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MINUTES - 04221986 - 2.6
2.6 The Board of Supervisors of Contra Costa County, California Adopted this Order on ApdI 22, 1986 by the following vote: AYES: Supervisors Fanden, Schroder, McPeak,Torlakson, Powers NOES: None ABSENT: None ABSTAIN: None SUBJECT: The Proposed PSA Lease The Board on March 18, 1986, accepted the reports entitled"Safety Study of Buchanan Field Airport" and Documentation for Initial Study of the Proposed PSA Scheduled Air Service and Lease at Buchanan Field Airport,"and fixed this time to consider approval of the Lease and the Negative Declaration relative to the application of Pacific Southwest Airlines(PSA). The Board received a report dated April 17, 1986, from the County Administrator, Public Works Director, and Community Development Director, recommending certain actions to be taken relative to the proposed PSA Lease. A copy of the report is attached and included as a part of this document. James Cutler of the Community Development Department gave a brief overview of the procedures relative to the PSA application. Mr.Cutler referred to two additional documents for inclusion in the record on this matter: (1) "The City of Pleasant Hill's Reponse to Response 11 Prepared by the County of Contra Costa," and(2)"Supplemental Responses to Comments on the Proposed PSA Scheduled Air Service and Lease at Buchanan Field" prepared by Contra Costa County, McClintock, Becker&Associates, and the Flight Safety Institute. J. M.Watford, Public Works Director commented on the proposed lease and noted that the lease has a one-year term. The following persons spoke in support of the proposed PSA lease and urged the Board to take the necessary actions to approve the PSA application: Dennis O'Dell, PSA Vice President and General Counsel, 3225 N. Harbor, San Diego 91202; Jack Welch,Walnut Creek Chamber of Commerce, 1501 N. Broadway,Walnut Creek, CA; Rick Fleming, Antioch Chamber of Commerce, 3412 Heather Court,Antioch, CA; Faith Jansen, 1585 Waltham Road, Concord,CA; Howard L. Jenkins, Jenkins Machinery Co., 1848 Arnold Industrial Place, Concord,CA; Ron Sorenson, Contra Costa Airports Business Association, 1124 Jamie Drive, Concord,CA; Rick Vossekuil, Contra Costa Council, 1834 Yolanda Circle, Clayton, CA; Richard Floyd,2800 Miranda Avenue,Alamo, CA; Mel C. Eckerstrom, Pleasant Hill Chamber of Commerce, 1962 Elinora Drive, Pleasant Hill, CA; Harry Bowers, Concord Chamber of Commerce, 3330 Clayton Road,Concord, CA; Jorge Testolin, 1984 Magnolia Way,Walnut Creek, C&who presented a petition of support signed by Students of Diablo Valley College; Marilyn King, 14 William Henry Court, Pleasant Hill, CA; and Gary Swartz, Shepherd Pontiac Inc., 1300 Concord Avenue, Concord, CA. The following persons spoke in opposition to the proposed PSA lease: D. McCulloch, 3035 Vessing Road, Pleasant Hill, CA; Pamela Sousa, 15 Palo Alto Court, Pleasant Hill, CA; Dennie Lee, 3300 N. Main Street, Pleasant Hill, CA; and Jack Fitzgerald,2591 Montgomery Avenue, Concord, CA. All persons desiring to speak were heard. Board members considered the testimony presented this day on the proposed PSA lease. The Chair noted that the Board of Supervisors has received other letters and public testimony on this matter. There was consensus among Board members that no information or evidence has been presented which would show that the PSA lease and air carrier service might have a significant impact on the environment. � - a TO: BOARD OF SUPERVISORS 5 Phil Batchelor, County Administrator i�" (, � J. Michael Walford, Public Works Director CJI " Harvey E. Bragdon, Acting Director of Community Developmen April 22, 1986 DATE: Consideration of the Proposed PSA Lease "J SUBJECT: SPECIFIC REQUEST(S) OR RECOMMENDATIONS) & BACK6ROUAD AAD JUSTIFICATION RECOMMENDATION The Board of Supervisors has received the following major reports on this issue: - "Initial Study and Negative Declaration, PSA Air Service and Lease at Buchanan Field." - "Documentation for Initial Study of Proposed PSA Scheduled Air Service- and Lease at Buchanan Field." - "Safety Study for Buchanan Field." - "Responses to Comments on the Proposed PSA Scheduled Air Service and Lease at Buchanan Field." - "City of Pleasant Hill 's Response to the Initial Study Recommending Negative Declaration on Proposed PSA Air Service and Lease at Buchanan Field." - "Supplemental Responses to Comments on the Proposed PSA Scheduled Air Service and Lease at Buchanan Field." In addition, the Board of Supervisors has received other letters and public testimony on this item, including comments received today. In conjunction with this issue, the Aviation Advisory Committee has held community forums and has recommended that the PSA lease be granted. Staff has reviewed and considered all of this information and does not feel that any information or evidence has been presented which would show that the PSA lease and air carrier service might have a significant impact on the environment. Based on the above reports, documents, and information, it is recommended that the Board of Supervisors: 1. .Find that the Initial Study, the supporting reports, the comments received from the public, and responses to those comments, all show that there is no substantial evidence that the proposed lease and scheduled air service to Buchanan Field Airport may have a significant effect on the environment; CONTINUED ON ATTACHMENT: X YES SIGMA RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER S I GNATURE I S 1: ACTION' OF BOARD ON _ April 22, 1986 APPROVED AS RECOMMENDED XX OTHER The Board considered and reviewed the information and documentation referenced above. The Board then adopted this order as Resolution No. 86/218 approving the recommendations set forth above. VOTE OF SUPERVISORS 1 HEREBY CERT 1 FY THAT TH I S IS A TRUE _XX UNANIMOUS (ABSENT TTT ) AND CORRECT COPY OF AN ACTION TAKEN AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: A13STA I N* OF SUPERVISORS ON THF_ DATE SHom. cc: Community Development Director ATTESTED April 22, 1986 Public Works Director Airport Manager PHIL BATCHELOR. CLERK OF THE BOARD OF PSA SUPERVISORS AND COUNTY ADMINISTRATOR FAA County Counsel , Auditor-Controller BY ��1 7l?¢,� (. 'DEPUTY M382/7-83 County Administrator Res 86/218 . r -2- 2. Approve the Negative Declaration on the PSA lease and scheduled air service; 3. Approve the proposed lease and authorize the Chairman to sign the PSA lease on behalf of the Board; and 4. Authorize the Director of Community Development to file a Notice of Determination with the County Clerk. FINANCIAL IMPACT The PSA base rent is $2,000 per month plus landing fees of approximately $4,000 per month. BACKGROUND/JUSTIFICATION On March 18, 1986, the Board of Supervisors of Contra Costa County accepted the reports entitled "Safety Study of Buchanan Field Airport (March 1986)" and "Documentation for Initial Study of the Proposed PSA Scheduled Air Service and Lease at Buchanan Field Airport". The Board further directed staff, based on those two reports, to file a Negative Declaration of Environmental Significance on the PSA lease agreement and to hold community workshops to discuss the results of those reports findings. On March 18, 1986, the County Community Development Department filed a Negative Declaration of Environmental Significance on this item. The item was published in the newspaper and approximately 70 copies of the two studies and the Negative Declaration were delivered to interested individuals and agencies and over 100 people received direct notice that a Negative Declaration had been processed. Two community forums were sponsored by the Contra Costa County Aviation Advisory Committee (AAC) on this issue. They were widely noticed, published in two display notices in the Contra Costa Times on March 27th and 28th, 1986. The meetings were held on March 31, 1986 at 7:30 p.m. at the Pleasant Hill Community Center and on April 7, 1986, at the same time, in the Concord City Council Chambers. Both forums were well attended by persons with varying viewpoints on this issue. The format of the community forums was to have the consultants present the main ,conclusions of the respective reports and then the meetings were opened to all who wished to comment on the issue, either of the two reports, the Negative Declaration, or just to express their views on the proposed PSA lease. Over six hours of public testimony was received by the AAC at the forums. The AAC at its meeting of April 15, 1986, completed its review of the reports "Documentation for Initial Study of the Proposed PSA Scheduled Air Service and Lease at Buchanan Field" and the "Safety Study for Buchanan Field Airport (March, 1985)". After careful consideration of those reports and of the testimony received at the community forums, the AAC unanimously reaffirmed its recommendation that PSA be granted a least to provide passenger air carrier service from Buchanan Field to Los Angeles International Airport as' described in the proposed lease agreement. Upon conclusion of the community forums, staff directed the consultants to respond to the environmental or safety issues raised, as well as to the written letters received to date in response to the Negative Declaration. The consultants have completed this effort and have produced the report entitled "Responses to Comments Raised on the Proposed PSA Scheduled Air Service and lease at Buchanan Field". For ease of use the report is divided into three chapters. Chapter I deals with general and environmental issues and Chapter II deals with airport safety issues. These chapters serve to supplement the two previously prepared reports on these subjects. Chapter III deals specifically with responses to written comments received on the Negative Declaration. While many additional , interesting and complex subject are discussed in this "Responses to Comments on the Proposed PSA Scheduled Air Service and Lease at Buchanan Field" document, no new factors have surfaced which would lead staff to feel that an EIR should be prepared on the PSA lease. It is recommended that the Board approve the initial study and Negative Declaration on this matter. Lastly, it is recommended that the Board approve the PSA Lease and authorize the Chairman to sign it on behalf of the Board of Supervisors. CONTRA COSTA C 0 U N C I L 268:1 Bidmp DI i\(', 51111 RI-InIoll" CIA 9,158.'-T`.38 April 18, 1986 The Honorable Tom Powers Chairman, Board of Supervisors Contra Costa County 651 Pine Street Martinez, CA 94553 Dear Chairman Powers and Members of the Board: The Contra Costa Council strongly urges your Board to approve PSA' s application to begin scheduled flights from Buchanan field. With Contra Costa' s expanding economy and increased level of business activity, it is clear that such service is needed to serve the business community. The establishment of the service will be of significant economic value to the County. The safety studies and environmental studies which have been conducted demonstrate that the flights pose no safety problems for the County' s residents. Parking and traffic impacts are also adequately addressed. We believe, therefore, that the establishment of PSA service is in the best interests of Contra Costa and its residents, and we urge you to approve the application and lease. Thank you for your consideration of our views. Sincerely, Linda Best Executive Director We the students. of Diablo Valley College are petitioning in order to show our support for the proposed commercial airline service, to Buchanon Field in Concord . We .feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, . increasing job opportunities , NA�E SOCIAL SEC`LRITY CTTY A�A S' f 1 -- L U _ �' �� � `I 7,3 7 DAL- ,L, u .iiactk �I L 3— (0 — 15 Z5 AWA ALVJ& Cie GG 9, c z 6 Ce9) 7 7 H We the students of Diablo Valley College are petitioning in order to show our support for the proposed commercial airline service, to Buchanon Field in Concord . We .feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore,' increasing Job opportunities , ------------ sorA� -RI Y - t csECIJ �3-02 (249wG o 5-71 ani 7 P"&, lam.o - CA 7W�M.4 - — 456 0 Tlu�� dive l We the students of .Diablo Valley College are petitioning in - order to show our support for the proposed commercial airli.rie service, to Buchanon Field in Concord . We feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing job opportunities , socrkL =UTRITY c=11 f. Az - r I , - 73 36 !� eta rDceL( 151. Mao- We the students of Diablo Valley College are -petitioning in order to show our support for the proposed commercial airlirie service, to Buchanon Field in Concord , We feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing yob opportunities . I SOCIAL JSK7UTRI�Y - 8oi ��usuIIJ11 1 kZ4� 12L 6-5- 9 - 3 s - - t1 I ( C Jt'l CO /Z.D S' p- 6 - ©Z �.on�o LL,166 C1 57 6 Ile lot 0 Z-3 �•��.�M4 G•�F"�'���M.cc �'i /�S,,� V V�"G/ d�/V(J We the students of Diablo Valley College are petitioning in order to show our support for the proposed commercial airlirfe service, to Buchanon Field in Concord . We feel this service will. facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing job opportunities . Iy SOCIA:-, SF'CU'RI 'Y CT'i Y. / Z I. Sill it Tr- S Ili o q z_ !36 3 777 rol j�� 444(0 (OGD fiU O r1 /� We the students of Diablo Valley College are petitioning in _ order to show our support for the proposed commercial airline service, to Buchanon Field in Concord , WeGfeel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing job opportunities , ?_-J 3 ! Gc��Co Via! u,+ t4 1 Ix �. ;- � S75-x"7- x/75 � �-- 6 96, 4 L. Ly6us� as 665 13-74,5714 l e a 7 6 3 . . , U �1 S" " f/ We the students of Diablo Valley College are petitioning in order to show our support for the proposed commercial airline service, to Buchanan Field in Concord . We feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increosing job opportunities , :vF SCX.:IAI, S-PuL-PITY CITY Y 34 r_ n -� � t � e - V 3 I y43 1 { 71 laz _ moi . Z ; / i We the students of Diablo Valley College are petitioning in order to .show our support for the proposed commercial airlirIfe service, to Buchanon Field in Concord. We feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing job opportunities . r socxL SECLRI'FY c=x OJ C�A� ' /`fid tfc- a ' 1 4 } _ 5 L/5 } aOkla 6�3 � rCkC� a, �. Ck L � � Q �- 50- - 0 r-'�-'— o/ ` a so vl� i./r' OKEI Isk00 Z_ r We the students of Diablo Volley College are petitioning in order to show our support for the proposed commercial airline service, to Buchonon Field in Concord , We feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing job opportunities , NF1h,� SC UPI SEOUT,I i Y CT'"�' �hn f r 5 5�1 s 6, iYo rindO C( JA4 PAfJ\11 LL-e '7 _ VI 7,X C'p',b / 1 a S-F o P $",tft 96 - q 1 Ate -"b N ' ��a � s-��so -� P� r 1 - v We the students of Diablo Valley College are petitioning in order to show our support for the proposed commercial airline service, to Buchanon Field in Concord . We feel this service will facilitate a better life for Contra Costa County residents and stimulate business; therefore, increasing job opportunities , I SOCIAL SECUPITY CITY y J3K Z Z1070 5--3-14-3-7 3 - i - ,-- � 9as R AM 11 G11 I Y � �; /�- So April 18, 1986 RECEIVED Board of Supervisors Hon. Tom Powers , Chairman APR 2 1 1986 651 Pine St . N!i,BATCHELOR Martinez, Ca. 94553 ERK COAR.D OF SUPFRYISORS 2 . NT.'J%�C�OSTA .. ..... .... De ut Hon. Supervisors : It has been interesting to read the pro' s and con's regarding the scheduled P.S.A. flights . I think the Board has done an excellent job in protecting the commercial as well as the safety and environmental interests of our County. I personally favor the expansion of Buchanan Field - with proper safeguards, of course. The reason for this letter is that there is a concern about the mixture of large passenger planes and small planes , especially regarding "touch and go" flight lessons (blindfolded student pilots) . Although F.A.A. rules require separation, this has proved not to be very workable. On Septermber 25, 1978 at 9: 02 A .M. , on a beautiful clear morning, there was a mid-air collision that took over 140 lives - on the , planes and on the ground. This was caused by a P.S .A. plane colliding with a "touch and go" (the small plane being in the right place) . P.S.A. did not contest their liability in this incident . There was also another small plane involved but it was not injured in the ensuing tragedy. Human beings make mistakes . We must learn from the mistakes of the past . We have an opportunity at this time to ensure that this particular type of accident will not occur in Contra Costa County. It will not cost anybody any money. All that needs to be done is to add a requirement that Ila/all "touch & go" lessons be scheduled so that there is not a lesson being conducted within five miles of the Airport fifteen minutes prior to a scheduled landing of any airplane large enough to carry 25 ormore passengers . " The F.A.A. does not require this . I hope that Contra Costa County will lead the way and make this small step towards greater air safety . Perhaps then other airports will also set this criteria, as part of their requirements . If you need any more information re the P.S.A. crash in 1978, 1 have the Hearing Report from Washington, D.C. , newspaper publications, and testimony from victims ' families (air and ground) plus personal knowledge, which I can furnish if needed. However, I think you have enough facts now to make a decision re this additional safety measure. -2- Thank you for your consideration of this matter. Sincerely yours , Marcella Colarich P. o. Box 891 Concord, Ca. 94522 MC/hp 930 -9/oo HAYS and ELDER ATTORNEYS AT LAW 3107 Clayton Road Concord, California 94519 (415) 676-7991 OF COUNSEL WILLIAM T. HAYS ARNOLD S. PETERSEN RICHARD E. ELDER, JR. ROBERT C. HAYS April 17, 1986 Contra Costa Board of Supervisors APR 1 8 1986 651 Pine Martinez, CA 94553 C, -2 ."— i SOP'S C 7�*Z COSTA C.0 Re: PSA Flights into Buchanan Field Deout Gentlepersons : I strongly support PSA Flights into and out of Buchanan Field. I have my office in Concord. I am under the extended flight path for the airfield. Planes fly over my office everyday with regularity. I think this is less dangerous to me than the cars and trucks going by on Clayton Road. I am a private pilot. I took my training at Buchanan Field. I have made about 350 take offs and landings from Buchanan. I am personally familiar with the airport, its physical layout, the surrounding area, their procedures and its capacities. I am also familiar as a long time passenger on PSA and I have flown several times on the airplanes they intend to fly into Buchanan. I say that PSA and the airplane in question are good, safe and efficient. The airplane is quiet. I am convinced that the addition of commercial flights into Buchanan Field would reduce the total number of flights because civilians and private pilots such as myself would have easy access to commercial flights. I would rather fly PSA to Los Angeles or San Diego than pilot myself. I am sure that many private pilots feel the same way. I suppose that four flights from PSA out of Buchanan would have a passenger capacity of around -32-0. I would bet that those flights would eliminate "at least four private flights. If so, I think safety would actually improve since PSA flights (although they involve bigger planes) are inherently safer . The planes are safer . The planes are better maintained and the pilots are much more experienced and qualified. I live in Moraga, 20 minutes from Buchanan. I work on Clayton Road, seven minutes from Buchanan. Commercial service out of Buchanan is much more convenient to me than service from Oakland. C ko Contra Costa Board of Supervisors April 17 , 1986 Page Two I recognize that some neighbors are concerned about safety but I believe the impact of the proposed commercial service by PSA will be an actual reduction in the already minimal risk of accident because general aviation flights will decrease somewhat and because PSA planes, procedures and pilots are better than general aviation. I am not saying that general aviation is not safe. I am saying that a PSA pilot with thousands of hours of experience, training and commercial qualifications who makes his living as a pilot is likely to be a better pilot than someone who has 50 or 60 hours of training and a few hundred hours in the air . I support commercial flights into Buchanan Field. Very truly yours, HAYS & ELDER l Richard E. Elder , Jr . REE:sl cc: Nancy Fanden, Supervisor City of Pleasant Hill 0993300 N. MAIN STREET, PLEASANT HILL, CALIFORNIA 94523 PHONE (415) 934-6050 RECEIVED April 17, 1986 APR 1 7 1996 PFCi.BATCHELOR CLERK B?ARD OF SUPERVISORS CONTRA COSTA CO. B De u Members of the Board of Supervisors Contra Costa County Administration Building 651 Pine Street Martinez, CA 94 553 Re: Proposed PSA Air Service and Lease at Buchanan Field Attached herewith is the City of Pleasant Hill' s response to the Initial Study recommending a Negative Declaration on the Proposed PSA Air Service and Lease at Buchanan Field. Yours very truly, I A. E City Attorney CC: Phil Batchelor, County. Administrator Jim Cutler, Community Development Dept. John Clausen, County Counsel DAL/als i f THE CITY OF PLEASANT HILL RESPONSE TO THE INITIAL STUDY RECOMMENDING A NEGATIVE DECLARATION ON THE fT PROPOSED PSA AIR SERVICE AND LEASE AT BUCHANAN FIELD L. APRIL 16, 1986 41. City of Pleasant Hill 93300 N. MAIN STREET, PLEASANT HILL, CALIFORNIA 94523 PHONE (415) 934-6050 Members of the Board of Supervisors April 16, 1986 County of -Contra Costa County Administration Building, North Wing P.O. Box 951 Martinez, CA 94553-0095 Re: Proposed PSA Air Service and Lease at Buchanan Field Members of the Board of Supervisors: f Based on a review of the Preliminary Negative Declaration, the Documentation for Initial Study, the Safety Study for Buchanan Field Airport, the 1983 EIR for Buchanan Field Airport (herein "Airport"), and other relevant documents, Hill herein "City") objects to the issuance of a negative the City of Pleasant ( y ) � g declaration for the subject project for reasons fully set forth in this letter, and adopts by reference the objections of all parties in this matter as though ( fully set forth. I The recommendation to issue a negative declaration is based mainly on l - information contained in two documents: "Documentation for Initial Study of Proposed PSA Scheduled Air Service and Lease at Buchanan Field Airport" prepared by McClintock, Becker & Associates (herein "McClintock Study") and "Safety Study for Buchanan Field Airport" prepared by' Flight Safety Institute �~ .on March 10 (herein Safety Study ) , both published , 1986. An initial observation is the fact that the structure and content of the McClintock Study is identical to that of an environmental impact report. The crucial differences are that a draft environmental impact report must be circulated for comments by the public and relevant public agencies and responses prepared thereto. In this case, the sole purpose of the document is to justify the [ issuance of a negative declaration and is therefore an abuse of the process required by the California Environmental Quality Act (herein "CEQA"). Although the McClintock Study refers to the 1983 Buchanan Field Airport EIR (herein "1983 EIR"), such references are selected for the sole purpose of supporting the negative declaration at issue. Thus, unless a member of the public is conversant with the impact discussions of the 1983 EIR, the background documents for the negative declaration sound convincing, but are, in fact, misleading. (See the Bendix critique on the inadequacy of the documents before the Board attached hereto as Exhibit A and incorporated by reference as though fully set forth) The purpose of the environmental review process is to provide objective information for the public and the decision makers upon which to arrive at an informed decision. For the subject project, only the preparation of a full environmental impact report could achieve that important public policy embodied in CEQA. Because the information provided in the background documents are highly technical and no apparent attempt was made to provide the information in plain language, the City had to retain experts in various fields to evaluate this negative declaration. The experts have advised the City that this negative declaration at best is deficient. f The City concurs with the comments by members of the public opposing the issuance of the negative declaration. This letter will only address those areas which were either not addressed by members of the public or to explain more fully the reasons for the City's objections. Please note that all references to the exhibits attached hereto are incorporated by reference as though fully set forth and hereto referred to only as Exhibit A and Exhibit B. A. PROJECT DESCRIPTION: The proposed project is simply described as a lease between PSA and the County to provide limited commuter services for one year, with a one year renewal option. To effectuate this proposed lease agreement, it is necessary to upgrade two runways, one for precision instrument landing and �. the other for non-precision instrument landing. The proposed project fundamentally changes the character of the Airport from a general aviation airport to an airport for mixing general aviation and air carrier operations in the absence of a duly adopted Airport Access Plan. The fundamental change in the character of the Airport and the absence .of a duly adopted Airport Access Plan was not mentioned in the project descrip- tion. Although the 1983 EIR did anticipate upgrading two of the runways 1: for precision instrument landing, it did not discuss mixing general aviation and air carrier operations. To accommodate scheduled air carrier operation, Runway 32R will be up- graded to a non-precision runway from visual , and Runway 19R will be up- graded from a non-precision runway to a precision runway. There are three alternative guidance systems for a precision instrument runway: an instrument landing system (ILS) , Microwave Landing System (MLS) or a precision approach radar (PAR). The City has been informed by County officials that due to the hilly terrain, an ILS would not work for the Airport. The 1983 EIR anticipated that the MLS would be installed; this was reaffirmed by County officials. However, the City was informed that MLS would not be available for some five years, but we must be aware that this Airport is not even on the waiting list as of this date. The PAR is a very expensive system. Insofar as the City is aware, there are no funds available for the purchasing of a PAR. Therefore, the project description is inadequate and should be revised to show what instrument landing guidance system, if any, will be used for the proposed project. (See Exhibit A) l B. PROJECT SETTING: The project setting description failed to include existing and public open space located adjacent to the Airport. As can be seen later, this omission resulted in a failure to discuss impact of the proposed project on existing and public open space, especially with reference to noise. l 1 r; I ' C. ENVIRONMENTAL IMPACT ANALYSES: jUnder CEQA, the environmental impact analyses must address project related impacts as well as cumulative impacts. The purpose of an initial study is to determine whether a project might have potential significant ( impacts on the environment. If potential significant impacts exist, then the appropriate procedure is the preparation of an environmental impact __. report analyzing those potential significant impacts; ultimately, the analyses may determine that such impacts may not be significant or i could be mitigated to an insignificant level . One of the deficiencies of this negative declaration is the fact that no �= mitigation measures are included although the background documents and the 1983 EIR clearly indicate that mitigation measures are required. Another deficiency is the fact that the background documents did not address cumulative environmental effects. (See also Exhibit A) r 1. Hydrology and Water Quality: Although the McClintock Study I. stated that the Airport is not within a designated flood hazard area, the 1983 EIR shows that the freezone area at the end of Runway 32R is located in an area shown to be a 100-year flood 1 hazard area and one dam inundation zone. Therefore, the conclusions stated on Page 30 of the McClintock Study should be re=examined and . fully discussed. (See also comment 19 of Exhibit A) L2. Geclogy and Soils: The McClintock Study incorporated by reference the—d scussio�r earthquake hazard potentials contained in the 1983 EIR. The 1983 EIR recommended certain mitigation measures for L., development on Parcel A and Parcel B. Since the proposed PSA passenger terminal is close to Parcel A, it appears that the mitigation measures stated for development on Parcel A would be equally applicable. However, the McClintock Study did not address the need to mitigate the potential earthquake hazard of the proposed passenger terminal . (See also comment 20 of Exhibit A) 1 3. Air Quality: The McClintock Study concluded that the air quality of tie region would not be degraded by the proposed project. However, the analyses is based only on a comparison of existing conditions, [ and existing conditions including the proposed project. It is general knowledge that the City of Concord has enjoyed unprecedented growth of office development near and around the Airport. The McClintock Study did not discuss the cumulative impacts on air quality. Detailed comments on these cumulative air quality impacts by Selina Bendix is submitted herewith in Exhibit A. Please note comments 22, 23 and 24. t_ l : 4. Noise: The adequacy of the noise analyses are set forth fully in letters from Wilson, Ihrig & Associates, Inc. , acoustical con- sultants to Mr. Dennis Lee, dated February 3, 1986, April 3, 1986, and April 16, 1986, which is submitted herewith as Exhibit B and incorporated herein by reference as though fully set forth. (See also Exhibit A) In addition, the mitigation measures discussed were largely applicable to general aviation and not specifically designed for air carrier operations. Furthermore, because the environmental setting discussion failed to include outdoor recrea- tion areas which may be impacted by the operations of the airport, there is no discussion of the cumulative noise impacts on existing or proposed open spaces and recreational areas, and should be included. 