GNOSS FIELD AIRPORT PROPOSED EXTENSION OF RUNWAY 13/31 UPDATED PURPOSE AND NEED WORKING PAPER DATE: February 20, 2018 REQUEST FOR PUBLIC COMMENTS

GENERAL INFORMATION ABOUT THIS DOCUMENT

This Updated Purpose and Need Working Paper has been developed to provide additional information to the public and regulatory agencies regarding the proposed extension of Runway 13/31 at Gnoss Field Airport, Marin County, California. This Working Paper describes a change in forecasted aviation activity at Gnoss Field Airport, including confirmation that the critical aircraft has changed since preparation of the June 2014 Final Environmental Impact Statement (EIS), and provides supporting documentation. The purpose and need for the proposed project – to allow existing aircraft, as represented by the family grouping of critical aircraft at DVO, to operate without operational weight restrictions under hot weather conditions – is unchanged. Since the critical aircraft has changed, the total necessary runway length at Gnoss Field Airport to meet the purpose and need of the proposed project has decreased from 4,400 feet, as identified in the Final EIS, to 3,600 feet. This conclusion was first reached in the April 2016 Purpose and Need Working Paper and reconfirmed in this Updated Purpose and Need Working Paper. As Runway 13/31 is currently 3,300 feet long, the current total necessary runway length of 3,600 feet could be obtained with a 300-foot runway extension, instead of the 1,100-foot runway extension identified in the June 2014 Final EIS. The Federal Aviation Administration (FAA) will be preparing a Supplement to the June 2014 Final EIS to address these changes.

REQUEST FOR PUBLIC COMMENTS

The FAA is requesting public comments on this Working Paper as part of an additional National Environmental Policy Act (NEPA), public scoping effort for this project prior to preparing a Supplement to the Final EIS. You may submit comments by mail from February 20, 2018 to April 6, 2018, e-mail to [email protected] or submit oral or written comments in person at a public meeting on this Working Paper held on March 20, 2018 at the Marin County Civic Center, 3501 Civic Center Drive – Room 330, San Rafael, California, at 7:00 P.M.

Before including your name, address and telephone number, email or other personal identifying information in your comment, be advised that your entire comment – including your personal identifying information - may be made publicly available at any time. While you can ask us in your comment to withhold from public review your personal identifying information, we cannot guarantee that we will be able to do so.

Please provide any written public comments to the point of contact below:

Mr. Doug Pomeroy Federal Aviation Administration San Francisco Airports District Office 1000 Marina Boulevard, Suite 220 Brisbane, California 94005-1835. Telephone 650-827-7612 FAX 650-827-7635 GNOSS FIELD AIRPORT UPDATED PURPOSE AND NEED WORKING PAPER FINAL

TABLE OF CONTENTS

PAGE

1.0 Introduction ...... 1 2.0 Purpose And Need ...... 1 2.1 Purpose And Need For Improvements ...... 3 2.1.1 Sponsor’s Purpose and Need ...... 3 2.1.2 FAA Purpose And Need ...... 4 2.1.3 Insufficient Runway Length ...... 4 3.0 300-foot Runway Extension Alternative ...... 6 4.0 Proposed Federal Actions ...... 7 5.0 Relationship of Working Paper to Other Environmental Impact Statement Documents ...... 13

Appendix A – Aviation Activity Demand Forecast Attachment 1: Interview Materials Appendix B – Runway Length Analysis

Appendix C – FAA Response to Comments

LIST OF TABLES PAGE

Table 2-1 Airport Reference Codes For Aircraft Typically Operating At Gnoss Field Airport ...... 3

LIST OF EXHIBITS

PAGE

Exhibit 3-1 Existing Airport Layout Plan ...... 9 Exhibit 3-2 300-Foot Runway Extension Alternative ...... 11

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1.0 INTRODUCTION

The Federal Aviation Administration (FAA) issued a Notice of Intent (NOI) in the Federal Register on July 11, 2008 announcing its intent to prepare an Environmental Impact Statement (EIS) for proposed improvements at Gnoss Field Airport (DVO or Airport) Novato, California, including an extension of Runway 13/31. The FAA issued a Notice of Availability and released the Draft EIS for a 60-day public review on December 9, 2011, held a public hearing to receive comments on the Draft EIS on January 10, 2012, and accepted public comments on the EIS through February 6, 2012. The FAA reviewed and responded to all comments on the Draft EIS in the Final EIS, which was published in June 2014. The FAA did not issue a Record of Decision (ROD) regarding the Federal actions in the Final EIS, but instead decided to prepare a Supplement to the Final EIS to address changes in the forecasted aviation activity and the critical aircraft at DVO.

In order to provide the public and regulatory agencies an opportunity to provide comments on information the FAA is considering as it develops a Supplement to the Final EIS, a Purpose and Need Working Paper was published in April 2016. The April 2016 Working Paper updated the aviation activity demand forecast to better reflect operating levels and fleet using DVO at that time. The information found during the forecasting analysis identified a different critical aircraft than what was identified in the June 2014 Final EIS. The runway length requirement for the new critical aircraft is 3,600 feet, 300 feet longer than the existing runway at DVO. Many commenters on the April 2016 working paper stated that they believed that the number of operations identified for jet aircraft in the April 2016 Purpose and Need Working Paper, specifically for the critical aircraft identified in the June 2014 Final EIS (the Cessna 525), were lower than the actual number of operations for that aircraft at DVO. In order to resolve whether the number of aircraft, particularly the most demanding aircraft, had been undercounted, the FAA undertook an update to the aviation activity demand forecast with an increased focus on the operating levels of the Cessna 525 aircraft. This Updated Purpose and Need Working Paper provides the results of the updated analysis for the public and regulatory agencies to comment on.

2.0 PURPOSE AND NEED

This working paper describes proposed improvements at DVO based on changes in forecasted aviation activity and the critical aircraft at DVO, and identifies FAA regulations and policies for aviation safety and the potential Federal approvals that would be required for the proposed project to be implemented. FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions requires that an EIS fully address and convey the purpose and need for a proposed project. According to the Council on Environmental Quality (CEQ) and their implementing regulations for NEPA, the purpose and need shall briefly specify the underlying purpose and need. As part of the EIS for this project, the FAA will consider the reasonable alternatives that meet the purpose and need of DVO and Marin County. The purpose and need for the proposed improvements serves as the foundation for the identification of reasonable alternatives to the Proposed Project and the comparative evaluation of impacts of development. In order for an

Landrum & Brown Purpose and Need Working Paper February 2018 Page 1 GNOSS FIELD AIRPORT UPDATED PURPOSE AND NEED WORKING PAPER FINAL alternative to be considered viable and carried forward for detailed evaluation within the NEPA process and an EIS, it must address the need for the project, as described more fully in the following sections.

The FAA is making this working paper available to the public and governmental agencies for review and comment. Once that review is complete, the FAA may include the information presented in this working paper in the Purpose and Need chapter of the Supplement to the Final EIS for the proposed extension of Runway 13/31 at DVO. The FAA is not making a decision regarding the proposed development in this working paper. That decision would be made as part of a Record of Decision on the Final EIS including the Supplement to the Final EIS.

The Airport is located in unincorporated Marin County north of the City of Novato, California and serves as an essential regional transportation resource by providing general aviation facilities in the northern portion of the San Francisco Bay area. People choose to use DVO for three primary purposes – flight training, recreation, and business travel. DVO has been defined by the FAA as a Non-Primary, Regional airport in the Bay area and served approximately 82,500 arrivals and departures in 2016 (see Appendix A, Aviation Activity Forecast). A Regional airport supports regional economies with interstate and some long-distance flying and have high levels of activity, including some jets and multiengine propeller aircraft.1

Regional airports provide pilots with attractive alternatives to using congested hub airports. They also provide general aviation access to the surrounding area. To be eligible for Regional designation, these airports must meet one or more of the following minimum criteria for annual activity:

 Located in a metropolitan statistical area, have one or more based jet or 100 or more based aircraft, 10 or more domestic flights over 500 miles, 1,000 or more instrument operations, AND 1 or more based jet or 100 or more based aircraft.  Reliever with 90 or more based aircraft.  Nonprimary commercial service airport (requiring scheduled service) within a metropolitan statistical area. The reliever program, which was established in 1962, has evolved over the years. Currently, many of the airports designated as relievers serve their own economic and operational role. DVO and other general aviation airports in the San Francisco Bay area designated as reliever airports serve to reduce congestion at San Francisco International Airport, Oakland International Airport, and San Jose International Airport. Therefore, the FAA has encouraged the development, maintenance, and expansion of general aviation airports in major metropolitan areas.

1 2017-2021 National Plan of Integrated Airport Systems (NPIAS).

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2.1 PURPOSE AND NEED FOR IMPROVEMENTS

The following sections present the Sponsor's and FAA's purpose and need.

2.1.1 Sponsor’s Purpose and Need

Gnoss Field Airport is currently designed to accommodate aircraft with a wingspan of 49 feet or less, and an approach speed of 91 to 121 knots (FAA Airport Reference Code B-1). Examples of different sizes of aircraft by Airport Reference Code are shown in Table 2-1.

TABLE 2-1 AIRPORT REFERENCE CODES FOR AIRCRAFT TYPICALLY OPERATING AT GNOSS FIELD AIRPORT Gnoss Field Airport

AIRPORT REFERENCE AIRCRAFT CHARACTERISTICS EXAMPLE AIRCRAFT TYPE CODE1 Cessna 172

Approach Speed: Less than 91 knots A-I Wingspan: Less than 49 feet

Cessna 525

Approach Speed: 91 knots or B-I greater, but less than 121 knots Wingspan: Less than 49 feet

Beechcraft Super King Air 200

Approach Speed: 91 knots or greater, but less than 121 knots B-II Wingspan: 49 feet or greater, but less than 79 feet

1 Source: FAA Advisory Circular 150/5300-13A “Airport Design”

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Marin County has prepared several evaluations of the Airport’s operations and facilities, including the 1989 Airport Master Plan2, the 1997 Update of the Airport Master Plan3, and the 2002 Preliminary Design Report for the proposed runway extension4. The June 2014 Final EIS prepared by the FAA also discussed operations at DVO.5 These studies identified the limitations regarding the Airport’s ability to accommodate existing aircraft and aviation users for which the Airport was designed. Specifically, the Airport cannot fully accommodate existing aviation activity, as represented by the family grouping of critical aircraft that regularly uses the Airport under hot weather conditions.6

The existing runway at DVO is 3,300 feet long and as a result cannot fully accommodate the operations of the family grouping of critical aircraft. Therefore, the purpose of the Sponsor’s Proposed Project is to:

allow existing aircraft, as represented by the family grouping of critical aircraft at DVO, to operate without operational weight restrictions under hot weather conditions.

2.1.2 FAA Purpose and Need

The FAA's statutory mission is to ensure the safe and efficient use of navigable airspace in the U.S. as set forth under 49 USC § 47101 (a)(1). The FAA must ensure that the proposed action does not derogate the safety of aircraft and airport operations at DVO. Moreover, it is the policy of the FAA under 49 USC § 47101(a)(6) that airport development projects provide for the protection and enhancement of natural resources and the quality of the environment of the United States.

2.1.3 Insufficient Runway Length

FAA Order 5090.3C Field Formulation of the National Plan of Integrated Airport Systems (NPIAS)7 identifies that airport dimensional standards such as runway length and width, separation standards (distances) between runways and taxiways, surface gradients, and similar dimensions should be appropriate for the “critical aircraft” that will make “substantial use” of the airport in the planning period for improvements. The FAA has issued additional guidance, FAA Advisory Circular (AC) 150/5000-17 Critical Aircraft and Regular Use Determination, dated June 20, 2017, to further define how to determine the critical aircraft for an airport. FAA AC 150/5000-17 replaced the term “substantial use” of an airport with “regular use” of an airport, and defines the term “regular use”.

2 Airport Master Plan Marin County Airport Gnoss Field, 1989. 3 Marin County Aviation Commission Resolution No. 97-1: A Resolution Adopting Chapter 6.0 – Airport Development Program Update 1997 – Marin County Airport Master Plan (Gnoss Field) and Recommendation of Approval of Chapter 6.0 1997 Update to the Marin County Board of Supervisors, February 5, 1997. 4 Cortright & Seibold, Preliminary Design Report, Runway Extension, Gnoss Field, 2002. 5 Landrum & Brown, Gnoss Field Airport Runway Length Analysis, 2008, 2013, 2016, & 2017. 6 For the purpose of this working paper, hot weather is defined as the mean daily maximum temperature of the hottest month at the Airport (FAA A/C 150/5325-4B Chapter 2). 7 FAA Order 5090.3C Field Formulation of the National Plan of Integrated Airport Systems (NPIAS) 3- 4 Airport Dimensional Standards. December 4, 2000.

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An aircraft or family of aircraft is called the “critical aircraft” because it is the most “demanding” aircraft in terms of the physical dimensions of the airport such as the length and width of the runways and taxiways, and separation distance between runways and taxiways required for that aircraft to operate at the airport. FAA AC 150/5000-17 defines the critical aircraft as the most demanding aircraft type, or grouping of aircraft with similar characteristics, that make regular use of the airport. Regular use is 500 annual operations, including both itinerant and local operations but excluding touch-and-go operations. An operation is either a takeoff or landing. The FAA uses the requirements of an airport’s critical aircraft as a basis for determining when new aviation development is justified. This type of evaluation is consistently applied across the aviation industry and is the recognized approach for determining the needs of an airport. See Appendix A, Section 6, for more information regarding the designation of the critical aircraft for DVO. Within the current fleet mix at DVO, the existing critical aircraft is the family of B-II Turboprop aircraft. This is the most demanding aircraft grouping for runway length with regular use (see Appendix A, Section 6).

The Marin County Aviation Commission Resolution No. 97-1: A Resolution Adopting Chapter 6.0 Airport Development Program Update 19978 identified a runway extension as a part of DVO’s future development program and a proposed runway length was developed as part of the 2002 Preliminary Design Report9. During the preparation of this working paper, FAA Advisory Circular (AC) 150/5325-4B Runway Length Requirements for Airport Design, was used to verify an appropriate length for Runway 13/31 at DVO. FAA AC 150/5325-4B, Paragraph 202, Design Approach, provides the acceptable methods to determine a recommended runway length. For this working paper, Chapter 2 of that AC, Runway Lengths for Small Airplanes with Maximum Certificated Takeoff Weight of 12,500 Pounds (5,670 Kg) or Less was used to verify the necessary runway length for the family grouping of critical aircraft at DVO.

The runway length analysis is described in detail in Appendix B, Runway Length Analysis. The following summarizes the inputs that were used to calculate the recommended runway length requirement for DVO to meet the project purpose and need. The project purpose and need is to allow existing aircraft, as represented by the family grouping of critical aircraft at DVO, to operate without operational weight restrictions under hot weather conditions.

8 Marin County Aviation Commission Resolution No. 97-1: A Resolution Adopting Chapter 6.0 – Airport Development Program Update 1997 – Marin County Airport Master Plan (Gnoss Field) and Recommendation of Approval of Chapter 6.0 1997 Update to the Marin County Board of Supervisors, February 5, 1997. 9 Cortright & Seibold, Preliminary Design Report, Runway Extension, Gnoss Field, 2002.

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Input Data: Airport elevation: Sea Level Mean daily maximum temperature of the hottest month: 82° Fahrenheit10

Using Figure 2-1 from FAA AC 150/5325-4B, Small Airplanes with Fewer than 10 Passenger Seats, the inputs listed above analyzed along the curve.

(1) Step 1 – Find the mean daily maximum temperature of the hottest month: 82° Fahrenheit (F). (2) Step 2 – Proceed vertically to the airport elevation: Sea Level (two feet). (3) Step 3 – Proceed horizontally to the runway length axis. (4) Step 4 – Read runway length. The runway length requirement derived from Figure 2-1, FAA AC 150/5325-4B, is 3,550 feet and is rounded up to 3,600 feet per FAA guidance.11

Based on the runway length analysis described above, the need at DVO is to address insufficient runway length that precludes the family grouping of critical aircraft from operating without operational weight restrictions under hot weather conditions.

3.0 300-FOOT RUNWAY EXTENSION ALTERNATIVE

Marin County developed the Sponsor’s Proposed Project, an 1,100-foot runway extension through the Master Plan for Marin County Airport12 the Marin County Aviation Commission Resolution No. 97-1: A Resolution Adopting Chapter 6.0 Airport Development Program Update 199713 and the Preliminary Design Report Runway Extension Gnoss Field.14 The Sponsor’s proposed project is described in detail in the June 2014 Final EIS. Exhibit 3-1 shows the existing Airport location and facilities. This Updated Purpose and Need Working Paper identifies the primary elements of a 300-foot Runway Extension Alternative, based on the runway length calculation for the current critical aircraft for DVO, which are shown on Exhibit 3-2, and include the following:

 Shift Runway 13/31 106 feet to the north and extend Runway 13/31 300 feet to the northwest from 3,300 feet to a total length of 3,600 feet while maintaining the 75-foot width of the runway;

10 United States Department of Commerce, National Oceanic & Atmospheric Administration, National Climatic Data Center (NCDC), Summary of Monthly Normal 1981-2010, Petaluma Airport, CA US. Webpage accessed on April 13, 2016, http://www.ncdc.noaa.gov/cdo-web/datatools/normals. 11 See Appendix B, Runway Length Analysis, for information on the calculation of the final runway length requirement. 12 Airport Master Plan Marin County Airport Gnoss Field, 1989. 13 Marin County Aviation Commission Resolution No. 97-1: A Resolution Adopting Chapter 6.0 – Airport Development Program Update 1997 – Marin County Airport Master Plan (Gnoss Field) and Recommendation of Approval of Chapter 6.0 1997 Update to the Marin County Board of Supervisors, February 5, 1997. 14 Cortright & Seibold, Preliminary Design Report, Runway Extension, Gnoss Field, 2002.

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 Relocate existing taxiways accessing south end of Runway 13/31 to new runway end.  Extend the parallel taxiway to the full length of the runway maintaining the existing runway to taxiway separation distance of 155 feet15;  Widen the existing Runway Safety Area (RSA) along the sides of Runway 13/31 from its existing width of 120 feet centered on the runway centerline to a RSA width of 150 feet centered on the runway centerline to meet current FAA B-II airport design standards;  Extend RSA to 300 feet long beyond each end of the shifted Runway 13/31 to meet current FAA B-II airport design standards;  Corresponding realignment of drainage channels to drain the extended runway and taxiway;  Corresponding levee extension to protect the extended runway and taxiway from flooding; and  Relocate the existing Precision Approach Path Indicator (PAPI) navigational aids that pilots use to land at the Airport to reflect the extended runway. Marin County intends to keep DVO open during construction of the proposed project. Any modifications to Airport operations necessary to maintain safety during construction would be addressed in a Construction Safety and Phasing Plan prepared in accordance with FAA AC 150/5370-2F, Operational Safety on Airport During Construction, and approved by the FAA.

