HomeMy WebLinkAbout04 E.I.R. NO. 573 MCAS 06-04-01AGENDA REPORT
MEETING DATE:
JUNE 4, 2001
TO:
WILLIAM A. HUSTON? CITY MANAGER
690-10
NO. 4
06-04-01
FROM:
REDEVELOPMENT AGENCY STAFF
SUBJECT:
CITY OF TUSTIN RESPONSE TO COUNTY OF ORANGE DRAFT SUPPLEMENTAL
ANALYSIS FOR ENVIRONMENTAL IMPACT REPORT NO. 573 PERTAINING TO THE
CIVILIAN REUSE CONVERSION OF MCAS EL TORO AND THE AIRPORT SYSTEM
MASTER PLAN FOR JOHN WAYNE AIRPORT AND PROPOSED ORANGE COUNTY
INTERNATIONAL AIRPORT
SUMMARY
City Council authorization is requested for the City of Tustin's response to the subject Draft
Supplemental Analysis for Environmental Impact Report No. 573 pertaining to the proposed
conversion of the former Marine Corps Air Station (MCAS) El Toro to the Orange County
International Airport (Attachment 1).
RECOMMENDATION
It is recommended that the City Council authorize staff to forward the attached draft response to
the County of Orange's Notice of Availability of the Draft Supplemental Analysis for
Environmental Impact Report No. 573 pertaining to the civilian reuse of Marine Corps Air Station
(MCAS) El Toro and the Airport System Master Plan for John Wayne Airport and proposed
Orange County International Airport.
FISCAL IMPACT
There are no fiscal impacts associated with this action.
BACKGROUND/DISCUSSION
MCAS El Toro is an installation that was officially closed in July 1999 under the Defense Base
Closure and Realignment Act of 1990. The County of Orange has been authorized by the
Department of Defense to act as the Local Redevelopment Authority (LRA) and is responsible for
planning the future civilian reuse of the closing base.
On December 11, 1996, the Orange County Board of Supervisors approved a Community Reuse
Plan (CRP) which included a full service commercial passenger and cargo airport estimated to
serve approximately 38.3 Million Annual Passengers (MAP) surrounded by aviation-compatible
land uses. The County had indicated at this time that John Wayne Airport would be closed and
William A. Huston
Supplemental Analysis, EIR 573
June 4. 2001
Page 2
that the existing aviation activities at JWA would be consolidated at the proposed international
airport at MCAS El Toro. This CRP is the only plan formally transmitted to the Department of
Defense (DOD) by the County and is currently recognized by the DOD as the only approved
Reuse Plan for MCAS El Toro.
As part of the Phase II planning process for the MCAS El Toro, the County circulated EIR 573
intended to analyze an airport Master Development Plan selected by the Board of Supervisors as
the "Proposed Project". EIR 573 indicated that John Wayne Airport (JWA) would be retained in a
general aviation and short and medium-haul passenger role serving approximately 5.4 MAP with
MCAS El Toro being converted to "Orange County International" (OCX) airport supporting an
international passenger and cargo role serving 28.8 MAP. EIR 573 was circulated for public
comment from December 23, 1999, through February 22, 2000.
In response to comments received, the County of Orange has now prepared and circulated for
comment the subject Supplemental Analysis. The Supplemental Analysis only addresses
proposed changes to previous EIR 573 discussions and analysis primarily related to Air Quality,
and Transportation, with some discussion provided concerning the project's inconsistency with
the City of Irvine's General Plan (for the southerly portion of MCAS El Toro within Irvine's Sphere
of Influence). Consequently, only comments addressing the changes discussed in the
Supplemental Analysis will be considered by the County of Orange in developing a Final EIR 573.
City Departments have reviewed the subject Supplemental Analysis and prepared the attached
letter of comment (Attachment 1). Staff requests that the Tustin City Council review and consider
these comments and, if acceptable, authorize their formal transmission to the County of Orange.