5. Natural Resources: Although the BAe 146-200 aircraft are new, it is doubtful tit—they operate without fuel . Yet, the McClintock Study stated that the PSA air service will not result in an increase in the rate of use of any natural resources nor did it discuss energy consumption of the renovated passsenger terminal . 6. Hazards: The discussion on hazard impacts refers to the Safety §t_u_(Ty_. However, the Safety Study did not address the potential for the release of toxic substances involving aircraft accidents. Please see Exhibit A for a more indepth discussion of the inadequacy of the hazard section. 7., Utilities and Public Servicet.j-The Safety Study went on at length comparing tfie 'incident and accident rates of the Airport .and other airfields located in nearby jurisdictions. The Safety Study pointed out that while the overall numbers of operations have declined at the Airport, the incident and accident rate has increased. There is no discussion on the causes which led to the increase of incident rates while the number of operations have declined and the type of mitigation measures needed to insure that the incident and/or accident rate would decrease. The comparison of the Airport and others mixing general aviation and air carrier airfields failed to address the safety records of those airfields, the local vs. itinerant aircraft operations, and the users of those airfields. The user information is important in determining whether the safety record of mixed use airfields is comparable because the Airport at issue is also a training airport; thus, many of the users are not. experienced pilots. The Safety Study failed to provide. all relevant information necessary for the determination of the impact, on public services, of initiation of air carrier operations at the Airport. Additionally, the Safety Study assumes that the MLS would be installed prior to initiation of the PSA scheduled service. � In the absence of a landing instru- ment which provides vertical and horizontal guidance, the Safety Study should be revised to discuss the impact of the lack of such a system on safety. (See also Exhibit A for a further discussion on the inadequacy of the "Safety. Study") i. 8. Transportation and Circulation: The cumulative transportation and circulation analyses of the" 3 EIR indicated that many of the existing intersections which provide access to the Airport are at level of service (L.O.S.) E and F. The cumulative impact would downgrade many more intersections to LOS E and F -- some inter- sections would be degraded from LOS B to F. Even with the proposed mitigation measures, those intersections with LOS E or F would remain at the same or would be upgraded only to LOS E. It should be noted that LOS F is essentially a grid lock condition, and LOS E means that vehicles are travelling at 10-15 miles per hour. Clearly, the level of traffic congestion would severely impact the response time of emergency vehicles. Furthermore, no information was provided on the status of these mitigation measures. Because this information was not presented in even a summary form, the public and the decision-makers are unable to realistically access the traffic related impacts, such as air quality and safety. Finally, the Airport's contribution to cumulative effects cannot be evaluated in the absence of an Airport Access Plan. (See also Exhibit A for further discussion) 9. Growth Inducing Impacts: Limitation on growth of other air carrier operations at the Airport depends on the content of the "Airport Access Plan." Contra Costa County has yet to complete or adopt the "Airport Access Plan" for the Airport. Therefore, it is impossible to determine the growth inducement impacts of the initiation of regularly scheduled commuter flights between Concord and other communities. Furthermore, without this',"Airport Access Plan", it is obvious that the County could not limit the airlines who .would want to come into the Airport if PSA scheduled services areimplemented. As discussed more fully i.n Exhibit A, this factor would in itself be a growth inducing impact that is recognized in the McClintock Report but yet, reaches the illogical conclusion that this project has no growth inducing impacts. (See Exhibit A for a more detailed dis- cussion) 10. Relationship to Regional Air Transportation Plans: In this section of the McCTTi6—tocV—Stuc]y, The consultant posed eight questions and then concluded, without any further explanation, that the answer to those questions were negative. Two of the questions especially deserve close examination; they are: Would the PSA project result in major expansion or major changes in the use of Buchanan Field?, and does the Airport operator own in fee simple the maximum approach area recommended by FAA standards for the appropriate runway instru- mentation categories, for possible use by future short takeoff and landing aircraft? The first question relates to the growth induce- ment impacts and the second question relates to the question of safety. (See also Exhibit A) 11. Emergency Response CaRabilities: The McClintock Study acknowledges that the project wouldrequire expanded security and fire protection services. The crucial issues in this type of analyses are the municipalities' ability to cope with airport and aircraft related emergencies. In any emergency, a crucial factor is response-time by the various emergency services. The only discussion on response- time was found on Page 68 of the McClintock Study. However, that discussion was incomplete because it was limited to only facts per- taining to the December 23, 1985 accident, and no response time for firefighting equipment and personnel was made available. Different types of fires have different flashover points. In the case of fire involving aircraft, there is always a danger of explosion. It was fortunate that the December 23, 1986 accident at Sun Valley Shopping Mall did not cause an explosion of the gasoline tank. Thus, the discussion of response time and the availability of equipment was not based on a worst case scenario. Additionally, the inability to install the MSL and its impact on safety relative to the Airport's mixing general aviation and air carrier operation must be reexamined. Aside from the literal compliance of the availability of emergency response equipment which may meet federal aviation standards, there are areas of concerns which were simply ignored by the Safety Study. Such questions involve the impact of existing and future traffic congestion on response time by the Fire District since any major emergency must be responded to by. different jurisdictions; the availability of adequate fire and other emergency -services to local jurisdictions to combat localized fire and other emergencies in the event of a major aircraft accident; and the availability of protec- tive clothing, breathing apparatus and other equipment used by fire, fighters; and the type of training available to fire fighters to combat fires caused by aircraft accidents. (See also Exhibit A for further discussion. The sections in Exhibit A on fire and emergency capabilities were prepared by a Fire Protection Engineer) D. SUBJECTS WHICH THE NEGATIVE DECLARATION AND ITS BACKGROUND MATERIAL FAILED TO DISCUSS, WHICH ARE RELEVANT TO EVALUAT-1NG7THE IMPACTS Or—f-H-E—P-00PTS—ED PROJECT 1. The McClintock Study arbitrarily selected a ten mile radius to determine traffic impact. A more relevant analysis would be the residents and businesses which are potential users of scheduled air- line flights. The potential users would help to define the growth inducement aspect of the proposed project and are relevant in analyzing cumulative impacts. 2. Many references are made to the fact that upgrading of the Airport would be funded by federal monies. In light of the fact that the federal government is contemplating cutbacks in many areas and the local governments' capability to raise revenue are limited by Proposition 13, the document fails to discuss the fiscal impacts on local jurisdictions. In summary, the McClintock Study should be revised as an environmental impact report to facilitate full discussion of the various potentially significant impacts of the proposed project. The issuance of a negative declaration is inappropriate and violates the mandates of CEQA. Therefore, it is respectfully submitted that the County of Contra Costa prepare an environmental impact report for the project so that all of the significant impacts of the project would be discussed and debated. Very truly yours, DENNIS A. LEE City Attorney ALICE BARKLEY Attorney at Law Attachments DAL/als ENVIRONMENTAL RESEARCH, INC. FOX PLAZA,SUITE 902 • 1390 MARKET STREET 9 SAN FRANCISCO, CA 94102 TELEPHONE(415)861-8484 15 April 1986 Dennis A. Lee City Attorney City of Pleasant Hill 3300 N. Main Street Pleasant Hill , CA 94523 RE: Critique of Environmental Evaluation of Proposed PSA Service to Buchanan Field Dear Mr. Lee: I have reviewed the Initial Study of Environmental Significance dated 18 March 1986 (henceforth IS), the Documentation for Initial Study for Pro- posed PSA Service to Buchanan Field dated 10 March 1986 (henceforth IS Documentation) , the Safety Study for Buchanan Field Airport dated 10 March 1986 (henceforth Safety Study) , referenced portion of the Draft Environmen- tal Impact Report for the Buchanan; Field Airport General Plan Amendment dated June 1983 (henceforth 1983 DEIR) , and New York Times News Service coverage of the 1978 PSA crash at San Diego Airport. ' In general , I find that these documents contain no substantiation for many of the statements made. The Inyo decision (Citizen's Association for Sen- sible Development of Bishop v. County of Inyo (1985) 172 Cal .App.3d 151) states that "Although an initial study of a project can identify environ- mental impact effects by use of checklist, it must also disclose the data or evidence on which the person conducting the study relied. Mere conclu- sions provide no vehicle for judicial review." Technical issues. are often discussed in such a fashion that they cannot be judged by a lay reader. CEQA Guidelines §15140 states "EIRs (thus, by implication, all environmental documents) shall be written in plain lan- guage and may use appropriate graphics so that decision-makers and the pub- lic can rapidly understand the documents." The Discussion in the January 1984 edition of the CEQA Guidelines, from the State Office of Planning and Research, 0. 146, states: "This section is intended to improve the clarity of EIRs. The section is also necessary to provide an interpretation re- solving the question of who is th'#"a'ppropriate audience for the EIR. Some EIRs have been written more like academic dissertations directed to other Ph.D.s rather than like public disclosure documents directed to busy deci- sion-makers and the general public.". Socific comments about these and other issues follow. EXHIBIT A -ENVIRONMENTAL CONSULTANTS AND FIRE PROTECTION ENGINEERS „ Buchanan Field Comments • ; Page:two 1. IS p. 1, item 1. The lands adjacent- to the Airport are part of the mature urban area of Central Contra Costa County...” Despite the supposed "maturity" of the project area, two sites on the Airport are designated for future development and there is community concern in Central Contra Costa County about continual growth. Under the circumstances, "mature" seems an inappropriate designation, implying that. the effects of additional growth need not be considered. 2. IS p. 1, item 2. This item refers to the Project Description section of the IS Documentation. Comments on the Project Decription in the IS Documentation follow: IS Documentation p. 8, Fig. 3. This figure contains an area labeled relocated taxiway future which I did not find mentioned in the text. When will this relocation take place? Will it affect runway use by PSA planes? What will determine implementation of this reloca- tion? eloca- tion? 3. IS Documentation p. 12, first complete V. "These potential parking sites consist of existing airfield apron areas currently used to park aircraft." If these sites are converted to automobile parking spaces, where will the aircraft now parked there be parked? 4. IS Documentation p. 13. I note that this table indicates flights arriving and departing between 6 and 7 pm daily, when residents near the airport may be dining. 5: IS Documentation p. 14, ¶ 1. This 9 ives the increase in` number of _ 9 plane movements but does not give the increase in number of passengers handled by Buchanan Field if the PSA service is provided. This percent increase would presumably be greater than the percent increase of plane movements, because the capacity of the PSA planes is greater than that of -the aircraft presently using Buchanan Field. 6 IS Documentation me tation p. 14, 11 2. No source or bass is given for the statement that 60% is a typical load factor; therefore, there is no way for the reader to know whether 60% load factor is a reasonable assumption. 7. IS Documentation p. 14, V 4. No source or basis is given for the statement that only seven percent of the passengers enplaning at Buchanan Field would be expected to return the same day. Since many of the weekday passengers will be going to Los Angeles for the day, I this seems a low percentage. In my experience, many business. travel- lers to Los Angeles return the same da • 9 Y 8. IS Documentation p. 15. No `ffsis is given for the breakdown of re- quired parking spaces into short, medium and long term. 9. IS Documentation p. 16, 9 4. If the site "is too contrained (sic) to allow adequate circulation for full-sized buses," is_:ff also too con- strained to allow ready access for fire trucks? Are any small buses used by local transit services? It is unfortunate that transit has l- Buchanan Field Comments Paget three been summarily dismissed in this discussion despite later evidence of traffic cong2stion. I 10. IS Documentation p. 17, line 3. What is the source and date of the statement that PSAs system-wide aircraft load factor averages 58%? Is the system-wide load factor appropriate for use in predicting Bucha- nan Field service characteristics? Does the load factor vary with the mix of planes used, the frequency of service, and/or .the availability of other scheduled airline services? 11. IS Documentation p. 18, 11 2. The BAe aircraft are claimed to be "fuel- efficient without any substantiating evidence. 12. IS Documentation p. 18, 1 4. Runways 19R and 32R, which would be used 90-95% of the time, are stated to have a load bearing strength of 90,000 pounds. The table on the following page indicates that the maximum take-off weight of the 146-200 aircraft is 90,000 pounds (rounding to the same two significant figures). This suggests that these planes will be at the limit of the bearing capacity of the runways. Will ff this increase the rate of runway wear and, hence, the cost of mainte- nance? The bearing strength of the runways which would be used the other 5%-10% of the time is not given. Is it the same? If less, what are the consequences of use by overweight aircraft? 13. IS Documentation p. 18, ¶ 5. The term engine-out is used without definition or explanation. for the reader not familiar with aircraft terminology. 14. IS Documentation p. 18, 9 6. The statements that the BAe 146 repre- sents "state-67-the-art in quiet technology," "very much in demand for service at noise impacted airports," and "extremely quiet aircraft" are presented without substantiation and read like a sales document rather than a neutral environmental document. Page 27 of this docu- ment shows the BAe 146 to be noisier on take-off and landing than three of the four aircraft to which it is compared. Line 4 refers to "lower noise emission characteristics" but does not state lower than what. The significance of exemption "from operational limits placed on other FAR Part 36 Stage 3 compliant aircraft at John Wayne Orange County Airport" is not explained. In the absence of such an explana- tion, this statement is meaningless. 15. IS Documentation p. 19. Table 3 contains a great deal of apparently unedited information from British Aerospace, including British units. This table contains numerous undefined abbreviations and terms which are unfamiliar to the average reader. 16. IS Documentation p. 20. Tatem 4 presents a highly technical figure explaining take-off field length. There is no explanation of how to read such a graph on page 18, where it is referenced. The use of such highly technical material in environmental documents without full l explanation is. inappropriate, and its use with explant ons should be avoided, because it makes interpretation of such documents by the ave- rage concerned citizen reader more difficult. IBuchanan Field Comments • Page`four 17. IS Documentation p. 21. Figures 7 and 8 both contain undefined tech- nical terms, and Figure 7 is virtually meaningless to the uninitiated without explanation. 18. IS Documentation p. 22. The term PNdB is not explained nor is its relationship to dBA and CNEL, which are used later in the document. (on p. 27 of the IS Documentation, Table 8 incorrectly gives the noise levels as dB, when they are A-weighted Decibels, or dBA). Again, the information is given in a highly technical format without explanation to make it interpretable by the audience for which the document is intended. Information about ICAO standards is meaningless without comparison to relevant US Environmental Protection Agency standards. If these standards differ, compliance with ICAO standards which permit pollution not permitted by USEPA standards is irrelevant for use of aircraft at Buchanan Field. I, note that the ICAO standards for nitro- gen oxides appear to be given in terms of nitrous oxide, which is not l :. the way similar standards are handled in the United States, where a mixture of various nitrogen oxides, all of which constitute air pollu- tants, is assumed to be formed by all combustion processes. "Smoke" emissions are not part of US air standards. If this is equivalent to a particulate standard this should be stated. The "Emissions compari- son" portion of Table 5 is unintelligible: it does not state what is being compared to what. If the unidentified numbers are aircraft model numbers, one would have to know more about the characteristics of these aircraft to know if they are comparable to the aircraft pro- posed for Buchanan Field. 19. IS . 2 Item 1.b . An increase in p ) aircraft using the airfield will increase the potential for fuel spills which could pass through cracks in the pavement to contaminate the ground under the airport and, ultimately, the groundwater. This may be judged to be a negligible change from the present condition, but cannot be stated to be an impact which does not exist. " Has any sampling of soil and groundwater under the surface of 1 Buchanan Field been done to determine whether there is any contamination? I note that no substantiation or explanation is given in the IS for checking 1 1.b) "No". 20. IS p. 2, Item 2.b). The 1983 DEIR indicates on p. 29 that an Al uist- Priolo Special Study earthquake zone runs along the east edge of the air- port, and I note that Item 2.b) asks whether potentially hazardous condi- tions exist "immediately adjoining the site." On p. 27 the 1983 DEIR states that earthquakes on the nearby Concord Fault may have a Richter mag- nitude of 6.6. Persons in a one-story building, such as the PSA terminal at Buchanan Field, are not at as great risk as those in taller buildings, but one-story buildings can damage occupants in a collapse or if ceiling fixtures fall. The impact of being in this particular location may be judged insignificant in view of tie generally seismically active environs, but few activities in a seismically active area can be said to have no geologic hazards. —' 21. IS p. 2, Item 3.c). Page 30 of the IS Documentation is referenced in response to this Item, This one paragraph statement indicates that the proposed project will not require any "significant site preparation." No a definition of "significant site preparation" is given, so the reader cannot Buchanan Field Comments • Page-five judge what will be involved or its significance. 22. IS p. 2, Item 4. This item is checked "no impact" on the basis of IS Documentation pp. 0-31. In fact, part of the air impacts discussion is in the setting section on pp. 28-29. In the first 9 of the air discussion on IS Documentation p. 28, PSA's aircraft are stated to offer "some startling air quality comparisons. " This is inappropriate language for an environmen tal document. The entire discussion of air impacts is meaningless in the absence of any discussion of the current air conditions at the airport or t . at the nearest Bay Area Air Quality Management District measurement station. Comparative air emissions of West Air and PSA aircraft are presented on IS Documentation p. 28 and of related automobile trips on p. 29. The cumula- tive effect of the two pollution sources is not given or compared to existing I conditions at the airport. 23. IS Documentation p. 31. Here,IPSA aircraft emissions are compared to county and regional emissions. The automobile emissions are not included in this comparison. Any single project is unlikely to have a significant impact on county-wide or regional air quality unless it is something like a coal-fired power plant. The appropriate comparison is to existing conditions on-site or as close to the site as informa- tion is available. Dispersion models are routinely used to estimate local impacts of pollution sources. t 24. IS Documentation pp. 32-33.. Particularly in view of the congested rush hour traffic conditions in the project area, automobile-associated carbon monoxide emissions should have been calculated for the busiest intersections and then potential for a contribution from aircraft emis- sions at these sites should have been evaluated to ensure that the in- crease in emissions could not be large enough .to produce local concen- trations of carbon monoxide of potential medical concern for sensitive receptors such as persons with heart trouble. 1. 25. IS p. 2, Item 5.b). This item is checked "negligible impact" on the basis of IS Documentation pp. 33-53. Page 27 of the IS Documentation states that "as a result of noise abatement piloting procedures, all of these air- craft (being used at Buchanan Field) can be, and are being, flown at substan- tially reduced sound levels." No measurements are supplied to substantiate this assertion. t 26. IS p. 2, Item 6.c). This item references the Safety Report, Section II. Safety Report, p. II-50, Paragraph 4.A. states: "Recommendations and guidelines promulgated by industry associations and committees do not pre- empt [F.A.R.] Part 139 C/F/R requirements and are generally advisory in nature. This statement is acceptable where Part 139 C/F/R requirements are stricter than other accepted standards, but in this case it results in fire protection below that generally ac ec pted as good practice. The voluntary concensus standards of the National Fire Protection Associa- tion (NFPA) are derived by consultation between representatives of various L._ interests in the fire protection community. These standards are respected na-tionally as reasonable and are frequently incorporated into local codes. Please note that Appendix B of the IS Documentation references several NFPA l„ standards. • ( Buchanan Field Comments Page s sx NFPA 403 covers Recommended Practice for Aircraft Rescue and Fire Fighting Services at Airports and Heliports. The latest edition was adopted in 1978, and the committee reponsible for its preparation included commercial air- line, military, airport, fire department and various other representatives. A nonvoting, FAA representative also served on the committee. Any community accepting responsiblity for airport fire protection which fails to meet NFPA 403 should be aware that they are settling for something below concen- sus standards. Section 1-4 of NFPA 403 defines "Conventional Airports" as all airports except those completely unattended and exclusively for the private use by the owner thereof or temporarily established to serve operations conducted with complete cognition of the total lack of ground support protection. Table 1A of NFPA 403 establishes Airport Indices based on overall length of aircraft. The BAe-146 aircraft proposed by PSA would categorize Buchanan Field Airport as Index 5. Subsequent comments on fire safety will be confined to Buchanan Field's f compliance with NFPA standards for Conventional Index 5 Airports. l� Table 1B of NFPA 403 requires availability of 2,000 gallons of water on the f apparatus, when using AFFF [Aqueous Film Forming Foam], and a discharge 1 . rate of 1,065 gallons per minute. Table II-22 of the Safety Study, p. II-49, shows that present equipment provides less than one quarter of these requirements and, even after .the additional C/F./R vehicle projected on p. II-50 of the Safety Study is acquired, there wou:l.d _still be less than half • the NFPA-recommended water available. Section 4-1.1 of NFPA 403 states that Major Fire Fighting Vehicles should comply with Part B of NFPA 414, Standard for Aircraft Rescue and Fire Fighting Vehicles, and Section 4-1.2 states: i "It is desirable to have more than one such vehicle available to facilitate attacking aircraft fires from more than one point or quarter, as an aid to expedite rescue, to reduce the potential seriousness of a vehicle breakdown and to minimize the "out of service" consequences when a vehicle is in need ' of repair. This applies particularly to the protection at conventional airports in Indexes 5 through 8 (see Table 1A. .." NFPA 414 Part B specifies in considerable detail the structural and func- tional requirements for the vehicles, and the Safety Report gives us no information that can be compared to these standards, except for the above ( related fact that the water tanks are inadequate. L_ Assistance from Pacheco Station 9 and Concord Station 6 may be relied upon to cover the Buchanan Airport apparatus deficiences in case of an anticipa- ted emergency landing. In the abse ce of advance notice, however, Mutual Aid would be of little value, since a "survivable crash" may be survivable only for the time that occupants can hold their breath once plastic inte- riors start to burn or smolder. When nitrogen-containing plastics burn, they give off hydrogen cyanide gas in amounts which have caused death after infi aiation of a single breath in some aircraft fires. Other toxic gases given off when plastic aircraft interiors and parts burn include hydro- chloric acid vapor, benzene, acrolein, vinyl chloride, and varftus other l IBuchanan Field Comments Page seven chemicals which cause difficulty f culty in breathing and tearing of the eyes. John Mulhall , Mayor of Pleasant Hill and an experienced local fire fighter, I indicated in a telephone conversation on 10 April 1986 that response times to an incident on the field would be significantly greater than stated in the 1983 EIR. This may be due to increased traffic and additional develop- ment since that time. Table 7, IS Documentation p. 73, indicates that some intersections leading to the Airport are now at Level of Service (LOS) F during rush hour and p. 80 indicates that more intersections will operate at LOS F in 1988 with anticipated development. LOS is defined in Appendix 1 D by numerical volume to capacity ranges used by traffic engineers to determine LOSs. Verbal descriptions to assist the reader in understanding what these LOSS mean are not given. The definition of LOS F currently being used in EIRs by the City and County of San Francisco is as follows: "Level of Service F represents a jammed condition. Backups from locations downstream or on the cross street may restrict or prevent movement of vehi- cles out of the approach under consideration. Hence, volumes of vehicles passing through the intersection vary from signal cycle to signal cycle. Because of the jammed condition, this volume would be less than capacity." I..:.. Capacity occurs at LOS E, which represents the greatest number of vehicles that an intersection can accommodate. "At capacity there may be long queues of vehicles waiting up-stream of the intersection and vehicles may be delayed up to several signal cycles." If both directions of traffic are at LOS E or F it may b y e difficult for emergency vehicles to get through the intersection. Should an aircraft crash .during rush hour, how long would it take emergency vehicles to negotiate a series of LOS F intersec- tions to arrive at the scene of the fire? A complete environmental analy- sis Y sis requires discussion of this issue. Of course, Stations 9 and 6 are not dedicated to Buchanan Field service, and their fire fighter companies may be at other incidents when needed. We must distinguish between, what is legal and what is reasonably safe. We I encounter disasters in situations where everyone follows the letter of the law, because the law did not allow an adequate safety factor for the impon- derable or for just plain bad luck. L. It is, therefore, unfortunate that Buchanan Field can meet the substandard F.A.R. Part 139 only by using an annual average to stay under five (5) departures per day and thus be subject to a laxer standard. The Safety Study has nothing to say about Airport fire fighter qualifica- tions. This subject is covered in NFPA 1003. Among other knowledge, tho- rough familiarity with all aircraft using the airport is required. Who would be responsible for providing Buchanan Field personnel with this knowledge? We are also given no information about existing or proposed fuel servicing facilities or practices. This subject is covered in NEPA 407. Deficien- cies in this area can result in severe hazards. The nature of these ha- zards cannot be evaluated by the reader in the absence of trTformation. The I�S=Documentation states on p. 7 that "Major aircraft and vehicle mainte- nance will not be performed except in emergencies, and in any event, not on the lease site. " What minor maintenance will be performed, in;m;�ving what l Buchanan Field Comments Page eight toxic or flammable materials? -How often' is i t expected that emergency major maintenance will be necessary? The standards of the National Fire Protection Association constitute the generally recognized yardstick for good fire protection. If the neighbors of Buchanan Field are to have confidence in emergency preparedness for scheduled air service at Buchanan, compliance with all relevant NFPA stan- dards should be a minimum. Pen-nits should specify who is responsible for implementation of which standards by what time. Provision for continuous compliance, such as the prompt training of new personnel , need to be en- sured. Annual certification by a California-registered Fire Protection Engineer that all NFPA standards have been met could serve to this end and should be considered as a mitigation measure. Please note that several fire protection engineering firms have branches in Central Contra Costa County. Page 2 of the Executive Summary of the Safety Report (unnumbered page) states that "The Airport Advisory Committee and Airport Management are up- dating existing procedures and regulations for stronger enforcement of air- port safety matters." This suggests that lack of adequate enforcement of safety procedures is known and it would be useful to know the specific nature of these inadequacies which should be included in environmental evaluation of this project. 