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Has the San Diego Water Board Provided the County Helpful Comments?
By Raymond Bender
In January 2018, the County unpacked its 2018 – 2038 McClellan-Palomar (Palomar) Airport Master Plan (PMP). Also, its sister Programmatic EIR (PEIR). The San Diego Water Board (SDWB) commented, but inadequately.
The Palomar Master Plan’s Purpose
The Board of Supervisors has a simple but complex question before it: Should county by 2038 spend $112 million to move and lengthen the Palomar 4900-foot runway by 800 feet to annually handle 30% fewer aircraft than county handled before?
The county needs to know the PMP project costs, project environmental impacts, and how safely aircraft can operate with a runway ending in a methane-emitting landfill “safety area.” To act wisely, board members need the expertise of various agencies including that of the SDWB.
The county will start some projects within 7 years, others by year 12, the rest within 20 years. They will analyze specific impacts as projects progress. Unfortunately, the SDWB comment letter accepts this premise. All the above sounds quite reasonable.
Until you think about it. Consider the following scenario:
Assume the county by Year 7 installs its $25 million runway west end safety system (EMAS) including massive retaining wall and also its 200-foot $10 million east end runway extension into the landfill. But without an east end EMAS system. Then, in Year 12 while studying an added 600-foot runway extension, the Board finds out that – no matter what technology is applied – drilling hundreds of 15 foot to 40-foot holes through the runway east end 19 acre landfill will migrate garbage juice to the clean soils underlying the landfill and to ground waters and will be exorbitantly expensive.
What is the good news and what is the bad news in Year 12? The good news is the county decides not to contaminate clean soils and ground waters by moving the runway or extending it farther. The bad news is:
- When building the $25 million Palomar runway west end EMAS, the county needlessly spent about $12 million to construct a massive retaining wall whose only purpose was to allow eventually extending the runway by 900 feet rather than by the advertised 800 feet.
- By adding 200-feet to the runway (anticipating an ultimate 800 to 900-foot extension), the county got little value. Because the stated extension purpose was to allow a few aircraft to fly internationally, a 200-foot extension “buys” little additional distance.
- By running the runway into the landfill maw without adding an east end EMAS (which the county plan says would be added after the runway is moved to the north), the county has increased safety and environmental risks in two ways. First, the 200-foot extension increases the odds of a crashed large aircraft, spilling several thousand gallons of explosive aviation fuel into the landfill, forced deeper by fire trucks pouring water on the downed aircraft. Second, the absence of an east end EMAS invites this result.
In short, Board members would likely say twelve years from now: We would never have spent $22 million for a needless Palomar west end retaining wall and east end 200-foot extension and would have added a Palomar runway east end EMAS immediately if we had known of the contamination problem.
The Purpose of a PMP Programmatic EIR
We can empathize with the apparent Water Board staff assumption underlying its limited comments: “The RWQCB is now providing only general comments and will provide more specific comments if and when county undertakes its airport projects.”
Deferring critical comments makes sense when a county or city adopts a twenty-year General Plan (GP) covering hundreds of square miles. The GP area is huge. No specific projects are known. No project sponsors have been identified. Regulatory agencies commenting have no relevant database to assess project impacts.
In contrast, the Palomar Programmatic EIR involves a small area, about 240 acres of airport land including 30 acres of landfill total and 19 acres in the runway extension area. The PMP identifies its specific projects and time frames. And since at least 1996, the Water Board has collected Palomar Airport landfill specific data. The data shows:
- Since 2000, Palomar landfill units have had at least two underground fires with the Unit 3 fire lasting more than 6 months.
- In the 2000s, regulatory agencies fined the County and/or its consultant for falsely reporting airport methane gas levels at multiple county airports including Palomar.
- As recently as January 2018, a Palomar landfill monitoring well showed methane gas levels greatly above regulatory explosive limits.
- Landfills deteriorate creating garbage juice.
- Modern landfills limit garbage juice migration with a 3-foot bottom clay liner. Old landfills, such as Palomar, have no bottom liner.
- By Order 96-13, the SDWB required the county to achieve certain levels for varied landfill contaminants.
- It appears the county for twenty years has continued to annually report landfill contaminant levels greatly in excess of the Order No. 96-13 target levels.
Also, the scientific literature available to SDWB experts shows:
- “Landfill gas … contains hundreds of toxic contaminants known as Non-Methane Organic Compounds (NMOCs) as well as inorganic toxic contaminants like mercury and sometimes even radioactive contaminants like tritium. [Fact Sheet: Landfill Gas, energyjustice.net ]
- Burning trash (as with underground landfill fires fed by oxygen, namely a large broken underground concrete storm drain line) creates hazardous material.
The Sufficiency of the SD Water Board Comments
Ask yourself a simple question: If you were a Board of Supervisor member deciding in 2018 whether to spend $112 million over the next 20 years to convert Palomar to an airport handing larger aircraft by extending the Palomar runway over a methane-emitting landfill and if you want to know whether drilling hundreds of pilings through landfill trash might impact water quality, how do the SDWB March 2018 comments help you when the SDWB defers specific comments to the distant future?
Should the SDWB have commented on the following issues?
- Nature of the Landfill Risk to Ground Waters. Does the presence of landfill gas and/or materials created by Palomar underground landfill fires mean that the “garbage juice” routinely created by deteriorating trash now carries hazardous materials?
- Impact of Drilling Hundreds of Holes Through the Palomar Unit 3 Landfill. Why will drilling hundreds of holes, each 15 feet to 40 feet in depth, through the Palomar Unit 3 landfill to extend the runway not automatically carry contaminated garbage juice into clean soils and ground waters underneath the Unit 3 landfill?
- Reliability of County Mitigation Promises. Given the apparent 20-year history of the county not meeting its WB Order 96-13 water quality objectives, why should anybody believe that county drilling of hundreds of holes through the Palomar landfill will prevent migration of hazardous materials both on and off the Palomar site?
Conclusion
The Water Board can do better. It should do better. It needs to (i) immediately begin enforcing WB Order 96-13 in a meaningful fashion and (ii) immediately supplement its comments on the county PMP and PEIR.
It seems like this is one case where the Board of Supervisors should have its head in the sand, or at least in the trash.
Raymond Bender
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