Palomar Airport: FAA Analysis: Good Faith?, Blog #30

Why the FAA and County Hate Assessing Cumulative Environmental Impacts

Blog #29 explained how and why the FAA and County avoid proper environmental analysis. Today, we look at the analysis that the FAA published last year when it looked at a new airline starting operations at Palomar Airport.

But first be surprised at how impacts add unexpectedly. Grab a checkerboard. Put grains of rice on each square. One on the first, two on the second, four on the third. Double the number of grains on each subsequent square until you reach square 64. How many grains of rice does the checkerboard hold? According to Wikipedia, 18,446,744,073,709,551,615. [Search “Wheat & Chessboard.]

Of course, business customers don’t double every year? Or even every 5 years. But their cumulative impacts on traffic and air quality are substantial. Assume 1,000 businesses operate in 2001. Each business may attract 4,000 customers annually [2 per hour for an 8 hour day, 5-day week].

So in 2001 these businesses generated 4,000,000 customers. [4,000 x 1,000]. And, the customers drove to and from your business. Make that 8,000,000 car trips causing traffic and smog. Add trips by workers and suppliers.

Fast forward 10 years. More people, customers, businesses, suppliers, and impacts. That’s why California law requires project developers to assess cumulative impacts.

Did the 2012 FAA CPA EA Analyze Environmental Impacts in Good Faith?

California Pacific Airlines [CPA] wants to start a new air service at Palomar. In July 2012, the FAA released its CPA environmental assessment [EA] for comment. The National Environmental Policy Act [NEPA] requires federal agencies to assess use of certain bigger planes at airports. Here is what the FAA did and did not do.
 
• Daily Palomar Operations Assessed. The FAA looked at the impacts of 30 daily operations [15 takeoffs + 15 landings per day] for the first 5 years of CPA operations. [See FAA CPA EA Table 3-3.] In contrast, the March 13, 2013 CPA report provided to the County showed CPA increasing its aircraft from 4 in Year 1 to 9 in years 2-3 and 20 by years 3-4.

• Passenger Increase Impacts. CPA plans to use planes carrying 70 or more passengers. At the rate of 30 operations per day, 365 days per year, with 70 passengers per day, CPA would handle 766,500 new passengers. Try to find any discussion of passenger levels in the FAA CPA EA and the traffic and air quality impacts of many more drivers on the road.
 
• Cumulative Environmental Impacts. See page 4-26 of the FAA CPA EA discussion of “Off-Airport Projects.” Notice there is no discussion of the “Palomar Commons” project. Was the project too hard to find? Too insignificant to assess? Let’s check.

Go to Palomar Airport Road & El Camino Road. On the airport’s south side, the $40 million Palomar Commons project arises: a Lowe’s Home Improvement Center, a bank, gas station, fast food eateries, and retail shops. The development is on land owned by County Airports but not part of the actual airport.

Why was a “mitigated negative declaration” [MND] prepared recently for this project? The Palomar Common businesses will substantially increase congestion at Palomar & El Camino right next to Palomar Airport. New traffic turning lanes are being added. Even so the traffic level of service [LOS] will decrease substantially.

LOS traffic ratings range from A to F. An “A” rating means clear sailing. “D” and “F” ratings mean count to 10 and control your temper. Even with the mitigation, the Palomar & El Camino LOS will decrease to near Level D at peak times.
 
Now, why would the FAA omit the above information from its July 2012 CPA EA? Was it that hard to identify a $40 million project on airport property across the street?

And by the way, how would 750,000 more passengers impact traffic?  Or, far more passengers if the CPA doubles the number of planes it uses? Or the added traffic from other off airport projects recently built or now pending, which the FAA failed to identify?

Does the FAA prepare its Palomar Airport environmental documents in good faith? Really? Break out the red-tipped white canes for FAA use.