4.0 PROPOSED FEDERAL ACTIONS

Several Federal actions are directly or indirectly proposed to occur. Implementation of the Sponsor’s Proposed Project or other build alternatives would require several Federal actions and approvals. These include:

 Unconditional approval of the Airport Layout Plan (ALP) to depict the proposed runway shift/extension and parallel taxiway extension pursuant to 49 United States Code (USC) §§ 40103(b) and 47107(a)(16);  Development of air traffic control and airspace management procedures designed to affect the safe and efficient movement of air traffic to and from the proposed runway development. Such actions would include, but are not limited to, the establishment or modification of flight procedures and the installation and/or relocation of Navigational Aids (NAVAIDs) associated with the proposed runway and taxiway extension.

15 FAA AC 1500/5300-13A, Airport Design A/C, identifies a minimum runway centerline to parallel taxiway centerline separation distance standard of 150 feet for B-1 small aircraft and 225 feet for B-1 and B-II aircraft. The existing Gnoss Field Airport runway to parallel taxiway separation of 155 feet meets the B-1 small standard. Marin County is anticipated to seek a Modification of Standards to retain the 155-foot runway to parallel taxiway separation distance, rather than relocate the existing parallel taxiway to meet the B-1 and B-2 taxiway separation standard.

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 Determination of eligibility for federal assistance for the proposed projects under the Federal grant-in-aid program authorized by the Airport and Airway Improvement Act of 1982, as amended (49 USC § 47101 et seq.);  Determinations under 49 USC §§ 47106 and 47107 relating to the eligibility of the Proposed Action for federal funding under the Airport Improvement Program (AIP) to assist with construction of potentially eligible development items shown on the ALP;  Determination of the effects of the proposed shift/extension of the runway and parallel taxiway and the corresponding increase in size of the associated runway safety area upon the safe and efficient use of navigable airspace pursuant to Title 14 Code of Federal Regulations (CFR) Part 77, Safe, Efficient Use, and Preservation of Navigable Airspace. The FAA must determine if the proposed improvements, as proposed by Marin County are consistent with the existing airspace utilization and procedures;  Determination under 49 USC § 44502(b) that the airport development is reasonably necessary for use in air commerce or in the interests of national defense;  Approval of further processing of an application for federal assistance for near- term eligible projects using federal funds from the Airport Improvement Program, as shown on the ALP; and  Approval of a Construction Safety and Phasing Plan to maintain aviation and airfield safety during construction pursuant to FAA Advisory Circular 150/5370- 2F Operational Safety on Airports During Construction.

The proposed improvements described in this working paper are designed to allow the Airport to accommodate existing aviation traffic and demand.

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NWP Railroad

13

Airport Rd Existing Runway 13/31 3,300' 13/31 Runway Existing

Binford Rd Gnoss Field Airport

Black John Slough 31

Legend

Existing Runway

Existing Buildings

Airport Property Boundary

0500' ±

Environmental FINAL Exhibit: Impact Statement 7/10/2013 Prepared by Landrum & Brown Exhibit: Filename: P:\DVO-Gnoss Field\GIS\MXD\ Existing Airport Layout EIS\EIS_Exhibits\EIS_Document\ 3-12-1 Gnoss Field Airport 2-1_Existing Airport Layout.mxd ¤£101

NWP Railroad

13 Extend Levee and Drainage Ditch

Construct 300-Foot x 150-Foot Safety Area

406-Foot Runway Construction (300-Foot Runway Extension Taxiway Plus 106-Foot Runway Shift) Extension

Airport Rd Extended Runway 13/31 3,600'

Binford Rd Gnoss Taxiway Construction Field Airport

Black John Slough 31 Construct 300-Foot x 150-Foot Safety Area Legend Proposed Runway Construction

! ! ! ! Taxiway Demolition ! ! ! ! Proposed Taxiway and Safety Areas Proposed Taxiway Demolition Proposed Drainage Ditch Proposed Levee Existing Runway Existing Buildings Airport Property Boundary 0 500' ±

Environmental DRAFT 10/27/2017 Prepared by Landrum & Brown Exhibit: Impact Statement Filename: P:\DVO-Gnoss Field\Interim 300-Foot Runway Airport Development Drawing\300 FOOT EXTENSION\3-2_300-Foot Runway 3-2 Gnoss Field Airport Extension Alt.mxd Extension Alternative GNOSS FIELD AIRPORT UPDATED PURPOSE AND NEED WORKING PAPER FINAL

5.0 RELATIONSHIP OF WORKING PAPER TO OTHER ENVIRONMENTAL IMPACT STATEMENT DOCUMENTS

The FAA issued a Federal Register Notice on July 11, 2008, announcing its intent to prepare an EIS for the proposed improvements at DVO. The FAA issued a Notice of Availability and released the Draft EIS for a 60-day public review on December 9, 2011, held a public hearing to receive comments on the Draft EIS on January 10, 2012, and accepted public comments on the EIS through February 6, 2012. The FAA reviewed and responded to all comments on the Draft EIS in the Final EIS, which was published in June 2014. The FAA did not issue a Record of Decision (ROD) regarding the Federal actions in the Final EIS, but instead decided to prepare a Supplement to the Final EIS to address changes in the critical aircraft at DVO. The FAA started preparing a Purpose and Need Working Paper in 2015 and issued that paper for public comment in April 2016. Based on comments received on the April 2016 working paper, the FAA prepared this updated working paper. This updated working paper provides the public and regulatory agencies an additional opportunity to provide comments on information the FAA is considering as it develops the Supplement to the Final EIS.

If the FAA issues a ROD to support proceeding with a runway extension project at DVO, Marin County could then seek Federal funding through the Airport Improvement Program grant program to assist in implementation of a runway extension project. Marin County would have to meet Federal, state and local environmental requirements, including complying with the California Environmental Quality Act, in order to proceed with the project.

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This Page Intentionally Blank APPENDIX A

AVIATION ACTIVITY FORECAST

GNOSS FIELD AIRPORT

Prepared By: Landrum & Brown February 2018

GNOSS FIELD AIRPORT AVIATION ACTIVITY FORECAST FINAL

TABLE OF CONTENTS PAGE 1.0 Purpose and Context ...... 1 2.0 General Aviation Forecast Information ...... 2 2.1 Prior Forecasts ...... 3 2.1.1 1989 Airport Master Plan ...... 3 3.0 Catchment Area ...... 4 4.0 Historical National and Local Trends ...... 4 4.1 National and Local Economy ...... 4 4.2 Population ...... 6 4.3 Per Capita Personal Income (PCPI) ...... 8 4.4 California Department of Transportation Economic Forecasts ...... 9 4.5 Association of Bay Area Governments Socio-Economic Forecasts ...... 9 4.6 Historical National GA Activity ...... 10 4.7 FAA National Forecast ...... 11 4.8 Emerging Aircraft Ownership ...... 14 4.9 Fleet Diversification ...... 14 4.10 Fuel Prices ...... 15 4.11 Business Use of General Aviation ...... 16 5.0 Overview of San Francisco Bay Area’s GA Airports ...... 17 5.1 Sonoma Valley Airport (0Q3)...... 19 5.2 San Rafael Airport (CA35) ...... 19 5.3 Napa County Airport (APC) ...... 19 5.4 Buchanan Field Airport (CCR) ...... 19 5.5 Half Moon Bay Airport (HAF) ...... 19 5.6 Hayward Executive Airport (HWD) ...... 20 5.7 Charles M. Schulz – Sonoma County Airport (STS) ...... 20 5.8 Nut Tree Airport (VCB) ...... 20 5.9 Petaluma Municipal Airport (O69) ...... 20 5.10 Sonoma Skypark (0Q9) ...... 20 5.11 Rio Vista Municipal Airport (O88) ...... 21 6.0 DVO Based Aircraft Information, Operations Information, Aviation Activity Forecast, and Critical Aircraft Determination ...... 21 6.1 Based Aircraft Information and Based Aircraft Aviation Forecast ...... 21 6.2 Annual Operations Information and Annual Operations Aviation Forcast .. 23 6.3 Operational Fleet Mix Forecast ...... 25 6.4 Critical Aircraft Determination ...... 27 7.0 Peak Operations ...... 33 8.0 Comparison to FAA TAF ...... 33 9.0 Forecast Scenarios ...... 35

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LIST OF TABLES PAGE

Table 4-1 Population (in Thousands) ...... 7 Table 4-2 Bay Area Forecasts ...... 9 Table 4-3 U.S. Active General Aviation Aircraft ...... 13 Table 6-1 Based Aircraft Forecast ...... 22 Table 6-2 Aircraft Operations Forecast ...... 23 Table 6-3 Airport Reference Code ...... 25 Table 6-4 DVO 2016 Aircraft Operations Documented By Airport Reference Code Using FAA Traffic Flow Management System Counts and Pilot-Aircraft Owner Interview Data ...... 29 Table 6-5 Operational Fleet Mix Forecast ...... 31 Table 7-1 Peak Operations Forecast ...... 33 Table 8-1 Forecast to TAF Comparison ...... 34 Table 9-1 Summary of Forecast Scenarios ...... 35

LIST OF EXHIBITS

PAGE

Exhibit 4-1 National and Local Economic Growth ...... 6 Exhibit 4-2 Top 10 Counties in U.S. by PCPI ...... 8 Exhibit 4-3 GA Operations at U.S. Airports ...... 11 Exhibit 4-4 Crude Oil Prices (2016$) ...... 16 Exhibit 5-1 San Francisco Bay Area’s GA Airports ...... 18 Exhibit 6-1 FAA Traffic Flow Management System Counts (TFMSC) Radar Data of Turboprop and Jet Aircraft Instrument Flight Rules ...... 24 Exhibit 6-2 FAA Traffic Flow Management System CountS (TFMSC) Radar Data for Aircraft Fleet Mix at DVO ...... 26 Exhibit 8-1 Forecast to TAF Comparison ...... 34

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1.0 PURPOSE AND CONTEXT

This report updates the aviation forecast provided in the April 2016 Gnoss Field Airport, Proposed Extension of Runway 13/31, Purpose and Need Working Paper, and presents the forecast of aviation demand for Gnoss Field Airport (DVO or the Airport). Aviation forecasts are prepared to estimate future demand for aviation activity. These estimates of future demand are used by airport operators, state transportation aviation departments, and the FAA in developing budgets and plans for future aviation infrastructure development. In order to identify future infrastructure development, the aviation forecast considers the number of “operations” (each takeoff or landing is one operation) that occur at an airport.

An important additional factor in identifying appropriate future aviation infrastructure requirements is what is the most demanding or “critical aircraft” that regularly uses an airport. FAA AC 150/5000-17 Critical Aircraft and Regular Use Determination defines the critical aircraft as the most demanding aircraft type, or grouping of aircraft with similar characteristics, that make regular use of the airport. Regular use is 500 annual operations (an operation is a takeoff or landing), including both itinerant and local operations but excluding touch-and-go operations. The most “demanding” aircraft is that aircraft which, in terms of the physical dimensions of the airport, requires the largest length and width of runway, widest taxiway, largest separation distance between runways and taxiways, and other design standards recommended by FAA airport design guidance for aircraft that regularly operate at an airport. Larger aircraft can and do operate safely at airports designed for smaller aircraft, however the preferred operational situation for efficient use of an airport and enhanced safety is for the physical dimensions of an airport to match the physical dimensions identified in FAA design standards for the critical aircraft for that airport.

At DVO, small piston-engine propeller aircraft account for most takeoffs and landings (operations) at the airport. DVO currently meets FAA airport design standards for these small airplanes. However, as described in this working paper, the current critical aircraft for DVO is a more demanding aircraft than the small piston-engine propeller aircraft that are the predominant users of the airport.

DVO exclusively serves general aviation (GA) and air taxi activity and does not have any scheduled commercial passenger air service. The term “general aviation” refers to any aircraft not operated by the commercial airlines (passenger or cargo) or the military. Typical GA activity includes recreational and flight training activities, business travel, news reporting, traffic observation, environmental surveys, police patrol, emergency medical evacuation, and crop dusting aircraft. Air taxi activity typically includes “for hire” aircraft chartered for specific trips on an on-demand basis. Air taxi operations are usually made up of larger GA aircraft, such as large turboprop aircraft and an array of corporate jets.

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2.0 GENERAL AVIATION FORECAST INFORMATION

In 2009, a forecast of aviation demand for DVO was developed as part of the Airport’s Environmental Impact Statement/Environmental Impact Report (2009 Forecast). Since the 2009 Forecast was published unforeseen events have resulted in lower than anticipated activity at DVO and significant changes to GA activity nationwide. Therefore, the forecast presented herein replaces the 2009 Forecast.

The Federal Aviation Administration (FAA) provides an update to the National Plan of Integrated Airport Systems (NPIAS) every two years. The NPIAS identifies nearly 3,400 existing and proposed airports that are significant to national air transportation. The airports identified in this plan are eligible to receive Federal grants under the Airport Improvement Program (AIP). The purpose of the plan is to provide Congress with a five-year estimate of AIP eligible development to occur and the cost of funding such development. The NPIAS contains all commercial service airports, all reliever airports (including DVO), and selected GA airports.

The NPIAS categorizes all the airports into either Primary or Nonprimary. Primary airports are defined as public airports receiving scheduled air carrier service with 10,000 or more enplaned passengers per year. Nonprimary airports are mainly used by GA aircraft. Nonprimary airports are further grouped into five categories based on their role within the national airport system. These categories are the following: (1) National, (2) Regional, (3) Local, (4) Basic, and (5) Unclassified.

DVO is classified by the FAA as a nonprimary regional airport. DVO is also a reliever airport. Reliever airports are “high-capacity general aviation airports in major metropolitan areas.”1 These reliever airports provide an attractive alternative to the larger and more congested primary airports in the area such as the San Francisco International Airport (SFO) and the Oakland International Airport (OAK). According to the FAA, there are 259 reliever airports in the United States.

This report provides an analysis of historical trends at the Airport and nationally, an overview of other San Francisco Bay area GA airports, and a forecast of operations at DVO. The forecast presented herein is “unconstrained” and as such does not take facility constraints or other outside limited factors into consideration. In other words, for the purposes of estimating future demand, the forecast assumes facilities can be provided to meet the demand.

1 Federal Aviation Administration, Report to Congress: National Plan of Integrated Airport Systems (NPIAS) 2017 – 2021, September 30, 2016.

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2.1 PRIOR FORECASTS

2.1.1 1989 AIRPORT MASTER PLAN

In 1989, Marin County adopted an Airport Master Plan, which was subsequently updated in 1997. The 1989 Master Plan included a forecast of aircraft operations and aircraft based at DVO, which was not updated in 1997.

An initial forecast of based aircraft was prepared in 1985. The forecast used a Marin County population forecast from the Association of Bay Area Governments (ABAG) and a GA aircraft forecast from the Metropolitan Transportation Commission (MTC) of the San Francisco Bay Area. The ABAG and MTC forecasts went through 2000. In order to determine the future based aircraft a ratio of population to aircraft was used through 2000. The result was that there would be 311 aircraft at DVO by 2000. The forecast assumed that the closure of Smith Ranch Airport, which was assumed to occur by 1991, would result in 80 of the 112 based aircraft relocating to DVO.2 In order to extend the forecast through 2006, a two percent growth rate was then applied. Utilizing the same methodology as the initial forecast, the Master Plan forecast was updated based on the 1986 actual number of based aircraft, which was 283, compared to 291 in 1985. The result was that based aircraft would increase from 283 in 1986 to 510 by 2006, representing an average annual growth rate of 3.0 percent.

The Master Plan used the based aircraft forecast detailed above and estimates for annual operations per based aircraft to develop a forecast of GA aircraft operations. National estimates from the FAA in the 1970s indicated that operations per based aircraft should typically range between 600 and 800. The California Department of Transportation (CalTrans) Division of Aeronautics (DOA) estimated this number is close to 650 for the state of California. However, due to the economic conditions and rapidly escalating costs at the time, an assumed value of 500 operations per based aircraft was used in order to estimate the 1986 annual operations of 142,000. It was assumed that the operations per based aircraft would decrease to 400 by 2006 due to the FAA national forecasts indicating a downward trend in operations per based aircraft. The result was an estimated 204,000 operations by 2006. The forecast also assumed a distribution of these operations to be 45 percent itinerant and 55 percent local, as that was the estimate provided by the FAA for a typical non-towered GA airport.

The forecast presented above was reiterated in the 1991 Airport Land Use Plan. Although the document points out that the actual number of based aircraft in 1986 was 230. It was assumed that the Airport would recover these relocated aircraft when aircraft owners relocated their aircraft back from other regional airports.

2 Smith Ranch Airport was not closed as predicted. It now operates as a private airport named the San Rafael Airport.

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3.0 CATCHMENT AREA

DVO is located to the north of the San Francisco Bay in unincorporated Marin County, California. The Airport is located approximately two miles north of Novato, 27 miles north of San Francisco, and 28 miles northwest of Oakland. The Airport serves as an essential regional transportation resource by providing GA facilities in the northern portion of the San Francisco Bay Area. A majority of the flight traffic at DVO is from residents of Marin County.

The San Francisco Bay Area is the second largest region in California, behind the Greater Los Angeles area, and is the fifth largest metropolitan area in the United States. The San Francisco Bay Area is divided into five sub-regions: the North Bay which includes Marin County, Sonoma County, Napa County, and Solano County; the East Bay which includes Contra Costa County and Alameda County; the South Bay which includes Santa Clara County; the Peninsula which includes San Mateo County; and San Francisco County. It has been determined that the South Bay, being over an hour drive from DVO, is located beyond the reach of DVO. However, the remaining sub-regions were deemed within a reasonable range from which the Airport may draw new based aircraft. In the remaining four sub-regions, all but one county are represented by current based aircraft. Therefore, these four sub-regions are defined as the Airport’s catchment area.

4.0 HISTORICAL NATIONAL AND LOCAL TRENDS

Understanding the history and current state of the air taxi and GA industry can help predict future aviation demand. Additionally, the health of the economy and fuel prices can have a significant impact on the ability of operators to afford the cost of flying GA and air taxi operations. This section discusses nationwide historical, emerging and forecast trends in these areas.

