SDIA Terminal 1 DEIR Review and Responses

  1. FINAL TECHNICAL MEMORANDUM, AVIATION ACTIVITY FORECAST UPDATESan Diego International Airport, AVIATION ACTIVITY FORECAST UPDATE REVIEW AND ASSESSMENT1 Prepared by: G Wonacott , 731 Avalon Court, San Diego(Mission Beach Community), CA 92109 Approved by: Mission Beach Town Council, January 14, 2020Prepared for: SDCRAA, Attention Ted Anasis, P.O. Box 82776, San Diego, CA 92138-2776October 30, 2019 1 Mr. Wonacott is Chair of the Airport Noise Committee, Mission Beach Town Council 1

  2. SYNOPSIS Currently, there are three studies underway related to SDIA, the Terminal 1 Expansion DEIR, the Part 150 Study, which is focused on changes to flight paths and other considerations that might decrease the number of people living in the 65 dB CNEL, and a Flight Procedures Study that was precipitated by 22 recommendations from the ANAC Subcommittee. The complete final Report for this work is at www.sannoisestudy.com. I will have further assessment of the results from that work in the near future, but suffice to say, that in general, nothing of any value as far as noise mitigation was accomplished. These the studies that would potentially benefit Mission Beach, but many were deferred to the Part 150 study. The main issue here is that even if a flight procedure change might benefit Mission Beach, it will not be considered unless it results in a decrease in the 65 dB CNEL,2Specifically to the DEIR assessment, there were 22 questions formulated from the report review and evaluation. These questions are currently being review by the Airport Authority consultant, who is motivated to always find the easiest solution or answer from the Airport Authority perspective. A couple of examples are:Your assumption of 50 operations per hour for a 17-hour day seems very optimistic given the FAA assumes 48 for all weather conditions. How do you justify the higher number?The constrained enplaned projection seems very optimistic at 2035 compared to the capacity projection in 2024. How do you justify this delay with a sudden flattening of the constrained enplanements, given that there is no evidence that aircraft size (number of passengers) and load factor will increase?It appears that since capacity will be reached two years after Terminal One is completed. Further, the DEIR report shows a substantial increase in the delta number of enplanements between constrained and unconstrained after capacity is reached. And when this is factored into the 2018 Airport Authority financial benefits study to the San Diego region, it appears that losses could be anywhere from $2.5B to $5B in the five to ten years beyond 2024. Why then is the SDCRAA not first addressing the capacity issue before investing $3-4B to enhance the passenger experience at Terminal 1.The plan is to add 11 new gates at terminal 1. The addition of these gates does not increase airport capacity, but could accelerate the airport reaching capacity for two years before it reaches capacity. There does not seem to be any rationale for including the new gates? What is the primary reason for adding the gates?One concern is that the gates are being added as justification for moving the curfew from 6:30 am to 5am. Which organization or government body makes the decision regarding the curfew start and stop times?There are sections included that illustrate the disruption of sleep due directly to aircraft noise between 10 pm and 11:30 pm. Of greatest concern is the projected increase in number of people living in the 65 dB CNEL from 19,339 in 2018, to 34,276 in 2026. Given that the SDCRAA has made no effort to off-load operations to other local airports, this is an abomination. We can expect substantial increases in operations and noise in Mission Beach. Of greatest concern is that the Airport Authority will move all of the current nighttime noise abatement departures from 290 degrees, up the channel, to PADRZ which flies directly over Mission Beach.Multiple ideas were submitted to reduce noise from PADRZ over SMB and or encourage more use of Stage 4 and 5 aircraft, however, the Airport Authority Noise Abatement Office consultants effectively bullied the members of the TAC and CAC and the general public into accepting the changes to avoid losing the current curfew. This really comes down to political will, and while Congressman Scott Peters has advanced legislation to address long term issues, he has not stepped into the help anyone except for the La Jolla constituents, which is where he lives.2 There must be an explanation coming from the MB representative on the TAC regarding the failure of options that might benefit Mission Beach being eliminated or deferred to the Part 150. which is very unlikely.