Dana Ogdon
Program Manager
Attachments:
i. Draft comment response letter
Attachment 1
DRAFT
June 5,2001
County of Orange
El Toro Master Development Program
Attn: Mr. Bryan Speegle
10 Civic Center Plaza, Second Floor
Santa Ana, CA 92702
RE:
DRAFT SUPPLEMENTAL ANALYSIS, ENVIRONMENTAL IMPACT REPORT
NO. 573, PERTAINING TO THE CIVILIAN REUSE CONVERSION OF MCAS
EL TORO AND THE AIRPORT SYSTEM MASTER PLAN FOR JOHN WAYNE
AIRPORT AND PROPOSED ORANGE COUNTY INTERNATIONAL AIRPORT
Dear Mr. Speegle:
Thank you for the opportunity to review and comment on the Draft Supplemental
Analysis for Environmental Impact Report (EIR) No. 573 pertaining to the civilian reuse
conversion of Marine Corps Air Station (MCAS) El Toro. It is noted that the Draft
Supplemental document provides new analyses, however, it does not address many of
the issues that were previously raised by the City of Tustin in our correspondence of
February 22, 2000 (attached). Our review of the document has identified the following
comments and concerns that have not been adequately addressed or responded to:
The Draft Supplemental Analysis states with respect to regional air quality that "the
Proposed Project would be self-mitigating" because there would be a reduction in
regional surface traffic movements due to the shorter trip lengths under the
proposed Orange County Airport System. This conclusion makes a generalized
assumption that with two commercial airports in Orange County, passengers and
cargo will not have to travel to more distant airports in other counties. This logic is
flawed because it fails to recognize that many passengers use shuttle and bus
services to access regional airports. In addition, passengers may be more likely to
drive to LAX and park their vehicles at LAX, whereas they may be more likely to be
dropped-off at John Wayne or the proposed Orange County International. When
passengers are dropped-off and picked-up at airports, two round trips are required.
Because these behaviors and resulting trip patterns are difficult to model, all
references to shorter trip lengths, the relevant analysis and the resulting conclusions
should be eliminated from the Draft Supplemental Analysis.
Mr. Bryan Speegle
EIR 573 Draft Supplemental Analysis
June 5, 2001
Page 2
Table 4.18-7 on Page 5-72 indicates that 244 jet fuel tank truck trips per day are
projected for 2020. This equates to approximately one truck trip every six (6)
minutes, twenty-four (24) hours per day. Please indicate where the air quality
impacts resulting from emissions generated by the truck delivery of fuel are
addressed in the Supplemental Analysis. If the impacts are not addressed, please
include an analysis of the impacts on the region. Use of the Norwalk and Santa Fe
Pacific Pipelines to eliminate identified impacts should not be assumed in the
Supplemental Analysis because pipeline use is within the responsibility and
jurisdiction of separate agencies. These agencies may or may not enter into
agreements with the County for use of their pipelines.
Preparation of the Draft EIR 573 traffic study is generally consistent with regionally
accepted methodology. The traffic study is consistent with information utilized for
the preparation of the City of Tustin's MCAS Tustin EIS/EIR. The analysis utilizes
the OCTAM 2.8 model and OCP 96 socioeconomic data and includes analysis of
peak hour and ADT data. The study area encompasses the entire City of Tustin
including all major intersections, arterial roadways, and the freeway/tollway systems.
The supplemental analyses primarily focus on updates to the freeway/tollway
analyses. Questions related to potential impacts of arterials in Tustin were,
therefore, not addressed. This would include the intersections of Red Hill Avenue &
I-5 NB Ramps, Red Hill Avenue & Irvine Boulevard, Tustin Ranch Road & Irvine
Boulevard and Prospect Avenue & Irvine Boulevard. Arterial roadway sections
would include Jamboree Road (Tustin Ranch Rd. to Chapman Ave.), Irvine
Boulevard (Prospect Ave. to Newport Ave.) and Red Hill (north of Bryan Ave. to El
Camino Real). It is possible that identification of additional freeway/tollway impacts
could translate to added traffic on the arterial road system, which would result in
additional arterial roadway impacts, which were not previously identified nor
analyzed in this Supplement.
The traffic study includes a project fair share analysis of locations where traffic
impacts affect the level of service and capacities of arterial roadways and
intersections. The County utilized Intersection Capacity Utilization (ICU)
methodology to determine the level of traffic service at arterial intersections within
the study area. The ICU methodology has been approved for use in traffic impact
studies by OCTA and all Orange County cities and is the accepted methodology
used throughout the County of Orange. ICU methodology includes not only the
volume of traffic through an intersection at a given time, but also identifies turning
Mr. Bryan Speegle
EIR 573 Draft Supplemental Analysis
June 5, 2001
Page 3
movements and distribution of traffic, which results in identification of critical
movements through the intersection. This ultimately determines the level of traffic
service for the location.
Typically, the ICU methodology is carried throughout a project and used for
determining future levels of service, future regional impacts and project fair share of
impacts. Distribution patterns and turning movements are determined from traffic
models are identified and added to intersections. The ICU is recalculated with the
future data resulting in a future level of service value. From this future ICU, project
impacts are determined and mitigation measures developed.
In the Draft EIR 573, the County utilized the ICU methodology for determining
impacts, but then used a different methodology for determining the project share of
impacts. The fair share methodology included the addition of future project traffic to
intersections without consideration of traffic distribution and turning movements.