27. Safety Reeort Executive Summary 3 (unnumbered page). Item 10 states: "F.A.hanagement staff and ATC not defined, air traffic con- `trpllers?) specialists offer no evidence that scheduled service has a negative impact on airport safety in any area. Conversely, scheduled air service was noted to promote airport safety through strengthened security, improved airport equipment and staffing, more frequent in- spections, and maintenance or IFR proficiency for air traffic control- lers." In reviewing New York Times News Service coverage of the accident at San Diego involving a PSA aircraft and a small private aircraft in which 150 persons died, we find that there is not unanimity on the safety of a mix of scheduled and private aircraft. On 26 September 1978, John J. O'Donnell , president of the Air Line Pilots Asso- ciation, told the wire service that "recent experience of airline pilots has shown that the danger of aerial collisions is greatest near airports where there is a mix of airline transports flying under control from the ground and other aircraft that frequently fly without such control ." He is quoted as stating that "The airline aircraft and the uncontrolled ones come close together near the airport. It is there, during approach and landing and during takeoff and climbout, that the workload of the airline flight crew is at its peak. Thus, the pilots have little time t5spend looking out the window for other aircraft and, therefore, would benefit greatly from having effective CAS (collision avoidance system) in the cockpit." The next day, the New York Times News Service stated _t1fa—t "air safety specialists in the National Transportation Safety Board and elsewhere have warned that the danger of mixing such traffic (large scheduled aircraft and small , private aircraft) was growing and some--Wave urged ( , Buchanan Field Comments Page nine that the private planes be prohibited_from the same airspace that is occupied by the commercial jets. However, an influential lobby of private .plane owners and small plane manufacturers have resisted such limitations, frequently allied with powerful congressmen who are pilots." On 27 September 1978, Ed Slattery of the National Transportation SafetyBoard (NTSB) was quoted as saying that the possibility of col- lisions q 9 between commercial and private aircraft is "an area of increas- ing concern to the board." He cited instances of near-collisions of commercial and private aircraft. It seems unlikely that these concerns have been entirely dealt with since 1978 and we feel that current NTSB publications and staff and the Air Line Pilots Association should be consulted to obtain a ba- lanced picture of the hazards of mixing commercial and private air- craft and methods of mitigating such hazards. It is not clear that the present Safety Report represents an unbiased sampling of current opinion. Where there is a difference of professional opinion an envi- ronmental document cannot be restricted to covering one side of the 1:. issue. 28. Safety Report p. I-14. The last sentence states "In follow-up corres- pondence, F.A.A. identified several items for corrective action, i .e. , dirt compaction, repainting, etc. This brief reference, without any explanation of the context or significance of the required actions, •s.eems designed t.o make. F.A.A. concerns appear trivial . The entire text of the F.A.A. correspondence should have been included in an appendix or additional information should have been given about all F.A.A. concerns and the reasons therefor so that the reader could make _. an informed judgement about the importance of the F.A.A. concerns. 29. Safety Report p. I-19. The last sentence indicates that written con- firmation of F.A.A. approval of the Part 107 Security Program is ex- pected. Will this written approval be required before initiation of PSA service? The reader cannot judge the effectiveness of this mitiga- tion measure without knowledge of when it would be effective. l._ 30. Safety Report p. II-2. It is stated that accident records for Antioch, Concord and Martinez were obtained from the F.A.A/NTSB computer. The Martinez data are not given. 31. Safety Study p. II-3. It is stated that recent accidents and "open cam are not included in the computerized accident records, but the most recent year of complete records is not identified so that there is no way for the reader to know which of the accident statistics dis- cussed are complete. 32. Safety Study, Table II-1, unnumbered pages following p. II-3. The '-Type of Event' column uses the symbols I and A which are not defined in the table or the text. From the text discwtsed the reader may guess that they refer to accidents and incidents, but there is no way to confirm the correctness of this guess. Other undefined terms include "VFR," "IFR," and "CFI." It is normal practice Wefine all ( Buchanan Field Comments Page ten I - abbreviations and acronyms used 'in tables in environmental documents I even if they have been previously defined. I 33. Safety Study, Table II-2, unnumbered page before p. II-4. This table shows that runways 19R, 1R and 32R had the highest total accidents and incidents in the 1980 - 1985 period (6, 5 and 5, respectively). Two of these three runways, 19R and 32R, would be used by PSA for 90 to 95% of their flights. Is the accident/incident rate higher for these run- ways because of more frequent use or other known factors? This table cannot be understood in the absence of appropriate explanation until the reader deduces that the numbers in the table represent the inci- dent nci-dent numbers from Table II-1. The continual effort to figure out unex- plained material in figures and tables makes this report slow reading and makes it difficult for the reader to follow the discussion. 34. Safety Study p. II-4. Paragraph 1 states that there has been a "steady ( increase in accidents at Buchanan Field between 1980 and 1985. This IT'.. has occurred despite a decrease in p flights through the airport. No reasons are proposed for this increase and no predictions as to future f trends are made with or without PSA flights, so the reader is left with I.= questions which the environmental evaluation should answer or explain why they cannot be answered. i._ 35. Safety Study Table II-3, unnumbered page following p. II-4. In order to .be useful , the accident totals need to be converted to rates. Using the information about total -flights from the IS Documentation p. 25, it can :be :determined that .there were no accidents in 340,000 flights in 1980, .about 1 accident per 100,000 flights in 1981-1982, about 1 accident per 75,000 flights in 1983, and 1 accident per 60,000 flights in 1984 and 1985. This information could be graphed and used to pre- dict future possible increases in accident rate. If this increase is statistically significant one would think that an attempt would be made to determine the reasons for it and to reverse the trend. It �. would appear reasonable for the environmental evaluation to discuss whether this situation could be corrected before increasing the number of flights. 36. Safety Study p. II-5. The information about Antioch cannot be meaning- fully—compared eaning- ful ycompared to Buchanan Field in the absence of information about the total number of flights and types of aircraft involved at Antioch. 37. Safety Study p. II-6. It is stated that the 81% rate of accidents related to pilot error at Buchanan Field is "generally consistent with a 1981 study by the N.T.S.B." Do NTSB data show any change since 1981? Are these data broken down for different types of airports? One might expect a higher rate of pilot error at airports with many student pilots. Are separate rates —ailable for such airports? Additional information would help the reader to interpret the meaning of the given statistics. l_ 38. Safety Study p. II-7, Item 10. What would constitute-I'-basis for re- stricting scheduled air service from Buchanan Field? In the absence of criteria for such restriccions it is difficult for the reader to judge the appropriateness of Item 10. An environmental study sherd contain i_ Buchanan Field Comments • Page eleven enough information for the reader to make meaningful judgements. 39. Safety Study p. II-9. In 11 3 it is stated that training activity at Buchanan Field has declined more rapidly. than predicted by the Master Plan Study. If training activity has declined, then flights by inex- perienced pilots could be expected to. have declined. The reader is left f wondering why the accident rate is going up and whether any decision on the proposed project can be fairly made in the absence of this infor- mation. 40. Safety Study Figure II-2, Aircraft Operations for 1981 - 1985, unnum- ered page following p. II-11. This figure should have been combined with Figure II-1 in order to facilitate comparison of predicted and 1 observed operations. 41. Safety Study p. II-16. The 1911 Master Plan Study is used in Item D and previously in t is section as a basis for identification of the busiest time at the airport. Recent data should have been used to confirm that the nine-year-old study is still applicable. It is normal environmental document practice not to use data more than five years old without presentation of evidence that conditions have not changed and the information is still relevant. Where conditions are changing rapidly, the use of data more than two years old is often not accepted. 42. Safety Study Table II-14, unnumbered pages before p. II-18. This table indicates that in :the period 1980-1985 Buchanan Field had the second highest accident rate of the five airports rated. The text only states that between 1980-and 1982 1 t, "was among the lowest of all five" (p. II-17) and then increased. Thi"s does not give the reader ( who does not consult tables an accurate picture of the relative accident t rate at Buchanan Field. 43. Safety Study p. I1-18. The recent increase in the Buchanan Field acci- dent rate is again stated without attempt to explain it or extrapolate into the future. 44. Safety Study p. I1-20. There is no indication as to whether the Air- port Manager has ever exercized his power to evict from the airport for noncompliance with safety rules. The reader cannot judge the use- fullness of this mitigation measure without knowing if this has ever l _ been done and, if yes, at what frequency and has there been a recent change in frequency? 45. Safety Study p. 11-21. Item e) refers to "difficulties encountered by Airport management when attempting to enforce" safety regulations at Buchanan Field but does not state what these difficulties have been so the reader cannot judge ttffimportance of these difficulties. Re- ference to measures to "prevent repeated disregard for safety regula- tions" suggests that such disregard has occurred. If there has been repeated disregard for safety regulations, why is this not discussed in the report? Safety at Buchanan Field cannot be -trv'aluated in the absence of such information. l : . fBuchanan Field Comments Page twelve 46. Safety Study p. II-23. Planning of 'a- program to enforce regulations prohibiting use of alcohol or other drugs by Buchanan Field pilots (Item C) suggests that pilot drug use is taking place. What is the ( evidence for this and why is this not discussed in the report? The reader is led to wonder whether drug use is related to recent increases in the accident rate but cannot find the answer to this question in f the Safety Study. 47. Safety Study Figures II-5 and II-6 on unnumbered pages prior to p. II- 27. These figures cannot be interpreted in the absence of I explana-- t�—on. 48. Safety Table II-17 on unnumbered page prior to . II-28. Again, a legend for abbreviations and symbols is needed in order for the rea- der to understand the information given. ( 49. Safety Study . II-28. There is a reference to airspeed in "knots" on t�- the next to the ast ine of this page. Now I finally understand that the unidentified abbreviation that has repeatedly appeared on tables previously in this report refers to knots. The expression "very simi- lar" in 11 2 is a subjective judgement whose meaning varies from person to person. It would have been appropriate to cite specific numbers and percentage differences to allow the reader to make a judgement of I _ degree of similarity. 50.: Safety Study p. II-32. It is inappropriate to use 1972 - 1976 accident ( data without ;establishing that conditions have not: changed and the information is still relevant to current decision-makiig;. Language such as "impressive...capabilities" (11 2) implies bias and is inappro- priate for an environmental document. 51. Safety Study p. II-39. The Introduction states that safety was discus- sed -with the administration of five airports to find out whether sche- duled airline operations had a significant effect on airport safety. The criteria used to establish significance are not stated. There is no indication that pilots were consulted as to their perception of safety conditions. A cross-section of opinion about safety conditions would have assisted the reader in judging the safety conditions at Buchanan Field. ( 52. Safety Stud II-41. Table II-21 compares activities, facilities and procedures at Buc anan Field to those of four other airports with lower 1985 annual aircraft operations (14% to 83% less) and longer runways (longest runway 40% to 96% longer). It is not clear why these particular airports were chosen for comparison and use of some airports with more annual traffic than Buchanan Field and runways of similar or shorter length would have impf*ved the value of the comparison. 53. Safety Study p. II-46. Item H states: -"Several Tower Chiefs indicated that airport utilization by a scheduled .air carrier promoted safety..." This is an exaggeration. Page II-42 says that the Buchman Field Tower (thief says that scheduled flights "may" have some positive safety ef- fects; page II-44 says that the Lake Tahoe Tower Chief "suggested" (. that scheduled air carrier operations "probably" enhancedfety; p. 1 - Buchanan Field Comments Page thirteen 11-45 says that the Monterey' Tower- Chief said they have "probably" been beneficial and the Redding Tower Chief said that mixed operations have not affected safety; and the Fresno Tower Chief (p. 11-43) says that scheduled air service has not had "any adverse effect on airport sa- fety." The consensus seems to be that scheduled carriers may (or may not) promote safety. 54. Safety Study p. 11-54. If the information about F.A.A. safety concerns is quoted from correspondence, then quotation marks should have been used. If it is paraphrased, as suggested by the absence of quotation marks, then the full text of this safety correspondence or direct quotes therefrom should have been used to assure the reader that F.A.A. concerns are adequately reflected. 55. Safety Study p . 111-6 to 111-8. As previously indicated, the use of d—ata more than five years old, such as the 1964 - 1972 accident records is inappropriate in an environmental document unless the applicability of the data is specifically established. 56. Safety Study P. 111-13. 1 note that accident statistics are given for 96 - period and for the 41972_- _ the 1 1980 - 1985 period and are not given for the 1975 - 1979 period which includes the multi-casualty PSA acci- dent in 1978. 57. IS p. 3, Item 7.b). This item is checked as "negligible impact." In view of the inadequacies of fire protection discussed in Comment 22 of this report, the potential impact is not negligible. 58. IS p., 3, Item 8.a) . This item is checked "negligible impact" on the basis of the discussion in the IS Background Report. P. 57 of the IS Background states in t 4 that "Neither the peak hour or peak day traffic associated with the PSA project could be expected to have a significant effect on street or intersection capacity in this area. The significance of a change in traffic depends on the traffic conditions exisiting before implementation of a proposed project. If traffic is flowing smoothly, a traffic increase of one to three percent is insignificant; but if, as in this case, traffic is already at or beyond the carrying capacity of portions of the roadway, with Levels of Service (LOS) of E or F, then any increase whatsoever will furthen worsen the situation and can constitute a signifi- cant impact. The next paragraph (t 5) on this page states that the impacts will be mitigated by "significant improvements to John Glenn Drive and Concord Avenue at the Airport," but Table 10 in the 1983 Draft EIR indi- cates that in 1988 many intersections are still expected to be at LOS E and F. I also note that the analyses in the 1983 EIR and the IS Documentation do not cover traffic north of Buchanan Field and it is possible that, in case of a major accident, Mutual Aid vehicles would attempt to approach the In any case, it is not airport on roadways which have not'Meen analyzed. clear why there is no intersection analysis of traffic in the entire area surrounding the airport from which passengers may be drawn (intersection study area shown in 1983 EIR Figure 18, p. 64). IBuchanan Field Comments . Page fourteen 59. 1983 Draft EIR p. 81. Paragraph 5 states that even with implementa- tion of the recommended mitigation measures for Concord Avenue, "fur- ther mitigation to improve levels of service will need to take the form of one or more parallel arterial streets such as Galaxy Way." This indicates that traffic impacts cannot be mitigated to an accept- able level and that any further traffic increase will produce a sig- nificant environmental impact. In the 1983 Draft EIR traffic analysis the use of a 10% overall traffic growth rate in addition to estimates of traffic from projects in the planning and permitting stage was discarded. In view of present concerns about traffic congestion in I_. the project area, this may not prove to have been an appropriate ro riate worst case analysis, and the future traffic congestion may be greater than predicted. 60. IS p. 3, Item 12. The proposed project is stated to have no impact on growth induction based on IS Documentation pp. 62-64. The first 9 of IS Documentation p. 62, Growth Inducing Impacts, says that the project would "not set a precedent for such use at the Airport," but 1 3 says that "The institution of PSA services to Los Angeles from Buchanan Field may ( result in additional requests from other airlines to offer similar sche- duled passenger service..." This is a clear recognition of a potential growthinducing effect which has to be evaluated. Until the Airport Access Plan is completed and adopted, there is no evidence that further growth in air service is precluded. An action taken now cannot rely on uncertain future mitigation to avoid discussion of growth-inducing and cumulative impacts. In turn, the availability of increased scheduled air service at Buchanan Field could induce .additional office growth in an .area already C' impacted b development. No .evidence is resented in the 1983 Y P P Draft EIR or the IS that no other air carrier could build air passenger terminal facilities at the airport and use aircraft similar in size to those pro- posed by PSA. In view of the above comments, we do not see how all the "Mandatory Findings of Significance" could have been checked "no." The project does appear to "have the potential to degrade the quality of the environment"; the poten- tial to achieve short-term economic and environmental goals of increased activity at Buchanan Field and decreased length of airport vehicle trips "to the disadvantage of long-term, environmental goals" because of increased traffic congestion and growth-inducing impacts; to have potential cumula- tive impacts which have not been analyzed; and to have environmental im- pacts which could "cause substantial adverse effects on human beings" because of inadequate fire protection, poor fire vehicle access during rush hours, and possible excess carbon monoxide at crowded intersections. The available environmental documentation is not neutral in its coverage, inadequately explains technical issues, contains many unsupported asser- tions, and is generally inappropri re for implementation of CEQA. t . Buchanan Field Comments .Page fifteen [ We recommend that an environmental imp-act _re be written for the Port �EIR) proposed PSA service at Buchanan Field and that it be written by a profes- sional EIR consultant familiar with the standards of neutrality and docu- mentation appropriate for such a document. Very truly yours, [ . ASelina Bendix, Ph.D. President / l�I Gi 1 bertA. Bends x,6P.E. Vice President f SB:sb l l._ i . RESUME: SELINA BENDIX EDUCATION: B.S. Chemistry, UCLA 1951; Ph.D. Zoology, UC Berkeley, 1957. EXPERIENCE: President, Bendix Environmental Research, Inc. Environmental and toxicological consultants. EIR prime consultant for housing, office, port, energy, wastewater and master plan projects. EIR adequacy analysis, editing and expediting service for EIRs for high-rise office buildings, downtown hotels, mixed-use developments -and wastewater projects. Initial studies for housing, energy, wastewater and industrial projects. EIR continuing education lecturer (1980 - present). Environmental Review Officer, administrator of the Office of Environmental Re- view of the City and County of San Francisco. Author, editor or commentor on nearly 100 EIR/Ss on: San Francisco's multi-billion dollar Wastewater Master Plan, housing developments, offshore oil , high-rise office buildings, hotels, ,water facilities; author of first Block Grant EIS (used as a model by the Pre- sident's Council on Environmental Quality ECEQ] and the Nat'l . Assoc. of Housing and Redevelopment Officials). City representative on environmental matters to CEQ-, State Attorney General 's Office, etc. 1974 - 1980. Managing Partner, ..- Bendi x Research- Environmental Consultants: EIRs (second home ;devel cpmentin Mendocino Co., etc.) review of EIRs . and, EISs; expert testimony in court on EIS adequacy; regulatory analyses, toxic substances control . policy. 1969 - 1980. Lecturer in Biology, Mills College, Oakland; research on freshwater algae, 1965 - 1969. Asst. Prof. Biology, San Francisco State Univ. , 1964-65. Environ- mental science and mathematicseducation consultant, 1959-68. Biological research,,' 'Lab. of Comparative Biology, Kaiser Foundation Research Inst., Rich- mond, 1957-64. Chemical textbook writing assistant to Dr. Linus Pauling, 1949. ADVISORY COMMITTEE MEMBERSHIPS: League of Women Voters Solid Waste Task Force, 1982; CA Hazardous Wastes Technology Assessment Advisory Committee, 1981; EPA Administrator's Toxic Substances Advisory Committee, 1977 - 1982; CA Attorney General 's Taskforce on Environmental Problems of the San Francisco Bay Area, 1972-78; 208 Technical Advisory Committee, Assoc. of Bay Area Governments, 1977. REPRESENTATIVE PUBLICATIONS: "How to Write a Socially Useful EIS,," in Hart, S. L. at al ., Improving Impact Assessment, Westview Press, 1984; "Dealing with Municipal and Hazardous Wastes," League of Women Voters of Berkeley, 1983; "Hazardous Materials and Environmental Documents," Environmental Impact Assess- ment Review, 1982; "A Short Introduction to the California Environmental Quality Act," Santa Clara Law Review, 1979; "Format and Guidelines for Preparing an Environmental Impact Report," San Francisco Department of City Planning (DCP), 1979; co-editor "Environmental Assessment: Approach.i-lLg. Maturity," Ann Arbor Science, 1978; Richmond/Sunset Water Pollution Control Plant Improvements EIR-,-DCP, 1976. 2/86 I RESUME: GILBERT G. BENDIX I EDUCATION: B.M.E. College of the City of New York - 1948 CALIFORNIA` ENGINEERING REGISTRATION: Mechanical M 11204 1956 Civil C 14787 1964 Fire Protection FPE 00028 1975 IEXPERIENCE: Principal Engineer, Bendix Environmental Research, Inc. , 1984 to present. Responsible for supervision and review of all engineering work performed by .the firm and its subconsultants. Manager, Suburban Operations, San Francisco Water Department, 1977 to 1984. Administrator of Water Department facilities in San Mateo, Santa Clara and Alameda Counties; responsible for an operating budget of over $8 million and I over 1OU employees involved in the operation and maintenance of 5 major reser- voirs, numerous aqueducts and 3 pumping stations, as well as valve lots, rights of way, and 60,000 acres of watershed. Superintendent of Bureau of Engineering and Water Supply, San Francisco Fire Department, 1968 to 1977. Responsible for planning, operation and maintenance of all water supply facilities of San Francisco Fire Department, including a I separate water distribution system serving approximately one third of San Francisco, with tanks, pump stations, piping and fire hydrants as well as 150 underground water storage cisterns; responsible for all engineering work of I the San Francisco - Fire : Department,: including~ code development, review of plans of major projects for adequacy of fire protection facilities, and advice to the Chief of Department and the Fire Marshal on any problems requiring engineering input. I Various Engineering positions with the Department of Public Works Het ch ch Hetchy Water and Power, Water Department and Utilities Engineering Bureau, I all of the City and County of San Francisco, 1950 to 1967. Work included hydroelectric developments, mechanical systems of buildings, water supply and sewage treatment facilities, and traffic engineering. I Junior Stress Analyst, Glenn L. Martin Co. , Baltimore, MD, 1948 to 1949. ( ' AUXILIARY ACTIVITIES: Member, San Francisco Fire Department Hazardous Materi- als Advisory Committee, 1980 to 1985. Chairperson, Joint Symposium of Society of Fire Protection Engineers, American Society of Safety Engineers and SRI International on Fire and Safety Hazards in the Semiconductor Industry, Menlo I Park, CA, November 1981. Member, City of Berkeley Solid Waste Management Commission and its Hazardous Waste Subcommittee, 1983 & 1984; Commission President, 1984. PROFESSIONAL MEMBERSHIPS: Member, Society of Fire Protection Engineers ; Past President, No. California - Nevada Chapter. Member, American Water Works Association. l t\ G. WILSON, IHRIG & ASSOCIATES, INC. f ACOUSTICAL CONSULTANTS 5776 BROADWAY OAKLAND, CA U.S.A. 94618 f (415) 658-6719 I 3 April 1986 Mr. Dennis A. Lee City Attorney City of Pleasant Hill 3300 N. Main Street f Pleasant Hill, CA 94523 Subject: Review of Report Titled: "Documentation For Initial Study of Proposed PSA Scheduled Air Service and Lease at Buchanan Field Airport" , March 10 , 1986 by McClintock, Becker & Associates Dear Mr. Lee: As requested , I have reviewed the details of the subject report, I referred :.to as the "Documentation" report,. regarding the proposed introduction of scheduled air carrier operations at Buchanan Field in Concord. In particular, the acoustical analysis or noise portions of the report have been reviewed to evaluate additional information and the assessments presented as compared with the previQus acoustical analysis report of October 30 , 1985 by Mestre Greve Associates, Inc. and for evaluation of the basis for the findings presented. Regarding noise, the "Documentation" report primarily addresses 1 and refers to the October 30 , 1985 Mestre Greve Associates report, including discussion of the details presented in that report and reproducing a number of the figures and tables to generally describe the expected noise exposures and noise impacts. There is - some additional information, discussion and analysis presented which responds to the comments in my 3 February 1986 review of the Mestre Greve Associates report. Also some technical points were clarified. However the additional information is very limited and is not sufficient to fully address the issues and is not sufficient to constitute a full and comprehensive study of the existing and expected noise environment and potential noise impacts. EXHIBIT 8 • WILSON, IHRIG &ASSOCIATES, INC. . . l - . 