HomeMy WebLinkAbout2000-07-25; City Council; 15841; Evaluation Of Acquisition Of Palomar Airport’ I .
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AB# 15,841 TITLE: Evaluation of Acquisition of DEPT Hi.=
MTG. 7-2s- 40 McClellan-Palomar Airport CITY AlTY
DEPT. RMlED iliE CITY MGR
RECOMMENDED ACTION:
Accept the Evahation of Acquisition of McClellan-Palomar Airport Report.
I tern Explanation:
In 1999, staff was assigned a City Council goal for fiscal year 1999-2000 to evaluate
the acquisition of McClellan-Palomar Airport. In support of the goal staff has
prepared an in depth report, shown as Exhibit 1, which addresses many of the
pertinent issues that the Council would need to consider before taking further
action toward acquisition, as well as issues which impact the City regardless of any
interest in acquisition.
In order to develop the report staff first interviewed City Council members to obtain
clarification on the intent and expectations around the goal. The interviews revealed
two primary goals for acquisition that were shared by all five Council members.
These included: (1) control of land uses, and (2) improved operation of the airport.
Other goals cited include, ensuring that funds earmarked for airport improvements
are spent at McClellan-Palomar and implemented in a timely manner, generation of
more revenue to the City, management of noise issues more effectively, and
expansion of commercial service. In addition, the City Council asked staff to
consider environmental issues and liabilities.
Based on staffs findings, it is clear that through an acquisition of McClellan-
Palomar Airport the City would achieve greater land use control than currently
exists. However, while greater land use control could be achieved, staff has
concluded that there are a number of factors that limit the City’s ability to influence
or affect how the airport operates. In addition, other factors were identified that
offset the benefits of airport ownership.
It is staff’s opinion that acquisition of McClellan-Palomar Airport would not be
prudent at this time; therefore, staff is recommending that Council accept the report
that includes measures that provide the City Council with alternatives to address
some of their concerns.
Fiscal Impact:
None.
Exhibits: t
C- - IQ I dTY OF CARLSBAD - AGENtfi BILL
1. Evaluation of Acquisition of McClellan-Palomar Airport Report (on file in the Office
of the City Clerk)
EVALUATION ofACOUISITION qf MCCLELLAN-PALOMAR AIRPORT REPORT
April 3,200O
EXECUTIVE SUMMARY
In 1999 staff was assigned a City Council goal to evaluate the acquisition of McClellan-
Palomar Airport. In support of the goal staff has prepared an in depth report which
addresses many of the pertinent issues that the Council would need to consider before
taking further action toward acquisition, as well as issues which impact the City
regardless of any interest in acquisition. In order to develop the report staff first
interviewed City Council members to obtain clarification on the intent and expectations
around the goal. The interviews revealed two primary goals for acquisition that were
shared by all five Council members. These included: (1) control of land uses, and (2)
improved operation of the airport. Other goals cited include, ensuring that funds
earmarked for airport improvements are spent at McClellan-Palomar and implemented in
a timely manner, generation of more revenue to the City, management of noise issues
more effectively, and expansion of commercial service. In addition the City Council
asked staff to consider environmental issues and liabilities.
Based on our findings, it is clear that through an acquisition of McClellan-Palomar
Airport, the City would achieve greater land use control than currently exists. However,
while greater land use control could be achieved, our research concluded that there are a
number of factors that limit the City’s ability to influence or affect how the airport
operates. In addition, other factors were identified that offset the benefits of airport
ownership. These factors are included in the Conclusions and Recommendations section
of the report.
It is staffs opinion that acquisition of McClellan-Palomar Airport would not be prudent
at this time; therefore, we are recommending City Council not take any further action on
this matter. However staff has identified measures in the report that provide the City
Council with alternatives to address some of their concerns.
Finally, environmental concerns associated with the landfill beneath the airport and
exacerbated by airport maintenance practices were identified. The significance of these
issues and their relevance to the community, as well as recommendations for addressing
them are included in the report.
REPORT OUTLINE
The report is divided into the following sections: I. How Airports Operate; II. San Diego
County Airports Overview; III. McClellan-Palomar Airport - Land Use; IV. Economic
Benefit of McClellan-Palomar Airport; V. Airport Financing; VI. McCellan-
PalomarKounty Airports Sale or Lease; VII. McClellan-Palomar Airport Environmental
Issues; VIII. Conclusions & Recommendations; IX. Exhibits: Exhibit 1 Total Impact of
McClellan-Palomar Airport ; Exhibit 2 Airport Enterprise Fund; Exhibits 3- 15 Airport
Noise.
I. HOW AIRPORTS OPERATE
Although each airport or system of airports in the United States is unique, most county
and multi-government airport facilities function similarly. In most cases airports are
overseen by a special district or authority, commission, special department of a city or
county, or an advisory board. Authorities can be multi-purpose or aviation only, and are
increasingly prevalent. An authority form of management is considered appropriate
when:
l A task or service is judged inappropriate to be performed by a private enterprise;
l Large amounts of capital are needed;
l Efficient management with initiative and business imagination is essential;
l Long-range planning must be in the hands of competent business, financial, and
professional technicians;
l The task/service must be self-supporting;
l The task/service must be free from political interference;
l The scope of the task/service involves areas more extensive than the established
geographic boundaries of state and local government.
Whatever the operating entity, it is critical for the airport administration to be able to
report directly and independently to the source of policy flow, and not be subordinated in
another unit created for another purpose. Airport officials must plan, develop, operate
and maintain airports so that they meet user’s requirements and owners level of quality.
Administrators must also arrange financing for capital improvements and budget
revenues from the various products so that costs can be equitably shared among the users
and owners.
Airports are usually divided into “air-side” and “land-side” areas for financing and
accounting purposes. The air-side portion consists of areas upon which an aircraft can
operate (runways, taxiways, aprons, and hangars). Land-side means terminals,
automobile parking, airport oriented businesses, roads, or mass transit leading to the
airport. The airport general manager is responsible for providing (or supervising the
provision by others) of air-side and land-side products at the quality levels established by
the policy source. For example, a major activity of the airport’s operations or
administration office focuses on negotiating leases with concessionaires, landing fees
with airlines, parking rates, and taxi-airport drop off fees. Essentially, airport
administration provides tools, procedures and programs under which the airport’s
management delivers, or supervises the delivery of the airports products and services.
Sources of Revenue
The most important product provided is air transportation. Carriers that wish to serve a
particular community or region seek to lease space at the airport of their choice. They
negotiate landing fees, the number of gates, space for ticket counters and offices, and
assorted other fees with airport administrators. For example, some airport authorities
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have individual lease agreements with several carriers. The rental fees charged them are
calculated to ensure that the airport generates sufficient revenues to operate the airport on
a break-even basis after paying debt service on all outstanding bonds; paying the costs of
operation and maintenance; and making agreed-upon contributions to the capital reserve
accounts.
Under the “residual cost” formula established in the agreements, revenues from sources
other than airline rentals and fees are credited against the airport’s total operating,
maintenance, and capital outlay requirements to determine the amount the carriers will
pay. Additional airfield and aviation revenues include ground and building rentals of
sites, hangars, and facilities leased to other airport tenants including fixed base operations
(FBO’s). There are also fuel flowage fees, and concession fees from in-flight catering
services. Ground transportation and concession revenues typically come from pubic
parking, employee parking, rental cars, food and beverage restaurants, as well as news
and gift stores. Airport revenues are also derived from telephone, advertising, and taxi
and limousine service.
Over the past several years, airlines have been able to negotiate favorable deals for
improved facilities at little cost to them. For example airport administration generally has
the discretion to waive or reduce certain fees, offer free ticket-counter and baggage claim
rental, and limit the cost of office space. However, one item that usually cannot be
waived is landing fees. If management reduces one carrier’s fees, the other airline(s)
generally will demand, and are entitled to the same treatment. Depending on the size and
degree of cost/revenue control, some airports generate revenues predominantly from the
rental of space, land or other facilities, rather than from landing fees and other operating
charges.
Airports can also be partially supported through city and county appropriations and/or
dedicated taxes; however, most medium sized and large airports are able to turn a profit
on their own and do not require local assistance. State governments have traditionally
played a subordinate role in financing air facilities, but the federal government has played
a primary role. When a decision is made to construct, improve or expand an airport,
federal grants are nearly always involved, as are local funds and money from the airlines
that stand to benefit from the change or improvement.
The portion of airport revenue derived from federal aid bears an inverse relationship to
the size of the airport. In other words, large airports receive significantly less funding on
a percentage basis than do non-hub reliever airports and general aviation airports. This
federal money comes from the Federal Aviation Administration’s (FM) Trust Fund.
FAA Trust Fund
The FAA Trust Fund was created in 1958, with part of its mission to manage federal
grants for airport planning and capital improvement projects. This money was
appropriated from the General Fund. The Airport and Airway Trust Fund and its grant
program, the Airport Development Aid Program, were established by Congress in 1970.
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The Trust Fund is capitalized through passenger ticket taxes and other excise taxes and
user fees. Congress reauthorized the budget for the Trust Fund under the Airport and
Airway Act of 1982. The grant program was renamed the Airport Improvement Program
(AIP), and the 1982 act defined airports eligible for grants.
Local FundinP Mechanisms
In the United States, ownership of airports rests almost entirely with local governmental
agencies. These typically have few capital resources, but federal involvement does not
eliminate the need for local financing mechanisms. Airport capital requirements are
generally met through the sale of obligation bonds or revenue bonds, with some measure
of state assistance.
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II. SAN DIEGO COUNTY AIRPORTS OVERVIEW
COUNTY AIRPORTS SYSTEM
The San Diego region has a total of 16 airport facilities owned and operated by a variety
of public agencies both local and federal. Eight of the region’s airports are owned and
operated by the County of San Diego, making it the largest airport system, serving the
greatest number of users in the San Diego Region. The County has been operating
airports since 1947, during which time it has developed into one of the largest regional
airport systems in the State of California. It is considered a part of the National Air
Transportation System and includes one (1) primary commercial airport, McClellan-
Palomar; two (2) regional airports, Gillespie Field and Ramona; three (3) community
airports, Jacumba, Borrego Valley, and Fallbrook; and two (2) limited use facilities, Agua
Caliente Springs Airstrip and Octotillo Airport. These airports collectively provide for
general aviation, corporate and commercial aviation, and provide land available for lease,
for aviation, industrial and non-aviation purposes.
Since these eight airports are owned and operated by the County of San Diego, the
County Board of Supervisors sets all policy and provides the overall direction for the
County airport system. In addition to its policy role, the Board of Supervisors has
appointed a number of advisory committees to monitor and advise County staff and the
Board on airport activities and issues. These committees include the Gillespie Field
Development Council, the Palomar Airport Advisory Committee, and the Fallbrook
Community Airpark Advisory Committee. The County airport system is operated by the
County’s Department of Public Works, Airport Division which includes a support staff of
25. Twelve of airport system team provide management and administrative support to all
eight airports, the balance of personnel are located at Gillespie Field, McClellan-Palomar
and Ramona airports.
A primary goal for the County Board of Supervisors has been to keep the airport system
fully self-supporting. In 1980, the Board established an Airport Enterprise Fund (AEF),
where revenues generated from each of the eight county airports are collected so that they
may be kept separate from the County’s General Fund. These airport revenues are then
used to fund the entire airport system as well as pay any debt service the system has
incurred. These monies also provide the required matching funds for FAA capital grants.
In addition, the AEF has provided some of the funding of other public improvements and
enhancements at individual airports deemed important for the continued economic growth
and financial health of the entire airport system. The use of an enterprise accounting
system has enabled the County airport system to operated within the revenues it
generates. The FY2000 County Airports budget request totals $25.6 million with $16
million requested for funding of a variety of capital improvement projects in the airport
system.
POLICY F-44
In 1987, the County Board of Supervisors established a policy (F-44) to provide
guidelines for the operation and development of McClellan-Palomar Airport. The policy
was modified in 1991 and then again in 1996. The policy is scheduled to sunset on
December 3 1,2002, but can be reviewed for continuance prior to this date. The
following eight items are outlined in Policy F-44:
1.
2.
3.
4.
5.
6.
7.
