Director of Airport Systems Planning San Diego Regional Airport Authority
SAN DIEGO AREA AVIATION COUNCIL
RONALD J. COZAD
2006 Palomar Airport Road, Ste 214, Carlsbad, CA 92008
April 15, 2005
Mr. Sunil Harman
Director of Airport Systems Planning San Diego Regional Airport Authority P.O. Box 82776
San Diego, CA 92138-2776
Dear Mr. Harman,
The San Diego Area Aviation Council (?SDAAC?) is pleased to submit its comments concerning the Authority?s proposed planning guidelines.
The SDAAC is an association composed of local airport pilot, community and airport user groups from each of the San Diego area public airports. These airports include McClellan-Palomar, French Valley, Borrego Valley, Fallbrook, Agua Caliente, Jacumba, Ocotillo, Montgomery Field, Oceanside, Ramona, Brown and Gillespie Fields. The purpose of the SDAAC is to promote safe and considerate operation of general aviation aircraft, community outreach and responsible planning and effective communication with local governing agencies. Significantly, neither the SDAAC, nor any of its member organizations are not for profit enterprises. Each organization is staffed entirely by volunteers whose sole goal is to promote safety and the quality of life in and around general aviation airports. A primary focus of the SDAAC and its member organizations is the prevention of community discord by avoiding irresponsible residential encroachment into areas heavily influenced by the operations of existing public airports.
As the value of San Diego real estate continues to rise to historic levels, competition among developers for available buildable land has intensified to the extent that developers and their organizations have planned and engaged in campaigns to target open area safety zones near existing public airports, and in some circumstances, to promote the closure of active public federally-funded airports in the name of achieving the ?highest and best use? of land occupied by airports. These well financed campaigns, with which we can not compete, include engaging in private lobbying efforts with local government officials, stacking public hearings with attorneys and public relations consultants and resisting efforts for more than minimal discloses to purchasers of the extent of nearby airport operations. The SDAAC respectfully suggests that public use airports, like parks, libraries, wild life preserves, public beaches and the like by their nature do not represent the highest and best economic use of the land they occupy yet deserve vigilant regulatory protection for their intrinsic values and for the value they represent to the community as a whole.
The SDAAC believes that many of the criteria contained in the proposed guidelines may be an unintended accommodation to developer efforts that upset the delicate balance between profit- motivated housing production, public safety and public airport operations. The following suggestions are designed to address those concerns:
1. Dimensions are needed for Compatibility Zones A-E. These are missing on some maps.
2. Increase noise reduction requirements to at least 35db in airport influence areas where people will live or work. We recommend 40dB.
3. No New Dwellings. The SD policies allow consideration of new residential in areas of safety concerns B and C. We believe this is not in the best interest of the public primarily for safety reasons, also for noise. We believe No New Dwellings in these areas for any type of airport (urban, suburban, and rural). Any area of safety concern where policy prohibits building schools and libraries should also prohibit new dwellings. Additionally, the possibility of considering Residential as “Non-Residential” is not recommended in airport zones.
4. Require Avigation Easements. Disclosures have not achieved their intended purpose of communities in harmony with airports. We recommend aviation easements be required for all new developments in all zones A, B, C and D for all airports. This is recommended by many aviation organizations to communicate the seriousness of locating in these areas.
5. Revise Aircraft Operations Forecasts. Operations data taken between the years 2000-2004 will be highly irregular and should not be used for 20 year planning forecasts. During that time period we had 1) Terrorist bombings and grounding/restrictions on VFR GA; 2) A war; 3) A recession. Where data from those periods was used, light GA VFR activity/flight paths are probably underestimated. Conversely, IFR/commercial operations ratios will be higher. Because of this SD ALUCP‘s estimates and forecasts for all airports with light-GA may be invalid. We recommend using data from 1999 for planning purposes. Using better data will show an increase in light-GA impact around airports such as Oceanside, Palomar, Montgomery, Brown, Gillespie, Ramona, and Fallbrook. It is in the best interest of disclosure to use pre-recession / pre 9-11 baseline data.
6. Compatibility Zone shapes not following guidelines. There are several airports where safety zones are unusually small, non-geometrically shaped (not per CA guidelines) or follow roads/jurisdictional boundaries. Any underestimate of safety concern areas due to developer and municipality pressures to allow certain types of development or to follow a profit motive should be avoided. We ask the commission resist pressures to allow new dwellings in areas of safety concern.
Thank you once again for your consideration. Please feel free to contact the undersigned with any general questions. Please also feel free to contact our Safety Committee with any questions of a technical nature. They may be reached at firstname.lastname@example.org.
Sincerely, Ronald J. Cozad cc:
Aircraft Owners and Pilots Association, 421 Aviation Way, Frederick, Maryland 21701
California Pilots Association, P.O. Box 6868, San Carlos, CA 94070–6868
Caltrans California Di