Open letter to San Benito Airport Land Use Commission on ill advised decision to approve Flea Market land use proposal on the edge of the runway 31 runway protection zone (RPZ).
Summary – San Benito County (SBC) is the airport sponsor for the Hollister Airport (CVH). The ALUC is made up of SBC Sups and a few from the Hollister City Council. None have the aviation experience required on an ALUC. Hollister does have an Airport Advisory Commission the city relies on. Unfortunately, a few of the SBC Sups tend to ignore them.
The ALUC made a questionable decision approving the location of a weekend Flea Market on the right edge of the runway protection zone (RPZ) for the primary runway – 31. Same old story – developer pushing a Sup to use the cheap land he bought close to the airport, means more jobs, taxes, etc., etc…
Action – Our rep and and a Airport Advisory Commission member asked us for help. After asking all of the normal questions, are the local pilots involved (not really), etc. I wrote a letter to the ALUC and that the decision was inappropriate given the location. I copied the appropriate people.
It appears that the Hollister CC and Planning Agency is against this but the one Sup is trying to push it through. I plan on attending the meeting being held Dec 7th.
For more detailed information you can read the letter below.
November 7, 2010
San Benito County Airport Land Use Commission
330 Tres Pinos Rd, Suite C7,
Hollister CA 95023
Subj: ALUC Approval of the Proposed Flea Market Project
Honorable San Benito County Airport Land Use Commissioners, Bilich, Botelho, De La Cruz, Emerson and Gomez
Mission: The California Pilots Association is a non-profit public benefit California Corporation formed in 1949. The mission of our statewide volunteer organization is to promote, preserve and protect the state’s general aviation airports and aviation privileges.
I am writing to you today on behalf of the board and statewide membership regarding the ill-advised approval by your commission of the proposed Weekend Flea Market to be located at the approach end, and at the edge of, the Runway Protection Zone (RPZ) of the Hollister Airport runway 31. [i]
The information we have regarding the vote is as follows: Commissioner Bilich, Botelho and De La Cruz voted to declare the application to be in compliance with the Hollister Airport Comprehensive Land Use Plan (CLUP), Gomez and Emerson voted against.
CALPILOTS disagrees with this approval, and will provide the information required to help your ALUC understand why the decision must be revisited and overturned.
We agree with the July 21, 2010 letter from Caltrans, Division of Aeronautics, which states ”The Division of Aeronautics supports ALUC’s determination that the proposed flea market project is inconsistent with the safety standards contained in the 2001 Hollister Land Use Compatibility Plan (ALUCP). We are concerned that the staff report provides a substantial discussion about meeting the letter of the law, rather than the spirit and the intent of the aeronautics act”. After reading this letter we are at a loss to understand how the project was approved.
We believe that it is appropriate to review the mission of an Airport Land Use Commission – which we would add, by definition requires two members with aviation expertise. Aviation expertise is critical to the airport land use compatibility decision process. [ii]
The 2002 California Airport Land Use Planning Handbook (CALUPH) states:
“It is the purpose of this article to protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses.”[iii]
Since the CLUP for Hollister Airport is somewhat out of date, the latest Division of Aeronautics airport information on land use compatibility must be used to insure the noise and safety issues are mitigated to every extent possible.
The following points must be revisited when considering the proposed Flea Market project, and will provide the basis to reevaluate and change the decision. These points are especially important since studies show that 75% of aircraft mishaps, incidents and accidents happen on take-off and landing. There is a valid reason for runway protection zones – which perhaps should be renamed to Community Protection Zones.
1. The Flea Market project’s proposed location places it at the edge of runway 31’s Runway Protection Zone (RPZ) – see graphic
2. Runway 31 is the primary use runway at the Hollister airport, and the base and final legs of all aircraft landing on runway 31 could overfly or fly very near to the proposed Flea Market location.