2 - Buchanan Fld Documentation Rept Review- In summary, the "Documentation" report presents some new information and discussion in an effort to be a more complete study and to include some of the points which should be addressed. However, the information presented is of such limited and incomplete nature that it does not. significantly improve the situation over the original acoustical analysis report. As indicated in my letter of 3 February, the acoustical analysis report relies primarily on computer models, statistical analysis I and use of long term averages to show that adding a small number of operations of a relatively "quiet" jet aircraft to an existing large number of aircraft operations creates only a small effect on ff long term exposures. This type of analysis and presentation can l. be misleading because, by its very nature, it requires a very large number of new or additional aircraft operations before any significant change in the noise exposure level numbers or the noise exposure level contours will occur. In order to be a full study, properly addressing noise issues important to the community, a full environmental study is needed with considerable additional information and clarification to provide a full basis for evaluation of the expected effects on the surrounding area of the noises related to commercial jet aircraft operations at Buchanan Field and, in particular , the effects on residents of the City of Pleasant Hill. As previously indicated, a complete study should include: 1 . Surveys of existing noise exposure levels. and typical maximum noise levels at representative residential and school sites around the airport. 2 . Presentation of typical or representative maximum noise levels for both existing and proposed aircraft in addition to calculated and measured noise exposure levels. I3 . Determination of noise from ground operations of the proposed t commercial aircraft. 4 . Determination of noise effects from street and highway traffic generated by the commercial aircraft operations. 5 . Presentation of simplified data and clearly understandable comparisons to assist non-technical people in interpreting and evaluating the information presented. The "Documentation" report does provide some additional information responding to some of the above points and some discussion clarifying technical questions raised. The following paragraphs indicate discussion relative to the above outlined considerations. 1 , . WILSON, IHRIG &ASSOCIATES, INC. . -- 3 Buchanan Fld Documentation Rept Review 1 . The "Documentation" report indicates that during the day of the demonstration flights, 17 October 1985 , and subsequently on 25 February and 3 March 1986, some "ambient" noise measurement surveys were conducted in the vicinity of the airport, using the same measurement locations as used for the PSA aircraft flight demonstration. Table 17 presents the "ambient" noise levels at three of the five locations used for measurements during the demonstration flights. The data presented are for the "ambient" noise derived from averaging a I number of different measurement samples taken at different time periods throughout the day, with noise from airport activities excluded. There is no indication of the length of �. the noise samples, nor the time of day at which they were obtained. i The survey data for existing noise are very limited in scope I,. because there is no indication of the length of the noise sample, the time of day of the sample and because it excludes noise from the airport activities. The intention apparently was to indicate the existing "ambient" sound levels with tabulation of the highest non-aircraft noise events. { Presentation of the maximum noise levels from typical existing I , aircraft events would have made the presentation much more useful and helpful in evaluating the potential effects of noise from the proposed PSA flights. LAnother consideration in .this regard is that the report indicates (page 72) that in 1979 a portable noise monitoring computer was purchased and deployed as part of the airport noise abatement plan. Neither the original acoustic analysis report nor the "Documentation" report includes any data on noise levels or noise contours obtained with this device. I 2 . The "Documentation" report ep t does include additional data, Table 18 , presenting the maximum noise levels measured during the BAe-146 demonstration flights at four of the measurement locations. The noise levels tabulated indicate a wide range of maximum sound levels with typical maximums of 70 to 81 dBA at three of the locations. Unfortunately, the added information on existing ambient noise did not include sound levels for existing aircraft to enable making a direct comparison of the BAe-146 aircraft with current existing aircraft operations. The report indicates (page 41) that when comparing aircraft noise levels with other noise sources such as automobiles, the maximum noise level value is more appropriate than the Single Event Level, an exposure level . However, this is not followed up with presentation of useful comparisons. The reader is left with the vague statement that the maximum levels are approximately 5 to 10 dBA less than the SEL levels shown in 1 the exhibits. 1 ' WILSON, IHRIG &ASSOCIATES, INC. 4 Buchanan Fld Documentation Rept Review I _ 3 . The "Documentation" report does not directly address the question of noise from ground operations for the proposed commercial aircraft except to mention that the BAe-146 airplane does not use thrust reversers. Therefore there will not be any noise from the thrust reversal operation during landing, as is typical of other types or jet aircraft which do use thrust reversers. There is no mention or estimate or evaluation of noise expected from taxiing operations or ground run-up operations for the PSA aircraft. 4 . The "Documentation" report does address the projected vehicular traffic to be generated by and associated with the proposed PSA passenger operations. The estimates of added traffic on off-airport streets and roadways is such that the projected peak day vehicle trips are not be sufficient to create a significant increase in off-airport vehicular noise levels , either from a single event or cumulative noise impact standpoint. Review of the details presented in the section on I transportation and circulation indicates a 10-17% increase on t John Glenn Drive and less than 5% on other nearby streets or highways. Such increases in traffic volume will not cause a significant increase in noise levels or noise exposure due to the vehicular traffic. 5 . As indicated above, the "Documentation" report does present fsome simplified data which could be of assistance in ; t developing understandable comparisons to aid in evaluation of the noise levels for the BAe-146 aircraft compared to- other, existing noises in the community. However the data presented ;s is very limited and does not include any directly measured data for existing aircraft operations in and around the ai-r-port or over the Pleasant Hill residential areas. Further the data is of very limited scope consisting of statistical and energy equivalent noise levels at three residential locations and BAe-146 aircraft noise levels at four locations. There is no indication in the report of why all five locations used for measurements of the demonstration flights were not included in the "ambient" noise and PSA aircraft maximum noise data presented nor of the time of day or type of events occurring during the survey periods. Another of the issues which is of considerable significance with regard to the proposed PSA flights is the establishment of an "Airport Access Plan" . The "Documentation" report presents a discussion on the limited need in the immediate future for an Airport Access Plan in the section on Growth Inducing Impacts. It is indicated that an Airport Access Plan is needed and that the County can establish performance standards which would severely limit the range of potential air carriers who could meet the standards. However, because of the lease terms an&physical limitations, the need for a Plan is minimal for up to two years-,. l__ I WILSON, IHRIG &ASSOCIATES, INC. - 5 Buchanan Fld Documentation Rept Review It is suggested that an Airport Access Plan usually works in conjunction with a Noise Control Plan containing several aircraft noise abatement measures, but the only definite recommendation given is that an Airport Access Plan should be developed along with a noise compatibility program. In contrast in the section on Mitigation of Environmental Effects, where it is concluded there are no significant growth-inducing impacts, it is stated that an airport Access Plan is necessary to ensure this remains the case. This section presents a detailed list of the anticipated elements needed in the Plan, along with discussion of need for tailoring to avoid discrimination issues . Because of the uncertainties associated with achieving an acceptable Plan, it is necessary either before or simultaneously with establishing initial service by any airline, that an Airport Access Plan be completed and in place and that it contain provisions defining (1) the noise characteristics of air traffic to be considered acceptable or qualified, (2) the I number of flights per day to be permitted for future expansion and 1. (,3) a Noise Control Plan indicating required aircraft operational procedures for noise mitigation, including ground operations. The "Documentation" report does address, at considerable length, the aircraftof n se abatement measures and the airport noise abatement measures now in effect.. It is apparent from the extensive list of measures now in effect (pages 70 ; .71 and 72) that noise has been and is of major concern for Buchanan Field operations. The fact that so many types and degrees of noise abatement measures are applied to aircraft and airport operations [ : indicates that noise is a major consideration and is a major environmental impact related to the Buchanan Field operations. Thus a -change of the magnitude represented by the proposed PSA operations, i.e. , addition of commercial jet aircraft operations, does represent a change which is of significant potential impact which should be recognized and evaluated by a full and complete environmental study. As an overall evaluation, it cannot be concluded from the ` information presented in the "Documentation" report and its l appendix (the acoustical analysis report) that the proposed project does not have the potential to degrade the quality of the environment or curtail the diversity in the environment. Further it does not support the conclusion that the proposed project does - not have environmental impacts which will cause adverse impacts on human beings. The noise information is simply too limited and incomplete to support these conclusions. The noise survey data for existing conditions is very limited - three locations and with no data for existing aircraft operations. The proposed aircraft operations maximum noise level data is very limited and there is f no data for existing operations to permit direct comparisons. There is no information on noise from ground operations. The i._ WILSON IHRIG &ASSOCIATES, INC. • SOC 6 Buchanan Fld Documentation Rept Review Documentation report has not included any additional discussion, review or analysis of various criteria for acceptability of the aircraft noise and their applicability to Buchanan Field operations and the surrounding communities. The street and highway traffic increases expected appear to have been adequately determined and potential noise effects addressed. 1 • The conclusions from this review of the "Documentation" report are essentially the same as for the review of the original acoustical [ analysis report. The indication is that there is still need for a full environmental impact study for the proposed PSA operations. Such a study should include: 1. Appropriate and fully documented on-site noise surveys in the area around and near Buchanan Field. 2 . Assessment of existing and proposed aircraft operation noise both in terms of noise exposure level and maximum noise levels with direct comparisons of typical existing maximum noise I levels with the proposed aircraft maximum noise at representative residential locations. 3 . Assessment of noise from ground operations of the proposed commercial aircraft. 4 . - Review and discussion of the significance of various criteria for acceptability of the aircraft noise .in residential land use areas and establishment of criteria appropriate to the Buchanan Field situation and responsive to the surrounding ` communities. Finally, it is important that an Airport Access Plan and a noise control plan or noise compatibility plan be established and in place before any commercial service is started , and consideration of such Plans must be part of any environmental review and evaluation because of the potential effects on future environmental conditions. Very truly yours, WILSON, IHRIG & ASSOCIATES, INC. Georg aul Wilson, Ph.D. 1_ l_ , WILSON, IHRIG & ASSOCIATES, INC. (f ACOUSTICAL CONSULTANTS 5776 BROADWAY OAKLAND, CA U.S.A. 94618 (415) 658-6719 ( 3 February 1986 Mr. Dennis A. Lee City Attorney City of Pleasant Hill 3300 N. Main Street Pleasant Hill, California 94523 Subject: Review of Report Titled "Acoustical Analysis of the Introduction of Schedule BAe-146 Operations" , October 30, 1985 by Mestre Greve Associates, Inc. ( Dear Mr. Lee: As requested, I have reviewed. .the details of the subject report I _ relative to the proposed introduction. of_ scheduled air car-ri.er ` operations at Buchanan Field -in Coftcord.: -S ecificall , the report addresses the proposal by PSA to operate five daily flights at Buchanan Field using the BAe-146 commercial jet airplane. Based on the analyses presented, the Mestre Greve Associates report- concludes that the proposed PSA operations will cause very little or no added noise impact in the areas around Buchanan Field. Further , the report indicates that total noise exposure levels, with the proposed PSA operations, will be in compliance with federal and state criteria for acceptable noise exposure from aircraft and that there will be only a small increase in the area of residential land use where the noise exposure will exceed the ( local jurisdiction criterion level for outdoor noise exposure. l: All of the estimates of noise exposure levels given in the Report are based on computer models using idealized flight tracks and f noise signatures for departing and arriving aircraft. All of the calculated noise exposure levels are based on annual averages with no indication of the effects of short or long term variations in runway usage or daily operations volume, variations which can and �.- do occur due to weather and usage patterns. No on-site surveys of the existing noise in the communities around the airport were made I to determine the actual existing maximum noise levels and noise l exposure levels due to aircraft and other noise sources. While a EXHIBIT B a I i WILSON, IHRIG &ASSOCIATES, INC. 2 Buchanan Field Report Review 1 some on-site noise measurements were made at the time of the f demonstration flights, only limited, incomplete information from 1 the measurements is presented in the Mestre Greve Associates report. In addition to the above points regarding take off and landing noise and existing community noise exposure levels, the report does not address noise impact due to ground operations of the commercial aircraft nor does it address the noise impact of street and highway traffic generated by the passengers who will use the proposed commercial flights. Also, the report is technical in nature and does not present easily understood comparisons allowing the non-technical reader to interpret and evaluate the information presented. Further, there are some technical inconsistencies within the report which should be addressed. Ir. In summary, the report relies primarily on computer models, s, statistical analyses and use of long term averages to show that adding a small number of operations of a relatively "quiet" jet aircraft to an existing large number of aircraft operations creates only a small effect on long term noise exposures. Such a conclusion can be derived without a detailed analysis and does not provide information which is useful or readily understandable in determining the potential effects on the community.. In fact, such a study and presentation can be misleading and considerable clarification and additional information are needed to provide a basis for full evaluation of the expected effects :of the noises related to commercial jet aircraft operations at Buchanan Field. L . A complete study should include: 1. - Surveys of existing noise exposure levels and typical maximum noise levels at representative residential and school sites around the airport. 2. Presentation of typical or representative maximum noise levels for both existing and proposed aircraft in addition to calculated and measured noise exposure levels. 3 . Determination of noise from ground operations of the proposed commercial aircraft. 4. Determination of noise effects from street and highway traffic generated by the commercial aircraft operations. 5. Presentation of simplified data and clearly understandable comparisons to assist non-technical people in interpreting and evaluating the information presented. The following paragraphs present detailed review comments for consideration regarding the Mestre Greve Associates Report. 0 WILSON, IHRIG &ASSOCIATES, INC. 3 Buchanan Field Report Review I - f 1.0 BACKGROUND 1 The noise definitions and assessment criteria sections present clear and correct discussions of the various measurement scales or metrics used in describing and/or measuring noise and of the f assessment criteria. An important point to be gleaned from the presentation is that there are two basic types of metric: (1) noise level or sound level - the actual or instantaneous level which we perceive as an event happens - and (2) noise exposure level or sound exposure level - an average of sound level over some time period, either for a single flyover event or for a long time period. Throughout the report the term noise level (or sound level) is used in referring to noise exposure level and can lead to some confusion. In most cases, because of the emphasis in the analysis on noise exposure levels, the quantity under discussion is an exposure level of some type, not a noise level, and as such the interpretation must be based on comparing with other similar noise exposure levels, not with a comparative noise level tabulation such as Exhibit A-1. f' The point is made, on page 2 in the section on single event noise metrics, that the highest noise level reached during a flyover is called the "Maximum Noise Level" or Lmax• This is followed by "It Iis this mpt.ric to which people instantaneously respond when an aircraft flyover occurs. " This is true and a very important point. However throughout the remainder of the report the Maximum Level is not discussed and no data are presented on Maximum Levels from either the BAe-146 or other aircraft. Even in the section on the demonstration flights - where it is pointed out that the instruments used "calculate" both the sound exposure level and the I maximum noise levels for any aircraft flyover - there are no data or information on the maximum levels observed, only exposure levels which are a combination of noise level and time. 1 Presenting maximum noise levels would provide information rmation on the direct measure of the noise experienced during flyovers and would allow readers to make direct comparisons with other every day experiences regarding noise. Presenting both maximum levels and typical time durations would further assist in understanding the information. In the discussion on noise metrics, the report points out that the public reaction to different noise levels varies from community to [ community. It is also important to know that the response to different types of noise varies within a community. Thus, care must be used in applying an overall metric such as Ldn or CNEL to La specific community noise, such as aircraft noise. The 60 CNEL noise exposure level, used by Contrz, Costa County and the cities WILSON, IHRIG&ASSOCIATES, INC. - 4 Buchanan Field Report Review around Buchanan Field to assess compatibility of residential land use, addresses mainly the relatively steady noise from street and I highway traffic. The highly varying noise from aircraft flyovers, quiet most of the time with short duration high sound levels, at the same 60 CNEL exposure level may not produce the same community f reaction. A number of studies have so indicated. Thus, it is important that other metrics, such as maximum level, be included ( to promote full understanding of the proposed service effects. 2.0 AIRCRAFT NOISE LEVELS The section on aircraft noise levels presents a chart, Exhibit 2, showing relative single event noise exposure levels for various aircraft. There is no indication of distance or altitude and no indication of whether the noise is sideline or overhead. Thus, it is difficult to know if the comparisons are valid for operations at Buchanan Field. The exposure levels given by Exhibit 2 may be certification levels which are developed from a very specific type of operation that may not be applicable to compare the BAe-146 levels with other aircraft at Buchanan Field. In fact, the report c . indicates that the noise level data for the BAe-146 and other "comparative" aircraft were obtained .from the noise monitoring logs for the San Jose International and John Wayne Airports, with the indication these are identical planes and pilots that would . .serve Buchanan ..Field. Since .this last statement can only apply to the BAe-146, itis not clear that the comparisons are applicable I to Buchanan Field operations. t_ A set of comparisons much more useful than the somewhat indefinite data of Exhibit 2 would be maximum levels at typical locations along- tracks from Runways 32R and 19R for both sideline and direct overhead noise. Such data would be obtained as part of noise survey results, for existing operations, had noise surveys been done. 1 The noise contours shown by Exhibits 3 and 4 in the report are based on calculations using a computer model. Necessarily, the computer model uses idealized tracks for the aircraft, based on standard aircraft noise and performance data adjusted to fit Buchanan Field. Even at best this is an approximation which should be verified and adjusted with on-site noise surveys. As pointed out in the report (pg. 14) each pilot operates an aircraft in a different manner in terms of flight track and operational procedures. Therefore, while the computer model probably presents a reasonable approximation of noise exposure levels due to operations at Buchanan Field, actual sound survey measurements would provide much greater confidence in the existing condition noise exposure contours and, hence, the calculated incremental l effect of adding the proposed PSA operations. T 1.` WILSON, IHRIG &ASSOCIATES, INC. '5 Buchanan Field Report Review f The major point of the airport noise exposure level contour presentation is to show the small effect of adding five flights per day (10 operations) of the BAe-146 aircraft. When it is considered that these 10 additional operations. are averaged with 687 other daily operations, it is not surprising that the effect is found to be small. This is particularly true using the base single event exposure levels which indicate the BAe-146 to be g comparable with some existing aircraft and lower than some business jets. Because adding the five flights per day proposed has a small effect on the overall statistics, the indicated change in annual average CNEL is small, 0.0 to 0.2 dB. This is then compared with the Federal Guidelines which indicate an increase of noise exposure level of 1. 5 dB or greater to be significant. It is instructive to work the problem in reverse and estimate the number of commercial flights which would be required to cause an increase of 1.5 dB in the noise exposure levels. Since the computer models and programs were not available for this review, two generalized scenarios were calculated by hand to determine approximate numbers of flights of commercial jets which would be needed to increase typical noise exposure levels by 1.5 dB. Both scenarios were considered for a location such as Site #1 (Diablo Valley College) with all flights using the runway oriented in that direction. The first scenario was. with the effects of the noisy business jets taken as. "nom.-Mally given by Exhibit 2 and using the total operations distribution as given by Table A-1. The result was that about 40 BAe-146 flights (80 operations) per f, day or two Boeing 737-200 (the noisier older type of 737) flights per day would be needed to increase noise exposure levels by _ 1.5 dB: For the second scenario a more severe effect of the noisier e business jets, as given by Exhibit 5 in the report, was assumed. With that type of assumption for the existing conditions (as is emphasized in the report) the result was that about 140 BAe-146 flights per day or about five Boeing 737-200 flights per day would be needed to increase the noise exposure levels by about 1.5 dB. It is apparent that adding 40 to 140 flights per day of the proposed commercial jet airplane would create a substantial impact on areas around and near Buchanan Field, not just a "significant" effect. This result shows that using the Federal Guidelines for evaluating the change which would constitute a "significant" impact is not appropriate for Buchanan Field. The report indicates on Page 8 that PSA bas estimated the Runway 32R can be utilized 95% of the time for BAe-146 departures, f with only 5% using 19R which routes planes over the residential area to the south. However, on Page 20 in the discussion on the t., ( WILSON, IHRIG &ASSOCIATES, INC. . ._. 6 Buchanan Field Report Review flight demonstration, the figures are changed and the indication i is estimated 10% usage of Runway 19R to the south. Further on I Page 8, as is well known, the final determination of departing runway is determined by the pilot in command, and safety must be a primary- consideration over noise abatement. The conclusion must ( be that there will be time when all the departures will be to the south, over Diablo Valley College and Pleasant Hill residential areas. At such times the daily noise exposure level will be significantly greater than that based on an annual average assuming only 5% of the flights depart to the south. 3.0 AIRPORT ACCESS PLANS This section discusses only airport access plan provisions as they may affect future increases in commercial aircraft usage of Buchanan Field. There is no discussion of access by passengers , and personnel and the impacts associated with the associated street and highway vehicular traffic. Regarding the aircraft access, four major points are indicated as f common and appropriate for such plans: 1. Aircraft qualifications regarding noise, II 2 . Number of .flights permitted, 3. Allocation to airlines of qualified flights, and 1`T 4 . A noise control plan regarding aircraft noise abatement procedures. Of these four, #1, #2 and #4 are of utmost importance in formulating any plan for establishing commercial passenger service at Buchanan Field. Item #3, allocation to airlines, is an administrative control not significant in noise effect. Either before or simultaneously with establishing initial service by any airlines, a plan should be established defining: - The noise characteristics of aircraft to be considered acceptable or qualified, - The number of flights per day to be permitted for future j expansion, and - A noise control plan indicating required aircraft f operational procedures for noise mitigation, including ground operations. ( WILSON, IHRIG &ASSOCIATES, INC. 7 Buchanan Field Report Review I _ CONCLUSIONS The conclusions from this review of the acoustical analysis report by Mestre Greve Associates are: f1. The information on aircraft noise levels as presented is limited and may be misleading because of the reliance on computer models and the lack of on-site noise surveys, because of the emphasis on noise exposure levels and long-term averages, and because of the lack of any information on maximum noise levels at representative locations for typical existing and proposed new operations at Buchanan Field. 