4.1 NATIONAL AND LOCAL ECONOMY

Historically, the U.S. economy, as measured by Gross Domestic Product (GDP), has grown at a relatively steady rate; averaging 3.0 percent per year between 1960 and 2016. The rate of growth, particularly since 1985, has been remarkably stable reflecting both the size and maturation of the U.S. economy. Individual years have fluctuated around the long-term trend for a variety of reasons including pure macro- economic factors, fuel shocks, war, and terrorist attacks.

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There have been two official economic recessions in the U.S. thus far in the 21st century. The first occurred between March and November of 2001 and was compounded by the September 11, 2001 terrorist attacks. The negative impact of these events on the airline industry is well documented. The recession itself was short-lived by historical standards and the economy returned to more normal growth rates quite quickly, fueled in large part by a gradual but prolonged reduction in interest rates.

The second recession, often referred to as the ‘Great Recession’, occurred between December 2007 and June 2009.3 The Great Recession was the worst financial crisis to affect the U.S. since the Great Depression and was the longest recession since airline deregulation4 in 1978. The nation’s unemployment rate rose from 5.0 percent in December of 2007 to a high of 10.0 percent in October 2009.5 In 2009, the American Recovery and Reinvestment Act (ARRA), was implemented in response to the economic crisis. This stimulus plan invested over $800 billion, with over half of it being spent during 2010. 6 The economy grew at an average annual rate of 1.2 percent in FY2011 and 2.7 percent in FY2012.

In 2002, Marin County’s GDP grew 5.6 percent from the previous year, more than twice the rate of the U.S. and California. However, from 2003 through 2006 the average annual growth rate for Marin County’s GDP was 3.5 percent which was in line with California and the U.S. as a whole. Starting in 2007, Marin County’s GDP began to decline and while the U.S. was amidst the Great Recession in 2009 Marin County’s GDP dropped 7.1 percent. In 2010, Marin County had a significant recovery at a growth of 4.6 percent. In 2015, the growth of Marin County’s GDP was behind both California and the U.S. but in 2016 growth was more in line with that of the state and the rest of the nation. Exhibit 4-1 shows the year over year growth rate of GDP for the U.S., California and Marin County since 2001.

From 2016 to 2050, the Marin County GDP is forecast to grow from $18.5 billion (constant 2009$) to $34.1 billion (constant 2009$), representing an average annual growth rate of 1.8 percent. This growth is slightly less than the state as a whole of 2.0 percent and the national GDP at 1.9 percent.

3 National Bureau of Economic Research, US Business Cycle Expansions and Contractions, September 20, 2010. 4 Deregulation refers to the Airline Deregulation Act of 1978 which reduced government control over the commercial aviation industry. 5 National Bureau of Economic Research, US Business Cycle Expansions and Contractions, September 20, 2010. 6 Congressional Budget Office, Estimated Impact of the American Recovery and Reinvestment Act on Employment and Economic Output from October 2011 Through December 2011, February 2012.

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EXHIBIT 4-1 NATIONAL AND LOCAL ECONOMIC GROWTH

Source: Woods & Poole 2017.

4.2 POPULATION

Since 2001, the population in Marin County has grown from 247,900 to 262,400 residents. The 0.4 percent growth per annum was less than half the growth in California and the nation as a whole at 0.9 percent during that same span. The population of Marin County is forecast to continue to grow at a rate well below the state of California and the United States. Table 4-1 provides a comparison of Marin County’s historical and forecast population to California and the United States.

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TABLE 4-1 POPULATION (IN THOUSANDS)

Population (in thousands) Year United States State of California Marin County Actual 2001 284,968.9 34,479.5 247.9 2002 287,625.1 34,871.8 246.2 2003 290,107.9 35,253.2 245.1 2004 292,805.3 35,574.6 243.8 2005 295,516.6 35,827.9 244.2 2006 298,379.9 36,021.2 244.6 2007 301,231.2 36,250.3 246.2 2008 304,093.9 36,604.3 248.4 2009 306,771.5 36,961.2 250.9 2010 309,346.8 37,334.1 252.9 2011 311,718.8 37,700.0 255.4 2012 314,102.5 38,056.1 256.0 2013 316,427.3 38,414.1 258.6 2014 318,906.9 38,792.3 260.6 2015 321,420.6 39,144.8 261.2 2016 324,160.8 39,512.7 262.4 Forecast 2020 336,382.5 41,135.4 268.0 2025 352,314.6 43,236.6 274.9 2030 368,644.1 45,375.6 281.6 2035 384,441.9 47,434.7 287.2 2040 399,418.8 49,374.3 291.7 2045 413,840.6 51,223.4 295.2 2050 428,118.9 53,029.7 298.1

AAGR 2001-2016 0.9% 0.9% 0.4% 2016-2050 0.8% 0.9% 0.4%

Source: Woods & Poole 2017.

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4.3 PER CAPITA PERSONAL INCOME (PCPI)

Income statistics are a broad indicator of the relative earning power and wealth of the region and inferences can be made to the residents’ ability to purchase and operate GA aircraft. Per capita personal income (PCPI) corresponds to the average income per inhabitant and is calculated by dividing total income by total population.

Marin County is one of the most affluent counties in the United States. According to Woods & Poole, Marin County had a PCPI of $97,139 (constant 2009$) in 2016 which was the sixth highest in the nation and the highest in California. The second highest income county in California was the County of San Francisco with a PCPI of $95,185. In comparison, California had a PCPI of $49,714 and the national average was $49,420. Exhibit 4-2 graphically depicts the PCPI of the top ten counties in the United States.

EXHIBIT 4-2 TOP 10 COUNTIES IN U.S. BY PCPI

Source: Woods & Poole 2017.

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Marin County is poised to continue to be one of the highest counties in the nation in terms of PCPI as it is forecast to grow at an average annual growth rate of 1.3 percent through 2050. During the same span, the PCPI of the state of California and the United States are forecast to grow 1.1 and 1.2 percent, respectively.

4.4 CALIFORNIA DEPARTMENT OF TRANSPORTATION ECONOMIC FORECASTS

The California Department of Transportation (CalTrans) provides county-level economic forecasts for all of the 58 counties in California. These long-term forecasts are updated annually and are released in the fall with the most recent release being the 2016 forecast. Some of the highlights presented in the forecast regarding Marin County include the following:

 Population will grow at an average annual rate of 0.3 percent through 2050, compared to Woods & Poole’s forecast of 0.4 percent.  Total employment is forecast to grow at an average annual rate of 0.6 percent through 2050. The difference in growth from population and employment will result in a drop of the unemployment rate from 3.2 percent in 2016 to 2.9 percent in 2050.  PCPI will grow at an average annual rate of 1.0 percent, compared to 1.3 percent indicated by Woods & Poole.

4.5 ASSOCIATION OF BAY AREA GOVERNMENTS SOCIO-ECONOMIC FORECASTS

In 2013, the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC) adopted the Plan Bay Area, a long-range integrated transportation and land-use/housing strategy. Plan Bay Area included population and employment forecasts by county for the Bay Area. In July 2017, a final report on the regional forecast of jobs, population, and housing was released. Table 4-2 provides the forecasts presented in the Plan Bay Area document.

TABLE 4-2 BAY AREA FORECASTS

Values (in thousands) Growth Rates Statistic 2010 2015 2040 2010‐40 2015‐40 Total Employment 3,410.9 4,025.6 4,698.4 1.1% 0.6% Population 7,150.7 7,609.0 9,522.3 1.0% 0.9% Households 2,606.3 2,699.3 3,388.6 0.9% 0.9%

Note: Sum of county totals may not match regional totals due to rounding. Sources: Association of Bay Area Governments (ABAG), Plan Bay Area 2040: Regional Forecast of Jobs, Population, and Housing, July 2017.

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4.6 HISTORICAL NATIONAL GA ACTIVITY

The civil aviation industry in the U.S. has experienced major changes over the past several decades. GA activity levels were at their highest in the late 1970s through 1981. GA activity levels and new aircraft production reached all-time lows in the early 1990s due to a number of factors including increasing fuel prices, increased product liability stemming from litigation concerns, and the resulting higher cost of new aircraft. The passage of the 1994 General Aviation Revitalization Act (GARA)7 combined with reduced new aircraft prices, lower fuel prices, resumed production of single-engine aircraft, continued strength in the production and sale of business jets, and a recovered economy led to growth in the GA industry in the latter half of the 1990s.8

The rebound in the U.S. GA industry that began with GARA started to subside by FY2000. GA traffic at airports with air traffic control service slowed considerably in FY2001 due largely to a U.S. economic recession and to some extent the terrorist attacks of September 11, 2001. GA traffic at airports with air traffic control service continued to decline through FY2006 as spikes in fuel costs occurred and the economy grew at a relatively even pace. For the first time since FY1999, GA traffic at airports with air traffic control service increased in FY2007, but just slightly (0.2 percent over FY2006). However, GA operations declined by 4.7 percent at airports with air traffic control service the following year. The decline in GA traffic continued due to the economic downturn and increases in fuel prices. GA operations decreased 11.3 percent in FY2009, 5.1 percent in FY2010, and 2.3 percent in FY2011. In FY2012, GA operations increased 0.6 percent but subsequently decreased each of the following years. Exhibit 4-3 shows the number of GA operations at U.S. airports since FY1990.

7 GARA imposes an 18-year statute of repose on product liability lawsuits for GA aircraft. 8 Based on information from the General Aviation Manufacturers Association (GAMA).

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EXHIBIT 4-3 GA OPERATIONS AT U.S. AIRPORTS

Sources: FAA Operations Network (OPSNET); Landrum & Brown analysis.

4.7 FAA NATIONAL FORECAST

The FAA annually publishes forecasts of the U.S. aviation industry. The FAA forecast is considered to be one of the most complete and reliable forecasts available for civil activity in the U.S. The FAA forecasts9 project the following trends in the U.S. GA industry from 2016 to 2037:

 The number of active GA aircraft is forecast to increase by 0.1 percent annually.  Growth of 0.9 percent per annum is expected in the number of GA hours flown.  The number of student pilots is expected to decline by 0.1 percent per annum through FY2037.  GA operations at airports with air traffic control service are forecast to increase by 0.3 percent annually through FY2037.  Business use of GA aircraft has experienced historically high growth rates and will continue to grow more rapidly than recreational use.

9 FAA Aerospace Forecast, Fiscal Years 2017-2037.

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As part of its forecasting effort, the FAA prepares national forecasts of active GA aircraft, fleet mix and general aircraft operations. The active aircraft forecast by fleet mix is presented in Table 4-3. It should be remembered that this is a national forecast and is not representative of any particular airport or region.

The overall number of active GA aircraft is projected to grow at an average annual rate of 0.1 percent for the next 21 years. However, there is variation both with respect to the mix of aircraft and the growth rate within each category. Starting in 2005, the FAA added “sport” aircraft as a registration category. Originally the FAA was expecting high registration in this category, but the growth rates have been modest and over the 21-year period the category is anticipated to grow at an annual rate of 4.1 percent. Other areas of growth include the turbine jets, turboprops, and rotorcraft. Single-engine and multi-engine piston aircraft are expected to decline at an average annual rate of 0.9 percent and 0.5 percent, respectively.

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F Total Page 13 Page General

209,905 209,710 223,370 209,735 220,453 210,380 209,034 212,110 199,927 212,670 204,408 213,420 210,031 Aviation Activity Forecast Sport Aviation 4,950 4,950 5,684 4,955 5,681 4,985 5,006 5,000 4,277 5,010 4,699 5,015 4,941 3,160 6,528 3,965 6,645 4,770 2,001 5,575 2,056 5,730 2,231 5,885 2,369 2,530 30,240 24,784 31,835 24,275 33,340 26,715 34,720 35,015 35,310 27,922 28,475 24,918 26,191 Rotorc raft 14,545 14,800 15,065 11,435 10,102 12,365 10,082 13,375 10,055 9,765 9,966 10,506 10,700 7,920 6,514 8,625 6,671 9,390 6,763 10,280 6,628 10,475 6,812 10,680 7,220 7,365 3,515 3,588 3,740 3,411 3,985 3,292 4,265 3,137 4,325 3,154 4,385 3,286 3,335 Turbine 24,195 20,853 26,385 21,173 29,395 22,097 32,940 21,256 33,720 22,139 34,625 23,152 23,230 18,975 11,793 21,105 21,570 22,040 15,115 11,484 16,965 11,650 11,637 12,362 13,440 13,770

Wing Fixed 9,080 9,369 9,420 9,523 10,420 10,304 11,835 9,619 12,150 9,777 12,585 9,712 9,460

ORECAST F Piston 135,730 155,419 130,230 152,597 124,515 143,160 119,330 137,655 118,395 139,182 117,520 141,141 140,020

IRPORT

A

CTIVITY

A Single- Multi- Turbo- Turbo IELD 13,045 15,900 12,820 15,702 12,505 14,313 12,125 13,257 12,045 13,146 11,970 13,254 13,200 F

NOSS 2020 122,685 2010 139,519 2025 117,410 2011 136,895 2030 112,010 2012 128,847 2035 107,205 2013 124,398 2036 106,350 2014 126,036 2037 105,550 2015 127,887 2010-162016-172016-262016-37 -1.1% -0.8% -0.9% -2.0% -0.9% -0.3% -0.3% -1.2% -0.5% -0.8% -0.8% -0.8% 0.1% -1.8% 0.1% 1.4% 2.0% 2.4% 2.3% 2.3% 1.2% 0.7% 1.5% -0.8% 1.9% 1.3% 1.3% 1.4% 1.3% 2.0% 1.8% 0.6% 1.8% 1.8% 1.6% 1.6% 1.6% 1.7% 1.2% -10.0% 1.0% 6.1% -1.5% 5.0% 4.1% 0.1% -0.7% 0.0% 0.1% -0.1% 0.0% 0.1% VIATION VIATION 2016E 126,820 Forecast YearHist oric al Engine Engine Total Prop Jet Total Piston Turbine Total Experimental Aircraft Other Fleet AAGR

G A TABLE 4-3 U.S. ACTIVE GENERAL AVIATION AIRCRAFT Source: 2017-2037. Years Fiscal Forecast, Aerospace FAA Landrum & Brown February 2018 GNOSS FIELD AIRPORT AVIATION ACTIVITY FORECAST FINAL

4.8 EMERGING AIRCRAFT OWNERSHIP

The concept of purchasing hours of jet time began to emerge in the 1990s with the fractional ownership of business jets gaining popularity. Fractional ownership, as it suggests, involves purchasing a share in a GA aircraft. The user also typically pays an hourly usage fee and a monthly management fee. Companies such as NetJets, FlexJet, Citation Shares, and others provide these types of services. The fractional ownership concept began with jets but has also begun to expand to all types of aircraft including single-engine piston aircraft. Fractional ownership has significantly contributed to the revitalization of the GA manufacturing industry in the 21st century. For example, NetJets alone has purchased hundreds of corporate jet aircraft of varying sizes ranging up to the Boeing BBJ (typically a derivative of the Boeing 737 aircraft). Projected increases in fractional ownership activity levels are a large part of the FAA’s projected growth in GA operations through 2037.

4.9 FLEET DIVERSIFICATION

In 1980, approximately 91.5 percent of all active U.S. GA and air taxi aircraft were piston airplanes. Since then active piston airplanes have been decreasing at an average annual rate of 1.0 percent resulting in the share of piston airplane dropping to an estimate of 60.4 percent of all active U.S. GA aircraft in 2016. The FAA forecast that piston airplanes will continue to decline at a rate of 0.9 percent annually through 2037. 10

During this span, business jets have been the fastest growing segment. The business jet fleet grew from 2,992 active aircraft in 1980 to an estimated 13,770 active aircraft in 2016, representing an average annual growth rate of 4.3 percent. A majority of this growth occurred between 1995 and 2004 when growth averaged 9.4 percent annually. Business jets now account for 6.6 percent of all active GA and air taxi aircraft. The FAA forecast that business jets will continue to grow at 2.3 percent annually through 2037.11

In 2007, a new category of personal jets, referred to as very light jets (VLJs), began delivery. A VLJ is defined as a small jet that seats four to eight people, is certified for single-pilot operations, and has a maximum takeoff weight of less than 10,000 pounds. The jets are aimed at owners of twin-engine piston and turboprop aircraft. The VLJs are able to operate at smaller airports with shorter runways, between 3,000 and 3,500 feet in length. Initial forecasts for VLJ called for over 400 aircraft to be delivered a year. However, in 2008, Eclipse Aviation, one of the largest manufacturers of VLJs, and DayJet, one of the largest users of VLJs, declared bankruptcy. In 2013, only 77 VLJs were delivered worldwide.12

10 FAA Aerospace Forecast, Fiscal Years 2017-2037. 11 FAA Aerospace Forecast, Fiscal Years 2017-2037. 12 FAA Aerospace Forecast, Fiscal Years 2017-2037.

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In 2016, turboprop airplane and rotorcraft accounted for approximately 4.5 percent and 5.1 percent of all active GA and air taxi aircraft, respectively; up from a combined 4.8 percent in 1980 (1.9 percent turboprop and 2.8 percent rotorcraft). The number of turboprop airplanes is forecast to grow at 1.4 percent annually while rotorcraft are forecast to grow at 1.6 percent annually through 2037.13

The category light-sport aircraft of aircraft was established on September 1, 2004. The category is built to industry consensus standards rather than requiring type and production certificates thereby reducing development costs which results in lower acquisition costs. The design of the aircraft in this category is limited to slow (less than 120 knots) and simple. The FAA is forecasting light-sport aircraft fleet to grow from an estimate of 2,530 aircraft in 2016 to 5,885 in 2037, representing an average annual growth rate of 4.1 percent.

4.10 FUEL PRICES

The price of fuel is one of the biggest costs to the airlines and GA aircraft owners. The price of West Texas Intermediate (WTI) crude oil increased dramatically in the 2006 to 2008 time period, posting a 290 percent increase in June 2008 compared to January 2004. After averaging $20 to $30 per barrel in the 2000 to 2003 time period, spot crude oil prices surged to about $140 per barrel in June/July 2008. Several factors drove the increase such as strong global demand, particularly in China and India, a weak U.S. dollar, commodity speculation, political unrest, and a reticence to materially increase supply.

The price of oil subsequently declined sharply in 2009 due to reduced demand resulting from the global financial crisis and resulting economic recession. However, oil prices increased in the subsequent three years as the economic climate slowly improved and unrest in the Middle East contributed to rising oil prices. In 2012, oil averaged 94 USD per barrel.

