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A peoples environmental impact report on El Toro International Airport

Courtesy of the Nasa WebsiteExcept for a few golfing diehards who don't mind a flat, featureless course; some local horse and Winnebago owners; and the occasional sheriff's deputy, nobody visits the abandoned El Toro Marine Corps Air Station anymore. And it really shows. The once-vibrant base is overgrown with head-high, prickly weeds. Most buildings are locked tight, their asbestos-lined walls slowly crumbling into the soil.

For the past four and a half years, county officials and outside consultants have been compiling the main El Toro Environmental Impact Report (EIR) and the vaunted Airport System Master Plan (ASMP) to explain what the county wants to do with this rapidly decaying base. Stacked, the reports and studies of the draft EIR top six feet.

But even a cursory read by the mildly curious reveals that the reports are plagued with inaccuracies, contradictions and ample evidence that the county's planned El Toro International Airport will be a monumental nightmare that—once built—will never go away.

The reports describe an international airport handling 28.8 million passengers per year, two million tons of cargo per year, and 300,574 flights per year—which pencils out to 823.5 flights per day, all day, every day. Roughly speaking, the county wants to build an airport the size of San Francisco International, the nation's fifth-largest. And county officials say they can do it all for $3 billion.

On Sept. 17, the county Board of Supervisors will vote 3-2 to approve the EIR and ASMP, signaling to the federal government that Orange County is ready to begin building the airport. The approving supervisors—Cynthia Coad, Chuck Smith and Jim Silva—will say El Toro will be a clean, neighborly airport. They will say county officials have done a wonderful job. They will say the airport will usher in a new golden age for the county.

They are wrong. El Toro will require a monumental construction job to convert it into a commercial airport. And once completed, the airport's design, surrounding terrain and weather will present considerable problems for the pilots who have to use it. The county's own noise consultants say overflying aircraft will drown thousands of homes in "sleep-disturbing" noise. Toxic emissions from the airport will, according to the county's contradictory and incomplete air-quality analyses, cause cancer in thousands of people who work in and live near El Toro. Most incredible of all, the county can't conceive of a reliable way to ship fuel to its monster airport.

What's needed is a People's Environmental Impact Report. So here it is.

TERRAIN

1. Mountain barriers. The place where the county wants to build its massive international airport is a nightmare for pilots. "The air station is screened on three sides by mountain barriers," states the National Oceanic and Atmospheric Administration (NOAA), the federal agency in charge of weather forecasting. There's 1,500-foot Loma Ridge to the north and more 1,000-foot ridges to the east. Saddleback Mountain, at more than 5,000 feet tall, lies a couple of miles to the northeast. The Laguna Hills lie four miles to the south.

2. Tailwinds. First, the physics: all pilots prefer taking off into the wind to ensure maximum airflow over their plane's wing surfaces, thus increasing lift. The worst situation: taking off with the wind—a condition called tailwinds. Now for the meteorology: NOAA and Marine Corps historical weather data show the wind at El Toro blows east eight months out of the year, averaging about six knots and often reaching 10. The county's plan calls for nearly 70 percent of all aircraft to depart to the east, with these tailwinds. To surrounding mountains and tailwinds, add . . .

3. Runway gradient. The base the Marines formally abandoned on July 2, 1999, was largely a World War II relic. Constructed in the early 1940s, when all aircraft had reciprocating engines and propellers that allowed for slow takeoff and landing speeds and distances, the surrounding terrain and weather meant little. Navy construction crews poured concrete into two runways pointing north-south and two heading east-west, crossing in the middle like a giant plus sign. Never properly graded, the base's southern and western edges are between 60 feet and 120 feet lower than the northern and eastern edges. That slope creates a 1.55 percent gradient on the east-west runways. And that will force aircraft to climb the equivalent of a 10-story building. It also violates Federal Aviation Administration (FAA) runway requirements.