The role of Mc-Clellan Palomar Airport shall be to provide air transportation for
the residents of North San Diego County and to facilitate General Aviation
activities while minimizing noise impacts on surrounding areas and communities.
Scheduled commuter airline operations are limited to aircraft having 10 to 60
seats and meeting the approach speed and wing span categories for McClellan-
Palomar Airport in accordance with FAA regulations. Commuter airline aircraft
shall meet the FAA State III noise criteria.
The Airport will operate with one runway that simultaneously accommodates a
4,700 foot landing distance and a 5,000 foot take off distance; the 300 foot
difference, a displaced threshold on the runway’s east end, will increase safety of
the airport while reducing noise levels.
The County will take a proactive role working with local agencies and the FAA to
protect the airspace around the airport ti-om encroachment and to promote
compatible off airport land development, and to insure the future safety and
compatibility of the existing runway length.
The County will operate the airport in accordance with any adopted FAA Part 150
Noise Compatibility Program and in full compliance with any State or Federal
mandated noise standards relating to the operation of a public airport. The
program will recognized the Noise Element of the City of Carlsbad’s General Plan
and implement mitigation measures to minimize noise impacts.
.
The County will monitor aircraft noise and verify the Community Noise
Equivalent Level (CNEL) noise contours within the airport influence area as
described in the Palomar Airport Comprehensive Land Use Plan as well as
monitor pilot compliance with any adopted FAA Part 150 Noise Abatement
Program. The County will continue to monitor air traffic around the airport with a
noise monitoring and flight tracking system and implement procedures to mitigate
single event noise complaints.
The Airport Manager will produce distribute and promote a detailed noise
abatement program for the airport. The program will contain specific flight
information and a chart identifying noise sensitive areas. The noise abatement
Program will be updated annually and distributed to pilots. The Airport Manager
will request pilot compliance with the program.
8. This policy recognizes SANDAG’s Airport Land Use Plan.
HISTORY OF MCCLELLAN-PALOMAR AIRPORT
Most of the land on which the County’s airport facilities are located were dedicated by
the federal government as a means of maintaining a general aviation network throughout
the nation. Originally the Airport was referred to simply as Palomar Airport, however, in
1982 the airport was rededicated to McClellan-Palomar Airport in honor of Gerald
McClellan, an aviator and North San Diego County leader who was instrumental in
developing the airport.
l In 1958, the County purchased approximately 238 acres for $144,000 to site Palomar
Airport in the City of Carlsbad. The Palomar Airport site was acquired as a
replacement for the De1 Mar Airport, which was also owned and operated by the
County of San Diego.
l In 1958, the Federal Aviation Administration (FAA) provided a grant for additional
land and improvements for Palomar Airport.
l In 1959, Palomar Airport opened for business after construction was completed on a
3,700 foot long, 100 foot wide runway.
l During the 1960’s, a terminal building was constructed, the runway was extended to
4,700 foot in length and widened to 150 feet, and runway lighting was installed.
l The air traffic control tower was installed by the FAA in 1973.
l In 1974, when the County acquired an additional 225 acres for $1.5 million, Palomar
Airport was expanded again.
l In 1976 an Airport Master Plan was approved by the County Board of Supervisors.
l An Instrument Landing System (ILS) and approach lighting system were installed in
1977.
l During the early 1990’s high intensity approach lights and airport perimeter fencing
was installed.
l In 1996/97 improvements were completed to comply with FAR Part 139 certification.
The certification took effect December 1,1998.
l In 1997 the County Board of Supervisors approved a new Master Plan for McClellan-
Palomar Airport.
l In 1999 a new, interim terminal facility was added.
,- In total, it is estimated that the FAA, through numerous grants, has participated in more
than 50% of the acquisition and development costs of McClellan-Palomar Airport.
AIRPORT FACILITIES
McClellan-Palomar Airport is a single runway facility serviced by an air traffic control
tower operated by the FAA. It is classified as a general utility facility, an airport mainly
serving aircraft with a maximum gross takeoff weight of 12,000 pounds or less, although
some larger aircraft do operate at the airport The airport occupies approximately 255
acres of land, with an additional 211 acres of County owned airport separated from the
airport by Palomar Airport Road and El Camino Real. McClellan-Palomar Airport is the
only airport with and Instrument Landing System (ILS) between Lindbergh Field and
Santa Ana that can accommodate the business aircraft over 12,500 pounds. The Airport
is open 24 hours a day, however, most take-off and landings occur between 7a.m. and
1 lp.m., with a voluntary curfew of 10 p.m. to 7 a.m.
Currently Palomar Airport is served by two regional airlines, United Express and
America West Express. United Express makes 11 round-trip flights per day to and from
Los Angeles International Airport. America West operates 4 round-trip flights per day to
. and from Sky Harbor Airport in Phoenix, Arizona.
Air traffic statistics at McClellan-Palomar Airport are recorded by on-site county airport
management staff. Information on aircraft operations is provided by the FAA control
tower staff. County staff also collects and records data concerning commercial
passenger activity at the airport.
AIRPORT OPERATIONS
In 1998 Palomar Airport handled over 60,000 enplanements and 132,000 total
passengers. The airport also serves a variety of corporate aircraft, general aviation fliers,
and offers sightseeing excursions on vintage aircraft. McClellan-Palomar recently
became a Federal Aviation Regulation Part 139 Certificated Airport, expanding safety
and security features, thereby enabling larger commercial aircraft to service the facility.
Emplanements at Palomar are projected to grow to more than 287,000 within the next 20
years, with passenger throughput forecast to exceed 630,000.
There are six (6) fixed base operators providing aircraft parking, aircraft storage hangars,
aviation fuel, major aircraft and engine repair, automobile rental and flight instruction. In
1998 there were 490 aircraft based at the airport, most of which involved single engine
aircraft. Revenue fi-om Palomar Airport are derived primarily from aviation and
commercial leases, and represent approximately 34% of the total airport system revenue.
III. MCCLELLAN-PALOMAR AIRPORT - LAND USE
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CARLSBAD GENERAL PLAN
There are eight elements of the Carlsbad General Plan, with four of them applicable to
McClellan-Palomar Airport. These include the Land Use Element, Circulation Element,
Noise Element and Public Safety Element. However, the General Plan elements that are
most comprehensive with respect to McClellan-Palomar are the Land Use and Noise
Elements. The General Plan also designates McClellan-Palomar Airport as a
Governmental Facility.
The General Plan requires coordination with the San Diego Association of Governments
and the Federal Aviation Administration to protect public health, safety and welfare by
ensuring the orderly operation of the Airport and the adoption of land use measures that
minimize the public’s exposure to excessive noise and safety hazards within areas around
the airport.
Land Use Element
Land for development of McClellan-Palomar Airport was purchased in 1958, with
construction of the airport complete in March of 1959. The airport was built atop the
mesa just south of the Agua Hedionda valley and lagoon. Oriented to take advantage of
the on-shore winds, the runway lies on an east-west axis. The associated glide path, crash
hazard, and noise impact areas around the airport significantly influence the type and
intensity of development across the entire central area of the City of Carlsbad. This area
of influence extends generally in a broad band east and west of the runway, and to a
lesser degree, north and south of the airport. To limit noise impacts on noise sensitive
land and for reasons of general health and safety, the City has designated areas
surrounding the Airport for predominately planned industrial and commercial uses. To
accomplish this, a significant amount of non-residential land has been designated on the
General Plan. Residential development and most institutional land uses, such as hospitals
and schools, are precluded from this area of airport influence.
Noise Element
California’s Planning and Zoning Laws require a Noise Element which identifies and
appraises noise problems in the community. The Law specifically requires that noise
levels of commercial, general aviation, heliport, helistop, and military airport operations,
aircraft overflights, jet engine test stands, and all other ground facilities and maintenance
functions related to airport operations be analyzed and quantified, to the extent
practicable by the legislative body.
In California, the technique used for quantifying aircraft noise is the community noise
equivalent level (CNEL). The CNEL is a descriptor of daily noise environment. It
accounts for the magnitude, the time of day, and the frequency of occurrence of noise
intrusions. The CNEL is calculated from the hourly noise by a formula prescribe in the
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California Noise Standards. The outside boundaries of the areas generally subject to such
noise are usually portrayed by lines overlaid on a map of the area around the airport.
These boundary lines are referred to as “noise contours”. The noise contours are the basis
for delineating the airport’s Area of Influence and for establishing a pattern of land uses
in the General Plan Land Use Element. Projected noise contours are provided in the
Comprehensive Land Use Plan for Palomar Airport.
COMPREHENSIVE LAND USE PLAN (CLUP)
In 1970, the State of California enacted a law requiring the formation of an Airport Land
Use Commission (ALUC) in each county containing a public airport. The law required
that a comprehensive land use plan be formulated that would provide for the orderly
growth of each public airport as well as the areas that surround an airport. This was done
as a means to insure the safety and the general welfare of the inhabitants within the
vicinity of the airport and the public in general.
The San Diego County Board of Supervisors, by unanimous vote on December 15,1970,
recommended that the San Diego Association of Governments (SANDAG) be designated
to assume the responsibility of the county’s Airport Land Use Commission (ALUC) and
be charged with development and adoption of a Comprehensive Land Use Plan (CLUP)
for each public airport. The purpose of the CLUP is to identify areas likely to be
impacted by noise and flight activity created by aircraft operations at the airports. Its
primary use is to provide information about specific impacted property in terms of land
use or construction implications, and mitigation measures necessary to permit
development that is compatible with airport operation. The most recent CLUP for
McClellan-Palomar Airport was adopted in April 1994. As a long range master plan the
CLUP reflects the anticipated growth of the airport over the next 20 years. So that the
information contained in the CLUP remains current, it is updated every five years.
State law requires that the City’s General Plan comply with the Airports Comprehensive
Land Use Plan. If the City chooses to overrule a finding of the Airport Land Use
Commission, it must do so by a two-thirds vote of the City Council, it makes a specific
finding that the General Plan and the CLUP are consistent. The City’s General Plan,
adopted in 1994 is consistent with the CLUP.
AIRPORT INFLUENCE AREA
The Airport Land Use Commission establishes an Airport Influence Area for each airport
in the region. The Influence Area encompasses those areas adjacent to airports that could
be impacted by noise levels exceeding the California State Noise Standards or where
height restrictions would be needed to prevent obstructions to navigable airspace as
outlined in the Federal Aviation Administration regulations. It represents the boundary of
the Commission’s planning and review authority. The Commission procedure ensures a
regional overview to protect the airport’s operations and to prevent the creation of new
noise and safety problems. The cities of Carlsbad, Encinitas, Vista, San Marcos, and
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Oceanside, through their community planning processes and zoning ordinances, retain
land use control within the Airport Influence Area.
The City of Carlsbad has established an overlay zone for the AI-UC designated Area of
Influence. The procedure requires that all parcels of land located in the Airport Influence
obtain either a site development plan, planned industrial permit, or other discretionary
permit and comply with the noise standards of the CLUP and Federal Aviation
Administration building height and lighting obstruction requirements.
RUNWAY PROTECTION ZONE
The Runway Protection Zone for McClellan-Palomar Airport are the land areas adjacent
to the ends of the runway’s primary surface, over which aircraft using the airport must
pass for each operation, either arrival or departure. The only land uses compatible with
the Runway Protection Zone are: natural recreation areas or habitat and species
preservation areas; public rights-of-way, agriculture, or storage facilities. In addition,
areas immediately adjacent to the airport in every direction are zoned with a height limit
of 35 feet (average), to ensure that new construction will not penetrate either the approach
surfaces at the runway ends or the transitional surfaces along the length of the runway.
FLIGHT ACTIVITY ZONE
Areas designated as within the Flight Activity Zone are sites where most problems my be
expected to occur. Flight activity hazard areas are those areas most likely to experience a
crash and generally lie beneath the flight pattern, especially in the final approach to the
runway. The Flight Activity Zone overlays private properties. It identifies areas which
should be held free of intensive development, including high rise development and all
uses that involve the assembly of large groups of people (more than 100).