Starting in July 2014, the price of crude oil began to drop significantly. In January 2017, Energy Information Administration (EIA) released their long-term energy outlook which projects the price of oil, adjusted for inflation, to reach 99 USD by the end of 2037. Consequently, it is likely that the cost of fuel will continue to put upward pressure on aircraft operating costs. Exhibit 4-4 shows the crude oil prices, adjusted for inflation, since 1998 and the forecast presented in EIA’s long-term forecast.

13 FAA Aerospace Forecast, Fiscal Years 2015-2035.

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EXHIBIT 4-4 CRUDE OIL PRICES (2016$)

Sources: Energy Information Administration (EIA); Landrum & Brown analysis.

4.11 BUSINESS USE OF GENERAL AVIATION

Companies and individuals use aircraft as a tool to improve their business’s efficiency and productivity. The terms business and corporate aircraft are often used interchangeably, as they both refer to aircraft used to support a business enterprise. The FAA defines corporate transportation as “any use of an aircraft by a corporation, company or other organization (not for compensation or hire) for the purposes of transporting its employees and/or property, and employing professional pilots for the operation of the aircraft.” Regardless of the terminology used, the business/corporate component of GA is an important one.

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Increased personnel productivity has been stated as one of the most important benefits of using business aircraft. Companies flying GA aircraft for business have more control of their travel. Itineraries can be changed as needed, and the aircraft can fly into destinations not served by scheduled airlines. Business aircraft usage provides:

 Employee time savings  Increased enroute productivity  Minimized time away from home  Enhanced industrial security  Enhanced personal safety  Management control over scheduling

Business use of GA aircraft ranges from small, single-engine aircraft rentals to multiple aircraft corporate fleets supported by dedicated flight crews and mechanics. GA aircraft use allows employers to transport personnel and air cargo efficiently. Businesses often use GA aircraft to link multiple office locations and reach existing and potential customers. Business aircraft use by smaller companies has diversified as various chartering, leasing, time-sharing, interchange agreements, partnerships, and management contracts have emerged. Businesses and corporations have come to value the use of business aircraft in their operations.

After growing rapidly for most of the past decade, the demand for business jet aircraft has decelerated over the past few years. While new products, including very light jets, and increasing foreign demand helped to spur this growth in the early 2000s, the past few years have seen the dramatic impact of the recession on the business jet market. Issues such as reduced corporate profits, bankruptcies, mergers, and an intense scrutiny on GA as a result of corporate collapses have resulted in reductions in corporate GA activity, especially in the business jet sector.

5.0 OVERVIEW OF SAN FRANCISCO BAY AREA’S GA AIRPORTS

There are nine other airports serving GA demand that have similar characteristics as DVO and are located within a reasonable driving distance (60 miles) of the Airport: Sonoma Valley Airport (0Q3), San Rafael Airport (CA35), Napa County Airport (APC), Buchanan Field Airport (CCR), Half Moon Bay Airport (HAF), Hayward Executive Airport (HWD), Charles M. Schulz – Sonoma County Airport, Nut Tree Airport (VCB), Petaluma Municipal Airport (O69), Sonoma Skypark (0Q9), and Rio Vista Municipal Airport (O88). All of the airports listed are within the catchment area. Exhibit 5-1 provides the location of each of the airports in relationship to DVO and summarizes the major facilities and key aviation activity characteristics of each of the aforementioned airport as compared to DVO.

In FY2015, DVO handled approximately 13.6 percent of the activity at these airports and accommodated approximately 9.2 percent of the based aircraft. Each of the remaining airports is discussed below.

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F Page 18 Page s consistents 7 8 O 57 47 273 O88 YES Local 35,000 35,000 Airport General Aviation General 07/25: 4,199 x 75 15/33: 2,199 x 60 Rio VistaRio Municipal Aviation Activity Forecast 04 95 ON 33 62 NO n.a. n.a. 0Q9 n.a. n.a. 15,000 Sonoma Skypark Sonoma d therefore are not forecasted by the FAA 08/26: 2,480 x 40 41 ON NO 203 220 197 O69 50,200 53,200 Airport Reliever Regional Petaluma Petaluma Municipal 1 7 1 71 ON NO 247 262 176 VCB 101,500 101,500 Regional General Aviation General 02/20: 4,700 x 75 11/29: 3,602 x 75 e airports are not included in the NPIAS an SN 43 64 - E 382 315 STS YES 1,014 79,231 Primary 117,748 Charles M Schulz - 14/32: 6,000 x 150 02/20: 5,202 x 100 Sonoma County Airport Nut Tree Airport SY 62 93 E NO 496 543 388 HWD Airport Reliever 127,518 118,170 National Hayward Executive Executive Hayward 10L/28R: 3,107 x 75 10R/28L: 10R/28L: 5,694 x 150 83 94 OY 70 29 NO 325 HAF Local 60,150 50,150 Reliever taxiway while the Form 5010 states Runway 4/22 is 2,700 feet long. This document states the runway is 2,140 feet long as this i this as long feet 2,140 runway is the states document This long. feet 2,700 4/22 is Runway 5010 states Form the while taxiway 12/30: 5,000 x 150 SN 63 84 E NO 495 390 594 CCR Reliever 124,737 106,442 National 14R/32L: 2,799 x 75 01R/19L: 2,770 x 75 01L/19R: 5,001 x 150 14L/32R: 4,602 x 150 with the exception of Sonoma Va lley, San Rafael, and Sonoma Skypark. Thes SY 42 03 E 820 184 248 APC YES 48,752 Reliever 124,650 National 06/24: 5,007 x 150 18L/36R: 2,510 x 75 18R/36L: 5,930 x 150 1 03 OY NO 100 100 n.a. n.a. n.a. n.a. n.a. CA35 04/22: 2,140 x 30 om the FAA TAF for all airp orts 61 ON 79 NO 121 n.a. n.a. 0Q3 n.a. n.a.

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5.1 SONOMA VALLEY AIRPORT (0Q3)

Sonoma Valley Airport, also known as Schellville Airport, is the closest alternative airport to DVO. 0Q3 is a privately owned and open for public use of light aircraft during the daytime hours. The airport is limited to light aircraft (i.e. single- and multi-engine piston aircraft) due to the runway dimensions. 0Q3 has two runways; Runway 7/25 is 2,700 feet in length and 45 feet in width and Runway 17-35 is 1,513 feet in length and 50 feet in width. The Sonoma Valley Airport is not included in the NPIAS. According to the Airport Master Record, Sonoma Valley Airport had 16,000 total operations in 2015 and had 121 based aircraft.

5.2 SAN RAFAEL AIRPORT (CA35)

The San Rafael Airport is a privately owned GA airport. The airport has a single runway, Runway 4/22, that measures 2,140 feet in length and 30 feet in width. The dimension of the runway limits the type of aircraft capable of operating at the airport. According to the Airport Master Record, there are 100 aircraft currently based at CA35.

5.3 NAPA COUNTY AIRPORT (APC)

The Napa County Airport is the closest airport to DVO that has the facilities to handle turbine GA aircraft operations without restrictions unlike DVO. APC has three runways, Runway 18R/36L, Runway 6/24, and Runway 18L/36R, measuring at lengths of 5,930, 5,007, and 2,510 feet respectively. APC also is served by an FAA Air Traffic Control Tower (ATCT) allowing the airport to operate at a higher capacity than many of the GA airports in the area. Like DVO, the airport is designated as a reliever airport by the FAA. It has a national role per the NPIAS. In FY2015, APC reported 48,752 operations, nearly a third of the operations in FY2003, and had 184 based aircraft.

5.4 BUCHANAN FIELD AIRPORT (CCR)

The Buchanan Field Airport is a county-owned airport opened to the public. CCR is designated as a national reliever airport by the FAA and is served by an FAA ATCT. The airport is able to handle turbine GA aircraft operations. CCR has the following four runways: Runway 1L/19R at 5,001 feet in length, Runway 14L/32R at 4,602 feet in length, Runway 14R/32L at 2,799 feet in length, and Runway 1R/19L measuring at 2,770 feet in length. In FY2015, CCR reported 106,442 operations and had 390 based aircraft.

5.5 HALF MOON BAY AIRPORT (HAF)

The Half Moon Bay Airport is owned by San Mateo County and is located south of the city of San Francisco. Although HAF is categorized as a reliever airport, the airport is also classified as local as it only supplements the local communities, unlike DVO which supports the region. The airport has a single runway, Runway 12/30 that measures 5,000 feet in length and 150 feet in width. In FY2015, HAF reported 50,150 operations and had 29 based aircraft.

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5.6 HAYWARD EXECUTIVE AIRPORT (HWD)

In FY2015, the Hayward Executive Airport accounted for 16.4 percent of the activity at the GA airports with 118,170 operations and 388 based aircraft. HWD is a city- owned, public-use airport categorized as a national reliever airport by the FAA. The airport has a FAA ATCT and two runways, Runway 10R/28L and Runway 10L/28R, measuring at 5,694 feet and 3,107 feet in length respectively.

5.7 CHARLES M. SCHULZ – SONOMA COUNTY AIRPORT (STS)

The Charles M. Schulz is categorized as a nonhub primary airport by the FAA, the only primary airport identified in the group. The designation of a primary aircraft for STS is due to the daily scheduled passenger service provided by Alaska Airlines to the Los Angeles International Airport (LAX), San Diego International Airport (SAN), Portland International Airport (PDX), and the Seattle-Tacoma International Airport (SEA). Although the airport has scheduled service, a majority, 88.6 percent, of the operations are GA. STS is served by a FAA ATCT and has two runways, Runway 14/32 and Runway 2/20, measuring at 6,000 feet and 5,202 feet in length respectively. In FY2015, STS had 79,231 operations (69,715 GA operations) and 315 based aircraft.

5.8 NUT TREE AIRPORT (VCB)

The county-owned, public-use Nut Tree Airport has a single runway, Runway 2/20, which measures at 4,700 feet in length. The airport is designated as a regional GA airport by the FAA. In FY2015, VCB had the second most operations of the GA airports in the region with 101,500 operations and 176 based aircraft; nearly all of which are single-engine piston.

5.9 PETALUMA MUNICIPAL AIRPORT (O69)

Owned by the city of Petaluma, the Petaluma Municipal Airport is categorized by the FAA as a reliever airport. The airport is restricted in its use due to the dimensions of the single runway, Runway 11/29, which measure in at 3,602 feet in length and 75 feet in width. As such, a majority (95.9 percent) of the 197 based aircraft are single engine piston. In FY2015, O69 had 53,200 operations.

5.10 SONOMA SKYPARK (0Q9)

Sonoma Skypark is a privately owned airport and open for public use by light aircraft. The airport is limited to light aircraft due to the runway dimensions. 0Q9 has one runway; Runway 8/26 is 2,480 feet in length and 40 feet in width. The Sonoma Skypark is not included in the NPIAS. According to the Airport Master Record, 0Q9 had 15,000 total operations and 62 based aircraft in FY2015.

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5.11 RIO VISTA MUNICIPAL AIRPORT (O88)

The Rio Vista Municipal Airport is the furthest alternative to DVO in the catchment area. O88 is owned by the City of Rio Vista and is open to the public. O88 has two runways, Runway 7/25 and Runway 15/33, measuring 4,199 and 2,199 feet, respectively, in length. The airport is classified as local as it only supplements the local communities, unlike DVO, which supports the region. In FY2015, O88 reported 35,000 operations and had 47 based aircraft.

6.0 DVO BASED AIRCRAFT INFORMATION, OPERATIONS INFORMATION, AVIATION ACTIVITY FORECAST, AND CRITICAL AIRCRAFT DETERMINATION

6.1 BASED AIRCRAFT INFORMATION AND BASED AIRCRAFT AVIATION FORECAST

Background data on DVO based aircraft and operations was gathered from the Federal Aviation Administration (FAA) Form 5010-1, FAA Terminal Area Forecasts (TAF), and DVO Airport Management. Form 5010-1 is submitted by the airport operator. It estimates the based aircraft at the airport as well as the previous year’s estimate of operations broken down by operational category (air carrier, air taxi, general aviation, and military).

The FAA TAF uses the 5010-1 forms as a basis for defining historical and forecast based aircraft and operations. Operational counts for airports such as Gnoss Field Airport that do not have an Air Traffic Control Tower (ATCT) are often overestimated and are carried over year-after-year. A review of the 5010-1 form indicated that this is the case for Gnoss Field Airport. As a result, the operational counts on FAA Form 5010-1 and the FAA TAF for DVO were found to be overestimated. Therefore, operational numbers and based aircraft counts are based upon a revised estimate provided by DVO Airport Management.14

The aviation forecast for the number of based aircraft at DVO in future years was derived by applying the average of the growth rates presented in the FAA Aerospace Forecast – Fiscal Years 2017-2035, Table 28 Active General Aviation and Air Taxi Aircraft except for rotorcraft. The FAA Aerospace Forecast has a 1.6 percent annual growth rate for rotorcraft. However, over the past few years, the Airport’s Master Record, which had previously listed four rotorcraft based at DVO, now lists only one rotorcraft based at DVO for 2016. Therefore, the FAA Aerospace Forecast growth rate for rotorcraft does not reflect conditions at DVO. This forecast assumes one based rotorcraft aircraft will remain at DVO throughout the forecast period.

14 Based aircraft counts and operational numbers were provided by the Airport Manager, Dan Jensen, via e-mail dated June 15, 2015.

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As shown in Table 6-1, the overall number of aircraft based at DVO is forecast to decrease by 0.2 percent annually, from 226 in 2016 to 217 in 2035. The number of single-engine piston based aircraft and multi-engine piston aircraft are expected to decrease at average annual rates of 0.3 percent and 0.4 percent, respectively. These trends result from the fact that most of these aircraft become expensive to operate and maintain due to their old age. Turbine aircraft, which includes turboprop and turbofan (jet) aircraft are expected to be the fastest growing GA segment, are projected to grow at an average annual rate of 1.9 percent. At DVO, this growth is anticipated to occur in the number of turboprop aircraft, with the number of jet aircraft remaining constant.

TABLE 6-1 DVO BASED AIRCRAFT FORECAST

Single-Engine Multi-Engine Year Piston Piston Turbine Rotorcraft Total Actual 2016 202 10 13 1 226 Forecast 2020 200 10 14 1 225 2025 196 10 15 1 222 2030 192 9 16 1 218 2035 189 9 18 1 217

AAGR 2016-2020 -0.3% -0.3% 1.0% 0.0% -0.1% 2016-2035 -0.3% -0.4% 1.9% 0.0% -0.2%

Sources: Marin County Airport-Gnoss Field Airport Management, FAA Aerospace Forecast, Landrum & Brown Analysis. AAGR is Average Annual Growth Rate

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6.2 ANNUAL OPERATIONS INFORMATION AND ANNUAL OPERATIONS AVIATION FORCAST

Marin County estimates the annual number of aircraft operations at DVO as 82,500.15 National annual growth rates from the FAA Aerospace Forecast – Fiscal Years 2017- 2037, Table 32 Total Combined Aircraft Operations at Airports with FAA and Contract Control Service, were applied to the base year GA annual operations numbers to determine the forecast of annual GA operations as shown in Table 6-2. This analysis shows that although the number of based aircraft at DVO is forecasted to decrease slightly, the number of annual operations at DVO is forecasted to increase slightly. This is due to forecasted increases in the number of operations per the remaining based aircraft and an increase in the number of itinerant operations.

A composite growth rate was calculated using the national annual growth rates for fixed wing turboprop aircraft from the FAA Aerospace Forecast – Fiscal Years 2017- 2037, Table 29 Active General Aviation and Air Taxi Hours Flown, and an assumption that there will be zero growth operations by jet aircraft.

TABLE 6-2 DVO AIRCRAFT OPERATIONS FORECAST

Year GA Itinerant GA Loc al Air Taxi Military Total Actual 2016 23,925 55,275 3,300 0 82,500 Forecast 2020 24,480 55,640 3,300 0 83,420 2025 25,200 56,090 3,360 0 84,650 2030 25,950 56,540 3,500 0 85,990 2035 26,880 57,120 3,690 0 87,690

AAGR 2016-2020 0.6% 0.2% 0.0% n.a. 0.3% 2016-2035 0.6% 0.2% 0.6% n.a. 0.3%

Sources: County Airport-Gnoss Field Airport Management, FAA Aerospace Forecast, Landrum & Brown Analysis. AAGR is Average Annual Growth Rate

15 Based aircraft counts and operational numbers were provided by the Airport Manager, Dan Jensen, via e-mail dated June 15, 2015.

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The assumption that national annual aircraft operations growth rate was appropriate to apply to the fixed wing turboprop aircraft, but not jet aircraft, was based on a review of the FAA Traffic Flow Management System Counts (TFMSC) counts from radar/flight plan data for flights to and from DVO under Instrument Flight Rules (IFR) from 2007 to 2016 (Exhibit 6-1). From 2007 through 2013, jet aircraft operations declined at an average annual rate of 15.5 percent. Turboprop aircraft operations declined at an average rate of 3.3 percent per annum over the same span. However, since 2013, the decline in jet aircraft operations has nearly ceased, making a “no growth” estimate for in number of aircraft operations for jet aircraft at DVO a reasonable aviation forecast assumption. Also, after the steep decline in turboprop aircraft operations between 2007 and 2009 associated with the economic recession, turboprop operations as measured by TFMSC data have increased at an average annual rate of 5.0 percent per year since 2013. Therefore, it is reasonable to use the national annual aircraft operations growth rate to forecast future turboprop aircraft operations at DVO while holding jet aircraft annual operations stable.

EXHIBIT 6-1 FAA TRAFFIC FLOW MANAGEMENT SYSTEM COUNTS (TFMSC) RADAR DATA OF TURBOPROP AND JET AIRCRAFT INSTRUMENT FLIGHT RULES

Note: Operations were normalized using the higher of the arrival or departure count by aircraft type and multiplied by two in per the guidance in AC 150/5000-17. Sources: Traffic Flow Management System Counts (TFMSC).

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6.3 OPERATIONAL FLEET MIX FORECAST

An operational fleet mix for DVO was developed utilizing the FAA Traffic Flow Management System Counts (TFMSC) data, 16 the Airport’s operations count, the operations forecast, and the based aircraft forecast. This information was used to determine the critical aircraft at DVO. Additional information was also collected from voluntary interviews with pilots/owners of Cessna 525 and Cessna 525A/B/C business jets based at DVO, and with the fuel vendor at DVO, as was suggested in public comments on the Gnoss Field Airport, Proposed Extension of Runway 13/31, Purposed and Need Working Paper, dated April 2016. This information was collected to determine if additional operations of jet aircraft occurred that were not identified in the TFMSC radar data. The importance of the TFMSC radar data is that although most operations at DVO are Visual Flight Rules (VFR) operations by small aircraft that do not appear in the TFMSC data, the most demanding aircraft that operate at DVO primarily operate using Instrument Flight Rules (IFR), which are accurately counted in the TFMSC data. Therefore, the determination of the critical aircraft at DVO can appropriately be made based on the TFMSC operations data combined with the interview and fuel purchase receipt data.