This results in an understatement of the project share of impacts. The fair share
methodology used by the County is typical of a roadway link analysis, but is not
appropriate for intersection analysis. In conclusion, the Draft EIR 573 traffic fair
share methodology is not consistent with the ICU methodology and therefore,
grossly underestimates the project share of improvements. The project fair share
calculations (including Figures 5-14, 15-4 and 15-5) must be based on the
proportion of the future ICU value due to the project traffic. The fair share
methodology used in the DEIR evaluates the relative increase in total intersection
volumes without regard as to how increases in traffic volumes are distributed onto
critical movements. It is the sum of critical movements, not the sum of total
intersection volumes, which determines intersection capacity utilization. The MCAS
Tustin EIS/EIR Traffic Study provides a good discussion of appropriate fair share
methodology as an example.
The Supplemental document does not provide any updated evaluations of the
arterial intersections. The City of Tustin concerns regarding the previously proposed
"fair share" methodology used at the arterial intersections were, therefore, also not
addressed. As a part of these Supplemental freeway/tollway analyses, there are
descriptions of the "fair share" calculations used, which are based on traffic volume
totals.
As was previously expressed by the City of Tustin, total intersection volumes and
project related impacts (as defined by the ICU analyses) can be and are, two
independent traffic variables. Therefore if impacts are identified through the ICU
Mr. Bryan Speegle
EIR 573 Draft Supplemental Analysis
June 5, 2001
Page 4
analyses and mitigation is based on traffic volumes alone, it is not possible to assure
that the impacts have in fact been mitigated. As previously explained, if project
traffic is all added to the critical "ICU" movements there would be a 100%
contribution toward intersection impacts. A "fair share" based on total traffic
volumes alone, however, would "under estimate" the mitigation required and does
not relate directly to project impacts. The Supplement indicates the "fair share"
complies with a County procedure, but it must more importantly satisfy the
requirements of CEQA.
In summary, the Supplement does not respond directly to the City of Tustin
concerns. It also continues to utilize a "fair share" procedure, which does not serve
to fully mitigate project related impacts.
o
The traffic study fails to identify specific development thresholds that correlate to
improvements and timing of their implementation. A project of this magnitude will
not be developed all at once. As the project develops there will be traffic generated
by the new development. The study needs to identify the time frames when the
additional traffic generated by the project will necessitate roadway improvements to
accommodate the traffic demands. This would include the development of phasing
plan that identifies on-site development thresholds (DU's, S.F., etc) and associated
traffic volumes that would be tied to the construction of circulation improvements to
accommodate the additional project traffic.
The Supplemental analyses did not provide any response or further clarification,
with regard to mitigation of arterial roadway impacts in the City of Tustin. The
impacted arterial locations are identified in comment "1" and it is possible there
could be added locations subject to the freeway/tollway analysis changes.
Nevertheless there should be specific roadway improvements (in Tustin) to be
completed within specified time frames (in conjunction with the appropriate phases
of project development) to assure timely completion of the improvements, necessary
to serve the proposed project.
6. The Transportation and Circulation Mitigation Measures need to be modified to
include specific verbiage that identifies that construction of improvements within
Tustin will be done to the City's standards and satisfaction. The mitigation
measures should identify funding mechanisms to fund the project share obligations
of improvements. Review of the Supplemental Analysis has revealed that no action
appears to have been taken by the County on this matter or response provided to
the City's concern.
Mr. Bryan Speegle
EIR 573 Draft Supplemental Analysis
June 5, 2001
Page 5
Again, the City of Tustin's February 22, 2000 comment letter (attached) has not been
addressed or responded to as identified above. The City continues to believe that EIR
573 is inadequate and should not be adopted until the aforementioned issues and
concerns have been addressed.
Thank you again for providing the City with the opportunity to review and comment on
the Supplemental Analysis for EIR 573. The City of Tustin is interested in receiving a
response to our comments when they become available. Please call me at (714) 573-
3116, if you have any questions regarding this matter.
Sincerely,
Dana Ogdon
Redevelopment Program Manager
DO:'~mcas\lt r\speegle8
Attachment
CC:
William Huston
Christine A. Shingleton
Elizabeth Binsack
Tim Serlet
Lois Jeffrey
Deborah Rosenthal
Community Development Department
February 22, 2000
· ~ u . i '""----'~.--" "' '
!'.'i
~ : ]m~FEB2 5 2~ .... m
·. '~ ).! ',
· ! L...,-"
?