MC-CLELLAN PALOMAR AIRPORT MASTER PLAN
The County Board of Supervisors approved a Master Plan for McClellan-Palomar Airport
in 1976 that had a planning horizon of twenty (20) years (1975-1995). The purpose of
the Airport Master Plan is to identify the Airport’s potential needs and future
development during a twenty year period. In 1996, the County began an update of the
1976 Master Plan and provided the Carlsbad City Council with an overview of the major
components. In September 1997 the County Board of Supervisors approved the new
Airport Master Plan. As with the first Master Plan, it also has a 20 year planning horizon
(1995-2015).
The Plan is divided into five year increments. Certain facilities are required to be in place
as certain important thresholds are reached. A key factor in determining future facility
requirements was to estimate future demand. Forecasts of future aviation activity a the
Airport were estimated based on national, regional, and local trends in aviation activity
and economic growth as well as projected population growth in the Carlsbad area. This
information was then used to estimate numbers of based aircraft, aircraft fleet mix,
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passenger enplanements, annual aircraft operations, and peaking characteristics. Since
airport improvements are based primarily on demand and not a specific year or
timeframe, improvements are programmed as specified levels of activity are reached.
CITY OF CARLSBAD CONDITIONAL USE PERMIT
On September 24, 1980, the Carlsbad Planning Commission issued a Conditional Use
Permit (CUP 172) for McClellan-Palomar Airport which allowed for certain structures
and facilities without additional discretionary review. Provided uses proposed by the
County are consistent with the approved Master Plan and the Conditional Use Permit,
they are permitted to apply directly for a building permit. In this way the Airport Master
Plan is implemented administratively.
In 1998 the County of San Diego began processing a Conditional Use Permit Amendment
(CUP 172A) to update their existing conditional use permit to reflect (1) existing
conditions; (2) reflect the 1997 Board approved Master Plan, and (3) adjust the
configuration of the property covered by CUP 172. On February 4, 1999, the CUP
Amendment was withdrawn by the County, because of mitigation concerns for the
Palomar Airport Road/El Camino Real intersection failure. To date there has been no
resubmittal of the CUP amendment by the County.
CARLSBAD MUNICIPAL CODE
On August 5, 1980, an initiative petition dealing with future expansion of Palomar
Airport was presented to the Carlsbad City Council by Carlsbad voters. On August 12,
1980, the following ordinance was adopted by the Carlsbad City Council:
“2 1 S3.0 15 Voter authorization required for airport expansion.
(a) The City Council shall not approved any zone change, general plan
amendment or any other legislative enactment necessary to authorize
expansion of any airport in the city nor shall the city commence any
action or spend any funds preparatory to or in anticipation of such
approvals without having been first authorized to do so by a majority
vote of qualified electors of the city voting at an election for such
purposes.
(b) This section was proposed by initiative petition and adopted by the
vote of the city council without submission to the voters and it shall
not be repealed or amended except by a vote of the people.”
Based on this section of the Carlsbad Municipal Code, any proposal for construction of
structures or facilities which are not listed in the approved Conditional Use Permit, would
require an amendment.
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C IV. ECONOMIC BENEFIT OF MCCLELLAN-PALOMAR AIRPORT
ECONOMIC STUDY
The overwhelming majority of studies that examine the impact of airports on local or
regional economic development conclude that they exert a positive effect. However, it is
not altogether clear whether airports lead or follow economic growth. Air transportation
appears to be a prerequisite, but not necessarily a sufficient condition for certain
industries in their site selection deliberations. Also airport facilities alone are not the only
element involved in regional and local development. What is clear is that air travel has
grown significantly since deregulation in 1978, resulting in thousands more travelers
passing though airports across the country. It is also clear that a number of businesses
and industries value access to an airport.
In a study conducted by Carnegie Mellon University in 1989-90, researchers verified that
one of the most significant airport attributes affecting a regional economy is the number
of destinations available and the frequency of flights to those destinations. Combine the
expanding market with the need to reach those markets, and consistently the response
from public leaders as been clear, pro-growth airport policies. Cities across the nation
have begun to improve and expand their airports while others are constructing new ones
from the ground up. However, as air traffic in an area increases, and airports are
expanded to handle the flow and or boost the local economy, noise and vibrations from
aircraft create a problem for people living nearby. It is not uncommon for airport
development to be curtailed due to citizen opposition, In fact, economic impact studies
are often commissioned to convince nay-sayers of the advantages of airport development;
In 1994, the County of San Diego commissioned an Economic Benefit Study for
McClellan-Palomar Airport. The study was conducted by Coffinan Associates and
Arizona State University College of Business and followed procedures in its
methodology that were recommended by the Federal Aviation Administration (FAA) and
the California Department of Transportation (CalTrans). Since 1994, no new or updated
studies have been conducted and the estimates made at that time of future growth of the
airport are understated compared with actual data we have today. This section of the
airport analysis will not make an independent assessment of the economic benefits, rather
it will highlight the findings and predictions of the 1994 study.
According to the Study:
“Airports benefit the regional economy through the employment, payroll, and
spending associated with aviation activity both on and off the airport. Airports
are sources of measurable economic benefits impacting jobs, income and regional
spending levels.
13
Suppliers of aviation services, such as airlines, private businesses serving general
aviation, other airport tenants, and various government agencies, all create jobs
and value added for the local economy.
Air travelers create economic benefits that extend throughout the region. Visitors
who arrive by air generally have greater expenditures for lodging, retail,
entertainment, and food as compared to visitors using other modes of travel.
However, it is important for citizens and policy makers to be aware that airports
create significant unmeasured social and economic benefits for the regions which
they serve. For example, convenient air transportation allows freedom for
individuals to travel to satisfy their preferences for goods, services, and personal
needs Airports make the regional economy more competitive by providing
businesses ready access to markets, materials and international commerce.
Airports also bring essential services to a community, including enhanced medical
care (such as air ambulance service), support for law enforcement an fire control,
and courier delivery of mail and freight. These services raise the quality of life
for residents and maintain a competitive environment for economic development.”
“An efficient airport can provide a competitive edge for communities seeking
corporate relocations and expansions. Two out of every three Fortune 500
companies use private aircraft for their business to transport goods, material, and
personnel.”
Data collected during the study was input into special economic impact models
developed by the FAA and CalTrans in order to determine McClellan-Palomar Airports
contribution to the local, regional and state economy. Benefits were categorized as either
Direct or Induced (multiplier effect of direct benefits) and then combined to represent a
Total Benefit (Exhibit 1).
DIRECT BENEFITS
These are benefits that result from (1) on-airport economic activity of airlines, fixed base
operators, all other airport tenants, and government agencies including the airport
authority, as well as (2) off-airport activity that includes spending by air travelers for
lodging, restaurants, entertainment, ground transportation and retail goods and services.
These measures represent the amount of “first round spending, value added (new output),
,payroll, and jobs in the McClellan-Palomar service area that were the result of the
presence of the airport during the study period. This is the direct economic activity that
would not have occurred without the airport, the aviation services provide there, and
spending by users of these services.
14
INDUCED BENEFITS
These are the multiplier effects of the Direct Benefits and represent additional spending
that is generated as a result of the on and off airport activities. It in effect becomes a
“second round” of spending that occurs as a result of the airport. Dollars spent by
suppliers or users of aviation services create or induce additional output, jobs and payroll,
as they circulate within the economy, creating a multiplier effect. Induced impacts occur
when an on-airport service provider purchases supplies or services locally, pays wages to
its workers, or undertakes capital expenditures. All of these outlays create local jobs,
additional output and income as the dollars circulate in the economy.
In addition to direct and induced Benefits, the study looked at gross revenues, value
added, payroll and
employment as a way of measuring the economic benefits.
GROSS REVENUE
Total sales of business firms and budgets of government agencies, or the total flow of
dollars from aviation-related activity. These are not subject to multiplier effects, since
only the value added component stays within the local economy.
VALUE ADDED
This is a measure of new output created within the region. Value added results when
input materials are processed by labor, under the direction of management, to produce a
product for resale or service.
PAYROLL
This is a component of value added, representing the payment for labor used to create
new output from aviation related activity.
EMPLOYMENT
This is the number of jobs required to create the gross revenues and value added.
According to the 1994 study, in 1993-94 McClellan-Palomar Airport provided the
following benefits to the regional/local economy:
TOTAL ECONOMIC BENEFITS OF MCCLELLAN -PALOMAR
. 1,270 Jobs
l $33 Million Total Payroll
l $88 Million Value Added
l $108 Million Gross Revenues
15
These Total Economic Benefits can be broken into the following categories:
, /-.
Total Benefits from Air Operations: Includes airlines, air cargo, auto rental, FBO
services, food services, flight instruction, charter services, medical transport, aerial
photography, aircraft maintenance, aircraft sales and rentals, government agencies, airport
administration, and capital projects.
. 290 Jobs
l $7.4 Million Total Payroll
l $27.4 Million Value Added
l $32.9 Million Gross Revenues
Total Benefits from Air Visitors: Includes lodging, food and drink, retail goods and
services, entertainment and transportation.
. 320 Jobs
l $6.6 Million Total Payroll
l $12.7 Million Value Added
l $17 Million Gross Revenues
Total Benefits from Travel Agents:
. 13 Jobs
l $296,000 Payroll
l $740,000 Value Added
l $11 Million Gross Revenues
SUMMARY
The County commissioned study anticipated the future economic impact of McClellan-
Palomar Airport and made a number of projections for both 2000 and 2005 utilizing a
projected number of passenger enplanements of 33,000 and 45,000 respectively.
Unfortunately these figures understate the actual number of enplanements that occurred
even as early as 1998 (over 60,000 enplanements and 132,000 passengers) and therefore
significantly under estimate McClellan-Palomar’s future and current economic impact.
However, utilizing the projection of 45,000 enplanements for the year 2005, the direct
economic benefits from the airport were expected to be $114.5 Million in business
revenues, 1,472 Jobs, $33.9 million in payroll, and $71.1 million in value added.
Indirect benefits were expected to be an additional 1,531 jobs, $46 million in payroll and
$113.6 million in value added. Although the estimate of operations are lower that the
actual data they do indicate a significant economic contribution to the City of Carlsbad,
North San Diego County and the region.
It is safe to assume that continued growth in the number of enplanements and passengers
will result in greater economic growth and benefit to the City and the region in the future.
However, the extent of economic benefit will likely be contingent upon the County’s
16
.--
F
.
ability to continue to upgrade airport facilities and provide other on and offsite
improvements in support of this growth.
17
V. AIRPORT FINANCING
NATIONAL OVERVIEW
Airports are required by federal statute to operate as self-sufficiently as possible (49
U.S.C. Section 47107(a)( 13)(A)). This is a condition of federal grants, airports’
traditional source of capital, and an increasingly important obligation. Intense
competition in the airline industry has resulted in greater pressure on airports to contain
costs, the federal government has reduced the amount of grant funding available, and the
ability of existing sources of capital to meet airport infrastructure needs is uncertain.
Airport Improvement Program (AIP)
The Federal Aviation Administration administers the federal airport grant program, the
Airport Improvement Program (AIP). AIP grants help finance projects that enhance
airports’ capacity, safety, security, and noise mitigation. Generally, most types of airfield
improvements, such as runways, lighting, navigational aids, and land acquisition, are
eligible, while hangars and interest expense on airport debt are not. AIP-eligible projects
for airport areas serving travelers and the general public - called “land-side development”
- include entrance roadways, pedestrian walkways and movers, and space within terminal
buildings that does not produce revenue and is used by the public, such as waiting areas.
AIP-ineligible land-side development projects include revenue-producing terminal areas,
such as ticket counters and concessions, and the interest on construction bonds.
The AIP plays a significant role in funding airports, especially smaller airports
(commercial-service airports with fewer than 1.5 million passenger boardings a year). In
a 1999 report by the U.S. General Accounting Office (GAO), using data from 1996, the
most recent year for which the GAO conducted an analysis, the nation’s 3,233 smaller
national system airports obtained $1.5 billion in funding, about 22 percent of the total that
year. These airports relied on AIP grants for half of their funding, followed by tax-
exempt airport and special facility bonds, and state grants. Passenger facility charges
(PFC), a fee imposed on each passenger per trip segment and which is to be used on
airport related capital projects, accounted for only 7 percent of smaller airports’ funding
mix. Conversely, larger airports received more than $5.5 billion in funding, relying on
airport bonds for 62 percent of their total funding, followed by PFC collections. AIP
grants accounted for only 10 percent of larger airports’ funding.