The TFMSC radar data was summarized by Airport Reference Code (ARC). ARC as defined in FAA Advisory Circular 150/5300-13A Change 1, Airport Design, has two components; the Aircraft Approach Category (AAC) and the Airplane Design Group (ADG). The AAC is depicted by a letter and determined by the reference landing speed (VREF) or the approach speed of the aircraft. If the VREF is unavailable, the number refers to 1.3 times the stall speed (VSO). The ADG is depicted by a Roman numeral and is based on the physical characteristics of the aircraft, i.e. wingspan and tail height of the aircraft, whichever is more restrictive. Table 6-3 provides the categories for the AAC and the ADG.

TABLE 6-3 AIRPORT REFERENCE CODE

VREF/Approach Speed Tail Height Wingspan AAC MIN MAX ADG MIN MAX MIN MAX A 0 kt 91 kt I 0.0' 20.0' 0.0' 49.0' B 91 kt 121 kt II 20.0' 30.0' 49.0' 79.0' C 121 kt 141 kt III 30.0' 45.0' 79.0' 118.0' D 141 kt 166 kt IV 45.0' 60.0' 118.0' 171.0' E 166 kt V 60.0' 66.0' 171.0' 214.0' VI 66.0' 80.0' 214.0' 262.0'

Sources: AC 150/5300-13A, Airport Design, CHG1 pages 13-14

16 Radar operations were normalized using the higher of the arrival or departure count by aircraft type and multiplied by two in per the guidance in AC 150/5000-17.

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In 2016, B-I aircraft comprised of aircraft such as the Cirrus SR-22, Cessna 182 Skylane and the Piper PA-46 Malibu were the most predominate aircraft in the DVO TFMSC data accounting for 42.2 percent of the total radar operations. The second largest group, the B-II aircraft, including aircraft such as the Beechcraft Super King Air 200, the Cessna CitationJet C525A/B/C, and the Cessna Citation V accounted for 22.5 percent of radar operations. The Cessna Citation 525 has a wingspan of less than 49 feet, and was counted with the B-I aircraft, while the Cessna Citation 525A/B/C variations have wingspans of over 49 feet, and were counted with the B-II aircraft. A-I aircraft composed primarily of the Cessna 172 Skyhawk, the Beechcraft B36 Bonanza, and the Mooney M20 had 12.7 percent of radar operations. The Pilatus PC-12 was the only aircraft in group A-II but accounted for 22.4 percent of radar operations. There were two C-II aircraft operations at the Airport in 2016. No helicopters or rotorcraft operations were recorded in the radar data. Exhibit 6-2 provides a graphical summary of the aircraft operating at DVO.

EXHIBIT 6-2 FAA TRAFFIC FLOW MANAGEMENT SYSTEM COUNTS (TFMSC) RADAR DATA FOR AIRCRAFT FLEET MIX AT DVO

Note: Operations were normalized using the higher of the arrival or departure count by aircraft type and multiplied by two in per the guidance in AC 150/5000-17. Sources: 2016 Radar Data; Landrum & Brown analysis.

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6.4 CRITICAL AIRCRAFT DETERMINATION

In June 2017, FAA published AC 150/5000-17, Critical Aircraft and Regular Use Determination to provide additional guidance on the use of the Design Aircraft or Critical Aircraft in facility planning and design studies, and related FAA decision making, for federally obligated airports. This AC establishes a common, uniform definition of the number of annual aircraft operations to identify the Critical Aircraft for all deliberations of the FAA Office of Airports, inclusive of planning and environmental, design and engineering, and financial decision making regarding airport development. Regarding the definition of the critical aircraft, the Section 1.2.1 of the AC states:

“The critical aircraft is the most demanding aircraft type, or grouping of aircraft with similar characteristics, that make regular use of the airport. Regular use is 500 annual operations, including both itinerant and local operations but excluding touch-and-go operations. An operation is either a takeoff or landing.”

In previous analyses of the activity of the critical aircraft at DVO, the focus had been on the Cessna Citation Jet C525 and C525A/B/C variations (C525) aircraft because it has a runway length requirement that is longer than other similar sized aircraft operating at DVO. When the April 2016 Purpose and Need Working Paper concluded that the Cessna 525 was no longer the critical aircraft at DVO due to the lack of the necessary 500 annual operations, several commenters stated that C525 operations were being undercounted because they were being operated under Visual Flight Rules (VFR) and as a result not captured on TFMSC Instrument Flight Rules (IFR) radar data. Additional comments suggested that some pilots utilized ‘VFR flight following’ procedures where the pilot contacts FAA ATC and their location is monitored, which could also result in an undercounted flight. Therefore, for this forecast, interviews were conducted with the pilots/owners of the C525 aircraft based at DVO.

Interviews with the five C525 pilot/owners based at DVO were conducted in June and July 2017. All five provided responses to a questionnaire regarding their flight activity in and out of DVO. The questions asked about the number of operations they operated in 2016 with a particular focus on flights that were conducted VFR versus IFR. Pilots/owners provided flight log books or other similar documentation to support their reported operations. Through these interviews, it was determined that the radar data was accurately capturing the IFR activity by these pilot/owners. However, the interviews identified an additional 48 VFR aircraft operations in 2016 that were not captured by the radar data because they were VFR operations. This information was added to the count of activity from the radar data for the C525 aircraft.

To further substantiate if a substantial number of undetected C525 arrivals or departures by non-based aircraft occurred under VFR, the Fixed Base Operator was asked to provide information regarding fuel sales at DVO. Such an evaluation was suggested in the public comments on the April 2016 Purpose and Need Working Paper. Fuel logs were evaluated for the peak months of aviation activity at DVO – the summer months of June and July 2016.

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In June 2016, there were 55 records for aircraft fueling. The tail numbers provided in the fuel logs were used to identify the aircraft models by utilizing the FAA’s Aircraft Registry. It was determined that 19 of the 55 fueling records were associated with jet aircraft. The tail numbers of these records were cross referenced with the list of based aircraft provided by the Airport. Only four of the 19 records for jet aircraft in the fuel logs were for aircraft not based at the Airport. All four of these fuel records had a corresponding arrival and a departure within 24 hours of the fueling in the radar data. Therefore, it was determined that these aircraft operations were captured in the TFMSC radar data.

In July 2016, there were 47 records for aircraft fueling. It was determined that 13 of the 47 fueling records were associated with jet aircraft, all of which were based at DVO and therefore had already been counted either through the TFMSC radar data or through interviews.

The review of fuel records in the months with the highest fuel sales did not identify any additional operations of C525 or other jet aircraft not already accounted for by other data sources such as TFMSC radar data and pilot/aircraft owner interviews. Therefore, no change in the determination of annual operations at DVO by the C525 was necessary. In all, 295 operations of the C525 at DVO could be documented in 2016. The 295 C525 operations are split between B-I and B-II aircraft groups. The base variant of the Cessna 525, a B-I aircraft, had 90 operations in 2016 while the A, B, and C variants of the Cessna 525 (C25A/B/C), all B-II aircraft, had 205 operations in 2016.

The use of ‘VFR flight following’ as a source of additional aircraft operations was investigated with FAA operational databases. A review showed that only a small number of flights per month requested flight following. The operations using VFR flight following are captured in this analysis from the pilot interviews and fuel sale records that incorporate VFR operations into the operations forecast.

The total 2016 aircraft operations identified from the TFMSC radar data, including the additional flights provided in the interviews, for each aircraft category are provided in Table 6-4.

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TABLE 6-4 DVO 2016 AIRCRAFT OPERATIONS DOCUMENTED BY AIRPORT REFERENCE CODE USING FAA TRAFFIC FLOW MANAGEMENT SYSTEM COUNTS AND PILOT-AIRCRAFT OWNER INTERVIEW DATA

Doc ument ed Aircraft Operations Jet B-I Small 106 B-II Small 205 B- II Large 61 C-II Large 2 Total 374 Multi-Engine Turboprop B- I Small 74 B-II Small 204 B- II Large 28 C-II Small 2 Total 308 Single-Engine Turboprop A-I Small 4 A-II Small 436 B-I Small 170 B- II Small 4 Total 614 Multi-Engine Piston A-I Small 11 B-I Small 139 Total 150 Single-Engine Piston A-I Small 229 B-I Small 350 Total 579 Helic opter 0 Grand Total 2,025

Notes: A small airplane is defined as an airplane of 12,500 pounds (5,670 kg) or less maximum certificated takeoff weight. Anything larger is defined as a large airplane. Radar operations were normalized using the higher of the arrival or departure count by aircraft type and multiplied by two in per the guidance in AC 150/5000- 17. Most aircraft that operate at DVO are small airplanes. Aircraft operations that have requested privacy blocking from real-time flight tracking portals are included in the aggregate TFMSC counts. Sources: 2016 Radar Data; Aircraft owner interviews; Landrum & Brown analysis.

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For 2016, the jet and turboprop operations were captured by the radar data or from the information provided by the owners of the jet aircraft based at DVO or fuel sales receipt records. It was assumed that the majority of the jet and turboprop operations were for air taxi. The remaining air taxi operations were assumed to be operated by piston aircraft.

Therefore, the 3,300 air taxi operations shown in Table 6-2, excluding the jet and turboprop operations, were divided among the piston categories by their share of the radar data. Jet aircraft operations were assumed to remain constant through the forecast period. Turboprop aircraft operations were calculated by increasing the number of aircraft operations by the assumed 1.5 percent rate of growth for the aircraft per the FAA Aerospace Forecast. The remaining air taxi operations were assumed to be piston aircraft.

Typically, aircraft based at the Airport are assumed to generate a majority of the traffic. The estimated 23,925 itinerant and 55,275 local operations shown in Table 6-2 were assumed to be primarily using piston aircraft, excluding some helicopter operations, which were segmented into categories based on the number of aircraft based at the Airport.

Table 6-5 provides a summary of the fleet forecast at DVO by engine type and ARC.

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TABLE 6-5 OPERATIONAL FLEET MIX FORECAST

Operations Percent of Annual Aircraft 2016 2020 2025 2029 2035 2016 2020 2025 2029 2035 Jet B-I Small 106 106 106 106 106 0.1% 0.1% 0.1% 0.1% 0.1% B-II Small 205 205 205 205 205 0.2% 0.2% 0.2% 0.2% 0.2% B-II Large 61616161610.1%0.1%0.1%0.1%0.1% C-II Large 2 2 2 2 2 0.0% 0.0% 0.0% 0.0% 0.0% Total 374 374 374 374 374 0.5% 0.4% 0.4% 0.4% 0.4% Multi-Engine Turboprop B-I Small 74828592990.1%0.1%0.1%0.1%0.1% B-II Small 204 225 233 251 270 0.2% 0.3% 0.3% 0.3% 0.3% B-II Large 28313234370.0%0.0%0.0%0.0%0.0% C-II Small 2 2 2 2 2 0.0% 0.0% 0.0% 0.0% 0.0% Total 308 340 352 379 408 0.4% 0.4% 0.4% 0.4% 0.5% Single-Engine Turboprop A-I Small 455670.0%0.0%0.0%0.0%0.0% A-II Small 436 468 499 537 578 0.5% 0.6% 0.6% 0.6% 0.7% B-I Small 170 182 194 209 225 0.2% 0.2% 0.2% 0.2% 0.3% B-II Small 4 4 4 4 4 0.0% 0.0% 0.0% 0.0% 0.0% Total 614 659 702 756 814 0.7% 0.8% 0.8% 0.9% 0.9% Multi-Engine Piston A-I Small 303 305 373 388 404 0.4% 0.4% 0.4% 0.5% 0.5% B-I Small 3,826 3,855 4,715 4,898 5,106 4.6% 4.6% 5.6% 5.7% 5.8% Total 4,129 4,160 5,088 5,286 5,510 5.0% 5.0% 6.0% 6.1% 6.3% Single-Engine Piston A-I Small 30,330 30,651 30,745 31,161 31,706 36.8% 36.7% 36.3% 36.2% 36.2% B-I Small 46,355 46,846 46,989 47,624 48,458 56.2% 56.2% 55.5% 55.4% 55.3% Total 76,685 77,497 77,734 78,785 80,164 93.0% 92.9% 91.8% 91.6% 91.4% Helicopter 390 390 400 410 420 0.5% 0.5% 0.5% 0.5% 0.5% Grand Total 82,500 83,420 84,650 85,990 87,690 100.0% 100.0% 100.0% 100.0% 100.0%

Note: Small airplane is defined as an airplane of 12,500 pounds (5,670 kg) or less maximum certificated takeoff weight. Anything larger is defined as a large airplane. All Jet and turboprop counts for 2016 include data provided by the 2016 radar data supplemented with information provided during interviews with aircraft owners. Sources: Marin County Airport-Gnoss Field Airport Management, FAA Aerospace Forecast, Landrum & Brown Analysis

FAA AC 150/5300-13A, Airport Design, provides the airport design dimensions and standards the FAA recommends for use in the design of civil airports. The FAA requires that these standards be followed for all projects funded with federal Airport Improvement Program grant funds unless there is a determination why a standard cannot be met. For DVO, as shown on Table 6-5, there are more than 500 annual operations of aircraft with Airport Approach Category “B” between 121-141 knots. Also as shown on Table 6-5, there are more than 500 annual operations of aircraft in Airplane Design Group II, aircraft with wingspans between 49-79 feet wide or tail height between 20-30 feet high, which includes both A-II and B-II aircraft. Therefore, the critical aircraft for airport design purposes is the group of B-II aircraft.

Landrum & Brown Aviation Activity Forecast February 2018 Page 31 GNOSS FIELD AIRPORT AVIATION ACTIVITY FORECAST FINAL

While FAA AC 150/5300-13A identifies airport design standards for most airport dimensions, it does not specify airport design dimensions for runway length. This is because the necessary runway length for takeoff or landing of a critical aircraft varies between airports. An aircraft operating at an airport in warmer climate or at a higher elevation above level sea level will typically require a longer runway for the takeoff and landing compared to the same aircraft operating at an airport located in a cooler climate or at a lower elevation17. The FAA has addressed this by issuing specific guidance, FAA AC 150/5325-4B Runway Length Requirements for Airport Design, describing the appropriate methods to determine the required runway length at an airport.

The runway length needed at DVO was derived using the small airplane design concept from FAA AC 150/5325-4B. Within the current fleet mix at DVO, the existing critical aircraft for runway length is the family of B-II Turboprop aircraft, which is the most demanding aircraft grouping with regular use. Appendix B, Runway Length Analysis, describes how the runway length was established for the family of B-II Turboprop aircraft using FAA AC 150/5325-4B.

FAA AC 150/5325-4B also allows that when a specific critical aircraft’s airport planning manual shows a longer runway length than what is shown on the AC’s runway length curves, that an airplane manufacturer’s airport planning manual can be used instead. The airport planning manual for the Cessna 525 was used to determine the justified runway length in the Final EIS for the Proposed Extension of Runway 13/31 at DVO18. That approach is no longer applicable because the Cessna 525 no longer has the required 500 annual operations to be considered the critical aircraft for runway length calculations at DVO.

17 Hotter air is less dense than cooler air so that an aircraft wing creates less lift in hotter air requiring a longer runway for takeoffs and landings. Air is also less dense at higher altitudes when compared to lower altitudes. Therefore, other factors being equal, aircraft require a longer runway to attain sufficient speed to take off on a hot day, or at a higher altitude, as compared to the same aircraft on cooler day, or at a lower altitude.

18 The Cessna Citation CJ1+ Flight Planning Guide, Cessna Aircraft, February 2007 and Revision 3-March 27, 2012 were both used in calculating the required runway length for the Cessna C525 in the June 2014 Final EIS.

Landrum & Brown Aviation Activity Forecast February 2018 Page 32 GNOSS FIELD AIRPORT AVIATION ACTIVITY FORECAST FINAL

7.0 PEAK OPERATIONS

The traffic demand patterns imposed upon an airport are subject to seasonal, monthly, daily, and hourly variations. In order to evaluate the peaking patterns at an airport, the annual enplanements and aircraft operations forecasts are distributed to monthly, daily, and hourly equivalents. According to the radar data, May was the peak month in 2016 with 10.3 percent of the recorded operations. A typical day during the peak month accounts for 3.2 percent of the monthly operations. It is estimated that 9.0 percent of the daily operations occur during the peak hour. It was assumed that these factors would remain constant from 2016 to 2035. Table 7-1 provides the peak operations at DVO through the forecast period.

TABLE 7-1 PEAK OPERATIONS FORECAST

Statistic 2016 2020 2025 2030 2035 Annual Operations 82,500 83,420 84,650 85,990 87,690 Peak Month % of Annual 10.3% 10.3% 10.3% 10.3% 10.3% Peak Month Operations 8,501 8,596 8,722 8,860 9,036 Average Day % of Peak Month 3.2% 3.2% 3.2% 3.2% 3.2% Average Day Operations 274 277 281 286 291 Peak Hour % of Average Day 9.0% 9.0% 9.0% 9.0% 9.0% Peak Hour Operations 25 25 25 26 26

Sources: Radar Data; Landrum & Brown analysis

8.0 COMPARISON TO FAA TAF

The FAA develops the TAF on an annual basis for all active airports in the U.S. that are included in the NPIAS. The TAF is “prepared to meet the budget and planning needs of FAA and provide information for use by state and local authorities, the aviation industry, and the public.”19 The 2016 TAF was issued in January 2017 and is compared to the forecast for DVO herein. The FAA records aircraft operations as air carrier, commuter & air taxi, GA, or military.

The historical values for DVO in the TAF have not been updated since 2009 when operations at DVO were 98,000. On FAA Form 5010-1, an airport states the previous year’s count of operations broken down by category, as well as the based aircraft for the airport. The FAA TAF uses the 5010-1 forms as a basis for defining historical traffic. Operational counts for airports such as Gnoss Field Airport that do not have an ATCT are often incorrectly estimated and are carried over year-after-year. A review of the DVO data contained in Form 5010-1 form indicated that this is the case for Gnoss Field Airport. As a result, the annual operations in the FAA TAF for DVO was found to be higher than actual operations.

19 http://aspm.faa.gov/main/taf.asp

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Therefore, the base operations in 2016 for the forecast presented in this document did not match the 2016 TAF resulting in a variation of -15.8 percent in the base year. The 2016 TAF for DVO assumed that operations would remain at the 2009 level through the forecast period. Exhibit 8-1 and Table 8-1 present a comparison of DVO’s aircraft operations forecast with the most recent FAA TAF.

