From last week’s blog, we know that even the August 1, 2013
County Kimley-Horn [KH] Runway Extension Study, read closely, suggests that a
runway extension to the east will cost more than the revenues it will
generate. Driving more than
1,000 piles through the landfill makes the extension expensive.
Does the County even want a long runway extension now? Or is the County goal to build a safety system on the west – a good thing – but to also build large retaining walls as the first step to convert Palomar to an airport for faster and larger planes?
The County Goal
KH Study page 5-2 says – when discussing the KH proposed EMAS safety system:
“The west end RSA [Runways Safety Area] was graded to meet B- II criteria. Outside of the RSA footprint, the plateau was designed such that it could be upgraded to C-III standards in the future without major structural changes to any retaining wall locations if the airport decided to reclassify the Airport Reference Code (ARC). The proposed retaining walls and vehicle service road have been planned outside of the RSA limits for an ARC C-III to accommodate a future change.” [Emphasis added.]
In other words, though the KH Study says a 900-foot EAST runway capacity extension would preserve Palomar FAA ARC B-II requirements, the WEST end safety system and associated massive retaining walls included in the KH Study have been designed to ARC C-III standards so that Palomar could handle bigger and faster planes in the future.
This design creates two problems for the County.
The FAA Funding Problem. As KH notes and as discussed in last week’s blog, the County must calculate benefit cost ratios for capacity extensions but not for safety extensions such as the safety system that catches aircraft overshooting the runway at the west end. But the EMAS safety system does not need C-III size retaining walls.
The County appears to be combining EMAS safety costs with capacity costs [i.e. those associated with retaining walls designed to convert Palomar to a C-III airport]. In short, when the County applies for FAA grants for the EMAS, all costs associated with converting Palomar to a C-III airport, including such retaining wall costs must be deleted. Such retaining walls are part of a capacity runway extension that requires a FAA benefit cost analysis.
The CEQA Problems. The KH Study is not meant to be an environmental study that complies with the California Environmental Quality Act [CEQA]. But the County has said that it will prepare an EIR for the Palomar Master Plan [PMP] that the County is now writing.
Absent an objection from the public, it is likely that the County would simply include the KH Study EMAS analysis into the PMP. And that analysis would likely be included into the CEQA analysis for a Palomar EMAS system project. That approach would be a mistake and violate CEQA for two reasons.
First, CEQA prohibits the County from committing to or undertaking a project unless the project impacts are properly analyzed. Accordingly, C-III size retaining walls cannot be built as part of the EMAS project unless the County EIR analyzes what the environmental effects of converting Palomar to a C-III airport would be.
The County has a history of dividing large projects into small ones to avoid comprehensive environmental analysis. That past practice explains why the County has not prepared a Palomar EIR for nearly 40 years. Including massive retaining walls as part of an EMAS safety system would simply continue the past County practice of analyzing projects piecemeal - a CEQA violation.
Second, the KH study provided only one EMAS scenario and treats that scenario as a “given.” KH provides no alternative analysis. A proper CEQA PMP study and runway EMAS extension study must consider alternatives.
For instance, EMAS systems apparently are designed to stop only 90% of aircraft overruns based on the anticipated weight and speed of the involved aircraft. What this means at Palomar is that some planes overshooting the runway would drop off the end of the EMAS into the adjoining 80-foot deep canyon.
Other alternatives would avoid this safety and environmental hazard. For instance, the EMAS could be shifted 100 feet east especially if a 100-foot east runway extension were added.
Not to be indelicate. But is the County trying to sneak in C-III size retaining walls without the proper CEQA C-III analysis under the guise of making the airport safer?