Whether existing sources of capital will be adequate to meet future development needs is
uncertain. In GAO reports on airport development needs published in 1999, the Office
looked at studies which indicate substantial future investment in airport infrastructure is
needed. The reports use airport funding in 1996 and conclude that as much as $1.4
billion, or % of smaller airports’ planned development that is eligible for grants may not
be funded on an annual basis (a lack of funding for only about l/5 of larger airports’
planned development was projected). Small airports planned to spend nearly $3 billion
per year for capital development during 1997 through 2001, or $1.4 billion per year more
18
than they were able to fund in 1996. Smaller airports’ planned development consists of
projects eligible for Airport Improvement Program grants, such as air-side items which
include runways, taxiways and noise abatement, and projects not eligible for grants, such
as roads, parking lots, hangars and terminal retail space.
Despite smaller airports’ heavy reliance on federal funding and GAO reports identifying
critical capital improvement needs, the trend for the AIP is reduced funding that “will
represent a shrinking percentage of airport funding”, according to the GAO. At its peak in
fiscal year 1992, AIP spending was $1.9 billion, almost 25% of that year’s national
airport capital costs. Spending dropped below $1.5 billion in 1995, and did not increase
until 1998 when it totaled only $1.62 billion. Fiscal year 1999 AIP funding was $1.95
billion, but the AIP was authorized for only 6 months, through Mar, 3 1, 1999, and the
FAA was allowed to commit to airports only half the amount funded, or $975 million,
until the AIP was further extended. The inability of Congress to resolve FAA
reauthorization issues resulted in two more short term extensions and FAA funding
gridlock. The year ended with the FAA operating two months without authorization and
Congress continuing to debate legislation to reauthorize the FAA’s programs. Funding
for fiscal year 2000 is $1.85 billion, but as of February 17,2000, the program remained
suspended without authorization.
McClellan-PalomarKanital ImprovementsKountv Airnorts
The County’s airport system depends on financial assistance from the FAA to meet the
majority of its capital needs but it operates within the revenues that it generates.
According to “A Study of County Airports” conducted by the County in 1999, the system
is funded through the Airport Enterprise Fund (AEF), it does not receive any funding
from the County’s General Fund, and it has an operating budget of approximately $4
million, a capital budget close to $9 million, and operating revenue in the amount of
$4.26 million. The report also shows that the cost of operating the entire airport system is
$3.85 million, and only 2 of the system’s 8 airports operate with a surplus of revenue
over expenses: (1) Gillespie Field, with industrial leases contributing approximately 45%
of total operating revenues for the County airport system; and (2) Palomar, generating
34% of the total operating revenue of $4.26 million, or 37% of the cost of operating the
entire airport system with revenue primarily from aviation leases and commercial leases.
The 7/l/98 thru l/8/99 AEF revenue and expenses statement provided by the County is
shown in Exhibit 2.
A few years ago, County Airports had a reserve of around $6 million. Since that time,
according to the Study, the agency has embarked on a very aggressive capital program
and the great majority of this “reserve” was allocated to specific projects. The end result
is that the reserve fund is close to being depleted. The balance at the end of Fiscal Year
1998-99 was projected at $1.44 million.
The largest of the expenditures that has led to the reserve depletion was a loan of
approximately $6 million to the County’s Redevelopment Agency to help fund the
establishment of an industrial park next to Gillespie Field Airport, located in a
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Redevelopment Agency Project Area. It is a contiguous area of approximately 746 acres,
of which 342 acres are devoted to airport related activities. There are more large parcels
within this area to be developed. As a result, to continue the development of property for
non-aviation uses, additional loans from the AEF are projected through fiscal year 2012-
13 and the issuance of nearly $16 million of debt by the Redevelopment Agency is
planned before the end of 2006.
The County’s efforts to increase non-aviation revenue are consistent with federal statutes
that (1) require the airport system to operate with an overall goal to be “as self sustaining
as possible” (49 U.S.C. Section 47107(a)(13)(A)); and (2) encourage airports to become
totally self-supporting by enhancing their commercial or groundside revenues. Under 49
U.S.C. Section 47107(b), airports are mandated to limit total aeronautical revenues to
total aeronautical costs-thus prohibiting any operating income from aeronautical sources.
Moreover, without the development of non-aviation sources of revenue the County
airport system could not sustain itself. According to the Study, the County’s aviation
lease revenues do not support the cost of services provided to the airport users. The
addition of non-aviation and industrial park revenue provides needed capital for both the
operations and capital development of the airport system. Land placed in the non-
aviation arena brings five times the return of land that is restricted to aviation uses.
Finally, the non-aviation property is critical to airport funding as it provides for a more
diverse source of revenue than the land restricted to aviation uses only.
While there are ample opportunities for expansion of non-aviation revenue sources at
Gillespie, such opportunities at Palomar are limited. The airport is land locked and has
very little opportunity for expansion beyond the existing property boundaries. According
to Bob Durant, Airports/Transit Public Works Manager, there is a significant need,
however, for the expansion of commercial aviation uses at the airport. Mr. Durant reports
that the Fixed Base Operators (FBOs) are now moving toward more corporate clients
because they purchase more fuel than do general aviation aircraft operators, and the FBOs
may be able to increase rents with these clients. In addition, according to Airport
Manager Floyd Best, more commuter airlines are interested in Palomar. Expansion for
these uses, however, requires a new terminal and additional parking. According to the
County’s 1999Airports Annual Business Plan, with a financial plan spanning 20 years,
. ..aviation revenue at McClellan-Palomar airport should increase substantially with the
construction of the new terminal building and parking facility to service the growing
commercial passenger market. This will propel the aviation revenue system-wide to a
level of near self-supportability. This will likely occur between years five and ten based
on our current enplanement forecasts. At this time, however, there is little progress
toward realizing this projection. Both a new terminal and additional parking have not
been moved out of the early stages of planning.
A parking study to address long term needs and the design of a new terminal were
projected for this current and next fiscal year respectively. However, according to Mr.
Durant, the earliest the parking study could begin is fiscal year 2000-01 and it is uncertain
if the terminal design can be realized that year.
20
Over the past year or longer, the County as been discussing the development of the
terminal and parking with Palomar Airport Centre (PAC), the management firm for the
“Burrows Leasehold”, an FBO with the first right of refusal for the development of their
12 acre parcel. According to Mr. Durant, a study on the development of a terminal, just
south and west of the existing terminal, and parking on this property will be done by the
end of March, 2000. On the basis of that study, he believes that the parties should be able
to determine if they can pursue the project. While working with PAC, the long term
parking needs study has been put on hold. In any case, development of a new terminal
cannot proceed without first resolving the issue of parking.
Last year, Mr. Durant reported to the Palomar Airport Advisory Committee that the cost
of a new terminal is estimated at $4.5 million to $5 million, which cannot be justified
unless there is adequate parking. However, additional parking cannot be constructed
without an approved amended conditional use permit (CUP). The County has not
obtained this permit for 2 reasons.
(1) A CUP amendment application (CUP 172A) was submitted on May 12,
1998. It was withdrawn on February 4, 1999, as a result of traffic
mitigation requirements. According to Mr. Durant, the County’s
contribution to the Palomar Airport Road improvement project should
satisfy the requirement for County participation in traffic mitigation on
this roadway. In a March 22,200O interview of Mr. Durant, he added that
the improvements to the airport are even more important to the City than
the County, and some time ago, he sent the City a letter requesting relief
from the requirement but has not yet had a response. He acknowledged
that this may be because the CUP amendment application has not been re-
submitted. According to both the Planning and Engineering Departments,
the letter has not been received, and to date, the application has not been
re-submitted.
(2) According to Mr. Best, there has not been adequate staff time to complete
and re-submit the application.
Until the CUP amendment can begin to be processed, long term parking and a new
terminal cannot be addressed, and opportunities for expansion of revenue and revenue
sources will continue to be limited.
In the Business Plan the AEF reserve is projected to decline to about $500,000 in fiscal
year 2000-01, and then grow again to approximately $1 million in 2004-05, nearly $17
million in 2009-l 0, and approximately $80 million in 2018-l 9. However, capital projects
between 1999-00 and 2004-05 total more than $58 million with the AEF share targeted at
just over $11 million. As Mr. Durant wrote in the Fall ‘99 issue of PLANENEWS, the
County Airports’ newsletter, “while the 20-year financial plan for County Airports
provides a picture of prosperity, the immediate future has demands for improvements that
exceed available resources.” In addition, as the Business Plan emphasizes, the growing
level of the reserve over the twenty-year period should be viewed with caution because
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(1) years 6-20 of the Plan are very scant in terms of capital development; (2) it is based
on current economic conditions - if the economy deteriorates, the lease revenue streams
and the tax increment revenue that is generated by the Gillespie Field Redevelopment
Project will be affected and the reserve level will decline; and (3) the Plan assumes a very
high level (60%) of FAA assistance for capital development.
Another reason to view the projected growth in the AEF reserve with caution is the
financial liability County Airports has picked up since the Business Plan was completed.
At the end of 1999, improvements needed at Palomar as a result of airport property
deterioration associated with the underlying landfill were identified. While the County
Inactive Waste Site Management Group, a division of the County Department of Public
Works (DPW), has a trust fund of approximately $100 million that funds the maintenance
of the County’s eighteen (18) inactive landfills, part of the responsibility for the current
condition of the property has been allocated to the Airports Division of DPW. As a
result, some of the estimated $4 million cost of improvements taking place this year will
be “billed” to Airports. According to John Rollin, Public Works Manager in the Inactive
Waste Site Management division, in an interview in late 1999, the amount to be funded
by Airports has yet to be worked out. In the interest of time, his division agreed to pay
the full amount now and work out later the amount to be reimbursed by Airports. Finally,
it is unknown if there will be any future financial liability for the landfill allocated to the
Airports Division. According to Mr. Rollin, the regrading and re-paving work in
progress is only a “temporary fix.”
22
VI. MCCLELLAN-PALOMARKOUNTY AIRPORTS
SALE OR LEASE
NATIONAL OVERVIEW
Various legal obstacles have deterred attempts to sell or lease commercial airports in the
U.S. According to the November 7, 1996 GAO report “Airport Privatization: Issues
Related to the Sale or Lease of U.S. Commercial Airports”, the primary obstacle stems
from the legal assurances airports agree to meet as a condition to obtaining federal grants.
The FAA maintains that airports must continue to adhere to these assurances as part of
any transfer of control, and these legal obligations cannot be unilaterally extinguished by
repaying the grants (in testimony by the GAO earlier that same year, it was noted that the
FAA has not sought any reimbursement when airport ownership has been transferred
between public entities). Particularly problematic is the assurance regarding the use of
airport revenue. Current law generally requires that revenue generated by public airports
must be used exclusively to pay for their capital and operating costs and cannot be
diverted for non-airport purposes. Because the FAA contends that airport revenue
includes any sale or lease proceeds, local and state governments are entitled to recover
only their unreimbursed capital and operating costs from these proceeds. As a result, the
GAO concludes, the financial incentive to sell or lease is diminished.
McClellan-PalomarKountv Airports
In 1999, the County evaluated the feasibility and advisability of the sale or lease of one or
more of its airports. The County’s study included the results of a survey of twelve airport
agencies, a general assessment of the state of the County’s airports (County Airports),
and a review of the federal regulations related to the sale of a County airport.
Report findings include:
While the great majority of agencies develop and manage their own hangars, County
Airports is one of the few agencies that solely rely on the private sector to develop
hangar facilities, thus minimizing the County’s risk in economic downturns;
Although four of the twelve agencies surveyed depend on the receipt of general
government funds, County Airports does not rely on the County’s General Fund,
County Airports has one of the lowest fee structures and still is able to remain self-
sufficient;
County Airports’ staffing is very lean (staff of 25 to support 8 airports);
Tie-down fees could be increased;
Efficiency of lease administration needs to be examined; and
23
l Stakeholders have a high level of customer satisfaction.
Major conclusions of the study include:
1.
2.
3.
4.
5.
6.
