Dear Readers:
Please see the letter below written by Ed Crouse to Mead & Hunt, the consultants charged with studying the improvement and potential expansion of Cuyahoga County Airport.
March 18,2013
Lynn Wilson - Mead & Hunt
Public Comment on the Cuyahoga County Airport Environmental Assessment for the
Master Plan Open Comments to the Airport Staff, the Cuyahoga County Executive and
Council, the Mayors and Councils of the communities surrounding the airport, and the FAA
Dear Lynn:
As we discussed during the open house Feb 27,1 wanted to summarize questions and concerns about the proposed expansion of the Cuyahoga County Airport (CGF), and the process thus far. As your firm has only recently been engaged, and there has been a change in the reporting structure of the airport to the County, this summary is lengthy, but gives background to the issues still open. Specific questions are brought out, many of which have never been answered by the airport. The questions are summarized at the end for simplicity.
1. The purpose of the Environmental Assessment (EA):
I asked one of the Mead & Hunt representatives at the open house about the EA
and its purpose. The answer was that it is needed to get funding for the safety area
improvements and to address the pavement conditions at the airport. When I asked
about the EA as the next step for the Master Plan, I was told that it had nothing to do
with the Master Plan - it was about safety and pavement.
This is a very bad sign that the new consultants on the project don't understand why the EA is needed, and would deny the requirement for the EA being rooted in the proposed runway expansion. The verbal presentations were consistent with previous airport presentations that imply that the longer runway is required to address safety.
The website on the EA (see appendix A) says nothing about a runway expansion, yet all of the alternatives being reviewed do indeed increase runway length.
In fact, the FAA's comments (from the Airports District Office in Detroit, or ADO) on the draft plan in July, 2009 were very specific:
The report should first evaluate the existing conditions of the airfield, and then determine capacity needs to accommodate the current or forecasted demand. For the airport's single runway, this would mean separately evaluating meeting standards on the existing runway, which would be considered a safety/standards project; then evaluating any potential runway extensions that would increase capacity at the airport.
These are two distinctly different needs within the report (meeting FAA design standards on the existing runway and increasing runway length), yet the report only recommends an alternative that involves a runway extension while meeting design standards. The preferred alternative identified in the report includes a runway extension to 6,000' while incorporating Engineered Material Arresting Systems (EMAS) and the relocation of two roads in order to satisfy FAA design standards. This alternative adequately addresses both a proposed runway length that will increase capacity for the existing aircraft fleet mix at the airport as well as provide adequate RSA's. The report does not identify a recommended alternative that meets FAA design standards for the existing runway length or airport layout limitations. In order to proceed with further review and potentially concur with the sponsor's recommendations, the ADO is requesting that a preferred alternative that addresses the design standard deficiencies for the current condition be Identified as part of the RSA evaluation. As presented, the ADO cannot concur with your recommendation for implementing only Alternative 38 (capacity recommendation) in absence of a recommendation that addresses the current design standard deficiencies for the existing runway with no extension for capacity.
The FAA is very clear that the need to meet safety requirements is separate from a longer runway. Throughout the process since 2003, the airport has consistently mixed the desire to expand with the need to address RSA's to imply that a longer runway is needed. This is not true.
Question 1: Will the airport release a corrected presentation, and publicize the 3 distinct things it wants to accomplish - meeting RSA standards, pavement improvement, and increasing runway length?
The reference by the FAA to the preferred alternative in the July 2008 review was to alternative 38. This was the airport plan submitted in 2008, in spite of the tremendous protests by busloads of residents at a County Commissioner's meeting. The FAA asked for alternatives at each proposed runway length - i.e. one for the current 5,100 foot runway, one for a proposed 5,500 foot runway, and one for the proposed 6,000 foot length. At the time the FAA reviewed the plan, they were unaware of the requirement in Ohio that the local municipality must sign off on any road relocation, and that both Richmond Heights and Willoughby Hills had denied any relocation of Richmond or Bishop Roads. The airport and its consultants at the time, C&S Engineers, withheld that important detail.
The FAA was subsequently informed of the approval requirement, and that both cities had already denied approval. Then the airport updated the plan in 2010 to include alternative 23 as the proposed plan, with alternative 38 remaining as the ultimate plan.
But the airport still has not presented an answer to the FAA's direct request for a plan that addresses the deficiencies with the existing runway with no extension for capacity.
Question 2: Will the airport develop, publicly review, and submit an alternative that addresses the safety areas but keeps the runway at 5,100 feet before proceeding with the EA, per the FAA's request?
