Has the FAA been reading Lewis Carroll’s Alice’s Adventures in Wonderland & Through the Looking-Glass?
“If I had a world of my own, everything would be nonsense. Nothing would be what it is because everything would be what it isn’t. And contrary wise, what is, it wouldn’t be. And what it wouldn’t be, it would. You see?”
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Two examples.
Hearing the Public. Three months ago, I federal-expressed two letters to the FAA LA District Office. That office oversees most Palomar airport issues. The letters were sent to Mr. McClardy, Manager Airports Division and to Mr. Cushing, Airports District Office Manager.
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The letters quoted FAA written policy:
“The FAA is committed to complete, open, effective participation in agency actions. The agency regards community involvement as an essential element in the development of programs and decisions that affect the public.”
“The public has a right to know about our projects and to participate in our decision making process. To ensure that FAA actions serve the collective public interests, all stakeholders will have an opportunity to be heard. Our goals are:
- To provide active, early, and continuous public involvement;
- To provide reasonable public access to information;
- To provide the public an opportunity to comment prior to key decisions; and
- To solicit and consider public input on plans, proposals, alternatives, impacts, mitigation and final decision.” [See FAA Order JO 7400.2, Appendix 10 entitled “Community Involvement Policy,” effective February 9, 2012.]
My letters requested information related to pending FAA-Palomar matters. I also provided detailed cites to laws and regulations binding on the FAA. In part, the letters requested that the FAA analyze the safety of using the Palomar closed landfill as a runway safety area. I asked the FAA to hold public workshops. Still waiting for an FAA substantive reply.
To paraphrase Lewis Carroll: When dealing with the FAA, nothing is what it is because everything is what it isn’t. In modern computer terms, the FAA is not WYSIWYG. [“What you see is what you get.” Not.]
Informing the Public. Contrast the above announced FAA open door policy with FAA practice. Assume you want FAA Palomar-related data. Send a letter. Ah, maybe not.
Try a FOIA [Freedom of Information Act] request. But beware. Unlike California state and local agencies, the FAA charges for the staff time it takes the FAA to locate records and copy records. So you could be billed $400 for 300 pages of records. (At 20 cents a page, the County would charge $60.)
Perhaps ask for an FAA FOIA fee waiver as federal law allows. Point out that FAA-produced information will be used:
- To comment on NEPA & CEQA documents issued by the FAA and County related to Palomar Airport as part of the statutorily-mandated environmental process,
- To investigate County compliance with the land use restrictions imposed by Carlsbad including the Carlsbad Conditional Use Permit 172,
- To review whether the County has fully advised the FAA of Palomar Airport landfill problems,
- To question County compliance with FAA grants,
- To question County compliance with FAA requirements, such as the need to always maintain a current Airport Layout Plan on file with the FAA,
- To inform FAA, County, and Carlsbad public officials of Palomar problems,
- To inform citizens affected by Palomar operations of airport-related concerns by publishing a weekly article in Carlsbad.patch.com.
FAA response? Sorry, Mr. Bender. No fee waiver. You have not shown the ability to sufficiently inform the public of Palomar related issues. Do you hear a warning bell? Do you see stonewalling?
I am reminded of a sign a co-worker posted in jest on his office door: “Do not Agitate, Aggravate, Anger, Annoy, Bother, Bug, Enrage, Exasperate, Incense, Infuriate, Inflame, Irk, Irritate, Madden, or Vex Occupant.” [Readers, add your own.]
Apparently, the FAA takes such signs seriously. Perhaps I am too gullible. I thought the FAA would actually honor its nationwide communication policy. The FAA problems discussed in Blog #16 should have forewarned me.