Three “critical success factors” for County Airports are: (a) self-sufficiency; (b)
aggressive property development; and (c) partnership with the private sector to help
develop its airports.
The sale of any County airport would require FAA approval of those airports that
occupy land that was dedicated by the federal government, and reimbursement to the
FAA of funds that were awarded through grants for the improvement of the subject
airports. Specifically, the approximately $6.1 million of FAA funds that were used to
purchase and develop McClellan-Palomar Airport would have to be returned to the
FAA, assuming that the FAA approved of the sale.
Any sale of airport property would require that the County address its past use of
redevelopment bonds. The County issued redevelopment bonds in 1995 to finance the
development of an industrial park adjacent to Gillespie Field. The Master Pledge
Agreement for this bond issue requires the County to provide a solvent airport system
to ensure the security of the bonds. Because of this requirement, the Agreement
prohibits the sale of airport property except in narrowly defined circumstances.
About $230,000 of County Airports’ overhead is charged to Palomar on an annual
basis. While the elimination of Palomar from the County system would decrease
some overhead expense, the majority of this expense would need to be carried by the
remaining airports.
Any sale of Palomar would require consideration of the issue of the inactive landfills
upon which it is built. The sale would remove revenues but leave the County with
ongoing liabilities for the landfills.
Because the County’s airport system is self supporting and not a burden to the
General Fund, coupled with the revenue diversion restriction and grant repayment
requirement, there is no compelling reason for the County to sell at this time.
The report was given to the Board of Supervisors for their review with recommendations
to (1) continue with the current management system; (2) continue to explore legal
restrictions to long term leases or sale and assess the strength of the market as it becomes
mature; and (3) implement a process improvement plan to expedite the lease adjustment
when there is an escalation clause to ensure that the County receives market value on all
leases.
24
C -
VII. MCCLELLAN PALOMAR AIRPORT
ENVIRONMENTAL ISSUES
Airports create smog, contaminate waterways and generate a significant amount of noise
pollution. The environmental impacts of airports that will be discussed include noise, and
ground water contamination and hazardous gas specific to the landfills beneath Palomar
Airport.
NOISE
NATIONAL OVERVIEW
Communities throughout the U.S. are struggling to address the impact of aircraft noise on
residents. This nationwide struggle is the result of federal regulations that restrict the
control of airport operations for noise control purposes.
The limitations on noise control activities are spelled out in the Airport Noise and
Capacity Act of 1990 (ANCA). This legislation resulted in large part due to the efforts of
local agencies to restrict airport operations to reduce airport noise impacts on residents,
and concerns that these efforts would impede growth in aviation. Findings of Congress
cited in the Act include: (1) aviation noise management is crucial to the continued
increase in airport capacity; (2) community noise concerns have led to uncoordinated and
inconsistent restrictions on aviation which could impede the national air transportation
systems; and (3) a noise policy must be implemented at the national level. The main
features of the Act are requirements that (1) by the year 2000 all jet aircraft weighing
75,000 pounds or more at civilian airports be Stage-3 aircraft (aircraft that incorporate the
latest technology for suppressing jet-engine noise); and (2) impose further constraints on
the authority of airport owners to introduce any new noise and access restrictions.
Now, to obtain FAA approval for a restriction, ANCA implementing regulations in
Federal Aviation Regulation (FAR) Part 161 require substantial evidence to support
compliance with six statutory conditions. To meet these conditions, the airport sponsor
must demonstrate that the proposed restriction:
l is reasonable, non-arbitrary, and nondiscriminatory between classes of aircraft;
l does not create an undue burden on interstate or foreign commerce;
l is not inconsistent with maintaining the safe and efficient utilization of the navigable
airspace;
l does not conflict with any existing Federal statute or regulation;
l has been afforded adequate opportunity for public comment; and
l does not create an undue burden on the national aviation system.
According to FAA attorney Monroe Balton, compliance with Part 161 is very expensive,
time consuming, and requires an extensive noise study. Mr. Balton reports that there
25
have been only two attempts at this study in the Western Pacific region, and in the ten
years since passage of the Act, none have been completed.
McClellan-Palomar Airport
Noise Compatibility Program (Part 1.50 Program): In 1992, the County proposed some
noise abatement and mitigation measures to the FAA, through the development of a noise
compatibility program under Federal Aviation Regulation Part 150. The FAA’s FAR Part
150 noise compatibility program focuses on airport noise as it relates to land use
planning. It provides for the voluntary development of noise exposure maps and noise
compatibility programs by airport operators, and FAA approval procedures. An approved
Part 150 noise compatibility program is required for an airport operator to receive FAA
grant funds for most noise mitigation projects.
Many of the proposed measures that were approved were administrative, represented a
continuation of existing practices, or were already within the authority of the City of
Carlsbad and the County of San Diego. These included measures such as updating City
and County land use plans to reflect noise exposure areas, ensuring that aircraft noise
levels are included in the fair disclosure statement for certain properties (see the “Noise
Impact Notification Area” discussed in Exhibits 3a-c), educating pilots about noise
sensitive areas, and continuing to have the airport advisory committee serve as a forum
for discussion of noise abatement actions.
Only two other measures were approved as proposed: (1) a noise monitoring system, and
the FAA specified that “this approval does not extend to the use of monitoring equipment
for enforcement purposes by insitu measurement of any pre-set noise thresholds”; and (2)
a voluntary stage 2 (a level of technology for suppressing jet-engine noise) jet departure
curfew between 10:00 p.m. and 7:00 a.m. through a letter of agreement between the
County and stage 2 jet aircraft at the airport.
The remaining measures proposed were either disapproved, approved with the
modification that they be voluntary measures only, or the FAA determined that there was
“no action required at this time”. For some of the measures disapproved or for which no
action was taken, the FAA noted that additional analysis was required. According to
FAA Environmental Specialist David Kessler, who worked with the County on its
program, he is not aware of any additional analysis that was submitted. A complete
listing of the measures proposed and the FAA’s response to each is shown in Exhibit 4.
Noise Complaints: Noise complaints received at the airport center around low flying
planes, pilots who fly over residential areas, and planes that fly outside the voluntary
curfew hours. The following is a summary of relevant airport operations and noise
complaint statistics, some of the constraints to addressing the complaints, and recent
actions taken to address the issue.
26
.- 1. Airport Operations:
(a) Level: Airport operations - take-offs and landings - were greater in every month of
1999 than any previous year since 1992. Total operations in 1999 were 292,000, up
19% from the total of 245,000 in 1998 (Exhibit 5). Palomar Airport was the busiest
airport in the county last year, with more operations than both Lindbergh and
Montgomery airports (Exhibit 6).
(b) Factors in airport operation levels and aircraft true: General aviation (GA) makes up
78% of the aircraft using the airport; corporate jets make up 18% and commercial
flights make up 4%. According to Airport Manager Floyd Best, the predominant
factors responsible for the increase in operations are the mild weather and healthy
economy, which encourage general aviation flights (Exhibit 7). Mr. Best reports that
most GA pilots can’t fly in inclement weather because they are not instrument rated,
and the strong economy has made the high cost of flying more affordable.
(c) Traffic - Local and Transient: The majority of airport operations are transient. In
1998 about 2/3 of the operations were transient. In 1999, the total was closer to 3/
(Exhibit 8). According to the 1999 National Business Aviation Association
Handbook, Palomar is in the top 20 airports based on itinerant general aviation
operations (Exhibit 9).
2. Complaints: The following data is limited by the fact that technical problems at the
airport during 1999 prevented an unknown number of callers from logging their
complaints.
(a) Level: Complaints in 1999 were well above that of 1998, equivalent to the total in
1997, and with the exception of 1994, higher than any other year since1 992. Airport
staff has acknowledged that*during 1999, as a result of technical problems, not all
callers were able to log their complaints. As a result, it can only be concluded that
complaint levels in 1999 were most likely the second to the highest if not the highest
recorded since 1992. (Exhibit 10).
(b) Bv communitv: In 1999,2/3 of the complaints were from residents of Carlsbad, and
of those, nearly half originated from the Poinsettia area, southwest of the airport
(Exhibit 11).
(c) Bv aircraft tvpe: Noise complaints are predominantly over propeller-driven aircraft.
In 1999, the noise complaints by aircraft type were: propeller - 41%; jet - 28%;
helicopter - 7%; commercial - 5%; and unknown - 19% (Exhibit 12).
(d) Bv time of dav: Noise complaints are most often the result of flights between 7:00
a.m. and 5:00 p.m. In 1999, the noise complaints by time of day were: 7:00 a.m.-
5:00 p.m.: 75%; 5:00 p.m.-lo:00 p.m.: 13%; and 10:00 p.m.-7:OO a.m.: 12% (Exhibit
13).
27
3. Constraints to resolving complaints about (a) low-flying aircraft; (b) flight paths
over residential areas; and (c) flights outside the voluntary curfew hours:
(a) Flight Altitude - The airspace is controlled by the FAA. To provide maneuvering
room for aircraft to safely descend into and climb out from the airport, the FAA
established a cylinder of airspace 7 miles in diameter and 2,800 feet in altitude,
centered around the airport runway. This airspace is known as “Class D Airspace”.
“Class E” areas have been designated as extensions of this airspace to provide
controlled airspace for instrument approaches from the north and east (Exhibit 14).
These areas coincide closely with the noise impact notification area discussed in
Exhibits 3a-c and shown in Exhibit 15.
According to Mr. Best, a pilot needs to get to 1,000 feet as he exits the Class D air space
if he is going to transit over a populated area. However, while in this airspace he may be
lower than 1,000 feet and he can climb within the performance capabilities of his
airplane, or per instructions from the tower, to reach a cruising altitude or the coast.
Propeller-driven aircraft cannot climb as quickly as other aircraft, which may account in
part for the significant percentage of complaints attributed to these planes.
(b) Flight Path: Flight paths are controlled by the FAA’s control tower at the airport. The
“preferred path”, established by the FAA in consultation with airport management to
minimize aircraft noise impacts on the community, is directly west out of the airport
and over the intersection of Palomar Airport Road and I-5 to the ocean. This flight
pattern is recommended and voluntary to pilots. A pilot is free to take any course
he/she wants unless directed otherwise by a tower controller who is charged with
keeping aircraft at safe distances.
According to Air Traffic Control Tower Chief Sallyanne Rice, the tower must
frequently direct aircraft outside the preferred path for safety reasons. The airport is a
single runway facility with jet aircraft mixed in with much slower aircraft, and when
patterns are busy, controllers must vector (“fan out”) aircraft in other headings to
maintain a safe margin between them. According to Ms. Rice, this occurs 200-300
times per day. With an average of 8 11 operations per day last year, this means that %
to more than l/3 of the aircraft fly outside the preferred path every day.
(c) Curfew: Per the FAA, the airport’s curfew may be voluntary only. Any attempt to
make it mandatory would require the extensive studies required by the Airport Noise
and Capacity Act discussed earlier. According to Mr. Best, Airport staff does,
however, attempt to contact pilots who fly during curfew hours. Mr. Best reports that
when the security guard can, he notes the identification number of an aircraft that
“violates” the curfew and staff follows up with a letter to the operator. Mr. Best also
reports the following difficulties in reaching the operators and getting “compliance”
with the curfew: (1) transient aircraft may be registered to an aviation company in
another state with an address that is difficult to locate; (2) registration to a business
makes it difficult to locate the individual pilot; and (3) a pilot may have to fly after
hours because a client needs to travel during that time.
28
(4) Actions in response to complaints:
(a) Complaint call and response process - The airport’s response to complaints is to
identify the plane and its flight path through the noise monitoring system, and educate
pilots on proper flight procedures. Both the software and hardware of the noise
monitoring system were upgraded at the end of last year.
Since the end of December, the County has contracted with a Noise Reporting Specialist
who collects noise complaints left on voice mail, and according to Mr. Best, investigates
each one (in 1999, Mr. Durant reported that complaints were addressed on an ad hoc basis
and that this was going to change). In addition, the phone system was updated at the end
of last year to ensure that all callers could leave a message, and a complaint form was
added to the airport website to provide another means to file a complaint.