300 Contennial
'I-, ustin, CA @2?80
714.573.$~ O0
County of Orange
MOAS El Toro Master Development Program
Attn: Bryan Speegle
10 Civic Center Plaza, Second Floor
Santa Ana, CA 92702-4048
SUBJECT:
REVIEW OF DRAFT ENVIRONMENTAL IMPACT REPORT NO. 573 FOR
THE CIVILIAN REUSE OF MOAS EL TORO AND THE AIRPORT
SYSTEM MASTER PLAN FOR JWA AND PROPOSED COX
Dear Mr. Speegle:
Thank you for the opportunity to provide comments on the Draft Environmental impact
Report for the Civilian Reuse of MOAS El Toro and the Airport System Master Plan for
John Wayne Airport and Proposed Orange 'County International Airport. The City of
Tustin has identified the following comments and concerns:
General
The document indicates that the County's current plan for John Wayne Airport is to
reduce the number of annual passengers from its current level of 8.4 million annual
passengers (MAP) to a maximum of 5.4 MAP and to increase the current level of
18 thousand tons of air cargo to 20 thousand tons annually. General aviation
aircraft at JWA would not be increased. However, there is no guarantee stated in
the document that passenger, cargo and general aviation air traffic would be
constrained in perpetuity at that level. Please specifically state that the proposed
project would establish an enforceable restriction against increasing air passenger
service beyond the proposed 5.4 MAP level against increasing cargo operations
beyond the proposed 20 thousand tons, and against increasing general aviation
aircraft based at JWA.
Draft EIR No. 573 should state that the proposed project would establish an
enforceable commitment to limit air passenger service at El Toro to no more than
the proposed 28.8 MAP.
o
Page 1-7, Section 1.6.1 - The No Project Alternative is speculative and not a
realistic alternative. The County of Orange currently holds a lease from the military
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 2
for the golf course, riding stables, RV storage, Officer's Club and County on-site
offices. In addition, the Navy leases out agricultural activities and commissary
activities that could also continue to occur in the future, and Navy environmental
remediation of the military installation would absolutely continue. Further, federal
law mandates that military caretaker operations continue into the future. Please
revise and correct all assumptions and conclusions throughout the document
regarding the No Project Alternative.
Draft EIR No. 573 states that "the principal purpose of the ASMP [Airport System
Master Plan] is to provide enhanced commercial airport facilities in Orange County
to meet the demand for air service generated within Orange County." However,
the discussion in Section 2.2.1 on Aviation Demand focuses on market demand in
the six-county Airport Service Area (ASA). Draft EIR No. 573 should analyze the
demand for airpo¢~ service in Orange County rather than in the ASA. This analysis
should demonstrate if the proposed Orange County Airport System would meet
demand generated throughout the ASA or primarily from Orange County, and
areas such as southern Los Angeles County and northern San Diego County.
Jet Fuel Pipeline
5. According to the Draft EIR, pages 4.10-51 and 4.10-52:
"Without modifications to the existing system, the Norwalk Pipeline has capacity
to supply the aviation related fuel demands under the Proposed Project until
approximately 2008. With pump and pipeline flange upgrades, the Non.,,'alk
Pipeline could operate at a flow rate of 1,400 gpm, which would yield a daily fuel
supply of two million gallons. This would be adequate to serve OCX until 2020."
Although the Draft EIR identifies the use of the Norwalk Pipeline as a mitigation
measure, the document fails to describe in detail the nature and extent of the
necessary upgrades and the potential environmental impacts of these upgrades
on the communities though which the pipeline traverses, such as Tustin. Draft
EIR No. 573 should specifically describe the upgrades, the resulting potential
environmental impacts and appropriate mitigation measures. The use of the
Norwalk Pipeline should be evaluated at the same level of detail as the project.
The document should also address how fuel would be supplied after 2020.
Because Draft EIR No. 573 is limited to include only feasible mitigation
measures, the document should demonstrate that construction of the stated
pipeline upgrades is feasible. Furthermore, the potential impacts resulting from
the construction of the upgrades should be addressed separately from the
potential permanent impacts.
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Pa§e 3
7.
10.
11.
The risk of upset assessment on pages 4.18-32 and 4.18-33 should analyze the
probability of a pipeline accident and the level of property damage caused by
such an accident along the entire length of the Norwalk Pipeline, not just the
risks of proposed extension of the pipeline on the MCAS El Toro site. Since
flows through the pipeline are anticipated to increase and upgrades will be
made, the risks of upset are likely to be greater than that from the pre-existing
pipeline used by the U.S. Marine Corps.
Even if the pipeline does not need to be expanded or upgraded for the whole
length, the facility will carry approximately 20 times the amount of fuel than
during military usage. The Draft EIR should analyze the risk of the increased
usage and change in fuel type along the entire length of the pipeline. Please
indicate in this analysis the relationship (arithmetic, geometric, etc.) between the
volume of fuel and the hazard risk.