EXHIBIT 8-1 FORECAST TO TAF COMPARISON

160

140

120

100

80

(in thousands) 60

General Aviation Operations 40

20

0 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 Historical ΔTAF Forecast TAF

Sources: FAA Terminal Area Forecast (TAF); Landrum & Brown analysis.

TABLE 8-1 FORECAST TO TAF COMPARISON

Variance Year Forecast 2016 TAF (% Difference) Base Year 2016 82,500 98,000 ‐15.8% Base Year + 5 Years 2021 83,650 98,000 ‐14.6% Base Year + 10 Years 2026 84,910 98,000 ‐13.4% Base Year + 15 Years 2031 86,260 98,000 ‐12.0%

Sources: FAA Terminal Area Forecast (TAF); Landrum & Brown analysis

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9.0 FORECAST SCENARIOS

In addition to the baseline operations forecast presented in the above sections, high and low scenarios were developed. The high case forecast assumes that operations would grow at a faster rate than the base case due to changes in the socio-economic conditions in Marin County. The overall operations were assumed to grow at 1.5 times the rate of the base case. The low case forecast assumes that operations would reflect the growth in the 2016 TAF, i.e. zero growth through the forecast period. Table 9-1 provides a summary of the low, base, and high case scenario forecasts.

TABLE 9-1 SUMMARY OF FORECAST SCENARIOS

Low Base High Year Forecast Forecast Forecast Actual 2016 82,500 82,500 82,500 Forecast 2020 82,500 83,420 84,100 2025 82,500 84,650 86,150 2030 82,500 85,990 88,250 2035 82,500 87,690 90,400

AAGR 2016-2020 0.0% 0.3% 0.5% 2016-2035 0.0% 0.3% 0.5%

Sources: FAA Terminal Area Forecast (TAF); Landrum & Brown analysis

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ATTACHMENT 1

INTERVIEW MATERIALS

For detailed responses, contact Federal Aviation Administration, San Francisco Airports District Office: Doug Pomeroy, Telephone 650-827-7612 [email protected]

Landrum & Brown Aviation Activity Forecast February 2018 Page 36

Gnoss Field Environmental Impact Statement

QUESTIONNAIRE

Opening Statement Thank you for agreeing to participate in our process as we gather additional information on flight activity at Gnoss Field Airport. We are gathering this information to help the Federal Aviation Administration (FAA) determine the “critical aircraft” at Gnoss Field Airport. The critical aircraft is the most “demanding aircraft” in terms of the physical size of airport facilities, such as runway and taxiway length and width, to regularly use the airport. The purpose of these questions is to understand the type of aircraft you operate, how often you currently operate the aircraft at Gnoss Field Airport, the destinations you fly to and from Gnoss Field Airport, and any anticipated future changes to your activities.

We have available the FAA’s records of Instrument Flight Rules (IFR) flight plans, that are correlated with radar track data, for operations during 2016 at Gnoss Field Airport. Our objective in this data gathering effort is to add any missing flights, such as Visual Flight Rule (VFR) flights or other missed IFR flights, in order to develop a complete record of 2016 aircraft operations by demanding aircraft. For this purpose, an operation is a takeoff or landing, but excludes touch-and-goes.

The FAA will use the information gathered to assist in preparation of updated documentation regarding the determination of the critical aircraft and runway length at Gnoss Field Airport that can be justified for aviation infrastructure development under FAA guidance. This information will be summarized and analyzed in an Updated Purpose and Need Working Paper for Gnoss Field Airport, which will be available for public comment. After public review of the Updated Purpose and Need Working paper a summary the aviation activity information will be included in a Supplement to Gnoss Field Airport Final Environmental Impact Statement for the Extension of Runway 13/31. When answering the questions, please be as detailed as you can be and, if possible, provide documentation that supports your answers. Please be advised, we may not be able to use anecdotal information that cannot be corroborated with other data.

Name Email Phone Number

1. Do you or your company or organization currently operate a jet aircraft or larger turboprop aircraft at Gnoss Field Airport?

Circle one: YES NO

If NO, skip to Question 6

2. Which model of aircraft do you currently operate at Gnoss Field Airport? Please be specific, i.e., C525, C525A, C525B, etc.). What is the N#s of your aircraft?

Notes:

3. Do you operate under your aircraft under Part 135 and/or Part 91 regulations?

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4. At which airport is your aircraft based?

Notes:

5. Please review with us your flight activity for your aircraft to and from Gnoss Field Airport during calendar year 2016. We need to identify your total operations, excluding touch and goes. Do the 2016 IFR flights in the FAA records match the information in your logs? If not, please identify missing flights and provide documentation, such as logs. Please identify what trips you flew VFR versus IFR; this will help us to correlate your input with FAA records of flight plan and radar data.

Flight Date A/D Destination/Mission IFR/VFR Touch and Goes?

Notes:

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6. Were any of the trips short hauls, for example to have maintenance performed at a nearby airport?

7. More generally, is there a regular pattern in terms of the number of trips in a week, destinations, duration of trips?

8. Have you departed Gnoss Field Airport and needed to use one of the other local airports to take on additional fuel for your aircraft to reach your final destination? If yes, please provide details regarding which local airport you refuel at, which destinations require this extra stop, how often this occurred in 2016. What were the weather conditions and aircraft performance factors that resulted in the decision to use a nearby airport to for fueling?

Notes:

9. What were the weather conditions and aircraft performance factors that resulted in the decision to use a nearby airport to for fueling?

10. Do you have the name and contact information for other pilots that operate demanding aircraft at Gnoss Field Airport?

Notes:

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11. Do you anticipate that your flight activity at Gnoss Field will stay about the same, increase, or decrease during the next few years?

12. Are you or your company considering any additional aircraft purchases or upgrades?

Circle one: YES NO

If YES, please indicate how many, what type, and an approximate date: Notes:

Additional Notes by Interviewer:

FAA Contact: Katherine Kennedy Airports/Community Planner 1000 Marina Boulevard – Suite 220 Brisbane, CA 94005 Telephone: 650-827-7611 Email: [email protected]

Page 4

APPENDIX B

RUNWAY LENGTH ANALYSIS

GNOSS FIELD AIRPORT

Prepared By: Landrum & Brown February 2018

GNOSS FIELD AIRPORT RUNWAY LENGTH ANALYSIS FINAL

TABLE OF CONTENTS

PAGE

1.0 Introduction ...... 1 2.0 Runway Length Analysis ...... 4

LIST OF EXHIBITS

PAGE

Exhibit B-1 Runway Length Determination Using Runway Length Curves Process ...... 6

Landrum & Brown Runway Length Analysis February 2018 Page i GNOSS FIELD AIRPORT RUNWAY LENGTH ANALYSIS FINAL

RUNWAY LENGTH ANALYSIS

1.0 INTRODUCTION

Marin County has prepared several evaluations of the Gnoss Field Airport’s (DVO or Airport) operations and facilities, including the 1989 Airport Master Plan1, the 1997 Update of the Airport Master Plan, the 2002 Preliminary Design Report for the proposed runway extension2, and the evaluations leading up to the preparation of the Draft and Final EIS.3 These studies identified the limitations regarding the Airport’s ability to accommodate existing aircraft and aviation users for which the Airport was designed. Specifically, prior evaluations found the Airport’s 3,300-foot long runway could not fully accommodate existing aviation activity of the critical aircraft. This evaluation updates those prior evaluations based on the current critical aircraft identified in Appendix A the family of B-II Turboprop aircraft, which is the most demanding aircraft grouping with regular use.

FAA Advisory Circular (AC) 150/5325-4B, Runway Length Requirements for Airport Design4, is the FAA’s guidance document for identifying the appropriate runway length for airport runways. AC 150/5325-4B, Paragraph 101 Background, describes runway length factors and evaluations as follows:

“Airplanes today operate on a wide range of available runway lengths. Various factors, in turn, govern the suitability of those available runway lengths, most notably airport elevation above mean sea level, temperature, wind velocity, airplane operating weights, takeoff and landing flap settings, runway surface condition (dry or wet), effective runway gradient, presence of obstructions in the vicinity of the airport, and, if any, locally imposed noise abatement restrictions or other prohibitions. Of these factors, certain ones have an operational impact on available runway lengths. That is, for a given runway the usable length made available by the airport may not be entirely suitable for all types of airplane operations.”

AC 150/5300-13A, Airport Design, Paragraph 105b Design Aircraft, states describing aircraft using an airport that:

“The first consideration of the airport planner should be the safe operation of aircraft likely to use the airport… However, it is not the usual practice to base the airport design on an aircraft that uses the airport infrequently…”

1 Airport Master Plan Marin County Airport Gnoss Field, 1989. 2 Cortright & Seibold, Preliminary Design Report, Runway Extension, Gnoss Field, 2002. 3 Landrum & Brown, Gnoss Field Airport Runway Length Analysis, 2008, 2013, 2016, & 2017. 4 Advisory Circular 150/5325-4B, Runway Length Requirements for Airport Design, Federal Aviation Administration, July 1, 2005, errata July 31, 2008.

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As stated in AC 150/5300-13A Airport Design, Paragraph 105a, Applicability of Airport Design Standards:

“Airport designs that are based on large aircraft never likely to be served by the airport are not economical.”

The general approach to the selection of airport dimensional design standards is described in FAA Order 5090.3C Field Formulation of the National Plan of Integrated Airport Systems (NPIAS), Paragraph 3-4 Airport Dimensional Standards which states:

“Airport dimensional standards (such as runway length and width, separation standards, surface gradients, etc.) should be selected which are appropriate for the critical aircraft that will make substantial use of the airport in the planning period.” and “The critical aircraft may be a single aircraft or a composite of the most demanding characteristics of several aircraft. The critical aircraft is used to identify the appropriate Airport Reference Code for airport design criteria.”

In regard to the critical aircraft AC 150/5000-17, Critical Aircraft and Regular Use Determination states:

“The critical aircraft is the most demanding aircraft type, or grouping of aircraft with similar characteristics, that make regular use of the airport. Regular use is 500 annual operations, including both itinerant and local operations but excluding touch-and-go operations. An operation is either a takeoff or landing.”

As described in detail in Appendix A, the critical aircraft (also called the design aircraft, or critical design aircraft) for DVO is the family of B-II Turboprop aircraft, which is the most demanding aircraft grouping with regular use. The design concept followed in AC 150/5325-4B for determining the necessary runway length for the critical aircraft is to consider several physical characteristics of the critical aircraft including whether the Maximum Certificated Takeoff Weight is 12,500 pounds or less, the Approach Speed of the aircraft, and whether the aircraft carries less than 10 passengers, or 10 or more passengers. The appropriate chapter of AC 150/5325-4B is then followed to determine the appropriate runway length.

AC 150/5325-4B Runway Length Requirements for Airport Design provides guidelines for airport designers and planners to determine recommended runway lengths for new runways or extensions to existing runways. AC 150/5325-4B, Paragraph 101 states regarding runway length determinations that:

“In summary, the goal is to construct an available runway length for new runways or extensions to existing runways that is suitable for the forecasted critical design aircraft.”

AC 150/5325-4B, Paragraph 103 further states:

“The design objective for the main primary runway is to provide a runway length for all airplanes that will regularly use it without causing operational weight restrictions.”

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For airport projects receiving Federal funding, the use of the methods described in AC 150/5325-4B to determine runway length is mandatory. This Runway Length Analysis used the procedures in AC 150/5325-4B to verify the necessary runway length to meet the purpose and need of this project, which, consistent with AC 150/5325-4B, is: allow existing aircraft, as represented by the family grouping of critical aircraft at DVO, to operate without operational weight restrictions (i.e. at Maximum Gross Take Off Weight) under hot weather conditions (i.e., mean daily maximum temperature of the hottest month).5

AC 150/5325-4B Paragraph 201, Design Guidelines, identifies five specific variable factors that affect runway length that must be considered in determining the recommended runway length for an airport using the family grouping methodology. These are:

 Airplane Type  Approach Speed  Number of Passengers  Airport Elevation  Mean Daily Maximum Temperature of the Hottest Month

For aircraft with a Maximum Certificated Takeoff Weight (MTOW) of 12,500 pounds or less, such as the B-II family of turboprop aircraft at DVO, AC 150/5325-4B, Paragraph 202, Design Approach, provides a small airplane design concept for considering the five factors described above in order to determine a recommended runway length. Airport planners can use the appropriate “runway length curves” in AC 150/5325-4B for the weight and characteristics of a critical aircraft or a family grouping of critical aircraft under consideration to establish the necessary runway length. The current runway length determination for this project is based on the appropriate runway length curve for a family grouping of critical aircraft.

AC 150/5325-4B also allows the airport planner to consider the runway length requirements of a specific critical aircraft using that aircraft’s airplane flight manual if the aircraft’s requirements are not met using the runway length curves. Although that method was used to calculate the necessary runway length at Gnoss Field Airport based on the Cessna 525 aircraft airplane flight manual in the June 2014 Final EIS, that method is no longer applicable because the Cessna 525 business jet it was based on is not currently forecasted to have the minimum 500 annual operations at the airport necessary to be designated the critical aircraft for DVO (See Appendix A).

5 Hotter air is less dense than cooler air so that an aircraft wing creates less lift in hotter air. Therefore, other factors being equal, aircraft require a longer runway to attain sufficient speed to take off on a hot day, as compared to a cooler day.

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2.0 RUNWAY LENGTH ANALYSIS

AC 150/5325-4B Chapter 2, Runway Lengths for Small Airplanes with Maximum Certificated Takeoff Weight of 12,500 Pounds (5,670 Kg) or Less, describes procedures for calculating necessary runway lengths using a small airplane design concept. Paragraph 205 applies to Small Airplanes with Approach Speeds of 50 Knots or More with Maximum Certificated Takeoff Weight of 12,500 Pounds (5,670 Kg) or Less, which is the appropriate category for DVO. Paragraph 205 references two distinct runway length curves based on seating capacity and the mean daily maximum temperature of the hottest month of the year at the Airport. Using the most demanding aircraft category at DVO, it was determined the Small Airplane with Fewer than 10 Passenger Seats chart (i.e., Figure 2-1 of AC 150/5325-4B) also portrayed the most demanding runway length requirement. The following inputs were used to determine the recommended runway length requirement for DVO to meet the project purpose and need. The project purpose and need is to allow existing aircraft, as represented by the family grouping of critical aircraft at DVO, to operate without operational weight restrictions under hot weather conditions.

Input Data: Airport elevation: Sea Level Mean daily maximum temperature of the hottest month: 82° Fahrenheit6

Using Figure 2-1 from FAA AC 150/5325-4B, Small Airplanes with Fewer than 10 Passenger Seats, the inputs listed above analyzed along the curve (see Exhibit B- 1).

(1) Step 1 – Find the mean daily maximum temperature of the hottest month, 82° Fahrenheit (F). (2) Step 2 – Proceed vertically to the airport elevation, which for DVO is sea level (two feet). (3) Step 3 – Proceed horizontally to the runway length axis. (4) Step 4 – Read runway length. The runway length requirement derived from Figure 2-1, FAA AC 150/5325-4B, is 3,550 feet and rounded up to 3,600 feet per FAA guidance.

AC 150/5325-4B Paragraph 205 states:

“Figure 2-1 categorizes small airplanes with less than 10 passenger seats (excludes pilot and co-pilot) into two family groupings according to “percent of fleet,” namely, 95 and 100 percent of the fleet.”

6 United States Department of Commerce, National Oceanic & Atmospheric Administration, National Climatic Data Center (NCDC), Summary of Monthly Normal 1981-2010, Petaluma Airport, CA US. Webpage accessed on April 13, 2016, http://www.ncdc.noaa.gov/cdo-web/datatools/normals.

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Paragraph 205a goes on to state:

“The differences between the two percentage categories are based on the airport’s location and the amount of existing or planned aviation activities. The airport designer should make the selection based on the following criteria.”

Paragraph 205a (1) states:

“95 Percent of Fleet. This category applies to airports that are primarily intended to serve medium size population communities with a diversity of usage and a greater potential for increased aviation activities. Also included in this category are those airports that are primarily intended to serve low- activity locations, small population communities, and remote recreational areas. Their inclusion recognizes that these airports in many cases develop into airports with higher levels of aviation activities.”

Paragraph 205a (2) states:

“100 Percent of Fleet. This type of airport is primarily intended to serve communities located on the fringe of a metropolitan area or a relatively large population remote from a metropolitan area.”

DVO is located northeast of the City of Novato in Marin County. As Marin County is at the northern end of the San Francisco-Oakland-Hayward Metropolitan Statistical Area, the airport serves communities on the fringe of the metropolitan area.7 Therefore, the 100 Percent of Fleet category curve is appropriate to use in the analysis.

The runway length requirement derived from the 100 Percent of Fleet runway length curve in Figure 2-1 of AC 150/5325-4B and shown in Exhibit B-1 is 3,550 feet. FAA AC 150/5325-4B Appendix 3, Paragraph 1-3, Calculations, includes a provision for rounding calculated lengths of 30 feet and over up to the next 100-foot interval when using specific Aircraft Performance Manuals. Because the analysis using Figure 2-1 relies upon some visual interpretation, the same approach to round up to the next highest 100-foot runway length interval is applied to account for potential inaccuracies in the visual interpretation process. Thus, the runway length of 3,550 feet is rounded up to 3,600 feet to establish the runway length requirement.

7 U.S. Department of Commerce, Economics and Statistics Administration U.S. Census Bureau, 2012 Combined Statistical Area and Metropolitan/Micropolitan Statistical Areas boundaries and names as of February 2013. Map at https://www2.census.gov/geo/maps/metroarea/ stcbsa_pg/Feb2013/cbsa2013_CA.pdf Accessed October 13, 2017.

Landrum & Brown Runway Length Analysis February 2018 Page 5 GNOSS FIELD AIRPORT RUNWAY LENGTH ANALYSIS FINAL

EXHIBIT B-1 RUNWAY LENGTH DETERMINATION USING RUNWAY LENGTH CURVES PROCESS Gnoss Field Airport

Sources: Runway length for 100 percent of Fleet at Gnoss Field Airport based on FAA AC 150/5325-4B Runway Length Requirements for Airport Design, Figure 2-1; Landrum & Brown analysis.