(b) Education/Awareness: Actions the County reported taking the past year to reinforce
noise abatement efforts include: (1) meetings with FAA tower personnel, airline
owners, flight schools and air carrier chief pilots; (2) reinforcing the preferred flight
pattern, and noise sensitivity in the County’s PLANENEWS publication; and (3)
placing the noise abatement procedures on County Airports’ website.
(c) Coordination between FAA, County and City and outreach to public: As a result of
escalating noise complaints in 1999, a public workshop on airport noise issues was
held by the County, along with the FAA and the City of Carlsbad, on January 20,
2000. About 100 citizens attended the meeting. As a result of the workshop and a
meeting between the City, County and FAA held earlier that same day, consensus was
reached on 3 actions items: (1) update the Part 150 Noise Compatibility Program; (2)
the County will request that the FAA allow the airport to use the noise monitoring
equipment for enforcement purposes; and (3) establish periodic roundtable
discussions involving all the interested stakeholders to better understand and address
the complexities of airport operations and noise control.
Since the workshop and as of February 16,2000, the following actions have been taken:
(1) the County has sent a letter to the FAA requesting permission to use the monitoring
system for enforcement purposes; (2) Mr. Durant reported to Council that in March,
County staff would like to visit roundtable discussions in the cities of Santa Monica and
Torrance, and he would like City staff and interested groups to go as well; (3) on
February 8,2000, the Council expressed support for these actions, City participation in
the roundtable discussions, and the County seeking solutions by investigating noise
control activities at other airports; and (4) on February 15,2000, the County Board of
Supervisors gave staff approval to apply for a grant to update the existing Part 150 Noise
Study. According to the staff report that went to the Board, the study is expected to cost
approximately $250,000 (the FAA’s grant program typically funds 90% of the cost) and
take a minimum of three years to complete.
29
LANDFILL
STATE OVERVIEW
According to the State Water Resources Control Board (SWRCB), until the early 198Os,
little attention was given to regulating or investigating potential ground water pollution
sources. Water pollution control efforts focused primarily on controlling the discharge of
sewage and industrial wastes into surface waters - rivers, streams, lakes and the ocean.
Since then, pollution concerns have shifted to contamination of ground water by toxic
chemicals and other substances. This change in focus was prompted by the introduction
of thousands of new chemicals into the environment since World War II, and major
advances in detection technology which revealed traces of chemicals in wells state and
nationwide.
A significant source of ground water contamination is leaking landfills. In a 1995
SWRCB study of active and inactive landfills in California, for which water quality solid
waste assessment test reports were submitted, the percentage found to be polluting
ground water with municipal solid waste (MSW) leachate (“garbage juice”) was between
72% and 86%.
In a 1994 paper by G. Fred Lee, Ph.D., PE, DEE, prepared for the California
Environmental Protection Agency, Dr. Lee wrote that chemicals released from landfills to
nearby ground water and to the air via leachate and landfill gas contain a wide variety of
potential carcinogens and potentially toxic chemicals that represent a threat to public
health. According to Dr. Lee, the leachate from MSW landfills is a highly concentrated
“chemical soup”, so concentrated that small amounts of leachate can pollute large
amounts of ground water rendering it unsuitable for use for domestic water supply.
Furthermore, he wrote, both gas and Ieachate from MSW landfills contain many organic
chemicals that have not been characterized with respect to specific chemical content or
their associated public health or other hazards. These <non-conventional pollutants ’
include more than 95% of the prganics in MSW leachate.
According to SWRCB, monitoring data collected in the late seventies “indicated that
fluids leaked from landfills were reaching ground water.” In 1984, an increased
awareness of the adverse environmental and health effects caused by many common
organic compounds prompted the inclusion of organic compounds in water quality
analyses from landfills. These analyses indicated that volatile and semi-volatile organic
compounds (VOCs) were found in ground water near landfills, and in many cases, at
concentrations exceeding regulatory levels. That same year, revisions to the California
Code of Regulations, Title 23, Division 3, Chapter 15, governing discharges of waste to
land, required landfill operators to prepare a monitoring plan for all active landfills; the
decision as to whether to monitor an inactive landfill was at the discretion of the Regional
Water Quality Control Board (RWQCB), based on potential threat to water quality.
Monitoring wells were to be designed specifically for the purpose of ground water
monitoring. After the RWQCB approved the plan, the discharger was to establish
monitoring points, start monitoring and submit monitoring reports. In 1986, the first year
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of the program, few such monitoring programs had been established. In addition,
according to SWRCB, funding for this program was reduced significantly in 1988, cut
completely in fiscal year 1991-92, and only limited funds were available in fiscal years
1992-93 through 1994-95 to review a backlog of submitted reports. According to San
Diego RWQCB staff, funding has not been appropriated since that time, resulting in little
review of these ground water monitoring reports.
PALOMAR AIRPORT LANDFILL
Three closed landfill sites, owned and operated by the County between 1962 and 1975,
and referred to as Landfill Units l-3, lie beneath the airport. Situated from west to east,
Unit 1, the oldest unit, is approximately 9 acres, Unit 2 is 5 acres, and Unit 3 is 19 acres.
The average trash depth for each unit is approximately 20 feet. The top deck of Unit 1 is
paved with asphalt concrete and the area is leased for general aviation purposes. Portable
hangars and light weight storage buildings have been erected over Unit 1, with adjacent
parking facilities for automobiles and fixed-wing aircraft. Similarly, the top deck of Unit
2 has been paved with asphalt concrete, and this area provides maneuvering room for
aircraft, aircraft tie downs, and access to permanent hangers outside the Unit. There is no
development on Unit 3, located at the eastern end of the runway.
A review of RWQCB and Department of Environmental Health files on the Landfill
reveal (1) concerns about landfill gas emissions and the protection of ground water that
date back nearly 10 years; and (2) the County Department of Public Works’ (DPW) slow
and inadequate responses to the requests of the environmental oversight agencies for
measures to prevent environmental degradation and protect the public’s health.
Environmental hazards documented by the Air Pollution Control District, RWQCB and
Department of Environmental Health include: (1) inadequate monitoring and control of
methane gas emissions; (2) cracking of asphalt which allows infiltration of water into
underlying wastes; (3) “differential settlement” that (a) impacts drainage structures, (b)
impacts sideslopes (causing erosion rills which can result in exposed solid wastes), (c)
impacts the integrity of structures, and (d) provides a pathway for the release of landfill
gases into the atmosphere and structures, and which can compromise the integrity of the
landfill gas collection system; and (4) methane emissions through asphalt fractures
exceeding the “lower explosive limit”. Documentation also includes (1) the Landfill is
leaking and needs monitoring to assess the extent of contamination of ground water; (2)
there are an insufficient number of monitoring wells to determine ground water flow
direction; and (3) correspondence over inadequate responses, insufficient required reports
from DPW, and the issuance of numerous notices of violation.
The County’s lack of action to resolve these problems resulted in actions by the oversight
agencies that include: (1) the issuance of 2 notices of violation by the Regional Water
Quality Control Board, one in 1998 and one in 1999; (2) a letter from the Local
Enforcement Agency (LEA) reviewing the recent history of numerous violations and
requiring immediate corrective actions (the LEA is the County Department of
Environmental Health, responsible for the regulation of solid waste disposal sites under
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the authority of the Public Resources Code and Title 27 of the California Code of
Regulations); and (3) an inspection by the California Interactive Waste Management
Board.
These actions and the agencies seem to have a limited impact on DPW. While some
remediation work is currently in progress, there is little evidence to suggest that there will
be on-going and long term efforts to prevent environmental degradation and comply with
waste discharge regulations to protect the environment and the public. A review of the
violations documented by RWQCB and the LEA, as well as information about ground
water issues documented over several years, recent actions by DPW, and implications for
the City’s Dry Weather Testing Program and ground water quality in Carlsbad are
discussed below.
(1) Regional Water Quality Control Board (RWQCB):
(A) On June 12,1998, RWQCB issued a notice of violation for failure to perform
adequate landfill maintenance, and the percolation of surface drainage through waste. A
workplan to mitigate the landfill settlement and improve drainage was required by July
3 1,1998. DPW submitted a workplan on July 30,1998; however, the RWQCB
responded to the submittal with concerns about both the vague scope of work and design
of remediation and repairs, and the lack of a start date for long-term compliance work.
(B) On April 22, 1999, a second notice of violation was issued in follow-up to the earlier
one because the violations regarding landfill maintenance and drainage had not been
addressed. The notice also included (1) the fact that gas measurements by the LEA
“indicated the lower explosive limit was exceeded for methane” and that this also was a
violation; and (2) the agency’s concerns about DPW’s lack of specific milestones and
dates in its long term workplan remained to be addressed and were required by May 20,
1999. On May 19, 1999, DPW submitted a list of 5 general tasks: preliminary
engineering report, engineering, environmental approval, advertise/award contracts, and
construction with tentative completion dates between November 1999 and December
2000. RWQCB requested a more detailed schedule which was submitted the following
November with work projected to occur during the same time frame.
Missing from these notices was any mention of ground water monitoring, even though
attached to the April 22, 1999 notice was a April 8, 1999 inspection report documenting
inadequate ground water monitoring because of “inadequate number of monitoring wells
to determine ground water flow direction for each unit”. Furthermore, the need for
. additional monitoring wells for the determination of ground water flow direction had
been documented many times since 1997, the first year DPW submitted a ground water
monitoring report under the RWQCB’s 1996 updated waste discharge requirements
(WDR). In that report the County’s consultant noted the following violations: (1) ground
water flow rate and direction has not been determined (because existing wells are
inadequate to enable this determination); and (2) water quality protection standards have
not been developed (because ground water flow directions are not available). The report
also noted that the County plans to establish additional wells.
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According to RWQCB staff, the violations did not mention the insufficient number of
wells because “there are so many things wrong out there” that RWQCB decided to just
focus on a few items, and the County has consistently reported that they will put in more
monitoring wells. RWQCB staff also reports that for some time the County maintained
that it would construct a “subsurface barrier” as a ground water protection measure. This
intention was communicated in a letter from DPW to the Department of Health Services
back in 1993, as a result of refuse found outside the known boundaries of Unit 2 and
discovered while drilling ground water monitoring wells. According to RWQCB staff,
the barrier was never constructed.
RWQCB has continued to document the inadequate ground water monitoring at the
airport, and information submitted by DPW during the past year, information collected in
the City’s Dry Weather Testing Program during the past year, and recent actions by DPW
highlight the importance of these wells. These three areas are discussed below.
On April 30, 1999, DPW submitted the 1998 annual monitoring report and cover memo
which included the following: (1) a number of volatile organic compounds (VOCs) were
detected in the wells at all of the units; (2) testing of a “seep” near the southwest comer of
Unit 3 revealed “constituents similar to those historically detected in ground water wells
downgradient from Units 2 and 3.” The seep occurred in the north face of a trench
associated with storm drain and road construction along the north side of Palomar
Airport Road. Evidence of seepage was noted along 30 to 50 feet of the trench wall east
and west of a storm drain outlet box located approximately 40 feet from the southwest
corner of Unit 3.... Standing water was present in the bottom of the storm drain outlet
box and, based on the assumption that the seep was the source of that water, a sample
was collected for analysis. The results were typical leachate indicators. Several metals
also exceeded applicable standards. The VOC constituents detected match those detected
in wells MW-I, MW-5 and MW-7, all of which monitor shallow ground water. The
laboratory results and the proximity of the seep to the land$ll suggest leachate as the
source.. . ; (3) The County is developing a site characterization and workplan for
implementation of an Evaluation Monitoring Program (EMP) at the site.... The
investigation is intended to evaluate the source, nature and extent of impacts to ground
water and determine ground water-flow directions.... As part the of EA4P investigation, . . .
the County plans to install a suficient number of wells in each aquifer to establish
ground water gradients andflow directions. Ground water contour maps will be
generated at that time. A preliminary draft site characterization and work plan has been
completed and is scheduledfor submittal June II, 1999.
In a June 22,1999 letter regarding the 1998 monitoring report, RWQCB commented that
the submittal of a ground water contour map is required, it has not been done because
there are an insufficient number of monitoring wells for each landfill unit, this is a
violation, and if not addressed in the next semi-annual monitoring report, a notice of
violation will be issued. In the October 30, 1999 cover memo to the 1999 semi-annual
monitoring report, John Rollin, DPW Public Works Manager, just reiterated the County‘s
intentions regarding an EMP, with no report of any progress made on this effort and no
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new date for it to be submitted. As of March 22,2000, the EMP still has not been
submitted and no notice of violation has been issued.
