By Raymond Bender
The San Diego County Board of Supervisors (BOS) cannot decide wisely when it relies on poor staff information.
Need an example? Look at the BOS October 10, 2018, McClellan-Palomar Airport, Agenda Item. Palomar is in the city of Carlsbad.
County staff recommends that the Board approve a 20-Year Palomar Master Plan (PMP) to spend up to $112,000,000 to extend the 4900-foot runway up to 900 feet and to relocate the runway about 100 feet to the north before 2036.
Conversing with Egyptian Sphinxes
Don your virtual reality glasses. The conversation below should but will not take place at the Palomar Agenda item October 10 meeting. Understand that BOS members rarely answer questions raised by the public or even ask the staff to respond. [Our hypothetical screenplay between the Supervisors/BOS and the public is italicized below.]
Palomar Master Plan (PMP) Financial Responsibility
BOS: [In confident tone.] “Sounds like a financially responsible PMP plan.” The County’s Economic Vitality Analysis Study [EVAS] shows Palomar boosts the economy. Let’s approve the PMP so we can design, approve, and construct a better runway.
The Public: But the financial numbers make no sense. Throughout the county PMP and Environmental Impact Reporter (EIR ) discussion, the county said it would use baseline data from 2016 to make its decision. The county financial study is from 2008, ten year old. Staff didn’t even tell you that. You’re not using 2016 data as promised.
BOS: We all know that airports benefit the economy.
The Public: You do realize that any 2008 financial report is woefully out of date. The entire U.S. economy nearly collapsed in 2008. Moreover, from 2014 to 2018 all Palomar air carriers failed or left Palomar and Palomar airport barely earned monies from airport operations during that period.
And one of the 2008 Emergency Visibility Assistance System financial scenarios presumed that Lindbergh Field would divert traffic to Palomar. The San Diego Regional Airport Authority and county now deny this scenario would occur.
BOS: [In gunfighter pose. Think Burt Lancaster in Gunfight at the Ok Corral. ] Is that all you got?
The Public: Glad you asked. What about:
- Palomar now has 45% fewer flights than 20 years ago.
- County itself forecasts future Palomar flights 30% less than 20 years ago.
- The FAA says county wears rose-colored glasses.
- Only 10,000 passenger flights are needed for county’s wished-for new passengers.
- County forecasts less than 500 flights out of 208,000 flights that might want a longer runway .
- County wants to spend $45 million to add 800 runway feet when Palomar replaced the entire 4900 runway feet for $8.6 million in 2009 [$50,000 v. $1,750 per linear foot].
- The county fails the FAA Grant Tests.
BOS: Why would we fail the FAA grant tests?
The Public: Because county accepted FAA grants and promised not to use Palomar Airport property for non-airport purposes without first receiving FAA written permission. For 14 years, the county used Palomar Airport canyons as trash dumping sites.
BOS: But we made land.
The Public: Yes you made unstable land that increased the runway construction cost more than 20 times, without FAA approval, and attracted birds to the landfill for 14 years, which created the threat of aircraft bird strikes.
BOS: [Aloof to facts.] Look. Since 2012, the county has spent about $2 million in county staff and consultant time studying Palomar. We will simply look bad if we don’t approve what staff wants.
The Public: [Restraining the obvious comment.] Perhaps, the Board would look good if it decided to keep the existing runway length and simply add the safety systems at runway ends that staff proposes. Only a weak BOS approves a meritless staff report.
BOS: We have to rely on staff. Staff says the EVAS study supports the PMP projects.
The Public: How is that possible? The 2008 EVAS does not even discuss the 2018 PMP 800-foot runway extension and the problems the landfill creates. Moreover, without any Palomar projects, county staff concedes that Palomar flights will increase from about 160,000 annually to more than 180,000 annually. In other words, Palomar grows without improvements,
BOS: But staff says we need the PMP improvements for safety.
The Public: In 2013, your staff hired a long-time county consultant to evaluate the safety and environmental risks of a large aircraft crashing into the landfill at the Palomar runway east end. The consultant found many potential safety and environmental risks resulting from county attracting larger aircraft to the Palomar Airport.
BOS:[Beaming & Fortissimo] There you have it. The county analyzed the risks in good faith.
The Public: Just one problem. One week ago in the Final PMP PEIR, county disavowed the county consultant report and said the consultant was not qualified to write it. Specifically, the Final PEIR says:
“The study was commissioned by the County and conducted by the County’s on-call landfill management consultant … However, after the County received a first draft of the study, staff determined that it contained incorrect assumptions of aviation principles and mechanics, and the analyzed conditions were too speculative in nature. … [T]he Study did not correctly portray how an aircraft collision would realistically occur. … [T]he Study was discontinued and never finalized.”
BOS: Well, why would we rely on an inaccurate report?
The Public: So let us understand. The county was incapable of picking a qualified consultant that had worked for the county for many years. And the consultant’s report was so harmful to the county that the county chose not to analyze the issue at all with another consultant?
BOS: We can always do another study.
The Public: That’s not the point. Staff was to provide you a report to justify designing and building $112,000,000 of improvements. When staff saw an obstacle to project approval, staff simply trash-canned the report. Shouldn’t we have the county consultant at the Board meeting so questions can be asked?
BOS: Besides we should have safety systems, the EMAS at each runway end.
The Public: The FAA has written an 80-page opinion, affirmed by the Washington Court of Appeals, that B-II airports can safely handle C and D aircraft with 350-foot runway safety areas and without an EMAS. Palomar does not need to spend $25 million for two EMAS systems. But we support them.
BOS: We understand the public objects to the county PMP Programmatic EIR. Why?
The Public: Many reasons. Let’s just discuss one: the county’s faulty Greenhouse Gas Analysis. In the last few years, the California courts have struck down the County of San Diego Greenhouse Gas General Plan and Regulatory program, most recently a few days ago when the Sierra Club prevailed. Why would you certify a PMP PEIR, which contains an equally defective Greenhouse Gas Analysis?
BOS: Well we can’t just stop county business.
The Public: Gee, we thought you might listen to what two courts have told you and do the Greenhouse Gas Analysis much more professionally.
BOS: Ok. All those in favor of adopting the PMP and certifying the PEIR, Vote. Let the county clerk record five Ayes.
The Public: Aye Ve.