2. The Federal Guidelines for assessing the significance of added noise are inappropriate for evaluating the situation at Buchanan Field where a large number of general aviation operations already exist and a small number of commercial jet operations are proposed. Under the Federal Guidelines an unrealistically large number of commercial jet operations, or the use of very noisy conventional jet airplanes, would be required before the type of analysis presented would show a f "significant" impact. L 3. The State and Federal Guidelines . for maximum acceptable noise exposure level for residential land use, 65 CNEL and 65 Ldn' respectively, are inappropriate because Contra Costa County has established a lower level, 60 CNEL, as the desired criterion level for outdoor noise exposure levels for residential land use. 4 . The local jurisdiction criterion of 60 CNEL should be applied with care and in conjunction with other criteria, such as maximum noise level, since the CNEL criterion is primarily based on the more prevalent types of community noise, traffic noise, and the community reaction to aircraft type noise may be different - requiring a different criterion level. The impending environmental impact study for the proposed PSA operations should include and address a number of factors regarding noise and noise criteria which are not included in the Mestre Greve Acoustical Analysis Report: 1. On-site noise surveys in the area around and near Buchanan fField. 2 Assessment of existing and proposed .aircraft operation noise both in terms of noise exposure level and maximum noise levels. l 1 t (( WILSON, IHRIG &ASSOCIATES, INC. _ .8 Buchanan Field Report Review i ' 3. Review and discussion of the significance of various criteria for acceptability of the aircraft noise in residential land use areas and establishment of criteria appropriate to the Buchanan Field situation and responsive to the surrounding communities. 4 . Assessment of noise from ground operations of the proposed commercial aircraft. 5. Assessment of noise impacts of street and highway traffic generated by the proposed aircraft operations. Please let me know any questions or if further analysis or clarifications are needed. Very truly yours, ff WILSON, IHRIG & ASSOCIATES, INC. I: Geor Paul Wilson, Ph.D. WILSON, IHRIG & ASSOCIATES, INC. f ACOUSTICAL CONSULTANTS 5776 BROADWAY OAKLAND, CA U.S.A. 94618 (415) 658-6719 C 16 April 1986 I � Mr. Dennis A. Lee City Attorney City of Pleasant Hill 3300 N. Main Street Pleasant Hill, California 94523 fT Subject: Review of Draft Environmental Impact Report, Buchanan Field Airport General Plan Amendment, f, June 1983 and Response to Comments , Sept. 1983 fDear Mr. Lee: In accordance with your request I have now reviewed the Draft Environment Impact Report, along with the Comments and Response to I .' Comments , which were prepared for the Buchanan Report General Plan Amendment in 1983 . The objective of the review was to determine if there are any details which affect or supplement the comments f presented in my reports of 3 February 1986 and 3 April 1986 , respectively, on the "Acoustical Analysis" report dated 30 October 1985 -and the "Documentation" report for the Proposed PSA Scheduled Air Service. The Draft EIR related to changes in the Airport Layout Plan for Buchanan Field Airport and an Amendment to the Contra Costa County General Plan for the Airport and for changing the land use designation of some immediately adjacent parcels. As such , the EIR presented an analysis of the various expected environmental impacts and proposed mitigation measures , including a noise analysis based on a report developed by Mestre Greves Associates, Inc. , the same firm that developed the acoustical analysis for reports regarding the proposed PSA scheduled air service. The Draft EIR also presents very extensive analysis of the street and highway traffic situation with recommended mitigation measures and with detailed planning and recommendations for changes in the street system. However , there is very little noise analysis associated with the street traffic environmental study. EXHIBIT 8 ,s ( WILSON, IHRIG &ASSOCIATES, INC. 2 Buchanan Field Draft EIR, 1983 I The basic methodology used for the noise assessment at Buchanan Field for the Draft EIR was the same as for the acoustical analysis ( of the proposed PSA operations. That is, the expected noise exposure levels and the airport noise contours were generated using a computer program developed to plot aircraft noise contours around airports. The results are presented in terms of Community Noise Equivalent Level, CNEL, which is the annual average for the noise . exposure level. As stated previously, this is a 24-hour averaging type of measure that does not specifically address the sound levels of individual events but averages all events over a long time period, with the appropriate penalties for evening and nighttime periods. As for the PSA operations study, the computer program was ( provided with the data specific to Buchanan Field regarding departure profiles, approach parameters and aircraft noise data for the specific type of aircraft and flight tracks used at Buchanan Field. However, at best, the noise contours which result are idealized and may not be specific to the Buchanan Field situation because the methods of operation by the individual pilots may not follow the idealized computer program noise model. For the Draft EIR the existing street and highway noise levels were also determined by computation with a computer program using a Highway Noise Model published by the Federal Highway Administration. This model uses traffic volumes, vehicle mix, speed, time distribution and roadway geometry to compute the CNEL noise exposure level . Again, this is 'a somewhat idealized means � '. for obtaining noise exposure levels in. the- community and should be supplemented with noise measurements at the site. The Draft EIR does differ from the original PSA acoustical analysis report and from the "Documentation" report in that there is indication that the noise contours for existing conditions at Buchanan Field were compared with noise measurement data taken at a number of sites around the airport, including two sites in Pleasant Hill. Each of the monitoring locations included a minimum of five days of continuous measurements, which is an appropriate way to determine noise exposure levels in the community. However, as for the "Documentation" report, the actual information presented is extremely limited. In fact, only one location was reported in the I report. That location was a residential area stated to be exposed to the highest noise levels, an area north northeast of the airport. At this location the noise exposure level was predicted to be just under 65 CNEL and it is reported that a seven-day noise measurement survey at this location also indicated an average noise exposure level just under 65 CNEL. It certainly would have been helpful if such data was presented at the "number of sites around the airport" where the existing noise levels were measured so that they could have been compared with the noise contours generated on a theoretical basis. I:- WQSON, IHRIG &ASSOCIATES, INC. 3 Buchanan Field Draft EIR, 1983 The Draft EIR does point out on Page 55 and in Appendix C, Section C .2 .1.3 that in assessing the impacts from general aviation airports such as Buchanan Field, it is appropriate and helpful to include ,in the evaluation the maximum noise levels, LmaxF that occur during aircraft flyovers. This is true because general I aviation airports tend to have more random flight tracks and occasional very loud single aircraft that may result in annoyance or speech interference. It is also pointed out that because these fhappen on relatively few occasions they have minimum influence on the annual average CNEL noise exposure level . That is the 24-hour averages do not account for maximum noise levels that may occur around the general aviation airport as a result of aircraft operations. Because they happen rarely, these single noise events have only a minimal influence. on the annual average CNEL noise level and " . . .their impacts on residents are underestimated." This point in the Draft EIR is similar to that outlined in my letters of 3 February and 3 April regarding the PSA operations acoustical analysis reports and emphasizes the importance of including other types of noise metric in the overall analysis. However, again, in the Draft EIR, these statements are made, but followed up with only very minimal information on maximum noise levels from aircraft presented and no analysis and comparisons. The Draft EIR addresses this point with only one paragraph of discussion of measured levels in Pleasant Hill and of sideline noise Levels for business jets and helicopters. Thus-,: there is no detailed ana ysis or data and there are no comparisons presented which would be useful in determining the potential effect on the community. The Draft EIR does present an analysis of the existing noise contours for Buchanan Field based on 1981 operations with I . determination of the expected contours in 1990 with and without the proposed precision landing system and for the year 2000 with the proposed precision landing system and the proposed changes in the airport layout plan. All of the contours are very similar in shape and size with the main result presented being a small decrease in the size of the contours or decrease in the area of the land exposed to specific levels of noise exposure. This decrease is based on the finding outlined in the report that with the number of aircraft increasing, the type of aircraft expected will be quieter than the current population resulting in decreased overall noise exposure. It is interesting to note that the Draft EIR bases the noise exposure levels on 301,081 annual operations in 1981 and expected l 366,000 in 1990 and 412 ,000 in the year 2000 . The report states that the normal annual growth rate for aircraft operations is 2%. The Acoustical Analysis for the PSA operations an the "Documentation" report both base the noise exposure level analysis 1.: 1 ( WILSON, IHRIG &ASSOCIATES, INC. 4 Buchanan Field Draft EIR, 1983 1 and the noise contours on a total number of annual operations in ( 1985 of 250,730. This is a considerably decreased number of I operationscompared to that indicated in the Draft EIR and would be expected to indicate some reduction in noise levels compared to those indicated in the Draft EIR. Comparison of the noise contours in the "Documentation" report and the PSA Operations Acoustical Analysis Report indicate that they ( are essentially the same as those presented in the Draft EIR for I the 1990 and year 2000 airport related CNEL noise contours, to within the accuracy that noise contours can be presented from the INM computer model. The point of this comparison is, again, to show that relatively large variations in the analysis base show essentially no change when compared on a noise exposure level basis, e.g. , in terms of CNEL. One of the points noted in the Draft EIR is that, while the noise contours are presented for existing traffic conditions and noise contours for the combined traffic noise and aircraft-related noise are presented for existing conditions for 1983 , the report includes no projections for .traffic noise in the future condition with the increased traffic and changes in the roadways proposed as part of L the General Plan Amendment. Considering the large amount of ` analysis and discussion on the traffic and the depth -of detail Y presented on the traffic volumes expected and the rearrangements of streets and intersections which would be required, it. is unusual that the Draft EIR did not include any projections regarding the expected future noise levels from the traffic. �.' In the comments and responses .to the Draft EIR there are no comments or questions regarding the aircraft related noise analysis. The only question with regard to noise was from the Contra Costa County Public Works Department. That question was a request to be sure that the increased noise due to traffic and development on all roads, particularly Marsh and Center Avenues, is adequately covered. As noted in the comment, the Draft EIR did not address that issue. The comment also requested that the EIR consider the automobile noise separately from aircraft noise because the County' s initial investigation indicated the effect of future traffic would be significant. The response indicated that there would be development located within the 60 CNEL noise contour and concluded with no further discussion other than that the exact definition of the 60 CNEL would vary based on vegetation present and presence of any existing noise barriers. Thus, the Draft EIR and response to comments accompanying the EIR basically did not address the effect of future traffic volumes on the noise exposure levels in the area around Buchanan Field due to the effects of the proposed General Plan Amendments. c_ ( WILSON, IHRIG &ASSOCIATES, INC. 5 Buchanan Field Draft EIR, 1983 I While the above discussion regarding the lack of attention to traffic noise effects in the Draft EIR does not have direct application to the situation and questions regarding the effects of the proposed PSA operations, it does indicate the general approach that seems to be used in evaluating noise impacts related to f changes at the Buchanan Field facility. The "Documentation" report does address the effect of traffic increases expected due only to ( the proposed PSA operations. l A significant point made in the Draft EIR relative to the effects of changes in the Airport operations on the noise levels, is a point made in comparing the noise contours with and without the project addressed by the Draft EIR. The comparison, presented in Section 2 .2 of Appendix C , indicates that the results show the noise levels around the Airport will increase by approximately 0.2 decibels. It is stated that this increase in the noise levels is not significant. Further, it is stated that "It generally takes a 3 decibel increase in an environmental noise level to be considered significant. This is the .limit of detection of a change in 1 _ environmental noise level that can be heard by the human ear." It further goes on to say that the main amount of the 0 .2 dB increase is due to a 10% increase in the number of business jets and large multi-engine aircraft and that the operational levels of that type of aircraft would have to increase by approximately 2-1/2 times in order to result in a 3 decibel increase in the noise exposure level at Pleasant :Aill. These comparisons and conclusions emphasize the fact that the type of analysis presented for the proposed PSA operations can be misleading in attempting to evaluate the 'impact involved. l _ 1. Change in Noise Level The assertion that a change in noise exposure level of 0.2 dB C is insignificant and that a 3 dB increase is required to be considered significant can be very misleading. This is a generalization of the normal finding that a constant noise level requires a change of 2 or 3 decibels before the change is noticeable. There have been a large number of tests on the subjective evaluation of noise which showed that, under controlled conditions, when presented with small changes in sound level for a constant sound or same type of sound, a change of 2 or 3 decibels is required before subjects are aware that the sound level has increased. This cannot be generalized to be applied to varying level environmental noise in the community. The implication of this type of generalization is that it requires a doubling of traffic or a doubling of the L number of aircraft flyovers before anyone would notice the difference. It is certainly apparent that changes in traffic volume or aircraft flyover volume less than a factor of 2 would be noticeable in the community. WILSON, IHRIG &ASSOCIATES, INC. 6 Buchanan Field Draft EIR, 1983 I 2 . This analysis and the point that the operational levels of the business jets and large multi-engine craft would have to increase by approximately 2-1/2 times to result in a significant increase in noise exposure levels in Pleasant Hill emphasizes the fact that this methodology of evaluation assures ( that the addition of five daily flights of the BAe-146 commercial jet airplane would not show any effect on the noise exposure levels or the noise contours when evaluated in terms ( of CNEL. Only through presentation of maximum sound levels for l typical aircraft and for the BAe-146 aircraft would it be possible to make meaningful comparisons and evaluate potential impact. As previously stated (3 February 1986 letter) , a large number of added jet aircraft operations is required before a significant change in CNEL results and this is, in fact, addressed in the Draft EIR. f. A final point with regard to the Draft EIR is the comparison of total number of annual operations indicated for the future. In Section 2 .2 .3 of Appendix C it is indicated that the CNEL noise contours for the year 2000 are presented based on 412 ,000 annual operations. These contours are essentially the same size and shape as those presented in the "Documentation" report for the proposed situation with 250,730 annual operations in 1985 , including the proposed PSA operations. Two conclusions can be drawn from this comparison. One. is that the comparison shows the extremely low sensitivity or effect of number of .flights on the calculated noise exposure level. The second is that an increase from 250,730 operations in 1985 to the predicted 412 ,000 in the year 2000 will ` result in significant increase in noise impact on the community, even without the PSA oPerations, unless very significant improvement is made in the noise emitted by the aircraft using Buchanan Field. Very truly yours, WILSON, IHRIG & ASSOCIATES, INC. GeorPaul Wilson Ph.D. h. I_ M SUPPLEMENTAL RESPONSES TO COMMENTS ON THE PROPOSED PSA SCHEDULED AIR SERVICE AND LEASE AT BUCHANAN FIELD PREPARED BY CONTRA COSTA COUNTY AND MC CLINTOCK, BECKER & ASSOCIATES AND FLIGHT SAFETY INSTITUTE April 21, 1986 • 1 Y INTRODUCTION This supplemental report has been prepared in direct response to voluminous written comments submitted to Contra Costa County at the close of the 30-day period established by the Board of Supervisors for public and agency review of the proposed PSA scheduled air service and lease at Buchanan Field , and its supporting documentation . This report continues the written response to comments section ( Chapter III ) of the "Responses to Comments on the Proposed PSA Scheduled Air Service and Lease at Buchanan Field" report , submitted to the Board of Supervisors on April 18, 1986 . It is important to note that in responding to any relevant comments received , the County has gone beyond the letter and i'ntent of CEQA to provide a discussion of the factual evidence supporting its (the County ' s ) decision to prepare a preliminary negative declaration on the proposed project . To quote an "authorative" source on the preparation of environmental review documents , " ( T) he most common mistake made in connection with environmental review is calling it the ' EIR Process . ' All projects subject to environmental review do not require EIRs1 . " Based on staff and consultant review of the initial study and all previously submitted supporting technical documentation, public and agency comments , and the following information from Zach Cowan , esq . , and the City of Pleasant Hill ( including Exhibits A and B) , it may be concluded that there is no substantial evidence that the proposed project will have a significant effect on the environment . i 1"Environmental Review Information For Project Sponsors , " Selina Bendix , Ph . D. (July 16, 1979, Rev . Feb . 7 , 1985) , Pg . 1 . CHAPTER III (continued) This chapter continues the responses to written comments received by the County during the public review period on the proposed PSA project and supporting documentation reports . Because much of the material in the attached comments have either been addressed in Chapters I and II of the "Responses to Comments On the Proposed PSA Scheduled Air Service and Lease at Buchanan Field " document or are unrelated or not germane to the proposed project , responses have been directed only at those comments deemed relevant . III-26 Zach Cowan Attorney At Law 66 MINT STREET SAN FRANCISCO, CALIFORNIA 94103 14151 543-2627 Jim cutler Department of CcmTunity Development P.O. Box 951 Martinez, CA 94553 April 17, 1986 Re: Negative Declaration on proposed lease with PSA to allow BAe-146 commercial jets to use Buchanan Field Dear Mr. Cutler, We represent Citizens for Responsible Use of Buchanan Field (CRUBF) on matters pertaining to the proposed lease with PSA to allow ccmmercial flights to and from Los Angeles. The true dimensions of the project dwarf the project presented :In the County's "environmental documentation," and the actual project represents a precedent-setting policy decision which will cause an enormous range of serious environmental impacts. Consideration of the project is also prema- ture because of the lack of an access plan for Buchanan Field, which is necessary in order to mitigate the effects of certification as an air car- rier airport. CRUBF therefore objects to the introduction of the proposed PSA service and certification of Buchanan Field as an air carrier airport, in the ab- sence of adequate and legally mandated environmental analysis (in the form of an environmental impact report [ETR] ) and mitigation measures, and prior to the preparation of a noise ccmpatibility program and access plan pur- suant to!FAR Part 150. This letter incorporates by reference the following materials in the record of proceedings in this matter: December 5, 1985 Letter from City of Pleasant Hill, with exhibits December 6, 1985 Letter frcm Zach Cowan January 2, 1986 Letter from Zach Cowan February 3, 1986 "Review of. . . 'Acoustical Analysis. . . "' by Wilson, Ihrig & Associates February 4, 1986 Letter from Zach Cowan March 31, 1986 Testimony presented at public hearing before Aviation Advisory Committee April 7, 1986 Testimony presented at public hearing before Aviation Advisory Cbm-nittee April 16, 1986 Letter from City of Pleasant Hill, with exhibits Page 1 111- 27 Inadequate Project Description The project before the County consists of certification of Buchanan Field as an air carrier airport, and the introduction of ccmercial air service necessitating such certification. The potential impacts of these actions cannot be predicted on the basis of any previous air service, in- cluding WestAir, since no previous air service required such certification., The project is a ccmnittTent to a magnitude of potential operations greater than any prior operations, and allows airport improvements which can sustain even greater numbers of operations, including: a) a new terminal facility of indeterminate size (between 2,505 and 3,550 square feet; at least double the size of the existing facility); b) upgrading CER vehicles to meet FAR Part 139 requirements; and c) possible addition of automobile parking. In this respect it is vital to note that the FAA has proposed a codifi- cation of its policy towards local control over airport access and capacity. 51 Fed.Reg. 2985, January 22, 1986. Among many other significant provisions, this policy states that capacity will be determined solely by reference to "airside capacity," and not by reference to "landside capacity," which may not be used as a basis for arbitrarily denying access to potential users. Moreover, future grant assurance may reflect the responsibility of local proprietors to provide sufficient landside facilities. It is also significant to note that even if the capacity of landside facilities at Buchanan Field could be used to limit access to potential users, the theoretical capacity to which staff has on occasion made refer- ence would not pose an obstacle to extreme increases in air carrier service. For instance, the landside facilities at John Wayne Airport for a decade acccmrK)dated over ten times their "capacity. The project therefore opens the door for future commercial air service of unknown proportions. The County's response to date has been that an access plan will be prepared, which, based on the County's proprietary control over Buchanan Field, will prevent further significant increases of air carrier service. (It is, curious that the County has repeatedly denied such control in its defense of claims arising from the Sun Valley crash. ) Putting aside serious reservations about the accuracy of this statement (in light of FAA policy), and that it has never been supported except by asser- tion, it assumes the existence, content, and effectiveness of a problematic document that has yet to be drafted. This is neither logical nor permissible from the standpoint of environmental analysis. The California Environmental Quality Act. (CEQA) requires that an EIR be prepared if a project has the potential to cause significant environmental impacts. The County has recognized that this project may have such impacts, but argues that the access plan will prevent those impacts. This simply does not wash. Without an effective access plan before certification as an air carrier ariport and introduction of PSA service, the County's fundamental analytical assumption is untenable. Page 2 111-28 moreover, the County has failed to address the question of need for the project. It appears (at least to PSA) that there is demand for service to Los Angeles. But the question of how much demand, and whether it would force future expansions (even regardless of an access plan) is left unexplored. Likewise, the question of need is ignored. With Oakland Airport readily accessible and operating at far below its capacity, is there really any need to expand Buchanan Field to caTpete with it? And finally, even if an access plan existedf it is doubtful that it would necessarily have the effect claimed. A recent FAA decision ordered San Francisco International Airport to accept aircraft that exceeded the noise cap (100 dbA) set by its access plan, even though they were significantly louder than other aircraft using the airport. In short, in order to comply with CEQA, the project description must include the full number of operations of BAe-146 type air-craft that could be accmnodated at Buchanan Field under the FAA's policies. This it con- spicuously fails to do. It is therefore inadequate and may not form the basis for approval of the project. Inadequate Impact Analysis Absent an adequate project description, every potential project impact is either understated or ignored. These include impacts on traffic, noise, air quality, growth induction, safety and land use, among others. These impacts are inadequately analyzed in any case, as detailed in the most recent letter from the City of Pleasant Hill, and the exhibits thereto, which have been incorporated in this letter. By way of overview, however, the following flaws are particularly egregious. a) There are no empirical acoustical data for Buchanan Field and its environs. Also, there is no indication whether the BAe-146s will always be flying partially (85%) loaded and/or fueled, or whether this will be a condition of the lease. b) There is no analysis of cumulative air quality and traffic impacts, and there is no list of other projects which contri- bute to cumulative impacts. There is thus no way to determine whether such impacts will occur. c) Growth inducing impacts are ignored, largely on the basis of what remains a phantom access plan. There is no consideration of what new businesses may be drawn to the area as a result of the project. There is no analysis of the housing needs of new employees resulting both directly and indirectly frau the pro- ject. There is no consideration of what other airlines have BAe-146s or comparable aircraft (or what other aircraft are comparable) and may wish to use Buchanan Field, no considera- tion of the possibility or likelihood of further expansion of landside facilities (for which the potential exists), and no consideration of the possibility or extent of potential runway or taxiway expansion. Page 3 111-29 In addition, the County's reliance on the 1983 EIR on the "Buchanan Field Master Plan," which served as the basis for approving WestAir service, is unjustified, as explained in my February 4, 1986 letter. Consequently, the documents circulated by the County improperly and unjustifiably lack any discussion or recognition of the significant unavoid- able adverse impacts of the project. This defect is epitomized by the County's failure to admit even that there is the potential for a significant unavoidable impact on safety. Even granting, for the sake of argument, the assertion that emergency response plans are adequate, it is absurd to con- tend that introduction of a whole new class of planes of the size of BAe- 146s has no potential to have an adverse impact on safety. In sum, evidence submitted by CRUBF, the City of Pleasant Hill and the public, common sense, and recent events, all conclusively demonstrate the potential for (if not certainty of) serious adverse impacts from the certi- fication of Buchanan Field as an air carrier airport and the introduction of PSA service. An EIR is therefore required. Moreover, the "environmental analysis" prepared for the County is so flawed and misdirected that it fails to provide substantial evidence to support the proposed finding that the project has no potential to result in significant adverse impacts on the environment. A negative declaration therefore cannot be adopted. Lack of Mitigation Measures As a result of the analytical defects in the disclosure and analysis of the environmental impacts of the project, those impacts are not mitigated, contrary to the fundamental requirement of CEQA. Such mitigation