During this same time frame, the City’s dry weather testing results at the intersections of
Camino Vida Roble and Yarrow Drive, and Camino Vida Roble and Palomar Oaks Way,
identified storm-water flow with a low pH reading, indicating a high acid content in the
runoff. In a July 20, 1999 memo from Associate Engineer Steve Jantz, Mr. Jantz reports
that the most recent dry weather testing report concludes that, based on the results offield
investigations, review of current and previous storm-water testing events, and ground
water sampling results from the test wells around the airport property, there is a high
possibility that the source of the low pHfrow observed at outfall EN-23 [the intersection
of Camino Vida Roble and Yarrow Drive] is the ground water-flow moving from the
aquifer underneath Palomar Airport Landfill Unit 2. Due to the distance between EN 14-
A [the intersection of Camino Vida Roble and Palomar Oaks Way] and the airport
property, there is no clear connection between the landfill and the discharge point.
However, the constituents in the runoffat EN 14-A are very similar in concentration and
make-up. Mr. Jantz met with County staff to share these results and reports that they were
not receptive to the possibility of a connection between the results and the landfill.
While the findings in the City’s Dry Weather Testing Program are disconcerting, they
also place the City in a difficult position. Under this program, mandated by RWQCB
Order 90-42, the City is responsible for the control of the discharge of waste in our storm
drain system. However, without an adequate number of monitoring wells at the airport to
determine ground water flow direction, it is difficult to directly tie the landfill leachate to
the stormwater test results. According to RWQCB staff, if the connection can be made,
RWQCB can require corrective action. When asked, RWQCB staff agreed with the
observation that DPW does not want enough monitoring wells established because this
would allow identification of responsibility for ground water contamination. According
to RWQCB Executive Officer John Robertus, “This is the psychology”.
Prospects for adequate ground water monitoring at the airport worsened during the week
of March 13,200O. According to Carol Tomaki, RWQCB Associate Water Resources
Control Engineer, DPW “destroyed” 6 monitoring wells as part of their re-grading and re-
paving work currently in progress. She reported that despite quarterly meetings with
DPW, the plan to do this had never been mentioned and she had not been notified by
DPW. She became aware that this was going to happen the day before it took place and
instructed that it not occur, to no avail. She also reports that DPW maintains that it will
not replace the destroyed wells until all re-paving is done under a schedule to complete
the work by the end of December, 2000. According to Ms. Tamaki, there is now only 1
well per unit left, and there should be at least 1 upgradient and 3 downgradient for each
unit. Finally, when asked if a notice of violation would now be issued, she responded
that she anticipates asking for a schedule for putting in wells and then issuing a violation
if DPW does not honor the schedule. Due to design and planning work that will be
needed, she believes that the monitoring wells will not be replaced until well into the year
2001.
34
In a March 24,200O interview of RWQCB Executive Officer John Robertus, to obtain
information about the RWQCB’s enforcement process, City staff concerns about the
results of our stormwater testing and the County’s lack of responsiveness to RWQCB
were shared. Highlights of Mr. Robertus’ comments from that interview are summarized
below.
l Take a serious look at the threat to water quality at Carlsbad beaches. What you may
be seeing in your storm drains could be “just the tip of the iceberg”. Last year, the
closure of beaches in Huntington Beach as a result of pollution from storm drains is a
good example of the tremendous impact this situation can have on the City and local
businesses.
l Steps the City can take to focus attention on the County’s poor compliance history
and the apparent connection between the landfill and the dry weather testing results
include: attending a public hearing of RWQCB or sending a letter to the Board
requesting that the issue be placed on their agenda and (1) state the City’s concerns
about water quality, and based on our review of the records we would like a status
report on the landfill, and we want to know what actions we can expect the County to
take to abate and control; and (2) state that the City thinks the source of the test
results of our storm drains is the airport property and the City is requesting that
RWQCB invoke California Water Code Section 13267 and require the County to
conduct and fund an investigation. This code section “is a powerful tool”.
l Fines up to $1,000 per day can be levied for violations of waste discharge
requirements. Based on inaction by the County for problems at the San Marcos
landfill, RWQCB recently imposed a fine of approximately $250,000. [He didn ‘t go
into the details about the amount but it should be noted that under Section 13264 of
the Water Code, the Superior Court may impose civil liability of up to $25,00Oper
day of violation. /
l RWQCB has an enforcement unit of only 2 people, headed by Mark Alpert, Senior
Engineering Geologist. A lack of funding for adequate staffing levels to carry out the
agency’s many oversight duties is one of the biggest obstacles his agency faces.
In an interview of Mr. Alpert, he reported that he was unaware of the results of our Dry
Weather Testing Program and offered to meet with City staff to review the data. He also
confirmed that violations on the matter of inadequate wells can be issued and more
enforcement can occur, but first, more documentation and follow-up on the County’s
promises is needed.
(2) On September 10,1999, the LEA (Local Enforcement Agency (County Department
of Environmental Health)), sent a letter notifying DPW that it is in violation of CCR Title
27 State Minimum Standards and corrective actions are required. The letter summarized
the violations and areas of concern (a condition that, if not corrected, has the potential to
become a violation) that had been cited over the previous seventeen (17) months.
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According to the letter, since 1998 there has been a succession of continuing violations.
Violations and areas of concern were noted in LEA inspection reports dated 3/3 l/98,
5/21/98,6/18/98,9/3/98, 1213198, 12/7/98,3/29/99,6/29/99, and 8120199. The violations
and areas of concern were cited because settlement was jeopardizing the integrity of
structures and providing a pathway for the release of landfill gases into the air and
structures, substantial cracking of the asphalt was allowing surface waters into the
underlying wastes, waste was exposed (DPW disputed this finding in a follow-up letter),
and because landfill gas was found to be migrating fi-om Unit 3.
The letter was entitled “Official Notice”, which according to LEA staff is meant to
indicate to the landfill operator that the letter is very serious. It does not carry the weight
of an “Order”, which is part of a specific enforcement process.
DPW actions required in the letter include the repair of cracks in the asphalt, a monitoring
program for the presence of methane in on-site structures to be submitted for review and
approval by September 27,1999, a monthly report to the LEA detailing the status of the
Landfill, required repairs completed, and all methane monitoring data beginning October
1, 1999. In addition, DPW required the submittal and approval of a workplan detailing
corrective action(s) and associated timelines to address the violations and areas of
concern by September 30,1999.
According to the LEA, DPW’s reply was a draft submitted November 1,1999. It was not
found to be adequate. The LEA notified DPW that a meeting would be scheduled to
discuss finalizing the submittal, and the LEA asked DPW to finalize it as soon as possible
so that the corrective action and monitoring plans could be provided to the City. A
January 14,200O submittal with monitoring to begin that month and a re-grading and re-
paving schedule between July and December 2000 was accepted by the LEA.
According to Mr. Rollin, Department of Public Works Manager in the Inactive Waste
Site Management Division, in an interview last November, this work is being done now
because “Horn wants it fixed.” When asked if this work will address the pollution
problems from the landfill, he responded that the ground water wells on the site reveal no
indication that there is any damage to ground water. He stated that the purpose of the
work is to address regulatory agency requirements that they must prevent water intrusion
into the trash, prevent water ponding on the asphalt, and to improve the surface and level
of the pavement for airport operations. Mr. Rollin also reported that this will be a
temporary fix only. Dirt will be imported to bring up areas that are now sunken, and then
they will re-pave. Subsidence will be continual as the trash continues to compact and
decompose. Finally, he stated that hopefully, these repairs will last 5 years, and if lucky,
10 years, but it is difficult to predict.
(3) On August 21, 1999, the California Integrated Waste Management Board (CIWMB),
and the LEA conducted an inspection of the airport property, and in a follow-up report on
the visit the CIWMB wrote the following in a letter to the LEA: . . . we noticed the same
conditions at the site as we had observed previously; namely settlement, drainage and
erosion problems. We noted structures notwithstanding the eflects of differential
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settlement and we observed huge cracks on the landfill surface. We further observed
runofffrom washing an aircraft, simply infiltrating into the landfill through the asphalt
cap. Based on the state of the landfill, Board staflbelieves that the site continues to
sufferfrom lack of adequate maintenance and that the routine and scheduled
maintenance of the site, as required and as designed to protect the health and safety of
the public and the environment, has been and continues to be either postponed or
ignored, despite the conditions at the site and the repeated requests from the regulatory
agencies to have the site be in compliance with state minimum standards. We have been
told that this airport is the largest single runway airport in the nation, and with so many
people using the airport, it only seems logical that adequate and on-time maintenance
should be$rstpriority, however, no evidence ofprevious or on going maintenance was
observed during our inspection.
The apparent lack of maintenance has caused substantial damage to the landfill cover
system and has jeopardized its integrity (27 CCR, S21140). Depressions, large and
small, apparently caused by settlement, were observed throughout the site. The
settlement has eflected site drainage (27 CCR, S21150) and tfnot corrected immediately
would continue to allowponding of water and water infiltration into the landfill.
Furthermore, it is possible that the settlement at the site will have already compromised
the integrity of the landJill gas collection system. Cracks approximately 4 to 6 inches
wide and 2 to 3 feet deep were also noted over some areas of the landfill. The cracks are
conduits for gas migration (27 CCR, S21160) and water infiltration and air intrusion into
the landfill.
. . . Overall, the site requires immediate and adequate maintenance to minimize the
potential threats the existing conditions pose to the health and safety of the public and the
environment. Please note that conditions noted above have been repeatedly cited in the
LEA ‘s previous inspection reports as violation of Title 27 of the California Code of
Regulations. We have reviewed the Oficial Notice dated September IO, 1999 from your
Department to the operator, . . . and we support your action and would like to offer our
assistance with any matter which would lead to site improvements.
According to RWQCB staff, the County appears to be on track with preparations to keep
to the regrading and re-paving schedule to repair the landfill cover during the last half of
2000.
The first methane gas monitoring report was submitted to the LEA on February 14,200O.
This report reviews some maintenance activities and concludes that the Landfill Gas
Migration Control facilities appear to be performing satisfactorily as of the date tested.
According to DPW’s cover merno to the report, a consultant has been retained “for the
design and implementation of the permanent on-site structure monitoring.”
File: Library Airport Master
37
VIII. CONCLUSIONS & REXOMMXNDATIONS
CONCLUSIONS:
Land Use:
l The City of Carlsbad currently participates in land use review and approval of all
projects in and around McClellan-Palomar Airport, along with other agencies.
l Under the existing Conditional Use Permit (issued by the Carlsbad Planning
Commission in 1980), certain structures and facilities are allowed without
discretionary review. In the event that an amendment to the CUP is submitted for
review and approval, the City will have an opportunity to revise the existing
conditions of approval to provide for a greater role in review of new improvements.
l Acquisition of the airport, by the City, would allow the City to control all on-site
planning, improvements, and uses.
Economic Benefit:
l McClellan-Palomar provides significant economic benefit to the City, the North
County area, and the San Diego Region. These benefits should continue as long as
the airport is able provide for the necessary capital improvements and infrastructure
to support its projected growth (enplanementslpassengers).
l Economic Benefits from airport growth must be weighed against “quality of life” and
safety impacts on Carlsbad and the neighboring cities.
Finance/Capital Improvements:
l Palomar, like the airport system, does not generate enough revenue to cover all the
needed capital improvements.
l County Airports has been proactive in developing non-aeronautical revenue sources
which are critical to the long term financial health of the airport system and the goal
to be self-sustaining. For at least the short term, the cost of not relying on General
Fund money has been high at Palomar - general maintenance for operations, public
safety and protection of the environment has been poor.
l It may be difficult to separate airport maintenance from landfill maintenance. The
potential for County Airports’ recent and unanticipated financial liability for property
deterioration associated with the landfill under Palomar to continue will be important
in future airport system financial planning. The extent to which this financial liability
could extend to a new owner will be important to any potential purchaser.