Alternative 8 was discussed by the FAA in regards to this need, but also identified that some of the distances were not calculated correctly. Alternative 8 does not seem to take advantage of the allowable distances in comparison to alternative 23. Specifically, if alternative 23 can allow up to 5,500 feet for departures and 5,200 feet for landings, it would seem that the airport could develop a 5,100 foot plan that allows fall use of all 5,100 feet for departures and landings, as the obstructions in the RSA's would be no closer than in alternative 23. The airport's focus on a longer runway apparently diverted attention from maximizing the use of the current 5,100 foot runway.
The "Fact Sheet" handed out at the open house states that alternative 23 of the master plan was preferred "because it complies with FAA airport design standards while also having fewer impacts to the neighboring communities and the environment than other alternatives". This is false, based on alternative 8, and the FAA's request for an alternative at the current runway length. Refer back to question 1: the airport needs to stop implying that the longer runway is a necessity, and correctly explain this to the public.
The pictures used on the EA website include a clear misrepresentation of the pavement conditions. The first picture (appendix A) is an area of the apron that was replaced in 2012 with new concrete, yet it is shown as a current need.
2. Runway length
The airport declares a "demonstrated" need for a longer runway, but has not substantiated the claim. Current runway limitations that were raised at one of the Community Advisory Committee meetings centered on the Hawker 400. The draft plan shows that this plane needs a 6,975 foot runway at max landing weight. Hawker's website, however, indicated a landing distance of 3,514 feet at max landing weight. At the 80% limit for usable length, the current 5,100 foot runway offers 4,080 feet of useable length. Given that the data in the draft plan shows 2,660 landings by this type of plane in 2003, the current runway length must not be such a huge limit.
There was a very detailed "analysis" made that purports to justify a 6,000 foot way. A simple review of this document shows, however, that the 6,000 foot length doesn't come from the calculations, but rather a survey of the airport tenants. If you ask for a wish list, what else would you expect? Yet the airport presents this as a "substantiated" need.
The airport also conveniently mixes the 80% of runway length and the 60% limit - the difference has been explained as the more conservative 60% limit being required when an operator has not listed an airport as an approved destination airport. If the airport tenants did not make this approval, then they clearly have no basis to complain that the runway is too short. At the common takeoff weights, the detailed analysis actually shows that the present 5,100 foot runway meets the needs of the operators.
The draft final report quotes feedback from Eaton indicating that it had to divert 10% of its flights away from the Cuyahoga County Airport due to wet or snowcovered runways. Flight Options, however, claims that only 50% of its planned flights could be conducted during the winter of 2004-2005. The claims are used as rationalization for a longer runway. But in the Airside Tenants Focus Group meeting on November 19,2004 feedback was given that poor wind conditions plus ice/snow will lead to cancelled flights.
When any of the tenants chose CGF to base their aircraft, they did so knowing that the mnway was 5,100 feet long. And presumably, they knew that it rains and snows here, and that the wind blows.
Question 3: Are the airport tenants that have requested a longer mnway using 80% of the runway length per FAR Part 135?
Question 4: Is there truly any substantiation beyond surveys and misinformation that a 5,500 foot runway is needed?
Question 5: What percentage of flights that were diverted or cancelled could have taken place with a 5,500 foot runaway, vs. what percentage would have been diverted or cancelled anyway due to other conditions?
There are various projections on the volume of traffic at the airport. None specifically break out the expected change if the runway is longer.
Question 6: Will the airport publish a full projection of traffic, and specifically identify the change in volume if the runway length goes to 5,500 feet?
3. Noise
At meeting after meeting, the issue of airport noise came up, and was sidelined. The "voluntary" curfew had been written off by the airport as unworkable. There was specific discussion of limiting certain aircraft types from operating overnight, but that was categorized as unacceptable, as any discrimination by aircraft type was not allowed. Requests for mandatory curfews were turned down with the explanation that a public airport must remain open 24 hours. The volume of night operations was unknown by the airport administrators.
Upon further research, we found that these responses were not entirely true. Specifically, a mandatory curfew is not only possible, but has been implemented at the San Diego airport, including additional limitations by class of aircraft:
What is a curfew violation, and how are they enforced?