4. Encroaching urban development. The hillsides surrounding El Toro are increasingly home to semiluxurious housing developments. "Land in the immediate vicinity of the station is cleared and cultivated and under extensive urbanization," states NOAA. Coto de Caza, Lake Forest and Mission Viejo are nothing but homes. The Irvine Co.'s massive Spectrum technology and entertainment complex lines the base's southern perimeter; beyond that, thousands of retirees live in Laguna Woods. In the Santiago Hills of east Orange just north of the base, the Irvine Co. is planning a massive 7,000-acre residential and commercial development.

"Urban encroachment is why the Marines closed El Toro in the first place," said Marine Lieutenant Colonel Tom O'Malley (retired), a consultant to the South County cities allied against the airport, during the Aug. 15 county El Toro forum in Lake Forest. A consultant who participated in the 1992-1993 Department of the Navy negotiations to close El Toro and who requested anonymity confirmed O'Malley's assessment to the Weekly.

SAFETY

5. Political runways. The county says it will tear up the current runways (because they're not dense enough to handle the pounding of modern commercial air traffic) but will reconstruct them in exactly the same way the Marines did more than 50 years ago—an archaic plus-sign layout with runways spaced less than 1,000 feet apart. The FAA would prefer to see all the runways run parallel—for reasons of safety as well as efficiency. But never mind airline safety: parallel runways are politically dangerous. Run them north-south, and you pound North County cities with noise; run them east-west, and you have planes flying over wealthy Newport Beach. And we can't have that. Hence the plus sign.

6. No simultaneous operations. Because the county insists on reusing the Marines' plus-sign layout, it'll be impossible for airport-traffic control to conduct simultaneous landings or takeoffs on either set of parallel runways. To do that, the runways would have to be at least 3,000 feet apart. That restriction will slow operations considerably.

7. Eastern departures. Making matters worse is the fact that the county wants nearly 70 percent of all aircraft to take off to the east on Runways 8L and 8R. That means they will have to take off uphill into rapidly rising terrain with a nearly constant tailwind—the worst combination of factors affecting any of El Toro's runways. And it shows in the county's own aircraft-performance analyses. Published in mid-1998 by the aviation firm Jeppesen Sanderson, which draws up all the airport charts that fill every pilot's flight bag, the analyses show that all aircraft departing on Runways 8L and 8R will suffer a nearly 10-ton "weight penalty." That means they will only be able to take off if they're carrying 20,000 pounds less of fuel, passengers or cargo than their maximum takeoff weight. Interestingly, the analyses also show that none of the other runways at El Toro—which point toward population centers south, north and west—will inflict similar weight penalties on aircraft.

8. Steep climbs. On top of that, the county wants all departing aircraft from every runway to begin an immediate climb at a rate of 420 feet per nautical mile just to avoid the surrounding hills and ridges. While the county has been quick to point out that such a climb is well within the flight capabilities of all of today's commercial airliners, this climb differs sharply from the 1,000-foot-per-nautical-mile climb carried out by aircraft leaving John Wayne Airport. That climb, while much steeper, is an artificial noise-mitigation measure; should the aircraft find itself unable to continue climbing, it can safely drop to a much lower altitude. But at El Toro, the planes either make the climb or they hit the ground.

9. Engine-out procedures. So here's a plane, loaded with fuel, passengers and baggage, hurtling down the runway at maximum power when, suddenly, an engine goes. Now the pilot is at two-thirds or even half power—and quickly running out of asphalt. Can the plane stop before it slams into the hill at the end of El Toro's Runway 8? Or should the pilot muscle the plane into takeoff and try to set it down again somewhere? Difficult questions—made worse by the fact that the pilot has perhaps one second to decide.

The situation is rare—a pilot may fly for 30 years and never encounter it—but it happens enough that every pilot must consider the possibility before every takeoff. As a result, every airport has special engine-out procedures. Because of El Toro's surrounding hills, the Jeppesen-developed special procedures require a stricken aircraft departing to the east to make a 15-degree banked climbing turn 100 degrees to the right. Pilots launching damaged planes to the north would have to make a similar climbing turn but would have to crank the aircraft 130 degrees to the left.