On page 4.18-33, the Draft EIR briefly discusses the number of incidents
i.nvolving the release of product from jet fuel pipelines, as listed by the U.S.
Department of Transportation, Office df Pipeline Safety. This discussion should
be expanded to explain the nature of the incidents (leaks, ruptures,
contaminstion, etc.) and the level of property damage caused in each incident.
The Draft EIR should also examine the.local permit requirements and potential
impacts associated with the use of the Norwalk Pipeline, such as leaks, ruptures,
and disruptions of repairs and accidents to public rights-of-way.
All previous incidents involving the release of product from the Norwalk Pipeline
should be discussed in detail, including cleanup requirements, costs, and
resulting health hazards.
Hazard footprints associated with potential rupture/explosion of the pipeline need
to be provided as part of this analysis. Also, information related to pipeline age,
maintenance history, etc, should be detailed in the environmental analyses for this
matter. DEIR 573 should not identify the-use of an underground pipeline(s) ss a
possible mitigation to tanker truck use at Orange County until it can be proven that
the proposed mitigation is actually a safer alternative to the method proposed (use
of tanker trucks).
If replacement of the Norwalk Pipeline is anticipated based on the age and/or
repair history of the pipeline, then the environmental impacts of replacemen¢ are
foreseeable and should be addressed.
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 4
12.
13,
Portions of the existing JP-5 pipeline serving the former MCAS El Toro currently
exist outside of public roadway right-of-ways (utilizing railroad rights-of-way, etc.)
and also follow routes that abut residential neighborhoods. If the use of an
underground pipeline is pursued by the County, all pipeline utilized should be
required to be located away from residential neighborhoods and only within
existing roadway rights-of-way. Again, DEIR 573 should not identify the use of an
underground pipeline(s) as a possible mitigation to tanker truck use at Orange
County until it can be proven that the proposed mitigation is actually a safer
alternative to the method proposed.
Draft EIR No. 573 recognizes that the likelihood of tank truck.transport highway
accidents is relatively high and therefore proposes pipeline mitigation measures
to utilize existing petroleum pipelines, including the Norwalk Pipeline and the
Santa Fe Pipeline. The County has no jurisdiction over these pipelines and
notes on page 4.10-52 that "In the event that neither pipeline can be used to
deliver Jet-A fuel to OCX, delivery would be by tanker truck;" therefore, additional
mitigation measures for the tank truck transport of Jet-A fuel need to be
provided. The Draft EIR also needs to discuss the actual truck routes propcsed
for fuel delivery, including alternate routes to be used in the event of
road/freeway closures, and the enforcement restrictions for these routes.
14.
The Draft EIR should identify if the transfer of the jet fuel line easement from the
federal government to the County is subject to the National Environmental Policy
Act (NEPA). Please specify all applicable code sections.
15.
Mitigation Measure RU-1, which pertains to the use of the Norwalk and Santa Fe
Pipelines, should indicate that the County will invite representatives from all
thi~een communities along the Norwalk Pipeline-route to participate in its
discussions related to the acquisition and/or lease of the Norwalk Pipeline.
16.
The Draft EIR should include a mitigation measure that would require the County
to inspect the Norwalk Pipeline on a regular basis, correct any leaks, ruptures or
other hazards, and to pay any damages associated with a pipeline hazard.
Noise
17.
Page 4.4-62, Flight Track Dispersion, third paragraph - Noise analyses performed
in the document assume'that future aircraft would follow flight paths identified in
the document. However, the document states that "departures may show mcre
early dispersion as aircraft are turned toward their destination by FAA air traf'r~c
controllers." This statement essentially means that departing aircraft may not
follow the flight paths detailed in the EIR. This is a significant concern to the City
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 5
18.
19.
20.
21.
of Tustin since the flight path depicted for runway 16 only theoretically avoids the
City of Tustin and its sphere of influence." Additional analyses and mitigation (i.e.,
penalties, curfews and departure thrust cutback) of all potential flight path noise
over Tustin and its sphere of influence should be undertaken by the County prior to
approval of the project.
Page 4.4-178 - Noise mitigation number N-1 indicates that "specific commitments
to any noise control measure cannot be made at this time" and that "noise
mitigation measures will be done as part of an Airport Master Plan environmental
review process." It is critical that noise mitigation measures be identified within the
document to mitigate noise impacts associated with an airport prior to County
Board of Supervisors' approval of the project. The City of Tustin requests that the
document's dismissal of a nighttime curfew (page 4.4-173), Dep'arture Thrust
Cutback (page 4.4-152), and use of landing fees for noisy aircraft be reevaluated.
As an owner/operator of the proposed airport, the County may have additional
authority to control noise, including penalties, curfews and departure thrust
cutback. Therefore, the County should commit to these mitigation measures at
this level of review. If the proposed project is approved, aviation noise over
residential areas must be mitigated.