The Airport Use Regulations (Regulations) for San Diego International Airport were adopted by the Board of Port Commissioners in 1989, and include Time of Day Restrictions (curfew). The curfew states that Stage 2 aircraft can depart from 7 a.m. to 10 p.m. Stage 2 aircraft have been phased out at San Diego International Airport as of January 1, 1999 for all regularly scheduled commercial, cargo, and commuter operators for their aircraft weighing more than 75,000 pounds. Stage 3 aircraft can depart between 6:30 a.m. and 11:30 p.m. Lifeguard, emergency flights, or flights for military necessity are permitted to operate as needed, and landings are permitted 24 hours a day at SDIA. When a violation of the curfew occurs, the Cm few Violation Review Panel (CVRP), comprised of Airport Authority staff from several departments, meets to decide whether or not the operator should be fined for the violation.
The administrative fines for violations of the curfew are: $2,000 for the first violation by a particular operator in a compliance period; $6,000 for the second violation in a compliance period; and, $10,000 for the third violation in a compliance period. Each compliance period is six (6) calendar months. Here is a more detailed description of the Airport Use Regulations.
What are the noise curfew times?
The Airport Use Regulations, Time of Day Restrictions, or Curfew, states that no departures of Stage 2 aircraft are allowed after 10:00 p.m. and before 7:00 a.m. All departures are restricted from 11:30 p.m. to 6:30 a.m. daily.
Are all operations subject to the curfew?
No. Arrivals are permitted twenty-four hours a day, and emergency mercy, and some governmental operations are exempt from the curfew.
(IUtp://www.san.org/alrpoit_aulhotHy/onvlronniental_arfnlrs/airport_noiso/faqs.asp)
When the San Diego information was brought up, then airport explained that San Diego was able to implement this before the FAA changed the rules that now prevent such restrictions. But the airport didn't acknowledge that it already has certain restrictions in place, implemented in 1978. Sec the detail in appendix B. Note that this document was signed by the FAA.
While the night curfew is a "request", i.e. voluntary, the prohibitions on any training flights for jets, night training flights, engine run-ups between 9:00 PM and 7:00 AM, as examples, are
hard requirements.
A Noise Abatement Council was based on the many noise discussions. Updates to the noise abatement procedures have been part of its focus.
Question 7: Has the airport kept and enforced the hard restrictions enacted in 1978?
Question 8: Can the airport publish the current version of noise restrictions?
In spite of the many discussions at various meetings, the airport refuses to acknowledge the magnitude of the impact on the community. The airport management commented at one of the update meetings in Willoughby Hills that there were "only" 350 noise complaints the previous year. Somehow, they don't recognize that this is nearly one for every day of the year. And this is in spite of the many complaints that don't gel reported because the airport routinely ignores the complaints, refuses to follow up, and has even lied by saying that the noise was not actually a plane landing or departing the airport.
On one hand, the airport uses the convenient excuse that it cannot restrict night operations because it is a public airport. But then it will not identify the operators that violate the night curfew.
Question 9: Rather than relying on noise complaints to be reported, will the airport take a proactive approach by adding a section to its website that publishes a list of curfew violations, including the aircraft owner?
As a public airport, this information should be made public. The 1978 restrictions include a requirement that engine runups be conducted at the designated remote aircraft engine runup area. Yet most of these tests are done today by parking the plane in the center of the airport.
Question 10: Where is the designated remote run-up area?
There were many discussions in the planning process about the need for a "hush house" for such run-ups. Yet at the open house, no one on the staff or with Mead & Hunt knew anything about this. Given the number of times this topic appears in the public documentation of the master plan process, this is either a very convenient omission or a sign of incompetence.
Question 11: Is the airport committed to providing a hush house?
Question 12: Will this hush house be installed as a priority before any potential runway
expansion?
Part of the proposed plan includes tearing down the existing T-hangers near Richmond Road. This will further exacerbate the noise problems by removing yet another sound block, as
happened when the airport cut down trees along the western edge of the field along Richmond
Road.
Question 13: Will the EA account for the removal of the T-hangers when doing a sound study?
Question 14: Are there any plans to add sound barriers to reduce the noise carried into
residential areas?
4. Airplane size
When the initial plan was presented in 2008, several meetings were held by the cities surrounding the airport, at which the airport manager and C&S Engineers presented the selected plan, with carefully biased answers to key questions. The Mayor of Highland Heights asked point blank if the expansion would mean larger planes using the airport. The answer was no - only planes that currently use the airport, but the presentation did not show a picture of the Global Express that was based at the airport - only 6 smaller corporate jets. See appendix C for a visual comparison of this plane to a typical corporate jet.
Question 15: Will a 5,500 foot runway allow planes larger than the typical corporate jets to use the airport?
Question 16: What is the largest plane that can use the airport, based on a 5,100 foot runway? If the runway is 5,500 feet?
