the revised EIR. The EIR discloses on page 4.15-70, paragraph 2 that the B767 "requires substantially more power on approach than the MD-80 and, hence, is noisier." The focus on the departure profile of the aircraft as -58- 4.15 S. 4.15 T. 4.15 U. compared with the approach path is logical given the fact that noise sensitive uses are at the departure end of the airport while the uses impacted by the approach are not noise sensitive. Further disclosure regarding the impacts of the projected probable fleet mix on the 65 dB CNEL contour at the arrival end is contained in Section 4.15.7.5.4. As documented in Table G-2 of Appendix G, the number of air carrier and business jet arrivals on flight paths 11B and llA (see Figure 4.15-4) is an insignificant portion of the total number of arrivals. Therefore, the County does not concur that the "Year 2005 conclusions for areas under the approach path" in the Mesa/Acacia area would be significantly different. As indicated by the response to comment R, the distinction has not been overlooked and it is acknowledged that the B-767 aircraft is noisier on approach. Appropriate revisions have been made in the revised EIR. It is true that the County generally requires a detailed analysis of the traffic noise associated with proposed projects which includes a general plan amendment and/or zone change if that noise is significant. However, these projects have development proposals as part of the project. The project described in the EIR includes only a land use compatibility plan and general plan amendment, zoning'level documentation, which may take the form of a specific plan, will be prepared after the Board of Supervisors has adopted the land use concept. That zoning action will be the subject of further CEQA documentation- This is amore appropriate location for the detailed noise analysis which the City suggests because an actual development concept will then be available, and a more complete analysis of the effects of traffic noise on the development and surrounding areas can be completed. Presently, there is no specific proposed development plan, and there is, therefore, no sufficient basis to provide such information. The referenced noise abatement cutback procedure is discussed in the revised EIR. Since this procedure is not recommended as a mitigation measure, the EIR does not discuss the impact of this procedure. -59-