These procedures are difficult enough for aircraft flying at maximum power, and they allow absolutely no margin for error. They also exemplify the extent to which county officials are willing to go to cram an airport into El Toro.

A TURNKEY OPERATION

One of the earliest gems of pro-airport propaganda came from Marine Brigadier General Art Bloomer (retired), currently executive director of the North County cities supporting the county's airport proposal. "Converting El Toro to an operational civilian airport is essentially a turnkey operation," Bloomer wrote in a 1993 LA Times editorial. That assurance reappeared countless times in pro-airport mailers. To voters who had no idea what the county's plan would entail, the statement made an airport at El Toro seem sensible and cheap.

10. Demolition. The ASMP makes it clear the county's plan is neither sensible nor cheap. Just about everything the Marines ever built at El Toro has to go: the air-traffic control tower, hangars, Quonset huts, buildings, streets and fuel tanks. All four runways are goners, too, with new concrete laid for each of the two north-south and two east-west runways in phases over the next 20 years. El Toro boss Gary Simon has called it "the largest demolition project in Orange County history."

11. Earth moving. This will be followed by the biggest earthmoving job in county history. The goal is to flatten the runway gradients, currently running between 0.62 percent for the north-south runways and 1.55 percent for the east-west runways. In 1998, the county's Facility Requirements technical report came out, saying engineers would have to cut 4.4 million cubic yards of dirt from the base's northeastern and southeastern quadrants and fill 10.3 million cubic yards of dirt in the northwestern and southwestern quadrants.

But a year later, the Grading Calculations table buried in the El Toro Financial Analysis technical report indicated a far larger—and more expensive—operation. According to the new calculations, engineers would have to cut more than 23 million cubic yards of dirt—enough to form five Hoover Dams—and fill a similar amount over the course of 20 years. The technical report estimates such a project would cost more than $145 million—a figure that, like all the county's financial estimates, seems low.

12. Re-grading. No matter the scale of El Toro's future earthmoving projects, the runways will still have gradients of between 0.52 percent and 0.91 percent. Runways 35R and 35L, which head north-south, won't change much, but east-west runways 8L and 8R will look radically different.

It's hard to tell from the ASMP which end of those runways will look worse. After the grading operation, the western end of runways 8L and 8R will rise more than 60 feet, taking on the characteristics of a tabletop. Drivers on the perimeter road that wraps around the western edge of the base were once able to see straight down the runway; if the county gets its way, those drivers will be looking at a 60-foot wall of dirt.

The opposite will occur at the eastern end of the runways. There, lowering runways 8L and 8R will create a sharply sloping hill at the end of the pavement. For now, the base perimeter road is dead even with the runways; in the future, it will eventually be 40 feet over it.

13. Out of gas. Aircraft engines need kerosene, and it's by no means certain that fuel will ever get to the county's airport. County El Toro spokesman Marine Lieutenant Colonel Tom Wall (retired), who has a tendency to minimize the impacts of the proposed airport, frequently tells people that fueling El Toro will be no problem: the county will use a couple of nearby fuel pipelines to get the precious—and highly combustible—kerosene to the proposed tank farm on the base's southern edge.

But the county's spokesman doesn't know his ass from a 40-mile-long hole in the ground. The pipelines are, by the county's own measure, useless to El Toro International. The eight-inch line once used by the Marines, which runs from the Defense Fuel Depot in Norwalk, was fine for a base handling a couple of hundred flight operations per month. But it's much too old and thin to supply an airport doing that every day. A second 16-inch line is already spoken for: it pumps fuel to Camp Pendleton.

14. Petroleum parade. So never mind the county's high-profile spokesperson. How will the county really fuel El Toro International? Trucks. The El Toro EIR proposes that the future airport's fuel will come from hundreds of tanker trucks rolling in and out of the airport 24 hours per day.