would include, at a minimum: a) Preparation and adoption (after FAA review and approval) of an access plan and noise compatibility program prior to certifica- tion and PSA service. These plans would mitigate to some extent the full range of project impacts, particularly noise, safety, and growth inducing impacts. b) Traffic mitigation measures, including appropriately phased road and intersection improvements financed by the commercial users of the airport, and measures to permit transit access to the airport. c) Acquisition of required and advisable CFR equipment prior to PSA service. Inconsistency with Governmental Plans As set forth in my letter of January 2, 1986, certification and intro- duction of PSA service at Buchanan Field is inconsistent with the Regional Airport Plan. The excerpts of that plan quoted by the County do not lessen or avoid this inconsistency-- the test is not whether the project is consis- tent with some parts of.the Regional Airport Plan, but whether it is incon- sistent with any part of it. Asalconsequence the impacts of the project on regional air traffic and safety are ignored. Page 4 111-30 In addition, as stated in my January 2, 1986 letter, the proposed PSA service would violate the Noise Element of the County General Plan (1975). The County has completely ignored this fact. An EIR would normally be required in order to address ways to mitigate these inconsistencies. An EIR is particularly needed in this case, since the County may not approve a project which is inconsistent with its General Plan. Conclusion It is tempting to rail against both the project and the process as an insult to the public, but this course of action is unlikely to bear fruit. Rather CRUBF urges the County to look before it leaps and-- for once-- take a hard look at what it proposes to do and the risks to which it proposes to subject the people who live and work near Buchanan Field. Very truly yours, Zach Cowan, Attorney Terry Watt, Urban Planner by: Zach Cowan Page 5 , III-31 y • J Response to letter of Zach Cowan , Attorney at Law, 66 Mint Street, San Francisco, CA (April 17, 1986) Mr . Cowan ' s introductory paragraphs express the objections and concerns of the Citizens for Responsible Use of Buchanan Field over the proposed PSA project . The letter also incorporates references to certain material in the record of proceedings in the matter at hand . These materials are hereby acknowledged and the County ' s previous responses are similarly incorporated into the record by reference . Response to " Inadequate Project Description", Page 2. Mr . Cowan clearly misstates the project at hand . The project is as set forth in Page 1 through 23 of the " Documentation For Initial Study of Proposed PSA Scheduled Air Service and Lease at Buchanan Field . " (March 10, 1986) . As noted in the "Documentation" report , Buchanan Field is , and has been , certified as an air carrier airport under Part 139 of the Federal Aviation Regulations (FAR Part 139) . Note that the title of FAR Part 139 is "Certifi - cation and Operations : Land Airports Serving CAB-Certificated Schedules Air Carriers Operating Large Aircraft ( Other than Helicopters ) . Mr . Cowan states that the "project is a commitment to a magnitude of potential operations greater than any prior operations , and allows airport improvements which can sustain even greater numbers of operations including : a. A new terminal of indeterminate size . . . b . Upgrading CFR vehicles to meet FAR Part 139 requirements ; and C . Possible addition of automobile parking. " Each of these aspects of the proposed project are addressed , in detail , in the "Project Description" section of the " Documentation" report , including the expansion of the existing modular mobile home structure to be used by PSA as an air passenger terminal. PSA must expand this structure ( previously used by WestAir Airlines as its passenger terminal ) to meet FAA security and handicap access standards . PSA would enlarge the structure from its existing 1 ,440 sq . ft . to approximately 2 ,505 sq . ft . to meet these standards . This would be somewhat less than the doubling of the size of the structure that Mr . Cowan. alleges . Mr. Cowan cites the FAA ' s Notice of Proposed Rule Making ( NPRM) on its Airport Access Policy as evidence of FAA ' s intent to control airport access and capacity over the objections of local jurisdictions . The NPRM is just that , a proposed rule . The issue is quite controversial and has yet to be resolved . Moreover, this ( the FAA ' s ) proposed policy is inconsistent with its published airport noise abatement policies . All major U . S . airports air carrier and general aviation) are united in their opposition to III-32 Y this proposed policy. To suggest at this point that a NPRM would dictate FAA policy at Buchanan Field is speculation, and ignores published FAA policy that is contrary to the NPRM. Mr . Cowan cites his concern that "The theoretical ( 1andside) capacity ( of Buchanan Field ) would not pose an obstacle to extreme increases in air carrier service. " He cites John Wayne Orange County Airport as an example of an airport whose landside facilities ( i .e . , passenger terminal building) "accommodated over ten times their ' capacity'" . Mr. Cowan neglects to point out that the air passenger terminal at Orange County Airport consisted of approximately 20, 000 square feet (as opposed to approximately 2 , 500 square feet 'as proposed by PSA) , was and is extremely crowded , and was so utilized as a direct result of policy decisions made by the Orange County Board of Supervisors . Moreover , this overcrowding of facilities was not mandated by new entrant carriers . To the contrary, court decisions gave the County the option to resist the entreaties of new carriers until airport access plans , a master plan and EIR had been completed. ( See PSA vs . Orange County Board of Supervisors ' u ervisors , U.S . District Court , Central District of California, No . CV-8 -3 48-TJH(Gx ) , and Midway Airlines vs . Co . of Westchester, 584 Federal Supplemental 436 ( 1984) ) . The Orange County Board of Supervisors allowed such increased service as referenced by Mr .Cowan of their own volition, not under duress . If anything , the Orange County situation supports the Contra Costa Board of Supervisors in their contention that the proposed lease with PSA and the subsequent Airport Access Plan would effectively limit air carrier operations at Buchanan Field . It is perhaps even more important to note that an airport access plan for Orange County was developed , not before air carrier service was established, but concurrent with existing service . Mr . Cowan further states that CEQA "requires that an EIR be prepared if a project has the potential to cause significant (emphasis added) environmental impacts" . The County has recognize that the proposed project may have impacts , but evidence in the record does not support his contention that such impacts would be significant . It follows that his conclusion that "without an effective access plan before certification as 'an air carrier airport and introduction of PSA service, " is in and of itself untenable and is based on the incorrect assumption that the proposed PSA service would require a change in status of the airport . Mr . Cowan further assumes that the purpose of the Proposed PSA service would be to compete with Oakland International Airport . This is clearly not the case , but if it were true PSA would be competing with itself! Mr . Cowan cites the current controversy at San Francisco Interna- tional Airport over the introduction of cargo service by a re-engined Boeing 707 aircraft as an example of an attempt by the FAA to force an airport sponsor to accept an aircraft with noise levels greater than those established by an airport access III-33 plan . Research indicates that the issue is not as presented by Mr . Cowan , but one of San Francisco International airport not wanting to accept an aircraft that is less noisy than other aircraft currently in operation at the airport ( an apparent contradiction on the part of the City and County of San Francisco to their own access plan) . Response to °Inadequate Impact Analysis, " Page 3 Mr: Cowan opines that "every potential project impact is either understated or ignored . " Potential project impacts are addressed on pages 3U throughof the "Documentation" report. Moreover, the specific issues of aircraft safety are addressed in full in the Flight Safety Institute Report, "Safety Study for Buchanan Field Airport (March 10, 1986) and in Chapter II of the "Response to Comments" document. Response to "Lack of Mitigation Measures," Page 4 Mr . Cowan cites the " Fundamental requirement of CEQA " that project related impacts be mitigated . This is a misstatement of the letter and intent of CEQA in that only significant impacts require mitigation . There is nothing in the record to substantiate his contention that there would be significant environmental impacts associated with the limited extent and nature of PSA ' s proposed project. Response to "Inconsistency with Governmental Plans," Page 4. Mr . Cowan alleges inconsistency of the proposed PSA project with the Regional Airport Plan . This issue is addressed as Response 6 in Chapter I of the "Response to Comments " document ( Page I-8) . Potential impacts of the proposed project on regional air traffic and safety are discussed in the "Safety Study for Buchanan Field Airport" , and in Chapter II of the "Response to Comments" document . He further alleges a "violation" of the Noise Element of the 1975 County general Plan . The Contra Costa- County Community Development Department is aware of no such "violation" . Response to "Conclusion" , Page 5. The County has , and is , considering all sides of the issue at hand . Thank you for your interest and commentary on this matter . III-34 Response to Comments of City of Pleasant Hill , Re: Proposed PSA Air Service and Lease at Buchanan Field (April 16, 1986) , including Exhibit A and B (Note : This letter and its supporting documenta- tion was submitted to the Board of Supervisors under separate cover and is not contained in this chapter for this reason) . The City of Pleasant Hill sets forth its objections to the proposed PSA Project in the introductory paragraph of its letter. The City errs in its observation that "The structure and content of the McClintock Study is identical to that of an environmental impact report . " The content and format of the McClintock Study is as set forth in Sections 15063 (d) of the "State CEQA Guidelines " for an Initial Study ( see McClintock Report, Page 1 ) . The City further errs in its conclusion that I A) lthough the McClintock Study refers to the 1983 Buchanan Field Airport EIR (herein ' 1983 EIR ' ) , such references are selected for the sole purpose of supporting the negative declaration at issue. " CEQA allows the incorporation by reference of all or portions of another document which is a matter of public record or is generally available to the public And the incorporated material is considered to be set forth in full as part of the test of an EIR or negative declaration. The 1983 EIR is a matter of public record and is available to the public in the offices of the Contra Costa County Community Development Department, 4th Floor, North Wing, County Administra- tion Building, Pine .and Escobar Streets , Martinez , California. The County fully recognizes and in fact concurs with the City that it is the purpose of the environmental review process to provide objective information for the public and decision makers upon which to arrive at an informed and objective decision on a proposed project . The basis for the County decision to prepare a preliminary negative declaration on the proposed PSA project and lease is the technical documentation that supports the conclusion of the Initial Study that the proposed project would not have a significant effect on the environment . There is no question of the fact that issues dealing with the environmental impacts of airports and issues of air safety are highly technical and complex , hence the alleged "highly technical " nature of the two reports submitted in support of the Initial Study . However , every effort was made to present the factual matters in the two reports as simply as possible to benefit the lay reader and local public agencies . In this regard the County has prepared a document that exceeds the requirements of CEQA for documentation of an Initial Study. It is indeed unfortunate that the "experts " hired by the City of Pleasant Hill to review the County ' s documentation were not sufficiently versed in airport planning and environmental matters , and air safety issues to assess the adequacy of the technical material prepared for the proposed project . As a consequence the County cannot concur with the City of Pleasant Hill ' s allegations of technical deficiency. III-35 A. Response to Project Description The City' s comment states "To effectuate this proposed lease agreement , it is necessary to upgrade two runways , one for precision instrument landing and the other for non-precision instrument landing . " This information is totally incorrect . There is no requirement either by the Airport or by the FAA that these approaches be installed prior to, as a part of , or after the fact , to have PSA service . The discussion relative to the fundamental change in the character of the Airport in the absence of a duly-adopted airport access plan , does not make any sense. General aviation and scheduled air carriers operate compatibly at approximately 1 ,000 airports throughout the United States . The second paragraph of this comment states "To accommodate scheduled air carrier operation , Runway 32R will be upgraded to a non-precision runway from visual , and Runway 19R will be upgraded from a non-precision runway to a precision runway. " This statement is false in the implication where it states ; "To accommodate scheduled air carrier operation , . . . . " . These runways have been programmed for upgrading for a number of years and this was indicated in the 1983 EIR before there was any consideration given to PSA scheduled service from Buchanan Field . The City ' s comment indicates that one of three alternative guidance systems for a precision instrument runway is Precision Approach Radar ( PAR) . The phasing out of Precision Approach Radar began approximately 20 years ago ;and was completed approximately ten years ago at U . S. Civil Airports . This type of navigational aid no longer exists at civilian airports in the continental United States . We are in agreement with the. City ' s contention that the PAR is a very expensive system and further agree that there would be no funds available for purchasing of a PAR, particularly in light of the fact that they are no longer installed at civilian airports . The City ' s comment states, "However, the City was informed that MLS would not be available for some five years , but we must be aware that this airport is not even on the waiting list as of this date . " The current schedule for an MLS installation at the airport ( providing that the 100% federal funding remains available) is for late 1987 or early 1988 . The existing and future navigational facilities for the airport are in the public domain and are used equally and made available equally to all types of aircraft with no discrimination as to aircraft category or type . III-36 Y B. Response to "B. Project Setting" : The City expressed concern that the "project setting description failed to include existing and public open space located adjacent to the Airport" . Figure 9 (generalized existing land use ) in the " Documentation" report indicates the location and extent of at least two categories of open space in the airport environments . Public open spaces such as parks and the Buchanan Field Golf Course are indicated on this figure., as are areas of vacant and undeveloped land . Open space , whether developed or undeveloped, is considered a noise compatible land use under both State and Federal airport land use compatibility guidelines . Moreover, golf courses are a preferred use at the ends of airport runways because of their relatively open nature and low concentration of people . C. Response to °C. Environmental Impact Analysis: . The County recognizes that the "purpose of an Initial Study is to determine whether a project might have potential significant impacts on the environment " . It is also aware of the other purposes an Initial Study can serve. These are referenced on page 1 of the "Documentation" report and are set forth in sections 15063 (c ) ( 1-7) of the "State CEQA Guidelines-" . It is not necessary, as the City maintains , to prepare an EIR to make a determination " that such impacts may not be significant. . . . " No mitigation measures are specified . in the background documents because ( 1 ) they' are either already built into the proposed project, or ( 2) are not required because the potential levels of project impact would not be significant . 1. Hydrology and Dater Quality: The Cit clearly misstates the finding of the " documentation" report (aka McClintock Study) . The "documentation " report states (on page 30) that "the proposed project site is located on the Airport and is not within a designated flood hazard area" . The statement clearly indicates that it is the project site that is not within a flood hazard area (reference is also made to figure 2 , "Airport Layout and Project Site Map " ( page 4) for the physical location of PSA ' s proposed operating facilities ) . The City further notes that "the freezone ( emphasis added ) area at the end of runway 32R is located in an area shown to be a 100-year flood hazard area and one dam inundation zone" . The term "freezone" has no recognizable connotation in airport planning or engineering. If the City by chance means the "clear zone" or "approach protection " area at the ends of runway 14L and 14R, this is an area consisting of imaginary surfaces extending outward and upward from an point beginning 200 feet off the runway ends in the horizontal /vertical ratios indicated on figure 2 . It is desirable to keep these areas clear of any obstructions :that might intrude into these imaginary surfaces . An unusable flood plain in such an area is probably a more desirable use than the previously mentioned golf course. III-37 2. Geology and Soils : The City attempts to equate the proposed one-story PSA terminal with a 10-story office building in terms of seismic risk potential . As noted in the project description section of the "documentation" report the proposed PSA terminal is of modular construction and represents no more of a seismic risk potential than the multiplicity of similar structures in the mobile home parks near the airport . 3. Air Quality: See response to comments on issues 22 , 23, and 24 of Exhibit A ( Bendix Report) . 4. Noise : See Appendix A (Mestre Greve Associates response to Wilson , Ihrig Associates ) , " Response to Comments" report and response to "Project Setting" issues , above . 5. Natural Resources : It is true that although the BAe 146 is a new aircraft it cannot operate without fuel , the fact remains that PSA is currently operating these aircraft and would continue to operate them whether in service at Buchanan Field or not . Fuel consumption by aircraft is a fact of life , either at Buchanan Field or elsewhere. The potential for a significant increase in the consumption of energy in the "renovated" passenger terminal was not evaluated in the McClintock Study because the potential increase in such consumption , when compared to other developments proposed for the area, would be miniscule . The County also contends that the renovation of the proposed PSA terminal building would represent a Class 1 categorical exemption under CEQA. 6. Hazards : Comment noted . 7 . Utilities and Public Services : See "Response to Comments" report , Chapter II . 8. Transportation and Circulation : The City attempts to cloud the fact that PSA ' s proposed project would not have a significant impact on local streets and intersections by bringing in a discussion of peak hour traffic conditions far removed from the PSA project site (the project site is on the airport and has the advantage of being able to use John Glenn Drive as a vehicular storage reservoir to meter traffic through the intersection of John Glenn Drive and Concord Avenue ) . In addition , the City tries to equate levels of service E and F conditions on these local streets and highways with PSA ' s operation . As stated in the "documentation" report ( pp . 56-57) PSA ' s traffic peaks do not coincide with the business traffic peaks that currently result in levels of service E and F that the City is so concerned about . Therefore , assuming the addition of a maximum of 156 vehicle trips generated by PSA ' s operation during its peak hour the net effect of this traffic on local streets would not be significant . This is further substantiated by Bendix Environmental Research, Inc . in Exhibit A, pg . 13 , item 58 , wherein it is stated that "if traffic is flowing smoothly, a traffic increase of one to three III-38 • Y percent is insignificant . ' Bendix errs in its assumption that in the case of PSA ' s traffic movements when "traffic is at or beyond the carrying capacity of portions of the roadway, with levels of service (LOS ) E or F, then any increase will furthen ( sic) worsen the situation and can constitute a significant impact . " Reference is made to Table 1 of the " documentation " report for PSA ' s proposed schedule and page 12 for a discussion of what this entails in terms of the hours associated with PSA traffic generation. 9 . Growth Inducing Impacts : See discussion of this issue in Chapter I of the " Response to Comments " documents ( pp . I -6 through I -8) and preceding responses to comments of Zach Cowan concerning " Inadequate Project Description" in this chapter. 10 . Relationship to Regional Air Transportation Plans : The questions posed are from the MTC/ABAG Regional Airport Plan (as noted in the " documentation " report , pp . G5-66 ) . There is sufficient documentation in the "Safety" study and McClintock Study to support the conclusions set forth. 11. Emergency Response Ca abilities : This paragraph questions the response time for fire fighting equipment and personnel . The requirement for response time is contained in FAR Part 139 specifically spelled out in section 139 .49 (e) ( 1 ) which states that "The applicant must show by demonstration run that - ( 1) at least one firefighting and rescue vehicle required by the applicable Index can reach the mid-point of the farthest runway serving air carrier users from its assigned post within three minutes from the time of alarm to the time of initial agent application" . The second paragraph of this section indicates that the discussion of response time and availability of equipment is not based on a "worst case scenario" . A "worst case scenario" is impossible to define . In addition , the second paragraph states " additionally , the inability to install the MSL and its impact on safety relative to the Airport ' s mixing of general aviation and air carrier operation must be re-examined . " We presume that this may have reference to MLS (Microwave Landing System) . Additional navigational aides does not in of themselves , have any relation to the mixing of general aviation and air carrier aircraft . When aircraft are utilizing a navigational approach system , they are on that approach system by themselves until they have either made a landing or gone to an alternate location. When an instrument approach is in use under instrument conditions , it is one aircraft at a time. This can be general aviation or air carrier aircraft on a first come basis . The intent of the third paragraph is somewhat unclear . It appears to be recommending that the studies develop emergency response plans for the Fire District . As indicated previously, Federal Air Regulation Part 139 is the regulation that establishes III-39 ' Y these issues for airports and the airport does meet or . exceed FAR Part 139 requirements . This includes equipment and training as suggested in the comment. III-40 TOSCO CORPORATION AVON REFINERY MARTINEZ. CALIFORNIA 94553 415/228.1220 JAMES M. CLEARY October 21 , 1985 REFINERY MANAGER Mr. Harold . E.- Wight Manager of Airports Contra Costa County 171 John Glenn Drive Concord, California 94520 Dear Mr. Wight: We have followed with some interest the discussions regarding proposed PSA commercial air service between. Buchanan Field Air- port and Los Angeles International Airport. While we are gen- erally supportive of such air service , we would like to indicate our concern over the proposed departure route to be used by air- craft departing runway 32R. Inasmuch as initial diagrams show departure routes which overfly our major processing center at the Avon Refinery , we believe it would be prudent for air control operations to require that de- parting pilots remain on a straight-out flight profile until they overfly the water ' s edge just north* of our facility. . Then., turns to the west or east could safely be undertaken without undue jeopardy to our personnel and manufacturing enterprise . While it is highly unusual for aircraft flight operations to terminate on our property , it is not without precedent. We be- lieve that our employees and the flying public would be best served by requiring commercial aircraft operators to avoid di - rect flyovers right above the heart of our processing area . This area , as you are aware , is generally marked by the presence of several tall stacks . We appreciate the opportunity to comment on this situation and look forward to continued good relations between Tosco Corpora- tion and Buchanan Field Airport. Sincerely, l ; ,J JMc : ifs 0489L cc: J. E. Simmons 111-41 1 1 :. ITT - ' IrTA j- l' f r I Ott T. TOSCO CORPORATIONa�l' �0 AVON REFINERY 2 a2 py + MARTINEZ,CALIFORNIA 94553 1 (� 419/228-1220 25 March 1986 Mr. Anthony A. Dehaesus �` Director of Community Development Contra Costa County P.Q. Box 951 , Martinez, CA 94553-0095 Dear Mr. Dehaesus :. Thank you for providing us with a copy of the "Notice of Preparation" regarding scheduled commercial air service out of Buchanan Field Airport. {File #PW 85-143} While Tosco Corporation and the Avon Refinery continue to endorse the proposed PSA service, for the purposes of your correspondence and our response, I enclose ". a copy of Avon Refinery Manager James M. Cleary' s letter to county Manager of Airports Hal Wight dated October 21 , 1985. We want to re-emphasize to the county and to PSA that aircraft have in the past crashed or otherwise landed within the refinery boundaries and we cannot stress strongly enough that aircraft operations departing Buchanan Field Airport' s runway 32R should be required to make no turns over Avon' s processing areas. Instead, all operations should be required to fly straight until reaching the river' s edge where safe turns , either right or left, can then be executed. We appreciate the opportunity, as one of the county's large neighbors near Buchanan, to comment on the proposed commercial air service and wish you the best in your efforts. Sinc ely yo 9l, J :e/S 4sifj`�� anager of Public Affairs III-42 • Y Response to comments of James M. Cleary, Refinery Manager, TOSCO Corporation . Comments Noted : PSA Flight Operations and the Air Traffic Control Tower will be made aware of this concern and flight profiles will be established to avoid the major processing center of the Avon Refinery. III-43 Y Responses to °D. Subjects which the Negative Declaration and its Background Material Failed to Discuss , which are Relevant to Evaluating the impacts of the proposed project° : 1 . The City errs in its conclusion that the "McClintock Study arbitrarily selected a ten mile radius ( emphasis added ) to departure traffic impact . " In the first place , the "Documentation" report does not purport to assess traffic impacts within a ten mile radius of the Airport. The Airport does, however, assume that the majority of potential passengers from Central Contra Costa County, who would elect to use PSA ' s proposed service at Buchanan Field would originate his or her trip within 10 miles of the Airport (see Page 17 of "Documentation" Report) . This is consistent with the location of the greatest concentration of population in the County , and includes such communities as Concord, Pleasant Hill , Martinez , and Walnut Creek . The report also assumes an average trip length of 10 miles for purposes of calculating vehicle miles travelled . It DOES NOT assume that only people from within a ten mile radius would use the proposed PSA service ( see "Response to Comments" , Pages I -10 through I -11 ) . 