Draft'EIR No. 573 indicates that an increase of 6.5 dB is projected at the Tustin
noise modeling receptor location (T1). This increase, however, is not considered
significant by the EIR because the location is not within the 65 CNEL contour.
Typicaily, an increase of three (3) dB or greater is recognized by noise analysts
as a significant environmental impact regardless of the overall noise level
Therefore, the projected increase at noise receptor T1 should be recognized as
significant and properly mitigated.
An additional noise receptor location for noise modeling purposes in the EIR
should be provided in the Tustin area so that potential noise impacts to the
Tustin Ranch community can be estimated. Exhibit 4-6 clearly shows that a
noise receptor location near the intersection of Tustin Ranch Road and
Jamboree Road is needed and justified, considering the relative locations of
noise receptors T1, O1, EO, and I1. Furthermore, Tustin Ranch would be in very
close proximity to arrivals on Runway 16.
Draft EIR No. 573 proposes a noise monitoring location north of Tustin in the City
of Orange. A noise monitoring location should be proposed in the Tustin Ranch
community. A location near the intersection of Tustin Ranch Road and
Jamboree Road is recommended because it is approximately the same distance
from the proposed flight path as the proposed location in Orange and is midway
between the proposed Irvine and Orange locations. As shown in Exhibit 6.1-4,
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 6
22.
23.
24.
25.
only three noise monitoring locations are proposed along the North Corridor,
whereas many locations are proposed in the South and East Corridors.
The exhibits in the Noise Analysis Technical Report (Appendix E) do not identify
many of the residential areas within the City of Tustin, especially in the Tustin
Ranch community. Please correct these exhibits so that they pro.perly reflect
residential land uses in Tustin. The City will provide land use maps upon
request.
Draft EIR No. 573 (pages 4.4-172 and 4.4-173) discusses, and then rejects, a
mitigation measure that would shift all nighttime departures to Runway 34. If
adopted, the measure would have eliminated nighttime overflights in Lake
Forest, Mission Viejo, Coto de Caza, and Santa Margarita while increasing
CNEL values and nighttime operations in Northwood, Cowan Heights, Tustin,
Orange and Anaheim Hills. According to the Draft EIR, the mitigation measure is
not proposed for adoption as project mitigation because it "...would not appear to
provide a clear net benefit, and would appear to increase any impact in some
communities while reducing impacts in other communities.". Because there may
be confusion regarding the mitigation 'measures that are discussed in detail but
not proposed, please provide a matrix or other listing of all of the mitigation
measures that are considered, but rejected, in the draft EIR.
According to Draft EIR No. 573, "...even if all 747 and DC-10 aircraft were
eliminated from operations in [2020], the reduction in the total number of
operations would not be substantial, and the significant impact identified earlier
in this section would not be mitigated." The City of Tustin strongly disagrees with
this statement because 747 and DC-10 aircraft generate higher Single Event
Noise Levels that could be eliminated. Further, a feasible mitigation measure
should not be rejected on the grounds that it would partially mitigate a significant
impact, rather than fully mitigate a significant impact. In fact, in EIR 563 the trial
court ordered the County to adopt feasible mitigation measures if they would
reduce significant impacts, even if they did not achieve full mitigation. An
Average Daily Departure noise classification regulation and allocation system
similar to the one use at John Wayne Airport should be proposed as a mitigation
measure in the Draft EIR. The mitigation measure should also require that all
aircraft used at El.Toro be Class "E" (exempt) in accordance with JWA criteria.
Although the Federal Aviation Administration does not typically fund sound
insulation programs in areas outside the 65 dB CNEL contour, the County
should, through a mitigation measure in Draft EIR No. 573, institute a sound
insulation program in areas where the CNEL level increases by more than 3 dB
as a result of the proposed project, regardless of the total CNEL
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 7
26.
The City of Tustin opposes any project alternative that proposes an increase in
the level of cargo operations at John Wayne Airport. The City of Tustin would be
significantly impacted by the noise impacts of nighttime air cargo .operations on
sensitive residential areas. These impacts would need to be mitigated. Please
include in the Draft EIR a comparison and analysis of the noise levels generated
by cargo aircraft versus passenger jets.
Air Quality
27.