  3. I.II.III.A.B.C.D.1. 2.IV.V.A.B.C.D.E.1. 2.VI. VII. TABLE OF CONTENTSINTRODUCTION 4SUMMARY OF QUESTIONS: 5PROJECTIONS OF ENPLANEMENTS, OPERATIONS, CAPACITY AND DELAYS 7KEY DRIVERS OF AVIATION ACTIVITY 7 REVIEW OF RECENT AVIATION TRENDS 7 UPDATED unconstrained AVIATION ACTIVITY FORECASTS 7CONSTRAINED DEMAND SCENARIO 15Capacity Assessment 15 Delay Assessment 19OFF-LOAD OPERATIONS AT SDIA 24SDIA NOISE ISSUES 26 Noise Impact in Mission Beach 26 Health Implications of Aircraft Noise 27 Congressman Scott Peters Letter 28 Noise Increases Projected 28Noise and Capacity Mitigation Recommendations 32Stage 4 and 5 aircraft 33 Move PADRZ south 36FINANCIAL IMPACT OF CONSTRAINED LINDBERGH FIELD 40 REFERENCES: 41

  4. I. IntroductionPart of the residents’ concern is the credibility of the Airport Authority Noise Abatement Office. Clearly, there were many institutions that questioned the DEIR forecast that preceded the one published in July 2019. The earlier forecast projections of operations were grossly underestimated and there was little or no discussion regarding capacity or a constrained airport. Now the latest version of the DEIR, using optimistic assumptions, is projecting that the airport will reach capacity in 3-5 years, and that enplanement constraint, again with a very optimistic assumption, is projected to start in 2035. There is substantial data that supports a much sooner constraint of enplanements. Given this background information, it strains credulity that the Airport Authority did not intentionally misrepresent the capacity and constrained airport issues to potentially decrease criticism as it is proposing a multibillion dollar project for the Terminal 1 expansion.But this is not the first time that the Airport Authority has received criticism for it projections. In 1996, the Airport Authority predicted that in the area west of the airport, the number of people exposed to 65dB or greater would be reduced from one-third to two-thirds, compared to current conditions. And to the east of the airport, noise levels would be similar to the 1996 base case, because future reductions in arrival noise level from Stage 3 aircraft are expected to be small.The two bar charts below show the projected value for population living within the 65 CNEL area.o A - ...”airfield status quo concept”... o B - ...increase airfield capacity by extending Taxiway C to the west... o C - ...construct new 7,500-ft. parallel runway south of existing Runway 9/27... o D - ...convert Taxiway C to 9,000-ft. runway - Runway 9/27 closed and converted to a parallel taxiway -new 9,400 ft. south side parallel runway... o E - ...construct new 9,000 ft. parallel runway to the north - runway 9/27 closed - construct new 9,400ft. parallel runway to the south... o F - ...construct new 9,400 ft. runway in a “V” configuration to the north of runway 9/27... o G - ...split use with NAS North Island... 35,000 28,000 21,000 14,0007,00001996 A B C D E F G Option 30,205 9,700 12,000 18,700 14,700 13,000 18,500 N/A Current 2019 number of people exposed to the > 65 dB CNEL Source: San Diego International Airport Master Plan - Environmental Constraints Analysis Forecasted Number of People Exposed to >65dB in 2020, Compared to 1996 Number of People

  5. We Don’t Believe You !Past Projections Were Incorrect ! What’s Wrong With These Projected Numbers ? The cartoons above represent questions from the residents with regard to the Airport Authority Noise Abatement Office in 1996. It has become increasingly apparent that this organization is not interested in noise mitigation. It is very concerned about propagating its own welfare in the years to come, even at the expense of the residents’ environmental impact and the economic health of the San Diego Region. The number one question is:IF THE RESIDENTS LIVING IN THE COMMUNITIES SURROUNDING LINDBERGH FIELD HAVE NOT BEEN ABLE TO TRUST THE SAN DIEGO COUNTY REGIONAL AIRPORT AUTHORITY (AIRPORT AUTHORITY, NOISE ABATEMENT OFFICE) HISTORICALLY, WHY SHOULD WE TRUST THEM NOW? II.6.7. 8.9.10. 11. 12.13. Summary of Questions:

  6. The number of operations is a function of enplanements (economy), number of passengers per aircraft, load factor.

  7. There is no evidence that supports larger aircraft being used at SDIA. Nor is there evidence of a load factor of 0.9. To the contrary, load factors at most constrained airports are lower. What is the basis for your assumption of a load factor of 0.9?

  8. Why did you not perform sensitivity studies on the key metrics used to calculate operations, as this would have allowed you to focus on accuracy for these variables?

  9. Why did you use hourly increments to calculate the number of operations per hour, when it is obvious from observations that the runway is well over capacity at 6:30 am, for example. Hourly operations in half hour increments provides far greater accuracy. The operations per hour data suggests that it will be difficult to fill in maximum number of operations per hour for a 17-hour day.

  10. What assumption did you make regarding the density of the operations per hour value?

  11. Your assumption of 50 operations per hour for a 17-hour day seems very optimistic given the FAA assumes 48 for all weather conditions. How do you justify the higher number?