38
Sale:
l FAA regulations and the County’s dependence on Palomar to sustain the airport
system make it unlikely that the County would be interested in selling Palomar at this
time.
Noise:
l Noise complaints will continue to increase as the City builds out, especially as people
begin to occupy the Can-i110 Ranch and Bressi Ranch developments, and airport
operations continue to increase.
l As operations continue to increase so too will the number of aircraft waiting on the
runway, resulting in more aircraft directed outside the “preferred path” and over
residences.
l The City’s ability to mitigate airport noise impacts on residents is very limited as a
result of the FAA’s control over the airspace and flight paths, federal regulations
designed to make aircraft restrictions for noise control purposes difficult to impose,
and the County’s control over airport operations.
l The success of efforts to emphasize noise sensitivity will depend heavily on the
airport staffs ability to reach and affect itinerant pilots.
Landfill:
l Without County Board Supervisor intervention and/or regulatory enforcement, poor
maintenance and property deterioration may be an ongoing issue at Palomar.
l The likely reasons there has been inadequate ground water monitoring at the airport
are: (1) the lack of enforcement by RWQCB; and (2) the threat of required abatement
action if ground water flow direction is established and the landfill is tied directly to
the Dry Weather Test results.
l Without greater RWQCB oversight, our ground water degradation and storm drain
test results will likely continue.
RECOMMENDATIONS:
Land Use:
l Consider adding new conditions to any future amendment to the existing Conditional
Use Permit (172) that would provide the City with greater review/approval/oversight
of new structures and facilities proposed for the airport, as well as airport
maintenance levels.
39
Financing/Capital Improvements:
l Support legislation which increases AIP funding and/or makes more funds available
to smaller airports.
l Investigate the advisability of participating in a redevelopment area around the airport
in exchange for the expenditure of tax increment funds on Palomar.
Sale:
l No further action toward acquisition at this time.
l If it is decided to continue working toward acquisition, any feasibility study should
include an analysis of:
1. the legal assurances an airport owner must agree to as a condition to obtaining
federal grants;
2. the legal obligations that may be inherited by a new owner because of prior use of
federal funds in the purchase and development of the airport;
3. restrictions on the use of airport revenue;
4. any relevant differences between the sale to a public entity versus a private entity;
5. potential FAA conditions of approval of the sale;
6. the airport’s revenues, expenses and capital improvement needs;
7. the potential for increasing revenue and expanding revenue sources; and
8. a new owner’s potential liability for the landfill beneath the airport.
Noise:
l Evaluate the need for additions to the Council’s legislative platform addressing the
measurement of community noise levels and aircraft noise levels.
l Encourage the County to evaluate the feasibility of tying lease agreements to
compliance with noise mitigation activities.
l When the FAA responds to the updated Part 150 Study, review the response for any
comments on the need for additional information or analyses, and where appropriate,
recommend to the County that these needs be met.
Landfill:
l Evaluate the need for additions to the Council’s legislative platform addressing
ground water protection.
l Review land use authorities for avenues to facilitate adequate and timely landfill
maintenance.
40
l Acquire staff expertise in the regulations and enforcement process of the various
environmental oversight agencies associated with the environmental issues at the
airport.
l Pursue a strategy of action steps to (1) raise the awareness among the County and
environmental agencies of the City’s concern about water quality and interest in the
County’s appropriate and timely remediation actions; (2) within the City’s
jurisdiction, continue to investigate the source and extent of pollutants in the storm
drains; and (3) share the Dry Weather Testing results with RWQCB enforcement staff
and coordinate with RWQCB to help facilitate County compliance.
41
C
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
IX. EXHIBITS
Total Impact of McClellan-Palomar
Airport Enterprise Fund
a. Airport Noise Impact Notification Area
b. Airport Noise Impact Notification Area
C. Notice Concerning Aircraft Environmental Impacts
McClellan-Palomar Airport 1992 County proposed Noise Abatement & Mitigation
Measures with Responses from FAA
Annual Operations Count
San Diego County’s Busiest Airports
Factors Effecting Airport Operation Totals
Local & Transient Traffic Breakdown
Top 20 U.S. Airports Based on Itinerant General Aviation Operations
Annual Noise Complaints
Annual Noise Complaints by Community
Annual Noise Complaints by Aircraft Type
Annual Noise Complaints by Time of Day
Federal Aviation Administration Class “D” & “E” Airspace
15. Comparison of NINA to Class “D” and “E” Airspace
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EXHIBIT 4
MCCLELLAN-PALOMAR AIRPORT
1992 COUNTY PROPOSED NOISE ABATEMENT & MITIGATION MEASURES
WITH RESPONSES FROM FM
Operational Measures
1. Raise the traffic pattern altitude from 800 feet above mean sea level (MSL) to 1,000
feet for helicopters, from 1,200 feet MSL to 1,500 feet for small aircraft, and from 1,500
feet MSL to 2,000 feet for large aircraft.
No action required at this time. This measure relates to flight procedures under Section
104(b) of the Aviation Safety and Noise Abatement Act of 1979. In addition, the NCP
would have to adequately demonstrate a noise benefit; there is insufficient statistical and
other data to make a determination on the benefits from a noise standpoint.
2. Increase the instrument landing system (ILS) glideslope angle and the visual approach
slope indicator (VASI) angle to 3.6 degrees, which would provide additional altitude to
arriving aircraft overflying neighborhoods to the east of the airport, including the
community of San Marcos and the Palomar West Mobile Home Park.
Disapproved. Increasing the glideslope and VASI angles from their current 3.2 degrees
to 3.6 degrees would not provide any meaningful noise reduction and would increase the
complexity faced by plots using these approach aids.
3. Modify the Oceanside very high frequency omnidirectional radio range (VOR)
approach for aircraft so that they maintain a minimum altitude of 3,000 feet MSL at the
Oceanside VOR, 2,000 feet MSL four miles past the VOR on a heading of 120 degrees,
and 1,400 feet MSL seven miles past the VOR.
Disapproved. Increasing the altitude to 1,400 feet at 7DME would require raising the
established minima and would thereby reduce the utility of the approach.
4. Require visual departures proceeding to the coast from Runway 24 to (a) make a right
turn as soon as feasible to a heading of 250 degrees, (b) fly over the vacant area between
the communities of Terramar and Solamar, and (c) maintain heading until one mile past
the shoreline before turning south or north.
Approved as a voluntary measure only. This measure reflects a recommended practice
which is already in effect at the airport. This measure should be implemented as a part
of, and at the same time as measure #18.
5. Prepare a standard instrument departure (SID) with the Federal Aviation
Administration (FAA) concerning instrument flight rules (IFR) jet departures from
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runway 24 to require that aircraft maintain a heading of 250 degrees and climb to a
minimum altitude of 2,000 feet MSL before crossing I-5 or the Oceanside 13 1 -degree
radial. Reduce power at I-5 as acceptable for safe flight, and maintain the initial heading
and altitude until at least three miles offshore.
No action required at this time. This measure relates to a flight procedure under Section
104(b) of the Airport Safety and Noise Abatement Act (ASNA) and requires additional
information and analysis.
6. Conduct a test, using noise monitoring equipment in which arriving aircraft to
Runway 24 maintain various gear and flap settings between the McClellan-Palomar
Airport outer market and the west edge of the Palomar West Mobile Home park. The
results of this test may recommend new approach procedures to reduce noise exposure.
Approved as a voluntarv measure only.
7. Require jet aircraft arrivals to Runway 24 to use the ILS approach.
Disapproved for purposes of Part 150. The measure as submitted does not demonstrate
any noise benefit. However, FAR Part 91.129 (d)(2) specifies that large and turbine
powered aircraft shall fly the final approach at or above the ILS glideslope and (3)
provides that all aircraft approaching a runway equipped with a visual approach slope
indicator shall fly at or above the glideslope until a lower altitude is necessary for
landing.
8. Specify Runway 24 for use by all aircraft during calm wind conditions.
Approved as a voluntary measure. The airport sponsor should consult with the manager
of the air traffic control tower regarding implementation of changes to the ATCT SOP.
9. Increase the helicopter route altitude from 800 feet MSL to 1,000 feet MSL.
Disapproved pendinp submission of additional information relative to anticipated noise
benefits. Information provided in the NCP is insufficient to determine the noise benefit,
if any, of this measure.
Ground Operation Measures
10. Locate the aircraft engine maintenance runup area on the west side of the Airport with
aircraft facing east. No maintenance runups should be conducted between 10:00 p.m.,
and 7:00 a.m.
Disapproved. There is no documentation that these measures will result in a noise benefit
for people in the airport vicinity. However, with respect to the location of an aircraft
maintenance runup area, the airport operator has the prerogative of designating such a
location.
,-
11. When more than four departing aircraft are waiting in queues on the taxiway,
additional departing aircraft should hold at their tiedown or hanger location with engines
off.
Disapproved. There is no indication that aircraft taxiing or holding for departure
contribute to noise impacts in the airport vicinity, nor is there any indication that this
measure provides any noise benefit.
Management Measures
12. Discourage use of the Airport by aircraft operating at a maximum weight of 60,000
pounds, or more.
Disapproved for purposes of Part 150. The cause and effect relationship between aircraft
weight and aircraft noise is not presented in the NCP. It is within an airport sponsor’s
discretion however, to develop or not develop airport facilities to serve larger aircraft and
to make known to pilots the physical limitation of the airfield.
13. Discourage jet training operations particularly by Stage 2 aircraft, through voluntary
compliance.
Approved as a voluntarv measure only. This measure provides for continuation of an
existing on-going program at the airport. Any mandatory restriction proposed for Stage 2
aircraft would be subject to analysis and review under the Airport Noise and Capacity Act
of 1990 and FAR Part 161.
14. Implement a voluntary Stage 2 jet departure curfew between 10:00 p.m., and 7:00
a.m. through a letter of agreement between the airport owner (County of San Diego) and
operators of Stage 2 jet aircraft located at the Airport.
Approved as a voluntarv measure onlv. Any attempt to make this measure mandatory
would be subject to analysis and review under the Aviation Noise and Capacity Act of
1990 (ANCA) and FAR Part 161.
15. Acquire and install a permanent noise monitoring system to validate the effectiveness
of the noise abatement procedures and to quantify noise problems in surrounding
neighborhoods in the future.
Approved. NOTE: For purposes of aviation safety, this approval does not extend to the
use of monitoring equipment for enforcement purposes by in situ measurement of any
pre-set noise thresholds.
,-.
16. Designate a noise abatement officer to administer the approved Noise Compatibility
Program.
Approved.
17. Continue to have the Palomar Airport Advisory Committee act as a forum for
discussion of noise abatement actions.
Approved.
18. Produce maps identifying noise sensitive areas around the Airport, and distribute
them to pilots to help them avoid these areas when possible.
Approved. Implementation of this measure should be combined with measure number 4
as a part of a comprehensive effort to inform pilots regarding the noise sensitive areas in
the vicinity of the airport.
Preventive Measures
19. Amend the San Diego County Airport Land Use Commission’s Comprehensive Land
use Plan for McClellan-Palomar Airport to reflect the new forecast noise exposure
area in the Airport Influence Area.
Approved. This measure is considered to be within the authority of the County Airport
Land Use Committee.
20. Amend the noise elements in the General Plans of San Diego County, and the City of
Carlsbad to reflect the new noise exposure maps.
Approved. This measure is considered to be within the authority of the County of San
Diego, and City of Carlsbad.
21. All undeveloped land exposed to noise of CNEL 65+ (current or future) should be
rezoned to a compatible use, or, if noise sensitive development is permitted, adequate
noise insulation should be required.
Approved. This measure is considered to be within the authority of the County of San
Diego, and City of Carlsbad.
22. If new noise sensitive development is permitted in areas of CNEL 65+, the granting
of an avigation easement to San Diego County should be required as a condition of
approval.
Approved. This measure is considered to be within the authority of the County of San
Diego, and City of Carlsbad.
23. The City of Carlsbad should ensure that for all properties in areas of CNEL 65+, the
aircraft noise levels are included in the fair disclosure statement, as required by the
State of California.
Approved.
24. The owner of the large agricultural area west of the Airport should be encouraged to
keep the land in an agricultural preserve under the Williamson Act.
Approved.
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