Today’s blog looks again at issues raised by a 2011 County Counsel letter to Carlsbad related to a Palomar Airport runway extension. The letter to the Carlsbad City Attorney said that Carlsbad need not take a zoning, planning, or legislative action to approve a runway extension. Therefore, Carlsbad voters have no right to vote on an extension. [See Blog 71.]
The county argues three points. First, the runway extension is not an airport expansion; hence, Carlsbad need not take a legislative action to amend Conditional Use Permit [CUP] 172 which requires an amendment for airport expansions. Today, we discuss this point. Second, California law does not allow cities and counties to regulate each other. See last week’s blog. Third, the State Aeronautics Act lets the county, not Carlsbad, decide whether to lengthen the runway. See next week’s blog.
The Facts: Will a Runway Extension Expand Palomar?
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As you read this, the county is folding the August 2013 Kimley Runway Extension Study into the Kimley Palomar Master Plan [PMP]. The Study and PMP “expansion language” was and is being carefully crafted. How?
Try a fun exercise. Search your internet for McClellan-Palomar Airport. You will find the county website. Go to it. Click Runway Extension Study link. The Study should appear as a Word document. Go to “Edit” in the Word menu at the screen top. Select “Find” from the “Edit” choices. In the “Find” search box at the top right of the screen, enter “growth.”
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You will pull up many pages in the Kimley Runway Study that discuss Palomar “growth.” Now compare the Study “growth” language in Study Chapters 1 – 8 with the language in Chapter 9, a very short environmental chapter:
“Based on the forecast analysis summarized in Chapter Three of the Feasibility Study, the airport is expected to have an average annual growth rate in total operations of approximately two percent through the year 2021 with the proposed runway improvements (Figure 3G). Annual growth in based aircraft is expected to be an average annual increase of 1.6 percent through 2021 (Table 3M). This amount of annual growth at the airport over the next 10 years would not be expected to result in secondary impacts on the County or the City of Carlsbad.” [Study page 9-18]
Isn’t that interesting. The $90 million runway and taxiway extension is so important that Kimley Study Chapter 8 tells us it will create $299,000,000 in economic benefits. [Table 8-D, page 8-6.] And that number is just the benefit from increased “useful loads.” The $299 million figure does not include figures for increased Palomar passenger levels because the Kimley study focused on corporate jets.
In other words, the Study says – for environmental purposes – there are no noticeable airport expansion and no “secondary impacts.” But for purposes of asking for $90 million in FAA grants, the extension benefits are significant. Really?
The issue of whether the runway extension is an airport expansion is academic. California Public Utilities Code Section 21664.5(a) in the State Aeronautics Act says that the county must get an amended airport permit from the state if Palomar is expanded. And Section 21664.5(b)(3) defines an “airport expansion” as including “the extension or realignment of an existing runway.”
When the county gives us the PMP, ask whether the County has disclosed all the facts and whether the economic and environmental forecasts are consistent.
[P.S. Yes, I know. Some have an odd idea of what a “fun exercise” is.]