"The Proposed Project assumes facilities configuration and activity reflecting tanker truck delivery, which is the method of fuel delivery to John Wayne Airport," which is how the dry ASMP puts it.

For comparison's sake, note that 23 fuel trucks arrive daily at John Wayne—every one of them after 11 p.m. But the plan for El Toro calls for an average of 244 trucks—each carrying 8,000 gallons of kerosene—to arrive daily at the airport. Since the county estimates it will take one hour to connect, unload and then disconnect each truck, it will have to move 10 trucks into the tank farm every hour of every day of every year.

SHOWDOWN

A solid 60 percent of the county opposes the proposed airport, but county officials are hell-bent on building it anyhow. They want to start demolishing buildings next December; they want the first airliner to land sometime in 2005.

In an attempt to blunt the opposition, pro-airport supervisors said two weeks ago they wanted to limit El Toro to just 18.8 million annual passengers (MAP). This is clearly a public-relations ploy, and it's not even a new one: Coad first floated the idea of keeping El Toro at 18.8 MAP way back in October 1999.

In any case, airports expand. This is a fact the residents who live near LAX and John Wayne know only too well.

Pro-airport Supervisor Chuck Smith understands this, too, which is why he told federal government officials during a Nov. 29, 2000, meeting at the White House, "We never planned to have a 38 MAP airport right off." Instead, Smith outlined for FAA, Navy and White House officials an airport that "will be developed in phases. Other boards will make future decisions whether or not to build larger airports based on demand."

What the airlines want is another story entirely. Few have expressed any interest in El Toro. Asking them to maintain their John Wayne operations and then set up shop seven miles down the road as well is too much.

TRAFFIC

Whatever gets built at El Toro will boost highway traffic. The county's own propaganda states the proposed airport will increase OC traffic by a massive 176,123 average daily trips. The county tries to offset this huge increase with two not-so-subtle tricks.

The first is that whatever traffic the airport causes will pale before that inflicted by anything other than an airport. County propaganda projects that "a non-aviation use" will produce a staggering 339,000 average daily trips.

The county is, of course, referring to the South County's old "Millennium Plan," a mixed proposal of commercial, residential, education and park uses. That plan has since been abandoned in favor of the vaguer "Great Park." And if the Great Park has even half as much parkland as its authors promise, it will yield far fewer daily trips than the 339,000 projected by the county for the Millennium Plan.

At the same time, county propaganda makes the incredible claim that traffic will get worse no matter what gets built—or even if nothing gets built—at El Toro. "There will be 761,910 fewer vehicle miles traveled than under a scenario in which an airport is not built," states a county flier on traffic.

The county's logic here is quite simple, if wrong: since so many county residents in the future are destined to be driving to an airport, it's better that they make short trips to El Toro than longer trips to LAX, Ontario or wherever. Thus, to keep traffic manageable, the county has no choice but to build a big airport at El Toro.

The problem with this spin is that the massive demand for an airport the county says it's trying to meet simply doesn't exist. A few months ago, the Southern California Association of Governments admitted it had overestimated the number of Orange County residents using local airports by 4 million—the right number was just 12 million, not 16 million, every year. Subtract from that number the approximately 5 million who use an airport other than John Wayne Airport, and you come up with an accurate county-airport-demand number of 7 million. And, indeed, in the past five years, demand at John Wayne has stayed pretty much stagnant, hovering around 7.5 million passengers per year.

If all that weren't enough, county El Toro spokesman Tom Wall recently told South County residents that El Toro International Airport isn't about their traveling needs. Instead, Wall said, El Toro International was really driven by the desire to attract global tourists.

THE C-WORD



County promotional materials talk about the airport's impact on air quality in vague, contradictory ways. One single-sheet flier titled "Frequently Asked Questions—Air Quality" mentions that El Toro will "potentially increase air pollution to the region" as well as "improve air quality." It bets on future cleaner-burning aircraft engines but adds the caveat that "the county's environmental analysis does not take into account this new technology."