2 . All funding from the Federal Aviation Administration is through an Aviation Trust Fund . This is funded through a system of user taxes and fees such as aviation fuel taxes , and airline ticket taxes . The Federal share for eligible airport projects is 90% . The local share of 10% comes from the Airport Enterprise Fund (Airport users ) . There will be no fiscal impact on local jurisdic- tions . Summary: Comments Noted. Responses to comments set forth in Exhibit A: This Exhibit consists of the report of Bendix Environmental Research , Inc . ( Bendix report) and forms the basis for many of the issues and concerns set forth in the City of Pleasant Hill ' s letter (which , 'for the most part have been responded to in the previous section) . For this reason , and the fact that many of Bendix ' s comments are speculative and/or editorial in nature not all of the comments in Exhibit A require a response . The Bendix Report sets forth the findings of Citizen ' s Association for Sensible Development of Bishop vs . County of Inyo 985 as the decision responsible for the requirement that an initial study be supported by the "data or evidence on which the person conducting the ( initial ) study relied " . It is precisely this decision that formed the basis for the County ' s preparation of the "Documentation for Initial Study report and the "Safety" study. These two reports meet and exceed the requirements of the " Inyo " decision for initial study documentation ! III-44 1. IS p. 1, Item 1: The term "mature urban area" is a descriptive term . Does Bendix really believe that the use of such a description implies no vacant or undeveloped land in the area , or a lack of parkland or open space? By Bendix ' definition, it seems that the answer would be "yes" , in which case the mature urban areas of New York and Boston would be without two important assets -- Central Park and the Boston Commons . In any event the section under discussion is accompanied by a generalized land use map (figure 9, page 24) . The two sites on the Airport Proposed for Future Development were discussed the the 1983 Airport EIR as sites A and B . 2. IS Documentation p. 8, Fig. 3. This relocated taxiway was a part of a previous project that was completed at approximately the time the Consultant ' s report was being drafted. This reloca- tion had nothing to do with the planned PSA service . It was a part of Airport seal coating and repair work that was ongoing . The actual relocation consisted of restriping the taxiway center- line from its previous location to the relocated position approxi - mately 50 feet to provide more direct taxiway access for all aircraft . 3 . IS Documentation p . 12: The referenced aircraft would be relocated to other aircraft parking areas on the airport . 5 . IS Documentation p . 14 : From Table 2 ( " documentation " report, p . 15 ) it can be determined that with a 60% aircraft load factor PSA would handle 255 enplaning and 255 deplaning passengers , for a combined daily volume of 510 daily passengers for its peak day operation ( 5 flights per day ) . With 100% peak day load factor PSA could accommodate 425 enplaning and 425 deplaning passengers , for a combined total of 850 peak day passengers . 6 . IS Documentation p. 14: PSA' s actual systemwide passenger To—ad factor is 58%. Load factors of 60% and 100% respectively were used to estimate potential traffic and parking impacts for PSA' s proposed service . 7 . IS Documentation p . 14 : Bendix ' " experience that many business travelers to Los Angeles return the same day" , is substitute for PSA ' s experience that only 7% of its passengers complete a roundtrip circuit in one day. 12. IS Documentation p. 18, 4. The gross parked weight of the aircraft is 90 , 000 lbs . The maximum takeoff weight of the aircraft is 89 , 500 lbs . The maximum landing weight of the aircraft is 75 ,000 lbs . The normal takeoff weight of the aircraft departing from Buchanan Field to southern California would range from 70 , 000 lbs . to 78, 000 lbs . The 90, 000 lb . strength rating , however , is designed to last twenty ( 20) years with 1 , 200 annual operations at 90 , 000 lbs . This will not occur since the aircraft is not certificated for a 90, 000 lbs departure weight . As mentioned previously, the Airport is an enterprise fund, and the users of the Airport pay for all costs of operations III- 45 and capital improvements at the Airport. The comment further indicates that the bearing strength of runways which would be used the other 5-10% of the time is not given . These runways are the same since they are in fact the same runways . . The opposite end of Runway 19R is considered a ' different runway which is Runway 1L . 16. IS Documentation p. 20: Technical information by its very nature can be complex . The information set forth in these tables was used by the County to assess the potential of Buchanan Field runway to accommodate the BAe 146 under a variety of conditions . The County is truly sorry at Bendix ' apparent inability to comprehend the technical specifications provided for BAe 146 operating parameters , but question what Bendix would have the County use as the basis for determining the adequacy of airport runways to accommodate the BAe 146? 22 . IS p . 2 , Item 4 : In terms of the limited of numbers of aircraft operations proposed as part of the proposed PSA project, such an analysis of cumulative impact would be less than meaningless , particularly when one stops to consider that Buchanan Field is located between three freeways and is contiguous to some of N . California ' s largest concentrations of petroleum refineries and oil storage facilities . 23. IS Documentation p.31: See 22 above. 24 . ' IS Documentation pp . 32-33 : The " congested rush hour traffic conditions in the project area" alluded to do not coincide with PSA peak traffic periods . Hence such an analysis of cumulative impacts would not give a true picture of actual conditions . 25. IS p.2, Item 5.b: See Mestre Greve report (Appendix A to "documentation" report) and "Response to Comments" report (Appendix A -- "Response to Wilson , Ihrig & Associates " report) . 26. IS p. 2, Item 6.c) . The Federal Aviation Administration is the safety agency for aviation in the United States. The FAA has developed Federal Air Regulation Part 139 as the Safety Regulation governing airports having scheduled or unscheduled passenger operation for an air carrier . The apparent intent of this paragraph is to imply that the NFPA standards are the correct ones . This section also implies that the NFPA standards are the generally accepted standards for airports . The standards for airports are covered in Federal Air Regulation Part 139 . Buchanan Field Airport will comply with Part 139 including equipment, staffing, training , and all of the other requirements contained therein . 28. Safety Report p. I-14. The response to this is contained in the Safety Report on pages II-52 and II -53 . III-46 ' Y 29. Safety Report p. I-19. This is a Security Program. It will be required prior to the start of PSA Service. It is not available to the general public or to public bodies or consultants . It is a "Security Program" . 33. Safety Study, Table II-2, un-numbered page before p. II-4. Response to this is. given in Section II of the responses . 34. Safety Study p. II-4. Response to this is given in Section II of the responses . 35. Safety Study Table II-3,un-numbered page following p. 11-4. Response to this is given in Section II of the responses . 39. Safety Study p. II-9. Response to this is given in Section II of the reponses . 58. IS p. 3, Item 8.a. ) . See discussion under "8 . Transportation and Circulation " , in above response to comments of City of Pleasant Hill . 59. 1983 Draft EIR, p.81: See above. 60. IS p. 3, Item 12: Bendix continues to ignore the facts that PSA ' s proposed project would not set a precedent for air carrier service at Buchanan Field , can be controlled through the terms of the lease with the County, and would be subject to the provisions of the upcoming airport access plan . This issue is also discussed in Chapter I of the "Response to Comments" document and in this report under responses to Zach Cowan , " Inadequate Project Description" . Response to Wilson Ihrig & Associates, Letter Report of April 3, 1986• See Appendix A of "Response to Comments" report, response of Mestre Greve Associates to February 3 , 1986 Wilson Ihrig & Associates Report. The April 3, 1986 Wilson , Ihrig report did not contain any substantial new issues . psa. addit . info .t3 III— 47 i �.. , CONTRA COSTA COUNTY ��� �.��,� COMMUlIlT" PEVEI+PMENT DEPT. _'';� �� W Inut APR 11 4 40 PM '86 APR 11 1986 "� 4/ r Z6111 �'` VISORS Of t' is%�Oi q� Deputy 1 RECEIVED April 7, 1986 APR 161986 AUCHANAN FIELD Contra Costa County Board of Supervisors 651 Pine Street Martinez , CA 94553 Dear Members of the Board: The Walnut Creek City Council wishes to record its support for the position stated by the City of Pleasant Hill regarding commercial air service to Buchanan Field. It seems quite proper that before the Board acts on the PSA. request to establish a commercial service that the access plan currently in preparation be completed and adopted. Doing so would assure the interested citizens in Central Contra Costa County that their concerns regarding possible adverse effects of allowing too much commercial traffic in and out of the Buchanan ield has been fully and thoughtfully considered. eely, Mary ou Lucas MAYO DISTRIBUTION Corrd Members Crjut;;y Ad.ninistrator �1 •a;;!th :er;•io,�s C�c,m nity D�ve!opment RECEIVED APR 161986 allCHANAN FIELD P.O. Box 8039, 1666 North Main Street, Walnut Creek, California 94596 (415)943-5800 LAW OFFICES Lazzarini & Frazier A PROFESSIONAL CORPORATION TELEPHONE (415)934-5000 ROBERT W.LAZZARINI 49 QUAIL COURT CINDY WEBB FRAZIER SUITE 212 WALNUT CREEK,CALIFORNIA 94596 March 26, 1986 PLEASE REFER TO OUR FILE NO VU-1] 'Et VED Tom Powers, Chairman MAR 2 8 1986 Contra Costa County Board of Supervisors 100-37th Street rH!!-BATCHELOR 1.1� Richmond, 'CA 94805 Ct CtARD C SUPERVISO S 5TA CO. By AL Oe Pty RE: PSA Permit Dear Mr. Powers: As an attorney who represents two of the victims of the disaster at Sun Valley Mall in December of 1985, 1 am very concerned over the prospect that PSA jets will be flying out of Buchanan Field in Concord. The National Transportation Safety Board, as you know, has yet to issue its opinion as to the cause of the crash. Apparently the investigation is not being continued because the NTSB doesn' t wish to perform its tasks in the presence of outside witnesses . In any event, there are serious questions as to the exact cause of the accident and the degree of responsibility that may be attributed to each aspect. I have recently been advised that Jim Graham, the deceased pilot of the aircraft, had serious concerns with "noise abatement problems" in the vicinity of Buchanan Field. To the extent that Mr . Graham' s concerns over the complaints of Concord citizens over noisy conditions surrounding take offs sand landings by small planes contributed to his operation of the aircraft and was responsible for the horrible crash, it would appear to me that it is clearly premature to permit PSA to operate out of Buchanan Field at this time. If noise considerations were such a problem that private pilots were concerned? one can imagine what PSA will have to cope with in terms of operation of its aircraft which will certainly create much more noise than small private aircraft. Will PSA alte'?. its normal flight operations and engine performance requirements in order to 'keep the public complaints to a minimum; and, if so, won' t that endanger not only the people who go to Sun Valley but al4o--thp- 77��Ul Jg ,prrounding Ul C-,,rnmvnily Development C,1-_,.1.*v Ccunsal t` k Tom Powers, Chairman March, 26, 1986 Page Two homes and neighborhood adjacent to the airport? Is it so important that PSA fly May 1 , 1986? I think not! I urge you not to permit any PSA flights in and out of Concord' s Buchanan Field until the impacts of such flights have been weighed along with the results of the National Transportation Safety Board investigation, Very truly yours, LAllARINI & FRAZ A Profession 6orpo tion By: ROBERT W. LAZZARINI RWL:kmn cc: Jon Crouch Nora Taylor THE CITY OF PLEASANT HILL' S RESPONSE TO RESPONSE II$ PREPARED BY THE COUNTY OF CONTRA COSTA ON THE INITIAL STUDY RECOMMENDING A NEGATIVE DECLARATION ON THE PROPOSED':PSA AIR' SERVICE: AND LEASE ...AT BUCHANAN FIELD City of Pleasant Hill 093300 N. MAIN STREET, PLEASANT HILL, CALIFORNIA 94523 PHONE (475) 934-6050 Members of the Board of Supervisors April 21, 1986 County of Contra Costa County Administration Building P.O. Box 951 Martinez, CA 94553-0095 Re: Response to Comments Regarding Use of Proprietary Powers to Exercise Local Control over Buchanan Field Members of the Board of Supervisors: Section II .C.1 (P.II-12) of the County's Response to Comments, suggests that the availability of "proprietary powers" of the County over Buchanan Field means "airport owning jurisdictions are not powerless to control airport activity". This exceeding broad statement, framed as a negative, raises more questions than it answers. It is therefore insufficient to address the concerns raised by both citizens and public agencies in response to the Preliminary Negative Declaration. This portion of the County's response refers to two legal cases: Santa Monica Airport Association v:,.'Ci tv of Santa Monica (9th Cir. 1981 )' 659 F..2d 11 6, and British Airways Board �v Port Aut�it oFNew York (2nd Cir. 1977) 564 F.2d 1002 — — These cases, and others, affirm that Congress intended a "two-tiered scheme" in enacting Federal regulatory laws covering this subject. The Federal government occupies the first tier and generally preempts local agency control of aviation. However, on the secondary tier, airport owners, if local governmental agencies, are allowed a degree of "proprietary control ". The full extent of this control is not presently determined. The U.S. Supreme Court has not yet spoken on the issue. Applicable legislative history indicates Congress sought to avoid interference with "long recognized powers of the airport operators to deal with noise and other environmental problems at the local level ". 3 However, only local noise reguTat of ns ami veGeen�nitively reviewed by the courts, and no one yet knows the scope of exemption from federal preemption which will be accorded local proprietary regulations on "other environmental problems". 1 This case is known as "Concorde II". The relevant proposition the County relies upon is actually discussed in the earlier case of "Concorde I". (558 F.2d 75.) 2 The control cannot be exercised as a police power of local government. Burbank v. Lockheed Air Terminal , Inc. (1973) 411 U.S.624 3 124 CongressioT nal Record 3 19'7fl-Z Senator Kennedy] Furthermore, even noise regulation is the subject of Federal regulation e.g. , 49 U.S.C. Section 1431(b) , holding that local government cannot regulate noise by controlling aircraft flight patterns. (In view of this statute, Section 8.D of the County's proposed lease with PSA is noted). Finally, the County response, as well as the proposed lease with PSA, appears to assume that the proprietary p-ower of the County will allow regulation of carrier access. However, this assumption is not supported. At least three Federal statutes indicate a wide degree of Federal preemption regarding the access issue: 49 U.S.C. Section 2210 [airports must be available for public use on fair and reasonable terms], 49 U.S.C. Section 1349(a) [airport proprietors cannot grant exclusive rights for use of loading areas or air navigation facil i ties.where federal funds are involved], and 49 U.S.C. Section 1305 (a)(1 ) [local agencies cannot regulate rates, routes or service of carriers]. In fact, to date, a court has only allowed temporary access restriction by a local agency pending "an informed study in order to establish rational guidelines . . . for use of scarce airport capacity. " Midway Airlines v. County of Weschester, New York (S.D.N.Y. 1984) 584 Fed.Supp.436. In that ja--se—,—t-Fe- County owner Fa-T-en a ed the services of an airport consultant to develop "a comprehensive and complete statement of policy for the airport" (Id. at 439) In conclusion, it should be noted that this County is seeking to significantly change the use of Buchanan Field, and to negotiate access provisions with a single carrier,, without any.comprehensive review of general airport policy, or of the environmental e'f—ects of that airport policy (when determined). The .- -doctrine-of ,proprietary power provides no talisman to avoid thes'e' responsibili- ties. It therefore seems both prudent and legally necessary at this time to evaluate the probable impact of initiating carrier service, and the means- of mitigating the effects of that impact. (0117 ry truly y truly 'y y/ ENNIS A 4. L E City Attorney DAL/als ENVIRONMENTAL RESEARCH, INC. FOX PLAZA, SUITE 902 • 1390 MARKET STREET • SAN FRANCISCO, CA 94102 • TELEPHONE (415)861-8484 20 April 1986 Dennis A. Lee City Attorney City of Pleasant Hill 3300 N. Main Street Pleasant Hill , CA 94523 RE: Critique of Environmental Evaluation of Proposed PSA Service.to Buchanan Field; II.A - II.E Responses to Comments Dear Mr. Lee: The following comments have been made on the assumption that subject document is considered to be part of,.the backup documentation: for the Ini- tial : Study (IS). 1. Figures II-1 and 1I-2. These ,figures may be appropriate:Y:,for a pilot audience but are not- appropriate for general audience. Some of -the infor- mation could probably have been deleted for this use and most of it should have had explanations of abbreviations and meaning. 2. 'Page II-3, 9 1. What happens if the tree grows? 3. Page II-4, 11 3.-2. Monterey also has a greater number of instrument approach procedures than Buchanan Field, judging by Figure II-3. 4. Page II-4, 11 3.-3. It is unclear to me to which four general aviation airports the last sentence refers. Does it refer to the non-Bay Area air- ports on Figure II-3? If so, is there a reason that ILS is more common at these airports, such as that they are newer airports more likely to have modern equipment? 5. Page II-5, 9 2, last sentence. Why are aircraft performing a circling approach at Buchanan Field not authorized to circle west of runways 1L and 14R? What is the significance of this restriction? Does it limit pilots in a fashion that affects safety? The reader cannot judge the significance of this restriction in the absence of additional information. 6. Page II-5, 9 4.-1. Why has Arcata Airport been included in this analy- sis but not in previous analyses? ENVIRONMENTAL CONSULTANTS AND FIRE PROTECTION ENGINEERS Buchanan Field Page two 7. Page II-5, 9 4.-2. Is 1,000' the point at which Travis air controllers hand over control to Buchanan Field? It. is not clear from the text. At what elevations °are midair crashes or near-misses most probable? How do commercial pilots feel about the lack of radar control below 1000' ? In the absence of this information, the reader cannot judge the significance of the present procedures. We note that later. on there is a statement that radar for Buchanan Field is considered a high priority, suggesting that it would contribute to safety. 8. Figure II-5, unnumbered pages. Why is a different list - of airports analyzed from t e previous table. In the absence of a stated reason, one wonders if the selection in each case has been made to prove a point and neither selection represents an unbiased sample from which to draw conclu- sions. 9. Page II-6, t 5.C. How much control do the ATCs have in the absence of radar? What is the effect of the difference in available information on their operation? Does it affect the evaluation time per aircraft? Does it affect their response time in case of potential emergency? 10. Page II-7, last $. Judging by the vigorous protests by Airport manage- ment by the Airline Pilots ' Association against a Millbrae hotel in the San Francisco International Airport flight path, which received FAA authoriza- tion, and by other similar incidents which have been discussed in profes- sional publications (such as Engineering News Record) and the press, there is not professional agreement on what constitutes safe building heights and potential flightOpaths near airports. FAA approval appears not to be a guarantee of :adequate safety according to some members of the aviation industry. When there is professional difference of opinion on an issue evaluated in an environmental document, all major points of view must be presented together with the reasons for agreement with any particular point of view, if this is the case. 11. Figure II-6, unnumbered pages. If everything approved or approvable according to this table is built, what will happen to approach and take-off paths? What is the net effect of multiple actions by some communities, such as Con- cord, on the net status of compliance of their general plans and project approvals with the Buchanan Field Airport Land Use Policy Plan? Land use issues are a key component of a CEQA document and the evaluation of the proposed project should have included a cumulative analysis of the land use issues raised by repeated actions not consistent with the Buchanan Field Airport Land Use Policy Plan with respect to operations and safety at the Airport and to safety and traffic congestion in areas around Buchanan Field. Where "Local Jurisdiction Action" is listed as "Approved by City of Concord," does this mean that the recommended conditions were not included in the per- mit? What does "Reconsidered by City of Concord" mean? Was the project approved or not and, if approved, with or without recommended conditions? • .Buchanan Field Page three 12. Page II-8, last 11. What are the manmade obstructions built since De- cember 1983 and what is their effect on approach and take-off paths? Are other such projects under construction? 13. Page II-9, 9 1. What has been the result of the FAA studies conducted at Buchanan -Field? Have these studies , been made available to neighboring communities? I note that private office developments rarely involve Federal funding or approvals, hence do not appear to be subject to much pressure from FAA hazard judgements. Communities which approve projects which are rot compatible with the local Airport Plan, as is shown in Figure II-6 to have happened repeatedly, can be expected to approve projects regardless of FAA determina- tions. 14. Page I1-9, ¶ 2. What is the procedure for informing the FAA about the potential construction of man-made objects in the airport's environs? Who has responsibility for doing so? How long does the FAA determination take? Is FAA informed about plan actions which permit approval of buildings which may affect airport activities? Was the FAA informed of all the actions by local jurisdictions in contravention of the Airport Plan listed in Figure II-6? If so, what was the FAA reaction? Was any such reaction transmitted to the jurisdictions involved? Did they explain their reasons for their actions to the FAA or to Buchanan Field? 15. Page II-9, §: 4. The .Final EIR for the Kicker Pass dump should be cited here. 16. Figure II-7, 'unnumbered page after page II-9. More information is needed to understand the data in this table. What is the significance of the "Distance From Brake Release Point? Would no take-offs occur with a tail-wind or with a headwind greater than 20 Knots? The next page indi- cates that take-offs would generally occur with headwinds of 20-25 Knots. What would be the maximum headwind expected at Buchanan Field? Would air- craft take off under these conditions? What would be the maximum headwind under which aircraft would take off? What would be the distances from brake release point under these circumstances? How would the distances from brake release point given be affected if the aircraft were to be at maximum take-off weight? If any of these questions are not relevant, this should be explained in terms comprehensible to a lay audience. What is the defini- tion of a "Standard Day"? What would happen on non-Standard days? 17. Page II-10, 9 2. Do the 20-25 knot headwinds prevail the 90 to 95% of the time that runway 19R would be in use? 18. Page II-10, 9 6.4. Once again, what is the expected cumulative impact - of all approved projects and projects potentially approvable under current master plans on instrument approach minimums and operating procedures? On visual flight approaches? 19. Page II-11. What would be the relationship of the BAe-146's altitude at the given sites be to requirements? What would be the altitudes for the BAe-200? What would be the noise levels at Diablo Valley College and Beacon Hill under these circumstances? Under what conditions would PSA pilots ' r .Buchanan Field Page four make a straight-out departure even though this would not be a planned regu- lar procedure? Would FSA have to inform these sensitive receptors if they changed their standard procedures? What would be the differences when winds were greater than 20 knots? 20. Page II-13, § 2, ¶ 3. When will the new Part 150 Noise Study for Buchanan Field be availa le? Is it correct to assume that none of these measures are currently funded? In view of Gramm-Rudman, what is the probability that Federal funds will be available for any of these measures? Which of these capital improvement plans are designed to improve safety at Buchanan Field and how would they do so? 21. Page II-13, § 2.1. Note that even this unfunded measure would not bring Buchanan Field up to the minimum fire safety standards recommended by the National Fire Protection Association (NFPA) , as discussed in our report of 15 April 1986. 22. Page II-13, § 2.3. Why is this project recommended? It is difficult for the non-pilot to judge this, as so many other parts of the IS support documentation, because of inadequate information and a text poorly designed to inform non-pilot readers`: despite the general nature of the intended audience for environmental documents. 23. . Page II-14, § 3 ,. ¶ 2. .What are the significant aspects of the pro- posed update? Are they relevant to issues ;surrounding evaluation of the proposed PSA service? . On what basis has a decision been :made to complete environmental review.of the PSA service prior to completionand adoption of the revised Airport Rules and Regulations Ordinance for Buchanan Field? 24. Page II-15, 9 3.. This 9 acknowledges the potential growth-inducing impact of approval of PSA operations at Buchanan Field. The impacts of such growth induction have not been analyzed, as indicated in our previous set of comments. 25. Page II-15, § 5.5. This 9 appears to contradict the first partial t on the same page. Further discussion is needed to understand why both of these statements can be true. 26. Page II-15A, 9 2. Again we note that the referenced FAA standards are far below the NFPA Code recommendations which are used by many jurisdictions as guidance for reasonable fire safety. 27. Page II-15A, 1 4. If this 9 means that it is anticipated that failure to meet even the .FA standards will occur, how often is it expected that -_ this would happen? Has PSA agreed not to operate under these conditions? Whose responsibility would it be to inform PSA of these conditions? In view of the questionable adequacy of the FAA requirements, the occurrence of conditions under which even these requirements would not be met is of concern. We note that the content of § 6 is not reflected in the summary on page II-16, which seems inappropriate. • r ,Buchanan Field Page five 28. Page II-17, § 1.A. This 9 emphasizes the existence of a category of aircraft operations at Buchanan Field which are not under Tower control . 29. Page II-17, § 1.B. , 9 2. The assertion that "many pilots with impres- sive credentials and extensive flight experience periodically engage in touch & go or low approach training activities" is unsubstantiated. 30. Page II-18, 9 1. The percentage of unused annual capacity at Buchanan Field is relevant only if the unused capacity is available at the hours of proposed PSA operation and if the impact of PSA operations on -private air- craft is proportional to this percentage. If, as seems possible if not probable, the impact of relatively large aircraft on conditions at Buchanan Field is greater, perhaps even much greater, than their percentage of un- used aircraft capacity at Buchanan Field, the use of these percentages to imply the magnitude of impact is misleading. Environmental impacts are often difficult to quantitate; 'great care must be taken in formulating comparisons in order to avoid misleading the reader. 31. Page II-18, § 3. On what basis was it detemined that an evaluation of the reasons for the increase in accident rate at Buchanan Field in recent years was beyond the scope of evironmental analysis .for the proposed project? In view of 'the potential importance of such information for en evaluation of the safety impacts of the proposed project, it is difficult to understand this decision. The reasons therefore should have been explicitly stated somewhere in the IS. I.t woul d have been- :appropriate to add to the ,§ 3 list of potential factors contributing to an increased accident rate .the existence `of a political climate that does not favor government regulation and•'enforcement. 32. Page II-18, §4, 9 1. We have been given no reason to believe that the survey was conducted by an unbiased party with neutral questions. Infor- mation presented in the IS Documentation does not substantiate the state- ment that it is "a common view that airline service had no detrimental ef- fects on general aviation and in some cases serves to enhance overall air- port safety. . ." Data on pre- and post-scheduled airline operations acci- dent frequency at these airports are needed to substantiate repeated state- ments which appear to be based on verbal interview impressions rather than facts. 33. Page II-19, top of page. Approval of a project should not be predi- cated on the hope that project implementation may make possible future mea- sures to mitigate the impact of the approved project. Evaluation of the adequacy of mitigation measures to mitigate impacts to an acceptable level cannot take into account mitigation measures which may never be implemen- ted. -_ 34. Page II-19, § 5.3. It is not clear that all available relevant infor- mation has been considered; this assertion is, therefore, not justified by the content of the IS presented to the reader. 