Landrum & Brown Runway Length Analysis February 2018 Page 6 APPENDIX C

FAA RESPONSE TO COMMENTS

GNOSS FIELD AIRPORT

Prepared By: Landrum & Brown February 2018

GNOSS FIELD AIRPORT FAA RESPONSE TO COMMENTS FINAL

The FAA has received public comments in response to the June 2014 Final Environmental Impact Statement (EIS), the April 2016 Purpose and Need Working Paper, and the Public Meeting held on May 18, 2017. Comments were received from Federal and local agencies, organizations, and individuals. The FAA’s responses to those comments and the letters received are included in this appendix.

1.0 JUNE 2014 FINAL EIS

Public comments were received after the Final EIS was published in June 2014. Two separate comment letters were received regarding the document.

Responses to comment letters received are in Section 1.1, Responses to Comments Received on the Final EIS. Comment letters received are in Section 1.2, Comment Letters Received on the Final EIS.

1.1 RESPONSES TO COMMENTS RECEIVED ON THE JUNE 2014 FINAL EIS

The comments are organized by seven specific topics used to categorize the public comments. These categories are:

Comment Topic Description 1 Don’t agree with FAA finding 2 Noise 3 Need 4 Floodplains 5 Wetlands 6 Land Use 7 Alternatives

For example, Comment 1.1 was “FAA guidelines used in calculating an appropriate runway length were used/applied incorrectly.” This issue was commented on by Steven J. Nebb. This comment is identified as Comment 1.1, and the response to this comment is shown in Table 1, in numerical order at Comment 1.1.

Readers interested in all responses to public comments on the Final EIS can review Section 1.1, Responses to Comments Received on the Final EIS in its entirety. Readers only interested in responses to specific comment letters or statements can use the listing below to review the Section 1.1, Responses to Comments Received on the Final EIS for responses to all comments received from specific commenter in the order they were made in the commenter’s letter.

Landrum & Brown . FAA Response to Comments February 2018 Page 2 GNOSS FIELD AIRPORT FAA RESPONSE TO COMMENTS FINAL

NAME ORGANIZATION (IF ANY) DATE COMMENT NUMBERS Kathleen Martyn Goforth USEPA 8/4/2014 3.1, 7.1, 5.1, 4.1, 1.2, 2.1/2.2, 6.1 Steven J. Nebb Nebb 8/1/2014 1.1, 6.2

Landrum & Brown FAA Response to Comments February 2018 Page 3 GNOSS FIELD AIRPORT FAA RESPONSE TO COMMENTS FINAL

Table 1 RESPONSE TO COMMENTS RECEIVED ON THE FINAL EIS Gnoss Field Airport

To ensure there is no misunderstanding by the reader, the general comment numbers by topic are shown consecutively on the left column of this table.

Table begins on next page

Landrum & Brown FAA Response to Comments February 2018 Page 4 GNOSS FIELD AIRPORT FAA RESPONSE TO COMMENTS FINAL

COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 1 Don't agree with FAA finding

FAA guidelines used in The FAA prepared a Purpose and Need Working calculating an Paper to update the information regarding the 1.1 appropriate runway Steven J. Nebb forecasted number of operations, identification of length were used/applied the critical aircraft, and the runway length incorrectly determination.

The stated need for the project was to accommodate existing aircraft. Demand for use Determination of critical of an airport is determined more about the local 1.2 aircraft (more runway = USEPA economy than the length of the runway. more larger aircraft) Therefore, the assertion of more runway = more larger aircraft is not accurate.

2 Noise

Post-project noise monitoring and 2.1 USEPA Comment noted. evaluation should continue

Include stipulation that if noise levels rise above Comment noted. The forthcoming Supplemental the 65 A-weighted EIS will include an updated noise analysis for all decibel (dBA) alternatives evaluated in detail using the current significance level, the FAA methodologies and thresholds for 2.2 USEPA Airport's voluntary noise determining impacts, following FAA Orders 1050.F abatement program and 5050.4B. Any significant noise impacts and measures would be the need for mitigation/monitoring programs will made requirements for be addressed in that process. runway use.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 3 Need

The purpose and need for the project is to allow Project only benefits existing aircraft, as represented by the family small percentage of grouping of critical aircraft at DVO, to operate 3.1 USEPA operators under rare without operational weight restrictions under hot conditions weather conditions. This is consistent with FAA guidelines for design of airport facilities.

4 Floodplains

Impact to the existing system of ditches and levees that help protect 4.1 USEPA Comment noted. the Airport from flooding should be evaluated and upgraded, as needed

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 5 Wetlands

Conceptual mitigation in the Final EIS was coordinated with the appropriate agencies and complied with all local, state, and Federal The Conceptual requirements, including the Clean Water Act, Mitigation options Endangered Species Act, and the National Historic included in the Final EIS Preservation Act. If additional mitigation options 5.1 USEPA are too narrow; the are identified in the Supplement to the Final EIS, project should include a they will be added to that document. Final full mitigation project mitigation measures associated with a Clean Water Act, Section 404 permit will be prepared when Marin County chooses to complete the Clean Water Act permitting process for the project.

6 Land Use

Section 5.9 of the Final EIS discusses the Redwood Landfill (RLI), FAA guidance on bird strikes, and the measures in place to reduce the potential for bird strikes. The Redwood Landfill (RLI) currently operates under a permit from Discuss/resolve the Marin County Environmental Health Services, inconsistency of the which was designated by the California Integrated 6.1 proposed action with FAA USEPA Waste Management Board as the solid waste Local bird-strike hazard Enforcement Agency. This permit includes mitigation guidance responsibilities of the landfill that include measures to reduce bird attractants. There have been no reported incidents of bird strikes associated with the RLI. This issue will be discussed in more detail in the Supplement to the Final EIS.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE The commenter suggests that DVO is incompatible with its surrounding environmental features, including wetlands. The Final EIS disclosed impacts to the surrounding environmental resources and developed a conceptual mitigation program to offset those impacts. The commenter also suggests that DVO is incompatible with surrounding land uses. The existing zoning and land use of the properties DVO is incompatible with adjacent to or in the vicinity of Gnoss Field Airport 6.2 its surrounding Steven J. Nebb are compatible with normal airport operations, as environment/land uses described in the Final EIS Section 5.2 - Compatible Land Use on page 5-17. Furthermore, a land assurance letter provided by the Marin County Community Development Agency states that the existing zoning will be maintained to ensure that land adjacent to or in the vicinity of Gnoss Field Airport in Marin County is compatible with normal airport operations. Therefore, DVO is compatible with surrounding land uses are and will continue to be compatible with normal airport operations.

7 Alternatives

Based on this and other comments, the FAA prepared a Purpose and Need Working Paper to update critical information and give the public and agencies an additional opportunity to comment. Recommend evaluating During this updating process, the FAA determined 7.1 shorter runway extension USEPA that the critical aircraft for Gnoss Field Airport had alternative changed to a less demanding aircraft that does not require an 1,100 foot runway extension to meet the purpose and need for the project. As a result, the Supplement to the Final EIS that will be prepared after the comment period on the Updated Purpose and Need Working Paper is

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE completed will include an additional runway extension alternative that is less than the 1,100- foot runway extension alternative.

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1.2 COMMENT LETTERS RECEIVED ON THE JUNE 2014 FINAL EIS

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2.0 APRIL 2016 PURPOSE AND NEED WORKING PAPER

Public comments were received on the April 2016 Purpose and Need Working Paper A total of 68 separate comment letters were received during the public comment period from May 2, 2016 to June 17, 2016. The total number of commenters was more than 68 as one written comment letter was signed by several commenters.

Responses to comment letters received are in Section 2.1, Responses to Comments Received on the Purpose & Need Working Paper. Comment letters received are in Section 2.2, Comment Letters Received on the Purpose & Need Working Paper.

2.1 RESPONSES TO COMMENTS RECEIVED ON THE PURPOSE & NEED WORKING PAPER

The comments are organized by the eight specific topics used to categorize the public comments. These categories are:

Comment Topic Description 1 Don’t agree with FAA finding 2 Support of Reduction in the Runway Extension 3 Noise 4 Need 5 General 6 Floodplains 7 Wetlands 8 Land Use

For example, Comment 1.1 was “Radar data is not accurate/complete.” This issue was commented on by several individuals, including Aviation Consulting Services Ltd., Richard Beach, Daniel R. Bedford, Mark Dawson, Eric Ganas, Fritz Glasser, Peter Gruhl, Stephen Knecht, Ted Newman, Mark Robertson, Charles E. Roell Jr., Cory Birnberg, and Malcom W. Ruthven. In every letter this comment is identified as Comment 1.1, and the response to this comment is shown in Table 2, in numerical order at Comment 1.1.

Readers interested in all responses to public comments can review Section 2.1, Responses to Comments Received on the Purpose & Need Working Paper in its entirety. Readers only interested in responses to specific comment letters or statements can use the listing below to review the Section 2.1, Responses to Comments Received on the Purpose & Need Working Paper for responses to all comments received from specific commenter in the order they were made in the commenter’s letter.

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NAME ORGANIZATION (IF ANY) DATE COMMENT NUMBERS Gregory M. Applegarth Applegarth 6/10/2016 1.4, 1.6, 1.4 Bradford Archer Archer 6/12/2016 1.2, 1.4, 1.6

Mark Feldman Aviation Consulting Services Ltd. 6/15/2016 1.2, 1.4, 1.6, 1.1, 1.6 Wright S. Bass Bass 6/16/2016 1.5, 1.4 Jack Bazler Bazler 6/14/2016 1.6, 4.1 1.2, 1.1, 1.2, 1.3. 1.6, Richard Beach Beach 6/19/2016 1.5, 1.6, 3.1, 3.2, 1.4 Phil Beaubois Beaubois 5/30/2016 1.4, 1.6, 1.4 Daniel R. Bedford Bedford 6/5/2016 1.2, 1.1, 1.3 Black Point Environmental Action Rosalie Webb Committee 5/27/2016 2.2 Tim Blofeld Blofeld 6/15/2016 1.4, 3.1 Cory Birnberg Birnberg 6/17/2016 1.6, 1.1 James Cavenaugh Cavenaugh 6/16/2016 1.4, 3.1, 4.1 Robert Comyn Comyn 6/16/2016 1.4, 1.6, 1.4 Tennis Wick County of Sonoma 5/26/2016 2.4 Daniel Crespo-Dubie Crespo-Dubie 6/16/2016 3.1 Carolyn Walker Davis Davis 6/17/2016 1.6/1.3, 4.2, 1.4, 3.1 Mark Dawson Dawson 5/30/2016 1.1, 1.6

TJ Neff DVO Fuel & TJ Aircraft Sales 6/11/2016 3.1, 1.3 Stewart Emery Emery 6/16/2016 1.6, 4.1, 1.6/1.3, 4.2 Federal Emergency Management Gregor Blackburn Agency 5/3/2016 6.1, 6.2, 6.3, 6.4, 6.5 Richard Gaines Gaines 6/7/2016 1.4, 1.6, 1.4 1.6, 1.6, 1.1, 1.6, 4.2, Eric Ganas Ganas 6/14/2016 1.3 Fritz Glasser Glasser 6/16/2016 1.6, 1.1, 1.6, 4.2

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NAME ORGANIZATION (IF ANY) DATE COMMENT NUMBERS Peter Gruhl Gruhl (1) 6/11/2016 1.1 Peter Gruhl Gruhl (2) 6/14/2016 1.6 Dennis M. Hart Hart 6/15/2016 1.4 Robert Hohman Hohman 6/16/2016 3.1, 1.6, 1.6, 1.4, 3.1 Alwyn Hughes A. Hughes 6/14/2016 1.2, 1.3 Ken Hughes K. Hughes 6/16/2016 1.4, 1.4, 3.1. 4.1 Stephen Isaacs Isaacs 6/9/2016 1.4 Glen Janssens Janssens 6/14/2016 1.4, 4.1 Kevin Jenkins Jenkins 6/14/2016 1.4, 1.6 Kenneth Klein Klein 6/7/2016 3.1, 3.1 1.6, 1.1, 1.6, 4.2, 3.1, Stephen Knecht Knecht 6/15/2016 1.4

Law Offices of David W. Trotter (on 2.4, 8.1, 3.3, 8.1, 8.1, David W. Trotter behalf of Lorraine F. Silveira) 6/16/2016 8.1 2.1/2.3, 5.1, 7.1, 7.2, Barbara Salzman Marin Audubon Society 6/14/2016 7.3, 7.4, 5.5, 5.6, 5.2 Susan Ristow Marin Baylands Advocates 6/13/2016 2.1 Kate Powers Marin Conservation League 6/9/2016 2.4, 7.5, 5.1 Luis Martinez L. Martinez 6/14/2016 1.6, 1.6, 1.4, 3.1 Vicki Martinez V. Martinez 6/11/2016 4.3 David McConnell D. McConnell 6/4/2016 1.4, 1.6, 1.4 Marilyn A. McConnell M. McConnell 6/5/2016 1.4, 3.1 Ken A. Mercer Mercer 6/7/2016 1.6,1.6/1.3,4.2,4.2 5.4,5.4,5.4,1.6,4.2, 1.1, 1.6, 1.2, 1.3, 1.6, 1.4, Ted Newman Newman 6/14/2016 4.1 John P. O'Connell O'Connell 6/8/2016 1.2/1.3, 4.2, 3.1 Cindy Pickett Pickett 6/15/2016 1.4, 3.1, 4.3, 4.1, 5.3

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NAME ORGANIZATION (IF ANY) DATE COMMENT NUMBERS David W. Rising Rising 6/17/2016 1.6, 1.4, 1.4, 1.6, 4.3 Mark Robertson Robertson 6/14/2016 1.2, 1.1, 1.4 Charles E. Roell Jr. Roell Jr. N/A 1.6, 1.1 Susan Royce Royce 6/13/2016 1.4, 1.4, 5.2 Malcom W. Ruthven Ruthven 6/7/2016 1.6, 1.1, 1.6, 4.2 Marc Salvisberg Salvisberg 6/14/2016 1.2 David Sargent Sargent 6/15/2016 4.2 Patrick H. Scanlon Scanlon Aviation 6/16/2016 1.3 Don Scott Scott 6/17/2016 1.6, 4.2 Mark Sheron Sheron 6/16/2016 1.4 Helmut G. Sommer Sommer 6/12/2016 1.4, 3.1 Ann Thomas Thomas 6/6/2016 2.1 Brian K. Walker B. Walker N/A 1.4, 1.6, 1.4 Sandra Walker S. Walker N/A 1.4, 1.6, 1.4 Tim Walter Walter 6/5/2016 1.4, 1.6, 1.4 Ralph Webb Webb 6/14/2016 2.3 Joyce Wells Wells 6/4/2016 1.4, 1.6, 1.4 Dave Hewitt Wheels Up 6/14/2016 2.3, 5.2 James R. Whittington Whittington 6/9/2016 1.4, 1.6, 1.4 Frank Woolard Woolard 6/16/2016 1.3, 1.2, 1.6, 1.4, 3.1 Margaret Zechlin Zechlin 6/23/2016 1.4, 3.1

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NAME ORGANIZATION (IF ANY) DATE COMMENT NUMBERS

Christopher Gilkerson, Steve and Sharon Nebb, Richard and Susan Markx, Duncan & Betsoy Ross, Jean Harris, Michael Morris, John & Elizabeth Mason, Jory Bergman, Amy Allerheiligen, Kevin Gilkerson/Nebb/Markx/Ross/Harris/ Lara, Todd Stevenson, Morris/Mason/Bergman/Allerheiligen/ Christopher & Kimberly Lara/Stevenson/Stephens/Shaw/ 6/17/2016 2.2, 5.1, 2.3 Stephens, Robert & Parnes/Maionchi/Calcaterra/Luis/ Georgina Shaw, Michael & Cioffi/Gahan/Donadio/Bonner/McMann Susan Parnes, Donna Maionchi, Richard & Wendy Calcaterra, Dan & Dana Luis, Frank M. Cioffi, Eric & Heather Gahan, David & Kristine Donadio, Jacqueline Bonner, Terry & Katie McMann

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Table 2 RESPONSE TO COMMENTS RECEIVED ON THE APRIL 2016 PURPOSE & NEED WORKING PAPER Gnoss Field Airport

To ensure there is no misunderstanding by the reader, the general comment numbers by topic are shown consecutively on the left column of this table.

Table begins on next page

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 1 Don't agree with FAA finding Aviation Consulting Services Ltd., Richard Beach, Daniel R. Based on this and other comments, additional Bedford, Mark Dawson, radar data was collected and interviews with Eric Ganas, Fritz Glasser, Radar data is not pilots/owners and the fixed-based operator 1.1 Peter Gruhl, Stephen accurate/complete were conducted to supplement and validate Knecht, Ted Newman, the radar data. The Updated Purpose & Need Mark Robertson, Charles Working Paper was revised, accordingly. E. Roell Jr., Cory Birnberg, Malcom W. Ruthven

Aviation Consulting Services Ltd., Bradford Based on this and other comments, additional Archer, Richard Beach, radar data was collected and interviews with Daniel R. Bedford, Alwyn Need to interview pilots/owners and the fixed-based operator 1.2 Hughes, Ted Newman, pilots were conducted to supplement and validate John P. O'Connell, Mark the radar data. The revised Purpose & Need Robertson, Marc Working Paper was revised, accordingly. Salvisberg, Frank Woolard

Need to interview Based on this and other comments, additional fixed-base operators DVO Fuel & TJ Aircraft radar data was collected and interviews with and fuel vendors Sales, Scanlon Aviation, pilots/owners of the most demanding aircraft because the pilots’ Richard Beach, Daniel R. using Gnoss Field Airport, and the fixed- 1.3 actual operations Bedford, Carolyn Walker based operator fuel vendor, were conducted counts, and fuel sales Davis, Stewart Emery, to supplement and validate the radar data. information, may show Eric Ganas, Alwyn The Updated Purpose & Need Working Paper additional aircraft Hughes, Ken A. Mercer, was revised, accordingly. operations not

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE accounted for by other Ted Newman, John P. data, such as the O'Connell, Frank Woolard radar information.