3. Aircraft taking off on runway 13 (the opposite end of runway 31) would be flying directly over the proposed Flea Market location on climb-out
4. Aircraft using Runway 24 which is also a also left hand traffic pattern would also be flying over the proposed Flea Market location
5. The instrument approach to Hollister Airport, used during fog and bad weather, routes aircraft from the southeast as low as 400 feet to land on runway 31, or to circle to land on the runway most appropriate considering the wind and weather [iv]
[i] (Runway Protection Zone [RPZ]: An area (formerly called a clear zone) off the end of a runway used to enhance the protection of people and property on the ground. Airport Design AC)
[ii] ALUC Single-Purpose Entity
If established as a single-purpose body, the standard membership composition of an airport land use commission consists of seven members selected as follows (Section 21670(b)):
- Two county representatives (selected by the board of supervisors);
- Two city representatives (selected by a committee comprised of the mayors of all cities in the county);
- Two having “expertise in aviation” as defined in Section 21670(e) (selected by a committee of the managers of all public airports in the county); and
- One general public representative (selected by the other six commission members).
[iii] FORMULATING AIRPORT LAND USE COMPAT I B I L I T Y P O L I C I E S CHAPTER 3
California Airport Land Use Planning Handbook (January 2002) 3-5
- Safety on the Ground: The most fundamental safety compatibility component is to provide for the safety of people and property on the ground in the event of an aircraft accident near an airport.
[iv] OVERFLIGHT
Basis for Compatibility Zone Delineation
The area of concern encompasses locations where frequent aircraft overflights can result in annoyance and complaints on the part of some residents.
- At general aviation airports, these locations include areas beneath the standard traffic patterns, portions of the pattern entry and departure routes flown at traffic pattern altitude, and sometimes additional places which experience a high concentration of overflights.
- Airspace protection surfaces defined in accordance with FAR Part 77 provide a useful starting point for delineating an overflight zone.
- At all airports, common instrument arrival and departure routes should also be considered when establishing an overflight zone.
Taken directly from the CALUPH – this drawing is a composite of actual runway arrival and departure mishaps, incidents and accidents on a 4,000’-4,999’ runway – note runway location in the middle of the page
When all of the issues are considered we believe that as an ALUC you must reconsider your decision, and change your vote to a “Not Compatible in the current location” on the Flea Market proposal. Doing so will mitigate future unreasonable safety and noise risks (and the associated costly liability) to the City of Hollister and San Benito County.
To fully understand how important your decision on this matter is to safety, we would also highly recommend that one or more of the ALUC fly with volunteer pilots from Hollister airport to better understand the flea market location proximity to the airport. Thank you for your attention to this issue and for your consideration. If there is any way we can be of further service to you please don’t hesitate to contact us.
Ed Rosiak – President
California Pilots Association
P.O. Box 6868
San Carlos, CA. 94070-6868
cc:
San Benito County Board of Supervisors
Hollister City Council
Airport Advisory Commission
Gary Cathy – Chief – Division of Aeronautics
CALPILOTS Board
John Pfiefer – Aircraft Owners and Pilots Association
www.calpilots.org
[1] (Runway Protection Zone [RPZ]: An area (formerly called a clear zone) off the end of a runway used to enhance the protection of people and property on the ground. Airport Design AC)
[1] ALUC Single-Purpose Entity
If established as a single-purpose body, the standard membership composition of an airport land use commission consists of seven members selected as follows (Section 21670(b)):
- Two county representatives (selected by the board of supervisors);
- Two city representatives (selected by a committee comprised of the mayors of all cities in the county);
- Two having “expertise in aviation” as defined in Section 21670(e) (selected by a committee of the managers of all public airports in the county); and
- One general public representative (selected by the other six commission members).
[1] FORMULATING AIRPORT LAND USE COMPAT I B I L I T Y P O L I C I E S CHAPTER 3
California Airport Land Use Planning Handbook (January 2002) 3-5
- Safety on the Ground: The most fundamental safety compatibility component is to provide for the safety of people and property on the ground in the event of an aircraft accident near an airport.
[1] OVERFLIGHT
Basis for Compatibility Zone Delineation
The area of concern encompasses locations where frequent aircraft overflights can result in annoyance and complaints on the part of some residents.
- At general aviation airports, these locations include areas beneath the standard traffic patterns, portions of the pattern entry and departure routes flown at traffic pattern altitude, and sometimes additional places which experience a high concentration of overflights.
- Airspace protection surfaces defined in accordance with FAR Part 77 provide a useful starting point for delineating an overflight zone.
- At all airports, common instrument arrival and departure routes should also be considered when establishing an overflight zone.