35. Page II-20, § 1. It is misleading to compare air transport fatality rates only to higher rates. Figure II-8 shows that out of the fifteen • � ,• Buchanan Field Page six years listed, in six years railroad passenger trains had a lower fatality rate than domestic schedule air tranport planes and in five years -buses had a lower accident rate than air transport. In fact, the table indicates that in only three of fifteen, or 20%, of the years, did domestic scheduled air transport planes have a lower fatality rate than any other mode of transportation. We feel that this document, as the other documents we have reviewed in con- nection with this case, does not meet the requirements of the California Environmental Quality Act for neutral , non-technical , documented analysis and is not appropriate for use as a basis for decisions on the project. Very truly yours, Selina Bendix, Ph.D. President XGilbert G: Bendix, P.E. 1 Vice President SB:sb Federal Register / Vol.:51, Na•14•/.wednesday, January 22, 1988 /:Notices fi amended to require that this could occur Written comments and prehearing conference report be only if such events relate to Unit 1 of recommendations for the proposed clarified to provide that non-applicant such Pssject.(2)Clause 12(C)(i),which forms should be sent within 80 days of parties need not file statements of presently requires prepayment of loans this notice,to:Selective Service,Reports position in advance of their briefs. under the Foreign Loan Agreement in Clearance Officer,Washington,DC The prehearing conference report` the event a governmental order or the 20435. states that". . .the parties would Me a like makes completion of the Project Send a copy of the comments to:OMB statement of posttion—as requested by. impracticable,would be amended to Reports,Management Branch,New Portland(Tr.89)--by January 21,1986 eliminate this prepayment requirement. Executive Office Building,Room 3208, (Tr.91):'Emery is correct,"Parties" (3)Clause 19(E),which presently' Washington.DC 20503. should be read to include only the requires MSE to use its best efforts to Dated:January 18,Iria& applicant carriers.The other partes are complete and maintain the Project in not required to file statements of commercial operation.wWd be ?homer K TtrrnsYe. position In advance of the date to be Dirotxot: amended so that this obligation-relates established for briefs. only lo-Unit i of the ProjecL (FR Doc.8e UM Plied 1-n-88:8:45 sm): Dated at Washington'.D.C.January 13. The amended declaration and any s'Lt"o coos 001"1-011 1986. further amendments thereto are i available for public inspection through John ni trative p p g OFFICE OF THE UNITED STATES AdminictrotiveLowjudgr. the Commission's Office of Public. TRADE REPRESENTATIVE (FR Doc.88-1322 Filed 121-ss:8:45 am) Referertice.Interested persons wishing to comment or'request a hearing should Advisory Committee for Trade s'J"a cooe 491"t-11111 submit their views in writing by-- Negotiations,investment Policy February 9.1988,to the Secretary. Advisory Committee,Services Policy Federal Aviation Admirdstration' Securities and Exchange Commission.. Advisory Committee;Meetings and Washington.DC 20549,and serve a copy Determination of Closing of Meetings Proposed Policy Regarding Airport on the declarants at the addresses Access and Capacity specified above.Proof of service(by The meetings of the Advisory — affidavit or.in case of an attorney at Committee for Trade.Negotiations=AcTiotc via�tien.� law.by certificate)should be filed with held Thursday.February 13.1988, AA),DOT. the request.Any request for a hearing 1:30 p.m.to 4:30 p m,4 the lnvestmeproposed polishall identify spe�cally the issues of Policy Advisory'Committea to be fact or law that are disputed.A person Wednesday,February 28,1988,from summARY:This notice annoences e who so requests will be notified of any 10:00 am.to 12:30 p.m.:and the Services ant of the Federal Aviation hearing.if ordered.and will receive a Policy Advisory Committee to be held Admr ' tion to set forth Fede copy of any notice or order issued in this Monday.Mardi 3.1988..from.2:00 p.m.to policy with reap access.and. matter.After said date,the.declaration, 5.•00 p.m.in Washington.DC,will capacity.The FAA believes public as now.amenided or as It may be,further include the development of review and comment on this issue li esiential to amended.,may be permitted to become discussion-ofcarrent leaues which development of a viable-policy.Asa. effective. influence the trade policy of the United consequence,this notice describes a For the Commission,by the DIvistan of States.Pursuant to section 2155(f)(2)of possible policy end requests public Investment Management,pursuant to Title 19,of the United States Code,I comment on the proposed policy and on delegated authority. have determined that these meetings issues relevant to developing an afiport Shirley F_Hollis, will be concerned with matters the access and capacity policy to serve the Assistant Secretary, disclosures of which would seriously public interest. lFR DOC 8t}-1544 Filed 1-21-8x;8:45 am) compromise the Government's FOR FURTHER tNFORiMION CONTACT: negotiating objectives or bargaining Office of Aviation Policy and Plans. aI4uNc CODE$010-01-M positions. Federal Aviation Administration.800 More detailed information can be Independence Avenue.SW., obtained by contacting Phyllis O. Washington.DC 20591. SELECTIVE.SERVICE SYSTEM Bonanno,Director.Office of Private Sector Liaison.Office of the United Introduction Agency Form Submitted to the.Oflice States Trade Representative,Executive The Federal Aviation Administration of Management and Dudget.for Office of the President,Washington.DC (FAA)is considering issuance of a Clearance 20506. policy statement that describes the The following form has been Clayton Yeutter, position of the Federal Government in submitted to the Office of Management United StaterTrodeRepresentative. reference to airport access and capacity and Budget(OMB)far clearance in IFR Doc.es-1289 Filed 1-2t-a8:8:45 aml issues. it would establish general complieace with the Paperwork" - asoma C06E 1111110-611-4111 hoc policy as opposed to current Reduction Act(44 U.S.Chapter 35): hoc response to access and use issues a at SSS Form No.and Title specific airports or groups of airports. DEPARTMENT OF TRANSPORTATION A formal statement of policy is '12aimDocumentation Form— desired for two reasons.First,ad hoc Conscientious Objector 1Docket 435751 response to use restrictions(including Copies of the above identified form Aviation Proceedings;U.S.—Japan rules imposed for environmental cmi he obtained upon written request to: Gateways Case reasons)enacted by airport authorities Selective Service Systern, Reports at hubs end other airports may produce Chwrance Officer. 1Nashington, DC Counsel for Emery Air Freight inconsistent or undesired results from a '10435. Corporation has requested that (lit! rational perspective of utilizing system 1 _ i i ,2986 Fadgral Register /. Vol. 51, No. 1¢ / Nednesday, January 22. 1988 / Notices, capacity and minimizing congestion and Presentations will be scheduled on a and to reduce the need for Federal delay.Second,policies formulated by first.request,first-heard basis.In intervention in airport issues.To be airport operators in the absence of addition,written comment is consistent with the objective&we should clearly stated Federal guidelines may encouraged.Comments should be strive to develop and operate a system ! result in an inefficient cycle of Federal submitted to the above address, of airports and airways with•minimum } review or legal action as new policies Proposed Airport Access and Capacity restrictions on runways,taxiways, . are Out forth.Thus,the FAA believes a Policy airspace,and landside facilities. comprehensive policy should be consistent with economic,safety.and developed. The FAA believes there is some environmental considerations. The development of an explicit benefit in issuing a statement that Additional capacity—where warranted Federal policy has been encouraged delineates airport access policies.It and feasible--should be established at from time to time by various segments of would be to the advantage of the entire existing,airports or new sites. i 'and others to community the aviation community.Most recently, aviation � Provision of airport capacity is,-a local a petition for rulemaking was submitted understand the parameters of statutory responsibility of airport operators and by the Air Transport Association on requirements and Federal policy. communities.If requested.and to the: September 14,1984.The petition was In order to engage In a constructive extent that such funds are available:the published in the Federal Register on dialogue with all members of the Federal Government will provide October Z5.1984,and comment invited. . aviation community and the affected financial assistance to airport operators ) This Notice of Proposed Policy,and the public.local governments,and planning for qualifying airport development : eventual Issuance of a policy Is Intended organizations,itis necessary to have a projects.Airport facilities developed starting point for discussion.One could with Federal funds should be operated to respond to,among other things:the P suggestions advanced by-the Air setfort ,.to capacity h general principles and solicit levels consistent with airside p Y comments asart of the-discourse or. ' Transport Association. alternatively,one could set out a capacity,except as limited by In additrore FAA believes the appropriate noise compatibility tentatively preferred set of policy programs. scope and ramificationa.ofsirport elements and address them directly.For ' access and capacity policy are such that The FAA is solely responsible for purposes of initiating a dialogue,the public comment and advice are determining efficient and safe use of the FAA has chosen the latter route with desirable.The policy will affect the . fu!l recognition that after public airspace,including capacity of airport general public as well as all segments of discourse many of the elements-will runways and taxiways•open to the. the aviation t to moreover.multi]dictionaluThe FAA proes are, bably be modified or deleted and public.rine efficciient and es.for safelf�runway and others may be added.Nevertheless we provides the.air.traffic control system taxiway operating'Ievela,and to impose and ground based air navigatioh believe that it provides the framework operational limits and allocation for constructive dialogue.The policy systems.while a variety of non-Federal itself,when formulated,may require procedures In such situations. public authorities own and operate implementation through rulemaking. Nonetheless,the FAA encourages airports.Nonetheless,the systems are. regional airport planning and'will not distinctly separate;jurisdiction over General Approach , „ cooperate with regional airport system interfaces.presents legal and The concept of:shared responsibility authorities by providing air traffic:.. practicaI'probiems must be identified is one which has been basic to the management consistent with regional and resolved development of the airport and airway airport system plans that provide Public Hearings system.Generally,local authorities have adequate overall levels of service to all had responsibility for the development users.In addition,the FAA recognizes The FAA believes that development and operation of the airport while the the right and responsibility of airport of an airport access and capacity policy Federal Government has developed the operators to achieve airport noise . should involve the widest possible . air traffic control,navigation and compatibility and will cooperate in dialogue with affected parties.To that communication systems.This has implementing actions specified in FAA end;a series of public discussions have historically been the posture adopted by approved noise compatibility programs. been scheduled at which views may be FAA.One of the factors to be Airport sponsors and operators are expressed orally.These discussions will considered in developing the policy is responsible for management of landside be scheduled as follows:Washington, where the line should be drawn to facilities.However,management of DC,on February 20&21,19M Denver, separate these responsibilities and how these facilities must not interfere with during the month of March firm that line should be. ' ' competition in air transportation,must Both discussions will be open to the The proposed policy relies on the not impose undue burden on interstate public from 9 a.m.to approximately 5 concept of shared responsibility commerce.must be consistent with p.m.on the-scheduled days.The second between the Federal Government and Federal grant agreements,and must not day of each meeting will be ended after local communities for the development violate existing prohibitions against the all present have been given an of the airport and airway system.By regulation of air transportation routes, opportunity to speak.The exact date of defining a common set of national policy rates,or service.Noise abatement pians the Denver discussions will be objectives.the fitting of these objectives and terminal capacity management + published in the Federal Register at to unique local airport/community procedures should not directly or j least 30 days in advance of the situations is facilitated. indirectly arbitrarily deny access to or discussion dates:Persons wishing to The objective underlying the policy is unjustly discriminate among potential or make a presentation at the Washington to ensure sufficient airport capacity to existing airport users, meeting should advise Carol Strong, meet the demands of the American In support of this approach to the Office of Aviation Policy and Plans, public for air transportation services in provision and use of airport capacity, Federal Aviation Administration. a safe.efficient. wid environmentally the FAA proposes the following Washington.DC 20591.Telephone:(202) sound manner, to clearly define the principles with respect to: provision of 420,4331. roles of the FAA and airport proprietors, airport f acuities;runway and taxiway i i Federal Register Na. .1g . Wedriesda anus 22''1986 'Notices. 81 / Vol.-.51. Y . $87 use;terminal'and landside facility use-, 1t.Runway and Taxiway Use Aviation Regulations(FAR)Part 150 and environmental impact management. A.Sole responsibility for assigning guidelines. L Provision of Airport Facilities use of navigable.airspace is vested in 1.Airport operators may t:ollect . the FAA and there shall be no exclusive reasonable use fees for purposes at, A.The FAA has statutory right granted for the use of any land defraying the cost of constructing, responsibility for promoting air area upon which federal funds have purchasing,and maintaining runways commerce,Including the development of been expended. and taxiways and related egdlpment,in a safe'and efficient National.air B.in managing the airspace and accordance with agreements negotiated, transportation system. runway access;the FAA will consider with users or by means of unilaterally D.To assure an adequate National proposals of regional airport authorities imposed charges,but such charges must system of public use airports,the FAA, having direct responsibility for several not be unjustly discriminatory nor as authorized by Congress,administers airports to develop specialized uses for otherwise prohibited by federal law. the Airport Improvement Program. individual airports under their 111. Terminal and Landside Facility Use Under this program grants are made to jurisdiction. public agencievand in some cases to C.Aircraft traffic control procedures A.Management of airparf facilities private owners,for the planning and and runway capacity determinations exclusive of FAA's air traffic'- development raffic'-development of public use airports will be developed and administered as responsibilities for runways and included in the National Plan of necessary by the FAA,based on safety, taxiways is the responsibility of the Integrated Airport Systems. efficiency,and environmental' Airport operator. C.Airport Improvement Program • considerations with a general objective B.Airport sponsors and operators priorities for grant awards reflect the of facilitating the movement of people should provide landside facility capacity'. degree of National interest,in projects. and goods in air commerce. consistent with capacity of runays and. Safety will be given first.i}�rity D.The FAA will monitor delays and taxiways.Future grant assurance may followed by preservation cif and their causes in the air transportation reflect this concept. increases to airport capacity where system and will identify the need and C.Airport operators may not regulate warranted.Projects at or related to potential for increasing capacity and airline routes,rates,or services.- ; airports-providing commercial air reducing delays.Where practical. However,physical limitations.'e.g.- service(including general aviation. system expansion,modernization,or runway design.weight or noise reliever airports)and experiencing or procedural improvements will be considerations,may affect aircraft anticipating capacity problems will undertaken to increase capacity. operations at some airports. continue to receive high priority. E.When necessitated by air traffic D.Management of airport facilities D.The FAA may,through the Airport delays,the FAA may implement must be consistent with Congressional Improvement Program,encourage . procedures for allocatingrunway intent to maximize competition and with i individual new airport construction access.The procedures will minimize provisions of Federal airport grant which it has identified as necessary to Government intervention,facilitate agreements,including access'to the reduce congestion and delay in the competition,and recognize that public airport for public use on fair and'-, National air transportation system: :. resources should-be available to'serve reasonable terms and without'uajttsf- ' E.Development and'maintenance of 'all the public.Specific measures to discrimination;to all Types;kfitds;'and airport facilities--runways, taxiways, achieve theseobjectives•at high density classes of aeronautical uses.'i andside terminals,and other facilities--=is airports acre the subject of separate• capacity may not be used as a basis for considered the responsibility of local rulemaking action and will'not be' arbitrarily denying airport access to ' airport operators and communities,with addressed in development of this policy. existing or potential users: an appropriate level of FAA financial F.If necessary,congestion problems E.Airport facility use procedures assistance through the-Airport experienced in the air transportation imposed by airport operators for Improvement Program. system may be mitigated by temporarily reasons other than noise shouldbe ' F.Airport grant recipients should delaying individual aircraft departures directed at landside problems.They through flow control procedures. should unreasonably constrain or,' ultimately provide a complete system of local airport facilities consistent with G.The airport sponsor and operator is reduce total airport capacity. ' responsible for the safe and efficient F.Airport sponsors are encouraged to the capacity of the element(s)funded by operation of the airport.On the airside, solve terminal and landside congestion Federal grants.The FAA is considering this includes: problems by expansion,modernization. amending its airport grant regulations to 1.Maintenance of sponsor owned or procedural improvements to increase require recipients to provide such facilities. capacity or to permit others to do so; :assurances. 2.Temporarily closing facilities during G.Airport operators may collect G.The FAA will cooperate with periods of adverse climatic conditions reasonable fees or commissions for airport operators and users to identify (e.g..snow.flood). purposes of defraying the costs of and implement capacity increasing 9. Decommissioning airport facilities constructing,purchasing,and development,equipment,and- (FAA approval is necessary if grant - maintaining airport facilities and related procedures whenever it will be funds have been expended at the equipment in accordance with• advantageous to the National air airport). agreements negotiated with aeronautical transportation system. 4.Requesting issuance of NOTAMS. users or by means of unilaterally H.The FAA will continually identify It.Airport operators may not impose imposed but not unjustly discriminatory advancements in facilities.equipment, arhitrar% restrictions denying use of charges. y and procedures(ground based or runways or taxiways for reasons IV Eravoranmental impact Monagetncnt f airborne) that are capable of increasing unwlate,'to noise.Where such noise airport capacity or efficiency and will restrictia-;is tyre necessary. they should A.In carrying out its statutory promote feasible development and be estalOtshed after consultation with responsibility to afford present and implementation. FAA an,: he consistent with Federal future relief and protection to the public t 1 �29c38 ,F.,edasstl%R"Wer a vol-51, No.,14_/,tWeadlleada,y,•Jana�y heal(hAnd wellere lrom aircWLnoiae, reducing nonoompatible land uses DEPARTMENT OF HE tTREASfiRY the FAA: around the airport., 1.Controls ikviatiou.noise through 5-%Confiict with.any exMgggrant Office of the Secretary regulations set out st.FAR Part 36.and agreements. Part 91. 8.Derogation of safety.oradverae IDepartment:Clrcular--Public DOWSwIes-- 2. controls the navigable airspace and effect on;theatffcaen4xae,and No.5-861 the manner in wMahainarafterellown management of the nevi bie.airs ace into.and.dut ofairparti;.and g P Treasury.Notes of January 34, 1988, 3.provides.technical.and.financia] and air traffic•coAtrol:systemn;. Series V�1988 support.for local airporLaoise 7.The�relstioaship ufmoise3imlta on compatibility programs, numbers;and typeSdf operations in Washington.4anuary'1e;:198s. B.-Control rofindiaidualakcraft.noise relationship to the overaltetransportatlon 1.Invitation for Tenders emission and the navigable airspace are needs of the area;and• ''I ' • Federdllypreempteii•areas,and are 8.Adverse effect•on-anyother-powers I.I.The+Recretery oRthe-Tmsury, solely-FAA responsibilities, and responsibilities of-the.Administrator under the authority df•Chapter8l of C.The formuiation and prescribed'.b law'orany other program, Title 82,!United States aCode,dllaiftes implementation.ofeairportnoise standard.or requirementestsbfiehedin tenders for.approximatelyS9.500A00,000 compatibilityprogramsare the accordance with'law. of United States securities.ide fignated responsibility of the airport proprietor, , or.P roetorsma .establish Treasury'Notea of January'81;'M, arising from its.liabilit riSeries V-1988 JCUSIPNo:9tM7-TD 4)..for.ap3r dame ea reasonablerestictions,onthetugeof - hereafter_referred.toasNotes..-4te resulting.from-the pperationof.the airports.by.time ofday or<noise Notes willbe sold atauction,:ivith encu r encouraged evalopn* etors are performance otaincraft,wheraother bidding:onsheFbasis;of yieldAh ymeat encouraged#a devatop airport noise alternatives.am ineffective-and�such will be required at-the priice.equivalent compatibility programs.in consultation restrictions areaucee with the FAA.usirlgpmceduresoutlined saryrto•ech1eve of the yield.ofaeach acceptedrbitl.aThe':. gifcautnoise. gaon. interest the in FAR Part 350. sinmititifl * D.In.formulati4locat:airportnoise KAny,proposed arestrictionson equivalent ofeachaccepte&-b"sdwttl+be' compatibility,programs,airport access,shouldbesubsutted,to-the FAA determineAin;the manner•described proprietors:are.encouraged-to:consider for review.'The'FA•A-shellconaidersuch below.(Additionalamountsmfahe,Notes revised flight.procedures,.-physical factors eorthe existing and'forecasted maybe issued to Governmeattaocounts airport:layout and development _ . noise„)rdbletn lhe•i^elative*effectiveness and Federal Reserve Banks for--their--.{-:. measures,aad4arid.use compatibility of fesiMble dlternetfve noisecoatrdis own account in exchange•#arvnatu ibto measures$s.4he4nincipal.means to and the-potential"f hpact oninterstate ' Treasury securities. minin-dze.noise.impacts.on adjacent commerce:FAR,Part'1'SOprovides Z.Descz>iption'of Securities communities.She programs may,include appropriate_guidance In cartytr%out extending control aver adjacent lands such angyses. ML The_NoteswW':be dated-January and landuses.Airpart userestrictions 31.1988,and-will accrue4aterest-frarn [ssuesfor Public Consent that a le.on a sendannuat ..; maybe-considered only.wheaothetless _ ��P res trictivealternaiivesare clearly. .'fbeo hons.aad .. baaiaon-July,3LA986.andrem!h_, a_; shown#obe.ina veteendless P policp.¢rovidedxn equent8months-on. this noticetaise issues-relevant to subs Janzm(y.3iwid effective.ways.toachieve-1hay goals of Federal airportaccese and.capacity July 3i�hroughithe date.thaiQhe.. :.. ,. the noise compatibility program-Any policy.Consequently.�IheFAA- s Principal•becomes payable:llhey!will such restrictions allould:be,reasonable interested in receiving comments mature-January 31,:1988.;andwillmot be in relationship:to the overall subject to.call•forredemption:priorRo; regarding:alternative policy options,.the maturity.la1heevent-an . a nt-slate transportation needs of.thearea and the specific.policy;putforthinthis.notioe. Y yp >m� nation. is a Saturday.Sunday;another E.Within thelimits ofavailable funds, andany additional areas relating;to nonbusiness,day..theamount-due will the FAA will.provide.Ai port airport ac cess.endrapacity.All be payable.(without additioualinterestj interested parties are invited to on#he.next-succeedin business da Improvement ProgmaiJAIP)grants to g y- participate-in the making of policy on deveIoP'andimptement.noise 2.2.7he Notes are subject loasll.taxes compatibility programs..wbere approved this subjecFby submitting such written imposed under the lnternat'Revenne bylhe FAA.Priorily,willbe•given to data,views,or arguments as they may pode:of.1954.The:Notes-arexxempt. those.airports which.have undertaken desire.-Communications-received on-or from all taxation:now or.heneafter FAR Part 150 noise_compati bili ty before April 16.1986 will be considered imposed on the obligation or interest studies. by the FAA. thereof.by any State,any possession of F.FAA review and approval of Questions concerning this policy may the.United.States.or any locattaxing•-, proposed airport noise.compatibility be directed,to:.Director.'Offiice of authority.-except as provided4n.31 ;programs will include_us_a minimum, Aviation Policy.and.Elans..Fedeial. U.S.C.3124. consideration.of: AviationAAdministratioa..Washington, 2.3.The Notes will.be acceptahle•3o:a . 1.Discrimination.against any type or D.C.20591.Telephone:202/426-3331. secure deposits of Federal public . class of user: monies.They will not be acceptablein- Z.Undue burdenon interstate or lssued'in Washington.DC january.15.1986. payment of Federal taxes. foreign commerce; Daief-McDaniel. .2.4.{Votes:in registered definitivedorm 3.Attempted controls over any Acting AvsocioteAdmiaistrotnr for Policy will beissued in denominations-of Federally preempted ureas: andlnternotionalAviation.APl-t. 55:000.$10,000.$1W.001J,and 31;000.000. 4. Effectiveness noise Notes in book-entry fora:will' be issued controls in addressing a a;ignificant 1!•'R Doc.80-1148 Filed 1-2i-aG:s:as.aml in multiplcn of those amounts:Notes will noise problem and.aclu,:v ing the goal ui oaLuwa.coof..010-13-H not be issued in bearer form. i i I L MARTINEZ AREA CHAMBER OFCONINIERCE I(CP j P.O.Ho%207 6201.esJuntas St. Nlartinet.Jnlif.94553 !Avp telt phfin[ (41S)228-1345 October 3 , 1985 Contra Costa Board of Supervisors 651 Pine Street Martinez , CA 94553 Dear Board of Supervisors, On October 1 , 1985, the Martinez Area Chamber of Commerce Board of Directors unanimously passed and adopted a resolution supporting Pacific Southwest Airlines (PSA) air service at Buchanan Airfield. I. It is the opinion of our Board of Directors that commercial air service in Contra Costa County is appropriate and very much needed and desired by the general public. Given Buchanan Field' s central location in the County and existing facilities, it would be considered and ideal choice. Therefore, we urge you to cast a favorable vote on this issue when it is before you. Sincerely eg avidson re i ent av idson en t GD/dv CONTRA COS-IA C 0 U N I L 2682 Bk I Di ivc- I,u i!r 110 S,Iri Rainoll, C", 945)8t-2338 April 18, 1986 The Honorable Tom Powers Chairman, Board of Supervisors Contra Costa County 651 Pine Street Martinez, CA 94553 Dear Chairman Powers and Members of the Board: The Contra Costa Council strongly urges your Board to approve PSA's application to begin scheduled flights from Buchanan. field. With Contra Costa' s expanding economy and increased level of business activity, it is clear that such service is needed to serve the business community. The establishment of the service will be of significant economic value to the County. The safety studies and environmental studies which have been conducted demonstrate that the flights pose no safety problems for the County' s residents. Parking and traffic impacts are also adequately addressed. We believe, therefore, that the establishment of PSA service is in the best interests of Contra Costa and its residents, and we urge you to approve the application and lease. Thank you for your consideration of our views. Sincerely, '� Linda Best Executive Director