The San Diego Regional Airport Authority has taken over responsibility for the Comprehensive Land Use Plans (CLUP) for San Diego County. They are actually using the CALTRANS Land Use Planning Handbook to guide them in updating these seriously outdated documents which are unique to California. CLUP?s are intended to protect the utility of Public Use Airports from encroachment by nearby incompatible land uses. The Planning Departments from the County and some cities in the area are complaining about the new restrictions to protect our airports (see related article on the topic on www.calpilots.org “San Diego County Regional Airport Authority Under Attack”). The following comments, from an aviation perspective, were submitted during the public comment period. It is hoped that the Airport Authority will use them to improve on the documents that are apparently going to serve their purpose.
1. The Airport Influence Area/Compatibility Maps could use some additional tailoring to more accurately reflect actual flight tracks associated with each airport. Local Pilots and Flight Track plots from the Lindbergh Noise Office (and possibly the FAA) can help in this regard. Some of the old SANDAG CLUP?s show this consideration, and might also be used for reference.
2. The Highway that separates air activity between Montgomery and Miramar does not appear to be taken into account in the Influence Areas of these two airports. The San Diego Class-B Chart can be used as a reference for this local use boundary. The Noise footprints between these two airports combine to produce complex CNEL patterns that do not appear to be (or ever have been) addressed in either CLUP (can this factor be addressed in the CNEL Model, and a note added to each CLUP).
3. Above Ground Storage of Hazardous Materials does not appear to be addressed as a consideration factor for evaluation within the Airport Influence Area/Compatibility Maps for the General Aviation Airports. The old SANDAG CLUP addressed this factor for Miramar; this (old) approach could be considered for use in the new Regional Authority document(s). There appears to be a significant number of above-ground tanks in the area.4. The Airport Influence Area/Compatibility Maps do not appear to properly portray nearby open-air facilities adjacent to Montgomery Field (the Football Stadium) or Brown Field (the Water Slide and Amphitheatre attractions). There is also a (spiker) power generating plant next to Brown Field that produces a cloud/smoke Visual Hazard under favorable meteorological conditions. Some airports have nearby water areas that attract birds. Birds and smoke are addressed in the CALTRANS Planning Handbook. San Diego has a number of Golf Driving Ranges that are illuminated at night (the one on approach to Montgomery Field is an example; there is something near Palomar as well); consideration for shading the bright lights from over flying aircraft and helicopters is recommended for consideration in the CLUP?s.
5. The TSA periodically restricts/prohibits the use of the airspace around national event venues. This has happened for Super Bowl and National Election Conventions in San Diego, which has basically shut-down Montgomery Field during these events and their associated daily activities for significant periods of time over a number of days. A new area, perhaps out to 30 miles or so, should be considered to address this growing concern. The last time such a severe restriction was imposed in San Diego, the TSA and FAA actually said that it was not required; the Police Chief and the Mayor were successful at getting such a restriction imposed. This is clearly a valid, and growing, topic to be addressed in the CLUP?s. As a Minimum, future expansion/modification activities at the nearby Football Stadium should be restricted.
Region IV VP
Cclifornia Pilots Association