The concern about air quality masks a darker anxiety about cancer. But even after reading the county's December 1999 EIR and the April 2001 misleadingly titled "Supplemental Air Quality Analysis" (it actually revises, not supplements, the original EIR), it's impossible to nail down a reliable estimate of how many people will die of cancer because of the giant airport.

Identifying cancer risk shouldn't be terribly difficult. But in the case of El Toro, no one knows what the elevated cancer risk is because the county's tables and calculations make no sense.

"The information provided in the EIRs is not sufficient to understand or verify," said Judy B. Yorke, a licensed environmental engineer who has been running her own San Juan Capistrano-based engineering firm for the past six years. "There's no way to know what the true health impact will be."

Yorke pored through the county's air-quality reports and tables on June 14, 2001. In comments she submitted to the county, she said she was astonished to find that county consultants had used an obsolete computer-modeling program that dated to 1993—still allowed by state law but long since abandoned by private industry. Into that obsolete model, Yorke soon discovered, county officials had fed information they didn't disclose in the EIR. Yorke was in the position of an algebra student whose test includes a faulty formula and no variables.

"Without those inputs, we can't verify what the county put into the computer model in the first place," said Yorke, who added that including these inputs is common—even mandatory —for firms fulfilling private contracts.

Despite those problems, Yorke identified a significant flaw in the county's research. If the county is correct, the impossible will occur sometime in the next few years: as El Toro International produces more pollution, the health risks to humans will fall.

For instance, the Supplemental Analysis lists 29 toxic compounds that both El Toro and John Wayne will emit. At build-out in 2020, El Toro considerably exceeds John Wayne in emitting 22 of these compounds, including such scary toxics as benzene, formaldehyde and diesel PM-10. But the Supplemental Analysis table titled "Worst-Plausible Excess Lifetime Cancer Risk" doesn't match those numbers.

Easily the most important table in the entire EIR, this is supposed to explain how many people will get cancer because they're exposed to emissions from El Toro. As you read the following, keep in mind that the South Coast Air Quality Management District considers a risk of 10 in 1 million excessive.

Under current conditions, according to the Supplemental EIR, the risk of getting cancer from working at John Wayne right now is 7,686 in 1 million, but only 134 in 1 million at El Toro. That's fair enough at the moment, since nothing is happening at El Toro while John Wayne serves 7.5 million passengers per year.

But when El Toro is finished in 2020 and John Wayne is handling considerably fewer flights, the on-site cancer risk for John Wayne climbs to 8,003 in 1 million while the risk associated with El Toro climbs to a relatively paltry 317 in 1 million. This brings a total cancer risk for both airports to 8,320 in 1 million.

Data for health risks at residential and occupational sites is similarly inscrutable. And this isn't even taking into account the fact that the tables in the county's original December 1999 EIR bore no resemblance whatsoever to the Supplemental Analysis. For example, the original EIR said the on-site El Toro cancer risk in 2020 would be 150 in 1 million—far smaller than the Supplemental figure. The existing on-site cancer risk for John Wayne was even more striking: just 230 in 1 million compared with the Supplemental Analysis figure of 7,686 in 1 million. And no reason was given for the disparity in the figures.

"Health risk is a huge issue," said Yorke. "But you get the sense that what's here can't be right."

NOISE



For a long time, county officials insisted that noise from this massive airport would not bother the tens of thousands of South County residents who live near the base. These days, they're not even pretending to believe that fiction. Materials put out by the county's outside public-relations firm Amies Communication say "regular night operations" will make "significant" noise.

But county officials still insist no homes are close enough to the base to warrant soundproofing. Are they right?

