On August 1, 2013, the County posted its Kimley-Horn [KH] Runway Extension Feasibility Study on its Palomar Airport website and answers to its own 37 “Frequently Asked Questions” (FAQ).
Blogs 43, 44, and 46 explained why the County’s FAQ answers -- related to the safety of Palomar Runway and to the financial benefits of extending the runway -- were inaccurate. Not based on my opinion. Based on information in the Study
Today, we again look at Palomar Airport safety.
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“County FAQ 22: Is a B-II airport unsafe for aircraft in the C/D category?”
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“County FAQ 22 Answer: An airport that does not meet the FAA design standard guidelines for a particular classification of aircraft is not necessarily unsafe for operations by those aircraft. Under federal law, the FAA has the exclusive authority to regulate aviation safety. Unless the FAA determines an airfield to be inherently unsafe, the final decision to land or depart is up to the aircraft operator who must abide by the Code of Federal Regulations for the aircraft and its operation.”
Comment on FAQ 22 Answer: According to the County, it is up to the FAA to make airports safe and up to pilots to fly wisely.
Now consider the FAA August 5, 2013 response to my March 11, 2013 letter to the FAA that noted the problem of larger, heavier, more fuel laden planes classified as FAA C and D planes using Palomar, a B airport. In part, the FAA said (letter p. 3):
“[T]he condition of the closed landfill is beyond the oversight of FAA unless … it has or could become an attractant for wildlife. The location of the landfill in relationship to any proposed runway extension would certainly be a significant factor for the airport sponsor to consider in a feasibility study. Should the airport sponsor [the County] submit a runway extension feasibility study to FAA, we would expect and require the study to adequately address the technical feasibility of such a proposal.”
According to the County KH Study, Palomar was not designed to handle 45% of the C and D jets that use the B-rated Palomar Airport. The Palomar runway east end adjacent to the closed methane-emitting landfill is designed with runway safety areas and approach areas much shorter than FAA-rated C & D planes require.
Quite simply the issues is this: When a large fuel laden jet crashes into the Palomar closed landfill, releases as much as 2000 gallons of aviation fuel into a landfill that was built without a liner, and results in deaths and injuries when the landfill methane collection system ruptures, does the County really believe it and the taxpayers are going to escape legal liability for $10 million to $100 millions dollars of damages including the cost of removing 20 to 30 feet deep aviation fuel- contaminated decomposing trash and groundwater?
As even the KH Study says, the cost of removing and relocating Palomar landfill trash is $50 to $66 Million. And those numbers assume the trash is NOT hazardous. Once the trash is contaminated with aviation fuel, relocation costs skyrocket.
What Should the County Do?
The County FAQs focus on justifying the use of an airport designed mainly for planes typically weighing up to 12,500 pounds, carrying a few hundred gallons of fuel, and flying at comparatively low takeoff and approach speeds (a “B airport). But about 45% of jets now using Palomar weigh from 30,000 to 90,000 pounds, carry up to 3,000 gallons of aviation fuel, and fly at takeoff and approach speeds much higher than B-rated airports.
The County has the space in the existing closed landfill to provide for runway safety and approach areas for C & D rated aircraft. The County should lengthen and properly prepare the existing safety and approach areas. Proper preparation requires at least two things.
First relocate and rebuild the existing subsurface methane gas collection system to withstand the force of large crashing aircraft in the expanded runway safety and approach areas. Second, install an impermeable landfill liner and aviation fuel collection system on the landfill to assure that any aviation fuel from ruptured aircraft tanks cannot sink to the bottom of the landfill.
And, do it now. The safety and environmental contamination issues exist now. Not only if and when the runway is extended.
The County position should never be that Palomar is “not necessarily” unsafe. As the owner, developer, and operator of Palomar, the only responsible County position is that Palomar Airport is safe and satisfies the design standards for the aircraft that use it.