  12. The correct methodology spelled out by the FAA to determine airport hourly capacity uses an interaction diagram. Did you use this approach, and if not, why not?

  13. In different sections, you make assumptions that larger aircraft will become more common in the future aircraft mix at SDIA, but then sometimes you state that the primary aircraft type will be narrow body. Which is it?

  14. Also, once capacity is reached, how do you know what direction the airport will go given that SDIA is a spoke airport and dependent on what happens at LAX, Sky Harbor, SFO?

  15. The airport is projected to reach capacity in the 2024-time period. Why was there not more analysis of delays, which are the primary symptoms that foretell capacity, as was done in the 2004 study by SH&E?

  16. The constrained enplaned projection seems very optimistic at 2035 compared to the capacity projection in 2024. How do you justify this delay with a sudden flattening of the constrained enplanements, given that there is no evidence that aircraft size (number of passengers) and load factor will increase?

  17. It would seem to make sense given how close the airport is to capacity to establish regular assessments of on-runway (taxi-way) delays, number of aircraft, etc. metrics. Why have you not made this recommendation?

  18. It appears that the airport will reach capacity two years after the Terminal 1 expansion is completed. What then is the basis for spending such a large amount of money ($3-4B), if it does not increase the capacity of the airport?

  19. The plan is to add 11 new gates at terminal 1. The addition of these gates does not increase airport capacity, but could accelerate the airport reaching capacity for two years before it reaches capacity.

  20. There does not seem to be any rationale for including the new gates? What is the primary reason for adding the gates?

  21. One concern is that the gates are being added as justification for moving the curfew from 6:30 am to 5am. Which organization or government body makes the decision regarding the curfew start and stop times?

  22. According to data in the public domain, about 42 percent of the arrivals into SDIA are from destinations that are less than 500 miles. Also, about fifty percent of these arrivals depart for destinations that are again less than 500 miles. Why has the SDCRAA not included in the future planning setting up commuter operations using regional jets that would move 150-200 departures daily from SDIA?

  23. The Airport Authority consultant has reported substantial increases in the size of the 65 dB CNEL and population living within this contour (about 13 percent by 2026). According to a FAA AEM analysis, the size of the 65 CNEL could be reduced by 18 percent by transitioning all Stage 3 aircraft departing post 10 pm to Stage 4 or 5 aircraft. While some Airport Authority personnel claim that this would be interference with Interstate Commerce; the Airport Authority has violated the same interference with Interstate Commerce in monumental terms by allowing the airport to reach capacity. How can interference with interstate commerce be a defense in this context?

  24. The Airport Authority consultants on the TAC and CAC have used their superior knowledge of aeronautics to discourage many if not all of the 22 recommendations made in 2017 by the ANAC Subcommittee. How can this be justified in light of the substantial projected increases in noise between now and when airport capacity is reached?

  25. Flighttrack data has shown that for decades aircraft have departed on multiple tracks, 290 versus PEBEL 6 at 293 (3 degrees difference) and 290 versus PADRZ at 295 degrees (5 degrees difference). So, how can the 15-degree rule be used to disqualify moving PADRZ south so that it coincides with the 290-nighttime departure heading up the channel between Dog Beach and the SMB jetty?

  26. Given the noise and nuisance impact projected in the DEIR report, why should the Airport Authority move forward with the project without first seeing the results of the Congress directed studies to the FAA on health consequences of aircraft noise and air pollution, Stage 3 phase out, the use and applicability of the SENL 65 that spreads the noise over 24 hours for the San Diego area, and better definition of how communities will participate in land use conversations around the airport?

  27. Why does the 15-degree rule apply given there is one runway which establishes by definition substantial spacing between all aircraft?

  28. Even if there is an effort to use the 15-degree rule (10-degree approved at Atlanta Hartsfield Airport), this requirement is satisfied, since the apex for the right turn is about 0.75 miles from the end of the runway. Why is this not considered?

  29. It appears that since capacity will be reached two years after Terminal One is completed. Further, the DEIR report shows a substantial increase in the delta number of enplanements between constrained and unconstrained after capacity is reached. And when this is factored into the 2018 Airport Authority financial benefits study to the San Diego region, it appears that losses could be anywhere from $1.25B to $2.5B in the five to ten years beyond 2024. Why then is the SDCRAA not first addressing the capacity issue before investing $3-4B to enhance the passenger experience at Terminal 1. 6

  30. If you would like a complete copy of the report, including figures, please contact me at gary@mb4residents.com

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