To continue with the Global Express topic, this plane is massive: 98,000 pounds max takeoff weight, a wingspan of 94 feet, and is 99 feet long. In section 6.02 of the draft final report:
The Airport Master Plan Update report defines Cuyahoga County Airport's role as a reliever airport with an Airport Reference Code (ARC) of D-II. The facility is expected to accommodate aircraft having approach speeds less than 166 knots for Aircraft Approach Categories A, B, C, and D, and wingspans up to, but not including, 79 feet for Airplane Design Groups I and II.
In the 1970's the airport was added lo the National Airport System Plan as a "designated reliever", and classified for "basic transport". The basic transport designation indicated a
"general aviation airport" which is capable of handling aircraft up lo 60,000 pounds gross
weight.
Appendix D is a copy of part of the transcript from a 1977 hearing on the airport - this was
likely related to the last master plan update. It indicates that the runway was rated for a gross
weight of 60,000 pounds.
Question 17: If the airport is intended to handle planes up to 60,000 pounds, and less than 79 foot wingspans, how was the Global Express allowed to not only use CGF, but to be based there?
Question 18: The airport currently claims that the runway has a weight limit of up to 100,000
pounds. Can the airport provide the Environmental Impact Statement that would have been
required to allow the airport to increase the weight rating up to this level, from the established
60,000 pounds?
5. Safety
There has been significant emphasis on urgency to improve safety with the proposed plan,
but this rings hollow for several reasons:
- The Richmond Heights school system is immediately adjacent to the Richmond Road
- The expanded safety areas don't cover the locations of any of the 4 most recent
The RSA requirements were created more than 15 years ago - the urgency seems more related to wanting money to lengthen the runway than improving safety end of the runway. Increased air traffic on a lengthened runway even closer to the school can't possibly be a safety improvement. Crashes that have occurred around this airport - in which several residents and multiple passengers have been killed. The aerial shot below shows the rough location of these
incidents (the one at the far right is the 2009 crash near SOM Center Road):
And most importantly, nothing in any of the plans addresses the map above.
Question 19: Given the number of planes that have crashed near the airport killing many people, what are the airport's plans to improve the safety performance?
6. Community Impacts
Chapter 2 of the plan summarizes the existing conditions at the airport, including environmental aspects. In part:
The Airport's Storm Water Pollution Prevention Plan (SWPPP), adopted in 2004, provides measures to be followed to mitigate impacts and notify appropriate agencies In the event of
an inadvertent fuel spill or chemical spill at the facility. This plan includes measures to protect workers, the public, and the environment from potential construction-related exposure to chemicals that may be present in the soil or water. In the event of a release of a hazardous substance in an amount greater than the reportable quantity of the substance, as established
by the EPA, a responsible party shall contact the National Response Center to provide details
of the incident and measures shall be taken to reduce the effects of the release. The Airport is subject to the Ohio Environmental Protection Agency (OEPA) Phase 1 storm water regulations.
That same chapter includes this summary statement: No communication has been received from the OEPA identifying significant water quality impacts or related problems existing around the airfield. Keeping in mind that this plan is dated May 2010, the statement above is absolutely false.
Appendix E shows pictures of a fuel spill at the airport in April of 2008, and the resulting cleanup. This ftiel spill was not reported by the airport as required by the EPA and the SWPPP. The airport made no attempt to clean it up when it happened -note that there are no containment booms in the first picture. The grass died as a result of the large volume of jet
fuel that saturated the ground.
When the EPA heard of the issue, they indeed contacted the airport, and the ensuing cleanup included removing 12 twenty-yard dumpsters of contaminated soil.
Worse, yet another fuel spill occurred in January of 2010 - at the exact same location. See Appendix F.
Question 20: What disciplinary/criminal penalties resulted from the April 2008 fuel spill?
Question 21: What was the cost of the two fuel spill cleanups, and who paid?
Question 22: What changes will be made to avoid a third fuel spill?
While great effort has recently gone into explaining the technical aspects to justify the need for
increased runway length, the starting premise was missed: Residents surrounding the airport do not have any obligation to accommodate the planes that the airport tenants bought that are
too large for the airport.
Assertions have been made that the airport was here first, which is clearly wrong. Richmond Heights was incorporated in 1917. The airport didn't open until 1950. There are still many residents that have lived here since before 1950. And all residents here now certainly are here before any expansion. This county airport was created for recreational aircraft - it is not a national airport.