Draf~ EIR No. 573 concludes that "the proposed project would be self-mitigating."
because there would be a reduction in regional surface traffic movements due to
the shorter trip lengths under the proposed Orange County Airport System. This
conclusion makes a generalized assumption that with two commercial airports in
Orange County, passengers and cargo will not have to travel to more distant
airports in other counties. This logic is flawed because it fails to recognize that
many passengers use shuttle and bus services to access regional airpo~s. In
addition, passengers may be more'likely to drive to LAX and park their vehicles
at LAX, whereas they may be more likely to be dropped-off at John Wayne or the
proposed Orange County International. When passengers are dropped-off and
picked-up at airports, two round trips 'are required. Because these behaviors and
resulting trip patterns are difficult to model, all references to shorter trip lengths,
the relevant analysis and the resulting conclusions should be eliminated from the
Draft EIR.
28.
In the Supplemental Analysis to EIR No. 563, the County found that local and
construction-related air quality impacts could not be mitigated. The County
continued to find that regional impacts were mitigated. Or~ February 4, 2000, the
trial judge found that the County's regional impact findings were not supported
by the evidence and ordered the County to propose a correctio,~. Therefore, the
County should acknowledge and mitigate the regional air quality impacts.
29.
The proposed airport system in Orange County would add 26.7 MAP capacity to
the regional air transportation system. The shorter trip length argument should
be eliminated from Draft EIR No. 573 because the 26.7 MAP increase wiil
generate millions of additional vehicle trips in the region regardless of trip length.
Even if every passenger who would make the trip to LAX, will instead drive to El
Toro, there will still be additional trips regionally because air .capacity at LAX will
not be reduced. The regional air quality analysis is somewhat misleading. The
County's setoff theory does not explain why the expected overall improvement in
air quality in the next 20 years in the absence of an airport at El Toro should be
jeopardized in Orange County.
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 8
30.
Draft EIR No. 573 should clarify in Mitigation Measure AQ-22 on page 4.5-81
that the program for the use or conversion of at least 90 percent of ground
support equipment (GSE) to electric powered by the year 2010 will be
implemented at OCX and JWA.
31.
Draft EIR No. 573 acknowledges on page 4.5-97 that fuel supply by pipeline'
would reduce total diesel PM10 emissions at OCX by an estimated 2 percent.
However, when combined with the proposed conversion of ground support
equipment to alternative fuels, the overall reduction in total diesel PM10
emissions at OCX would be reduced by an estimated 90 percent. This
discussion demonstrates that supplying jet fuel by pipeline is an insignificant
mitigation measure for reducing health risk impacts, compared with the mitigation
measure for ground support equipment. The discussion on page 4.5-99 is
misleading because it combines the effectiveness of the mitigation measures,
thereby over-emphasizing the effectiveness of the pipeline alternative. The
discussion should separately address the two mitigation measures to eliminate
any confusion.
32.
Please indicate where the air quality impacts resulting from the truck delivery of
fuel are addressed in the Air Quality Technical Report. If the impacts are not
addressed, please include an analysis of the impacts on the region.
33.
Draft EIR No. 573, page 151, references two particulate emissions studies, one
at John Wayne Airport (Newport Beach Fallout, JWA, January 15, 1993) and one
at Logan Airport in Boston, Massachusetts (Soot Deposition Study: Logan
Airport and Surrounding Communities, Massport, January, 1997). Please
provide the City of Tustin with copies of these studies or indicate where the City
would be able to obtain copies. Although the Draft EIR indicates that these
studies found no significant particulate emissions, the Draft EIR should, st a
minimum, include mitigation that would require the establishment of a baseline,
the implementation of a monitoring program for potential particulate emissions,
and the execution of appropriate mitigation measures.
Socioeconomics and Resulting Physical Changes
34.
Page 4.17.6.2, Socioeconomic Effects of the Proposed Project (and subsequent
sections) - The EIR repeatedly jointly discusses the regional benefits to
employment, housing and economic occurring as a result of the proposed project
via the changes proposed at both OCX and John Wayne airports. However, the
document does not specifically discuss the potential negative economic impacts
and subsequent physical changes to the environment that would occur as a result
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 9
of the proposed reduction of flights (8.4 MAP currently vs. 5.4 MAP proposed) at
John Wayne airport. A potentially significant negative environmental impact could
occur from the shift of airport related economic activity from John Wayne and
surrounding vicinity to El Toro. Please provide an analysis of this potentially
negative impact and provide appropriate mitigation.
35.
A 1/3 reduction in MAP at John Wayne Airport may result in significant vacancies
in the surrounding hotel, office and light manufacturing areas surrounding JWA.
The area is one of the largest business districts in California. Loss of value,
disinvestment and eventually physical deterioration may occur unless the uses
can be converted. The Draft EIR should address negative physical impacts
resulting from socioeconomic changes.
Draft EIR No. 573 should address the pressure for land use intensification in the
area surrounding the proposed Orange County International Airport. This area is
likely to experience significant pressure for redevelopment and higher density
development. Residential neighborhoods may be redeveloped for o~ce or
commercial uses, as has happened near O'Hare Airport in Chicago and near Los
Angeles International Airport.