As discussed throughout the Updated Aviation Consulting Purpose and Need Working Paper, the airport Services Ltd., Gregory M. sponsor’s purpose and need for the proposed Applegarth, Bradford project as identified by Marin County is to Archer, Brian K. Walker, allow existing aircraft, as represented by the Wright S. Bass, Richard family grouping of critical aircraft at DVO, to Beach, Phil Beaubois, operate without operational weight Tim Blofeld, James restrictions under hot weather conditions. As Cavenaugh, Robert discussed in Appendix B of the Updated Comyn, Carolyn Walker Purpose and Need Working Paper, this is Davis, Richard Gaines, consistent with the general approach to the Dennis M. Hart, Robert 300' extension would selection of airport dimensional design Hohman, Ken Hughes, not improve the standards as described in FAA Order 5090.3C Stephen Isaacs, Glen existing safety Field Formulation of the National Plan of 1.4 Janssens, Kevin Jenkins, deficiencies/operationa Integrated Airport Systems (NPIAS), Stephen Knecht, Luis l use at DVO for all Paragraph 3-4 Airport Dimensional Standards Martinez, David aircraft which states: McConnell, Marilyn A. McConnell, Cindy Pickett, “Airport dimensional standards (such as David W. Rising, Mark runway length and width, separation Robertson, Susan Royce, standards, surface gradients, etc.) should be Sandra Walker, Mark selected which are appropriate for the critical Sheron, Helmut G. aircraft that will make substantial use of the Sommer, Tim Walter, airport in the planning period.” Joyce Wells, James R. and Whittington, Frank Woolard, Margaret “The critical aircraft may be a single aircraft Zechlin or a composite of the most demanding characteristics of several aircraft. The critical

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE aircraft is used to identify the appropriate Airport Reference Code for airport design criteria.” Appendix B also provides further discussion of the FAA’s guidance on airport design from FAA A/C 150/5300-13A Airport Design, which states: “The first consideration of the airport planner should be the safe operation of aircraft likely to use the airport… However, it is not the usual practice to base the airport design on an aircraft that uses the airport infrequently…” and, “Airport designs that are based on large aircraft never likely to be served by the airport are not economical.” As described in Appendix B, FAA guidance specific to runway length determinations in FAA A/C 150/5325-4B Runway Length Requirements which states: “In summary, the goal is to construct an available runway length for new runways or extensions to existing runways that is suitable for the forecasted critical design aircraft.” and, “The design objective for the main primary runway is to provide a runway length for all airplanes that will regularly use it without causing operational weight restrictions.”

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE The need for 300 feet of additional runway length is based on FAA guidance designed to provide for the safe and efficient operation of the critical aircraft under prescribed conditions. Further, pilots have responsibilities under 14 CFR Part 91 to conduct safe operations within the available runway length.

FAA guidelines used in As described and explained in the Updated calculating an Purpose and Need Working Paper, the runway appropriate runway Wright S. Bass, Richard length calculation follows the methodology 1.5 length were Beach identified in the FAA Advisory Circular used/applied 150/5325-4B Runway Length Requirements incorrectly for Airport Design.

Aviation Consulting Services Ltd., Gregory M. Determination of Applegarth, Bradford Based on this and other comments, additional critical aircraft Archer, Brian K. Walker, radar data was collected and interviews with (forecast calculations Richard Beach, Phil pilots/owners and the fixed-based operator and assumptions are Beaubois, Jack Bazler, fuel vendor were conducted to supplement 1.6 flawed; more runway Robert Comyn, Carolyn and validate the radar data and confirm the = more/larger aircraft; Walker Davis, Mark critical aircraft for Gnoss Field Airport. The revert back to Cessna Dawson, Stewart Emery, Updated Purpose & Need Working Paper was as the critical aircraft) Richard Gaines, Eric revised, accordingly. Ganas, Fritz Glasser, Peter Gruhl, Robert Hohman, Kevin Jenkins,

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE Stephen Knecht, Luis Martinez, David McConnell, Ken A. Mercer, Ted Newman, David W. Rising, Charles E. Roell Jr., Cory Birnberg, Malcom W. Ruthven, Sandra Walker, Don Scott, Tim Walter, Joyce Wells, James R. Whittington, Frank Woolard 2 Support of Reduction in the Runway Extension Comment noted. The Supplemental EIS will Marin Audubon Society, Less environmental disclose the environmental impacts of the 2.1 Marin Baylands impact 300-foot Runway Length Extension Advocates, Ann Thomas Alternative.

Black Point Environmental Action Committee, Christopher Gilkerson, Steve and Shorter runway would Sharon Nebb, Richard Comment noted. The Supplemental EIS will reduce noise in and Susan Markx, disclose the environmental impacts of an 2.2 neighborhoods south Duncan & Betsoy Ross, additional Runway Length Extension of the airport Jean Harris, Michael Alternative of less than 1,100 feet. Morris, John & Elizabeth Mason, Jory Bergman, Amy Allerheiligen, Kevin Lara, Todd Stevenson, Christopher & Kimberly

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE Stephens, Robert & Georgina Shaw, Michael & Susan Parnes, Donna Maionchi, Richard & Wendy Calcaterra, Dan & Dana Luis, Frank M. Cioffi, Eric & Heather Gahan, David & Kristine Donadio, Jacqueline Bonner, Terry & Katie McMann

Wheels Up, Marin Audubon Society, Ralph Webb, Christopher Gilkerson, Steve and Sharon Nebb, Richard and Susan Markx, Duncan & Betsoy Ross, Jean Harris, Michael Morris, John & Elizabeth Increased 2.3 Mason, Jory Bergman, Comment noted. Safety/Operational Use Amy Allerheiligen, Kevin Lara, Todd Stevenson, Christopher & Kimberly Stephens, Robert & Georgina Shaw, Michael & Susan Parnes, Donna Maionchi, Richard & Wendy Calcaterra, Dan & Dana Luis, Frank M. Cioffi, Eric & Heather

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE Gahan, David & Kristine Donadio, Jacqueline Bonner, Terry & Katie McMann

County of Sonoma, Law Offices of David W. Stated general support Trotter (on behalf of 2.4 of reduction in the Comment noted. Lorraine F. Silveira), runway extension Marin Conservation League 3 Noise DVO Fuel & TJ Aircraft Sales, Richard Beach, Tim Blofeld, James Cavenaugh, Daniel Crespo-Dubie, Carolyn The forthcoming Supplement to the Final EIS Shorter 300' extension Walker Davis, Robert will include an updated noise analysis for all will provide little noise Hohman, Ken Hughes, alternatives evaluated in detail using the 3.1 benefits compared to Kenneth Klein, Stephen current FAA methodologies and thresholds for the 1,100' extension Knecht, Luis Martinez, determining noise impacts, following FAA Marilyn A. McConnell, Orders 1050.1F and 5050.4B. John P. O'Connell, Cindy Pickett, Helmut G. Sommer, Frank Woolard, Margaret Zechlin

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE The forthcoming Supplemental EIS will include an updated noise analysis using Noise exposure maps current FAA methodologies and thresholds for for the Rush Creek determining noise impacts, including FAA 3.2 Richard Beach neighborhood should Orders 1050.F and 5050.4B. Noise exposure be included contours will be developed and included in the Supplemental EIS according to FAA requirements.

The property in question is currently subject to aircraft overflights from operations at DVO, which will continue with or without the proposed runway extension. The mode of operation where aircraft would be closer to the Silveira's farm would be aircraft arrivals from the north on Runway 13. In this case, What are the impacts Law Offices of David W. however, aircraft are much quieter than when 3.3 to livestock (breaking Trotter (on behalf of departing. The forthcoming Supplemental EIS fence) Lorraine F. Silveira) will include an updated noise analysis using current FAA methodologies and thresholds for determining noise impacts, following FAA Orders 1050.F and 5050.4B. Noise exposure contours will be developed and included in the Supplemental EIS according to FAA requirements.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 4 Need The Sponsor’s purpose and need for the project is to allow existing aircraft, as represented by the family grouping of critical aircraft at DVO, to operate without Need should be Jack Bazler, James operational weight restrictions under hot focused on people who Cavenaugh, Stewart weather conditions. The runway length 4.1 charter for business or Emery, Ken Hughes, determination is based on an evaluation of pleasure and their Glen Janssens, Ted the needs of the critical aircraft, not an future needs Newman, Cindy Pickett evaluation of a group of users that visit the airport for a particular activity. This is consistent with identifying a purpose and need for the proposed project that is consistent with FAA guidance.

The commenter suggests that the critical aircraft from a six- to ten-year period rather Carolyn Walker Davis, than a five-year period should be used. Stewart Emery, Eric However, the methods used to determine the Aviation forecast Ganas, Fritz Glasser, critical aircraft are in accordance with the should look at long- Stephen Knecht, Ken A. FAA's AC 150/5000-17 and 150/5325-4B. 4.2 term period rather Mercer, Ted Newman, Further, the Sponsor’s purpose and need for than 5-year period John P. O'Connell, the project is to allow existing aircraft (not Malcom W. Ruthven, future), as represented by the family David Sargent, Don Scott grouping of critical aircraft at DVO, to operate without operational weight restrictions under hot weather conditions.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE The Sponsor’s purpose and need for the project is to allow existing aircraft, as Runway length should represented by the family grouping of critical accommodate the aircraft at DVO, to operate without variety of aircraft operational weight restrictions under hot needed for public weather conditions. According to Marin Vicki Martinez, Cindy 4.3 services (police, fire, County, existing aircraft includes those used Pickett, David W. Rising search and rescue) for medical, law enforcement, fire-fighting and those needed in support, and Civil Air Patrol flights1. The the event of a natural forthcoming Supplemental EIS will further disaster evaluate the impact on access of emergency vehicles to the Airport or surrounding areas, including hospitals in the area.

1 Airport Uses, Marin County Airport at Gnoss Field, Marin County Public Works. On-line at: https://www.marincounty.org/depts/pw/divisions/ transportation/airport Retrieved on October 9, 2017.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 5 General Marin Audubon Society, Marin Conservation League, Christopher Gilkerson, Steve and Sharon Nebb, Richard and Susan Markx, Duncan & Betsoy Ross, Jean Harris, Michael Morris, John & Elizabeth The Updated Purpose and Need Working Mason, Jory Bergman, Paper includes a description of the Sponsor’s Describe the Sponsor’s Amy Allerheiligen, Kevin Proposed Project, and a 300-foot Runway Proposed Project Lara, Todd Stevenson, 5.1 Extension Alternative, that are in accordance better—dimensions Christopher & Kimberly with FAA guidelines for the preparation of an and rationale Stephens, Robert & EIS. Each alternative evaluated in detail in Georgina Shaw, Michael the Supplemental EIS will be fully described. & Susan Parnes, Donna Maionchi, Richard & Wendy Calcaterra, Dan & Dana Luis, Frank M. Cioffi, Eric & Heather Gahan, David & Kristine Donadio, Jacqueline Bonner, Terry & Katie McMann

Quality of the existing Marin County undertook a runway runway surface should Wheels Up, Marin rehabilitation project starting in September 5.2 be reviewed and Audubon Society, Susan 2017 and completed in December 2017, to necessary repairs must Royce rehabilitate the existing runway. be made

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE Longer runway will 5.3 alleviate highway Cindy Pickett Comment noted. transportation issues

This comment suggests the inclusion of three airports in the Overview of San Francisco Bay Area's General Aviation Airports in the Aviation Activity Forecast: Healdsburg Municipal Airport (HES), San Carlos Airport (SQL), and Metropolitan Oakland International Airport (OAK). The Purpose and Need working paper has been revised to Suggested language to include HES and SQL in the Aviation Activity Appendix A, Section 5.4 Ted Newman Forecast. However, OAK was not included 5.0 - Overview of SF because OAK prohibits the full range of Bay Area's GA Airports general aviation flight activities that designated general aviation airports allow, such as flight training activities.

This comment also suggests the update of language regarding Petaluma Municipal Airport which was incorporated into the Updated Purpose and Need Working Paper.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE Community members took issue with the Aviation Activity Forecast, citing inaccurate airport activity data. Community members also took issue with the critical aircraft determination and Runway Length Analysis, citing faults in the forecast. The FAA has Discuss issues raised considered these comments and prepared an by pilots and possible Updated Purpose and Need Working Paper. 5.5 inaccuracies in the Marin Audubon Society As part of the update, interviews were appendices related to conducted with pilots and FBO/fuel vendors their concerns. and additional radar data was collected to ensure the latest correct information was being used in the aviation activity forecast. Additionally, the critical aircraft determination and Runway Length Analysis were updated to reflect the updated forecast.

Community members took issue with the Aviation Activity Forecast, claiming it used inaccurate airport activity data. The FAA has Discuss the contention considered these comments and prepared an that the current and Updated Purpose and Need Working Paper. 5.6 Marin Audubon Society projected use is an As part of the update, interviews were underestimate. conducted with pilots and FBO/fuel vendors and additional radar data was collected to ensure the latest correct information was being used in the aviation activity forecast.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE This comment argues that the Cessna 182 Skylane and the Cirrus SR22 were miscategorized as B-1 aircraft and should be listed as A-1 aircraft. The Cessna 182 Skylane Suggested corrections was correctly identified as a B-1 aircraft and to Appendix A, Section can be confirmed in the FAA's Advisory 5.7 Ted Newman 6.0 - DVO Historical Circular 150/5300 13A Change 1, Table A1- Trends 1. The Cirrus SR22 was miscategorized as a B-1 aircraft instead of an A-1 aircraft in the Aviation Activity Forecast text; the Updated Purpose and Need Working Paper has corrected this miscategorization. 6 Floodplains

There are no buildings being proposed, Building elevation Federal Emergency therefore the finished-floor elevation 6.1 requirements Management Agency requirements do not apply to the Sponsor’s Proposed Project or alternatives.

If the area of construction is located within a Regulatory The area of construction being proposed is Floodway as not located within a Regulatory Floodway; Federal Emergency 6.2 delineated on the therefore, base flood elevation level Management Agency FIRM, any requirements do not apply to the Sponsor’s development must not Proposed Project or alternatives. increase base flood elevation levels.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE

There are no buildings being proposed, Building foundation Federal Emergency therefore the requirements associated with 6.3 requirements Management Agency coastal high hazard areas do not apply to the Sponsor’s Proposed Project or alternatives.

Upon completion of any development that changes existing As Marin County is a participant in the Special Flood Hazard National Flood Insurance Program, the Areas, the National County would be responsible for submitting Flood Insurance appropriate hydrologic and hydraulic data to Program directs all Federal Emergency 6.4 FEMA for updating of Flood Insurance Rate participating Management Agency Maps if implementation of the airport project communities to submit resulted in any development that changes the the appropriate extent of existing Flood Insurance Rate Map hydrologic and Special Flood Hazard Areas. hydraulic data to FEMA for a Flood Insurance Rate Map revision.

The Sponsor’s Proposed Project will be updated and further evaluated in the Local building Federal Emergency 6.5 Supplement to the Final EIS to in relation to restrictions may apply Management Agency the Marin County flood zone development regulations. 7 Wetlands Include figure/text to disclose wetland loss The location of water resources and wetlands 7.1 Marin Audubon Society under the Sponsor’s and extent of environmental impacts on these Proposed Project resources will be evaluated for each

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE alternative evaluated in detail in the Supplemental EIS.

Include figure/table to compare the wetland The location of water resources and wetlands loss under the and extent of environmental impacts on these 7.2 Sponsor’s Proposed Marin Audubon Society resources will be evaluated for each Project to that under alternative evaluated in detail in the the previous preferred Supplemental EIS. project

Discuss the proposed Wetland mitigation for wetland impacts will 7.3 mitigation for the loss Marin Audubon Society be addressed in the Supplemental EIS. of wetlands

Discuss the proposed Possible mitigation sites will be addressed in 7.4 Marin Audubon Society mitigation sites the Supplemental EIS.

The compensatory mitigation ratio for environmental impact evaluation will be On-site mitigation identified in the Supplemental EIS. The final should be at a 2:1 Marin Conservation 7.5 mitigation requirements for wetlands and replacement ratio and League waters in the CWA jurisdiction will be off-site at 3:1 established during the CWA Section 404 permit process.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE 8 Land Use The property referenced by the commenter lies between the SMART railroad track and Highway 101, northwest of DVO property. These parcels are not within the Direct Study Area and therefore will not be physically impacted by the project. Additionally, the parcels were not within the 65 CNEL contour shown in Exhibit 5.1-2 of the Final EIS. An updated noise impact analysis will be provided in the Supplement to the Final EIS Specific zoning not for all alternatives considered in detail in the correct and not Supplemental EIS. included in analyzing Law Offices of David W. impacts in the future The parcels in question are zoned “A2 – 8.1 Trotter (on behalf of (land use Agricultural, Limited” according to Marin Lorraine F. Silveira) incompatibilities may County Zoning and Property Information2. warrant a regulatory These parcels are largely contained within the "taking") Baylands Corridor as defined in the Marin Countywide Plan adopted in 2007. Within this corridor, Marin County severely limits development, giving preference to wetland and wildlife habitats (see Policy BIO-5 in Marin Countywide Plan). There are small portions of these parcels that are located outside the Baylands Corridor, but within the Inland-Rural Corridor which is less restrictive. The zoning and land use of the parcels in question is compatible with airport activities.

2 Zoning and Property Information, Marin County, 2017. On-line at: https://www.marincounty.org/depts/cd/divisions/planning/zoning-and- general-plan-lookup Retrieved October 10, 2017.

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COMMENT # COMMENT/SUBJECT COMMENTER RESPONSE Unless other definitive information and sources are provided that indicate otherwise, this is the latest correct information that can be used in this EIS. The commenter additionally takes issue with the land assurance letter from the Marin County Community Development Agency stating that "the County of Marin provides assurance that appropriate action and enforcement of zoning laws has been or will be taken, to the extent reasonable, to restrict the use of land adjacent to or in the vicinity of Gnoss Field Airport to activities and purposes compatible with normal airport operations." This letter does not indicate that Marin County will purchase these parcels. The land assurance letter states that the existing zoning will be maintained to ensure that land adjacent to or in the vicinity of Gnoss Field Airport in Marin County is compatible with normal airport operations.

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2.2 COMMENT LETTERS RECEIVED ON THE APRIL 2016 PURPOSE & NEED WORKING PAPER

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3.0 PUBLIC MEETING HELD MAY 18, 2017

A public meeting was held on May 18, 2017 to update the public on the status of the environmental evaluations, provide information about the FAA data collection effort regarding aviation activity and the “critical aircraft” at the airport, and provide opportunity for public to ask questions regarding the presentation and data collection effort. The FAA did not circulate a document of any sort prior to the public meeting as the purpose was to provide an update on the data collection process. As such, there was not a formal comment period or request for public comments.

Nevertheless, three separate comment letters were received after the public meeting. All three letters were from commenters who previously commented on the Final EIS. Because these comments were not received as part of a formal comment period they are included for disclosure purposes only. Therefore, no formal response to comments is included for these comments.

However, the FAA appreciates the commenters providing the information and has incorporated the suggestions, as appropriate, in the preparation of the Updated Purpose and Need Working Paper.

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3.1 COMMENTS RECEIVED ON THE PUBLIC MEETING HELD MAY 18, 2017

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