Palomar's Problem: An FAA-Rated B or C Airport: Either/Or?

The County has an “either/or” Palomar problem.  What is an either/or problem?  It is a thought process that limits choices.

Think of driving from Vista to San Diego.  Do you take the I-5 or the I-15?  Your car GPS gives you three choices. Which do you take?

Human nature says take the shortest route.   Or even the slightly longer route you know.   But shortest does not mean fastest.  The fastest depends on traffic conditions.  An accident, road construction, or time of day may make the shortest route the slowest.   The third route may be the best.

Palomar’s Problem: An FAA-Rated B or FAA-Rated C Airport: Either/Or?

Palomar is an FAA-rated B airport.  It wants to be an FAA-C rated airport to serve faster, heavier jets.  Already about 45% of Palomar jets are FAA C-rated or even bigger and faster FAA D-rated.

The recent County Palomar Runway Extension Study recommends that the County extend the Palomar runway by 900 feet from 4900 to 5800 but that Palomar remain an FAA B-rated airport.    The report also suggests that the County wants to convert Palomar to an FAA-C rated airport at an undisclosed time.

To become a C-rated airport, Palomar needs increased FAA-required separation distances between its runway and its taxiways.  Why?  Planes veer off runways due to wind, other weather conditions, mechanical failure, runway surface defects, and pilot error. 

FAA-rated C and D planes have wider wingspans, faster speeds, and carry much more fuel than smaller planes.  If these planes veer off the runway, the chance of interfering with planes that are taxiing down a parallel taxiway increases.

But the County cannot achieve the FAA-required separation distances for a C-rated airport unless the County does two things.  First, build massive retaining walls to increase the useable Palomar flat land on its existing acreage.  Second, relocate some buildings.  Undertaking these two projects is costly.  So the County says Palomar remains an FAA-rated B airport for now.

Is the County Complying with FAA Airport Design Requirements?

FAA C-rated airports need more than increased runway-taxiway separation.  They also need longer runway safety areas [RSAs].  Why?  In addition to veering off runways, larger & faster aircraft also travel further if they overshoot the runway or land short on approach.

RSAs are the flat land areas at each end of paved runway surfaces.  At Palomar, the RSA at the west end is a paved surface that adjoins a canyon and at the east end is the sandy area over the Palomar Unit 3 problem-plagued landfill.  The Palomar RSAs have been designed to meet the short FAA B–rated requirements, not the FAA-C rated longer requirements.

In short, the County – with or without the 900-foot runway extension – has no plans to extend the Palomar runway safety areas to meet FAA design requirements for C and D aircraft. Even though 45% of the jets landing at Palomar today are C & D planes.

What Should the County Do?

FAA airport design requirements state:

“FAA recognizes that incremental improvements inside full RSA dimensions can enhance the margin of safety for aircraft.  This is a significant change from the earlier concept where the RSA was deemed to end at the point it was no longer graded and constructed to standards.  Previously, a modification to standards could be issued if the actual, graded and constructed RSA could not meet dimensional standards.  Today, modifications to standards no longer apply to RSAs.  The airport owner and the FAA must continually analyze a non-standard RSA with respect to operational, environmental, and technological changes and revise the determination as appropriate.” [See ¶307a(2) at page 59 of the September 28, 2013 FAA Airport Design standards [AC 150/5300-13A.]

In other words, both the FAA and County have a daily obligation to improve Palomar RSAs if practicable.  Despite this requirement, the County refuses to assess whether 90,000 pound aircraft traveling at 150 knots and carrying several thousand gallons of fuel should land on a Palomar Unit 3 landfill that has a known history of underground fires and methane gas periodically exceeding regulatory limits.

The County thinks of Palomar as either a B airport or C airport, merely an artificial designation.  The County simply ignores the high percentage of C and D planes that already use Palomar and deserve C and D rated RSAs.