Palomar Airport: Counting Environmental Impacts: Should You Care, Blog #29

The FAA and County avoid proper environmental analysis at Palomar Airport by a deceptively simple  method.  They don’t fairly analyze cumulative environmental impacts as the environmental laws expressly require.    

FAA & County Math   When the FAA and County count Palomar Airport project environmental impacts, 10 + 20 + 70 + 1 = 11.   Not 101.  Why do the FAA and County miscount the impacts?  

Counting 101 impacts might require the FAA to prepare a detailed environmental impact statement (EIS) under the National Environmental Policy Act [NEPA].  Similarly, the County might have to prepare a detailed environmental impact report (EIR) under the California Environmental Quality Act [CEQA].  

Counting only 11 impacts avoids an EIS or EIR and perhaps any assessment.   Why?  The FAA and County want a  “shovel ready” project, not a “paper ready” project.  

NEPA & CEQA Basics   To understand FAA and County math, understand two things about NEPA and CEQA.   First, NEPA requires federal agencies to analyze environmental impacts when federal approval or permit is needed for a project.  So too, CEQA requires the County and cities to analyze project impacts when local approvals or permits are needed.

Second, both NEPA and CEQA require agencies to study new project impacts including the CUMULATIVE impacts.  

CUMULATIVE analysis requires analyzing the additive effects of prior and reasonably foreseeable future projects in the area.
Impacts must be counted for both on and off airport projects.  Why?  The issue is what total environmental impacts exist after the latest project is built.  

How Do the FAA & County Frustrate the Environmental Process?  

Consider an example.  A new airline, Superfly, wants to fly a big plane at Palomar.     

Year 1: Palomar.  The FAA certifies Superfly for Palomar flights.  Superfly buys a plane.  Maybe it flies 10 flights per day.  The FAA environmentally assesses the air quality, noise, and traffic impacts of 10 Superfly daily flights including adding 10 drivers per day to local streets.  So far, so good.     

Year 1: Off Airport.  Also, Carlsbad in Year 1 grants a permit for a used bookstore near Palomar.  The City environmentally assesses the shortterm impact of this store including an estimated 7 daily patrons.  The store must have 10 parking spaces.
 
Years 2 to 10: Palomar.   Superfly is superfine.  It buys 2 more planes.  It adds 20 daily flights and 20 drivers to the roads. But there is no new environmental assessment.   Why?  Superfly did not need a new discretionary approval to fly more planes.   The planes use the same runway and same Superfly area.  

Years 2 to 10: Off Airport.   The used book store business booms.  Seven daily patrons in Year 1 grow to 70 daily in Year 10.   Now, many patrons park on the street.  But no new environmental assessment has been done for the new patrons because the store did not need a new permit to handle more patrons.

Year 11: Palomar Airport.  Superfly adds a worker.   The County gives Superfly a permit for a new parking space.  The County finds no environmental assessment is necessary.   Why?  Adding the single space has no significant environmental effect.

Cumulative Impacts: The Real Math   The County’s Year 11 conclusion that one new Superfly employee and parking space does not much impact the environment seems correct.  What’s the problem?   

The problem is that the County – perhaps like your spouse – is living in the past.  The County sees 1 more driver added to the 10 drivers assessed when Superfly first got its permit.  The County ignores Superfly’s 20 added daily drivers and the 70 added drivers from the used book store.  

The total drivers on the roads in Year 11 is 10 + 20 +70 + 1 = 101.  And CEQA requires the County to assess the environmental impact created by all drivers.

Should You Care?  

The next time you are stuck in slow moving traffic, don’t ask why the County failed to build more lanes.   The County CEQA traffic studies showed 11,000 drivers instead of 101,000.  Or 101,000 instead of 1.1 million.  

And forgive your spouse too.   He or she is living in the 1990s when women’s shoes were $70, not $170 and a car cost $17,000, not $27,000.