Only if you accept the county's meaningless way of defining and measuring noise with reference to what academics call the Community Noise Equivalent Level (CNEL). The CNEL analysis is a meaningless academic number that doesn't tell people a thing about how much noise they'll hear in their homes. It is the average of noise a person would hear over a 24-hour period. As such, it's powerfully misleading: take the 11-second, high-pitch, 90-decibel (dB), scream of a 747 flying over your house at 1:08 a.m., average that out over the 3.5 minutes of near silence on either side of that, and you emerge with a flatter noise pattern.

Even the county's own noise consultants understand this is crap. "CNEL is an inadequate descriptor of sleep disturbance," wrote chief county noise consultant Vince Mestre in a June 21, 1999, memo to then-El Toro program head Courtney Wiercioch.

But never mind the experts: county officials continue to use the CNEL measure because it helps them skirt a state law that would require them to soundproof any home exposed to an average daily noise level of 65 dB. And as the EIR and Amies Communication brochures make perfectly clear, "there would be no residential structures inside a commercial airport 65 CNEL line."

The June 21 Mestre memo is an astonishingly frank description of just how bad El Toro will be for the thousands of residents who live around the base. It ends forever the myth that residents who have lived next to an airport for many years will face nothing new when El Toro becomes operational. It is so revealing that the county went to extraordinary efforts to keep it under wraps.

For over a year, the county insisted it was exempt from public disclosure. The reason: "attorney-client privilege," a completely bogus rationalization achieved when someone crossed out the name Wiercioch—the individual Mestre normally reported to—at the top of the memo and wrote next to it "Mike Gatzke." Gatzke was then the county's outside counsel. The tactic failed to hold up on appeal, and the memo finally fell into airport opponents' hands on Aug. 3, 2000.

It's the fact that El Toro will be a round-the-clock airport with large numbers of night flights that will make the noise so bad. According to Mestre's once-secret memo, the Single Event Noise Level (SENEL) metric —which measures the actual noise produced by a single event, like a plane flying over your house—"is a better indicator of sleep disturbance [than CNEL]." Mestre added that SENEL levels of just 70 dB would be enough to wake up as much as 7 percent of the surrounding population.

Houses with the windows closed will screen out 20 dB, but a house with the windows open will screen out only 12 dB. Because of the local climate, Mestre recommended in the memo that the county should assume residents would keep their windows open at night and draw up an 82 dB SENEL contour to show true sleep-disturbance impacts.

"The mild climate of the area and the lack of historical military night operations may indicate widespread use of open windows at night," wrote Mestre. "Closing windows may not be an option in these areas, since they are not required by the county to have been constructed with mechanical ventilation."

All MD-80s, DC-10s, 727s and 747s produce at least 82 dB in flight. Mestre pulled no punches about what this would mean for county propaganda. Using this new contour, Mestre warned, "would impact homes that have been exempt from the county noise standards and may have not been constructed with sound-control treatments."

Such a "sound-print" would, according to Mestre's memo, suggest nearly 5,000 homes hit by at least 82 dB of noise. But there was worse news, Mestre warned: "The above analysis does not consider departures [to the south], which have SENEL contours significantly larger than those of Runway 34 arrivals."

Mestre then pointed out that the number of homes under the southbound departure corridor affected by at least 82 dB "will be a very, very large number."

Mestre buried his most devastating prediction beneath layers of negatives and dependent clauses: "Under no circumstances will the noise study conclude that there is no significant noise impact for a 28 MAP airport with 22 percent of the operations at night." Translation: jet noise from El Toro will be loud enough to wake people up. That will be true, Mestre added, even if the county does what it says it won't do and soundproofs homes around the new airport. Even then, Mestre wrote, "these night operations will still be a significant impact."

In conclusion, Mestre wrote that his firm, Mestre Greve Associates (MGA), "will represent in its noise study that night operations at El Toro are a significant impact." And just to make sure there was no mistaking his sincerity, Mestre ended his memo with the statement "The above findings are supported by the entire staff at MGA."

None of Mestre's recommendations made it into the EIR. Because county officials determined that no one lives in the 65 dB CNEL zone, the county will spend no money soundproofing homes.

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