Richmond Heights, as well as Highland Heights and Willoughby Hills, are residential communities. Check the little dots in the picture above - they are houses. The airport's consultant described the general problem with airports in the Northeast U.S. as residential areas "encroaching" on the airports. Yes, all the communities around the Cuyahoga County Airport are building more residential areas - but these are on property zoned as such, and not on airport property. To the opposite, the airport is trying to move closer to the residential areas, to the extreme of buying houses on Richmond Road and tearing them down, buying the Mayfair Club on Highland Road and tearing it down, and tearing down houses on Bishop Road, after one was destroyed by a plane crash.
Question 23: How will the impacts such as noise, fumes, night operations of the airport and property values be incoiporated in the EA?
7. Financial Impacts
The plan includes a financial impact study done in 2005. That study concluded that the direct economic impacts of the airport include 3,000 employees, with more than 1,000 of them working on the airport campus. This didn't make sense - the detail included in the report confirmed why: the study was not done on the airport itself, but rather an "airport study area" that was conveniently defined to include many businesses that are not located at the airport and have nothing to do with the airport. An example of this would be the inclusion of UPS on Bishop Road.
Question 24: Will the EA include an accurate economic study of the airport's impact?
Question 25: Will the EA break out the economic impact of aviation business at the airport separate from non-aviation (daycares, insurance companies, etc.) so that the true impact of the airport itself is apparent?
Question 26: Will the EA also study what the potential economic benefit would be if the airport were closed and the property used for alternatives such as a business park?
In spite of the airport's claims of economic benefits, it has been a financial drain for the county. Losses were in the millions of dollars over many years. The last available data from the county shows an operating loss of over $1.4 million in 2006 - see appendix G. These losses are paid for by taxpayers. Subsequent to the 2006 report, the county stopped publishing the annual financial information known as the Comprehensive Annual Financial Report. Question 27: Will the aiiport publish a financial history from 2000 to current? Question 28: What are the airport's plans to improve the financial performance to at least break-even?
The FAA comments on the draft plan included a specific request on funding: The costs for achieving greater capacity as presented in the master plan are substantial. The ADO is requesting that a financial plan be prepared that outlines the proposed funding sources to complete the proposed project(s) and backup funding plan in the event that federal funds are limited or not available. Based on the cost estimates included in the report, the preferred alternative for a runway extension while meeting FAA design standards approaches $40 million.
Cuyahoga County will be required to prepare a benefit cost analysis (BCA). Due to the financial magnitude of the proposed alternative, the ADO recommends that the BCA be completed prior to initiating an environmental study in order to avoid the involvement and energy of the resource agencies and the general public, should at a later date the costs are determined to be impracticable to achieve.
Question 29: Can the airport publish the BCA, which should already be complete since the EA is now starting?
Question 30: What is the backup funding plan?
Question 31: Consistent with question 1 above, will the airport break out the costs and benefits for each of the three segments of the project - meeting RSA standards, pavement improvement, and increasing runway length?
I was surprised that the EA was funded and launched, since there are multiple issues raised by the FAA in the 2009 review that have yet to be answered. It shouldn't be a surprise that the information on the EA was set up on a totally separate website from the airport's - appendix H. There is no link from the airport's Master Plan site to the EA - appendix A. The airport's site does include the following as part of the expected outcome of the master plan:
A concise and descriptive report so that the impact and logic of its recommendations can be clearly understood by local residents and by those authorities and public agencies charged with the approval, promotion, and funding of the improvements proposed in the master plan update.
Based on the discussion in this letter, the airport has failed miserably at this expected outcome. The FAA doesn't understand. The County officials don't understand. Even the consultants hired by the airport don't understand what is happening or why.
I took the time to summarize these issues and boil out the key questions because the process has been broken, with the airport and County Commissioners ignoring input from the community and not answering questions, or even giving dishonest responses. The airport has lost the support of the community because it refuses to support the community by ignoring noise issues and community concerns.
With new management at the airport and at the county, it is time to fix this. City and County officials, as well as residents, need honest information. The FAA's questions need to be answered.
I chose to live in Richmond Heights. I made that choice knowing that the airport was here - an airport with a 5,100 foot mnway. I am not asking that the airport be closed -1 recognize that the airport does serve a purpose in supporting businesses that need aviation access. The airport is functional today, as evidenced by the number of planes that use it. I support the need for improving the RSA's. But the need for a longer mnway seems more like a want than a need - and an expensive one at that. The airport may yet be able to show that it really does need a longer runway -1 am willing to listen if the questions above are finally answered with accurate information.
The questions have been collected together on the following page. Please contact me if you would like to discuss this further.
Ed Crouse
Richmond Heights, Ohio 44143
emchome@roadrunner.com
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