Transportation and Circulation
37.
Preparation of the Draft EIR 573 traffic study is generally consistent with
regionally accepted methodology. The traffic study is consistent with informatio,q
utilized for the preparation of the City of Tustin's MCAS Tustin EIS/EIR. The
analysis utilizes the OCTAM 2.8 model and OCP 96 socioeconomic data and
includes analysis of peak hour and ADT data. The study area encompasses the
entire City of Tustin including all major intersections, arterial roadways, and the
freeway/tollway systems.
38.
The traffic study includes a project fair share analysis of locations where traffic
impacts effect the level of service and capacities of arterial roadways and
intersections. The County utilized 'Intersection Capacity Utilization (ICU)
methodology to determine the level of traffic service at arterial intersections
within the study area. The ICU methodology has been approved for use in traffic
impact studies by OCTA and all Orange County cities and is the accepted
methodology used throughout the County of Orange. ICU methodology includes
not only the volume of traffic through an intersection at a given time, but also
identifies turning movements and distribution of traffic, which results in
identification of critical movements through the intersection. This ultimately
determines the level of traffic service for the location.
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
.February 22, 2000
Page 10
39.
40.
Typically, the ICU methodology is carried throughout a project and used for
determining future levels of service, future regional impacts and project fair share
of impacts. Distribution patterns and turning movements are determined from
traffic models are identified and added to intersections. The ICU is recalculated
with the future data resulting in a future level of service value. From this future
ICU, project impacts are determined and mitigation measures developed.
In the Dra~ EIR 573, the County utilized the ICU methodology for determining
impacts, but then used a different methodology for determining the project share
of impacts. The fair share methodology included the addition of future project
traffic to intersections without consideration of traffic distribution and turning
movements. This results in an understatement of the project share of impacts.
The fair share methodology used by the County is typical of a roadway link
analysis, but is not appropriate for intersection analysis. In conclusion, the Draft
EIR 573 traffic fair share methodology is not consistent with the ICU
methodology and therefore, grossly underestimates the project share of
improvements. The project fair share calculations (including Figures 5-14, 15-4
and 15-5) must be based on the proportion of the future ICU value due to the
project traffic. The fair share methedology used in the DEIR evaluates the
relative increase in total intersection volumes without regard as to how increases
in traffic volumes are distributed onto critical movements. It is the sum of critical
movements, not the sum of total intersection volumes, which determines
intersection capacity utilization. The MCAS Tustin EIS/EIR Traffic Study
provides a good discussion of appropriate fair share methodology as ~,n
example.
The traffic study fails to identify specific development thresholds that correlate to
improvements and timing of their implementation. A project of this magnitude
will not be developed all at once. As the project develops there will be traffic
generated by the new development. The study needs to identify time frames or
development thresholds when the additional traffic generated by the project will
necessitate roadway improvements to accommodate the traffic demands. This
would include the development of phasing plan that identifies on-site
development thresholds (DU's, S.F., etc) and associated traffic volumes that
would be tied to the construction of circulation improvements to accommodate
the additional project traffic.
The Transportation and Circulation Mitigation Measures need to be modified to
include specific verbiage that identifies that construction of improvements within
Tustin will be done to the City's standards and satisfaction. The mitigation
measures should identify funding mechanisms to fund the project share
obligations of improvements.
Mr. Bryan Speegle
Airport System Master Plan Draft EIR 573
February 22, 2000
Page 11
Request for Recirculation
Through our comments, the City of Tustin has identified several feasible mitigation
measures that are .considerably different from those analyzed that may lessen the
environmental impacts of the project. We have also identified substantial increases in the
severity of several environmental i'mpacts, including regional air quality and disinvestment
at John Wayne Airport. Therefore, the City of Tustin requests that the entire Draft EIR
No. 573 be recirculated to enable the public to address these changes.
Thank you again for the opportunity to provide comments on the Airport System Master
Plan Draft Environmental Impact Report No. 573. The City of Tustin would appreciate
receiving the recirculated Draft EIR and/or the Final EIR documents with the responses to
our comments when they become available.
If you have any questions regarding the City's comments, please call Rita Wes~'ield,
Assistant Director of Community Development, at (714) 573-3109 or Doug Anderson,
Senior Project Manager- Transportation, at (714) 573-3172.
Sincerely,
Elizabeth A. Binsack
Community Development Director
CC:
Chris Shingleton
Dana Ogdon
Tim Serlet
Dana Kasdan
Doug Anderson
Rita Westfield
Scott Reekstin
SR:environ,'A.rpc,';, Sys:em Master Plan DE!R 573 ,?,om,.me.~: Lett. er. cc,~