Agenda Item 1 ~ June 20, 2012 FileNo. Z’iO~’1O

AGENDA BILL

Subject: Town Council Direction on the Submission of the Revised Mammoth Yosemite Airport Layout Plan Update Narrative (ALPUN) to the Federal Aviation Administration for Review and Comment

Initiated by: Jen Daugherty, Associate Planner Ray Jarvis, Public Works Director Mark Wardlaw, Community Development Director

BACKGROUND The purpose of this agenda item is for the Town Council to consider the recommendations from the Airport and Planning Commissions and provide direction to staff regarding the formal submission of the Airport Layout Plan Update Narrative (ALPUN) to the Federal Aviation Administration (FAA) for review and comment.

Since the reintroduction of air service in 2008, the Town of Mammoth Lakes in partnership with Mammoth Mountain Ski Area (MMSA) and the FAA have made significant progress in securing air service contracts; completing required planning, design, and environmental analyses; and in capital facility improvements. Over time, the partnership has been expanded to include Mono County, and efforts are now underway, with the Eastern Sierra Air Alliance, to broaden the scope of participation and involvement to continue enhancement of commercial air service serving the community.

On May 22nd, after completing extensive review and holding four public meetings on the subject, the Airport Commission recommended that the revised ALPUN, with modifications, be submitted to the FAA following consideration by the Planning Commission and Town Council. The Airport Commission’s modifications are incorporated into the ALPUN errata sheet.

On June 13th, the Planning Commission found that the ALPUN is consistent with the General Plan and also recommended that the ALPUN be submitted to the FAA after Town Council consideration.

Page 1 of 5 The staff reports for both Commissions are attached for Town Council reference.

A meeting is also being scheduled for the Airport Land Use Commission’s review of the ALPUN for consistency with the Airport Land Use Plan’, but has not been scheduled at the time of this report’s publication. The Airport Land Use Plan was prepared in 1986 and established land use regulations for land surrounding the airport. The County will move forward with updating this Plan after the ALPUN process is completed and the FAA has approved the Airport Layout Plan (ALP).

ANALYSIS/DISCUSSION The ALPUN describes the development criteria and rationale for the existing and proposed facilities necessary for the operation and development of the airport. The draft ALPUN was prepared by the Town’s Consulting Airport Engineer in July 2011 and has undergone extensive public input, including a peer review by Mead & Hunt, Inc. The draft ALPUN has been substantially revised to incorporate Federal Aviation Administration (FAA) comments and direction, peer review report recommendations, Airport Commission direction, a revised air service forecast, and public comments.

The Airport and Planning Commissions have considered substantial public input and technical information (e.g., 283 comments and Mead & Hunt’s Peer Review Report) in developing their recommendations. Please see attached Airport and Planning Commission staff reports for additional information (Attachments 2 and 3).

OPTIONS ANALYSIS

Option 1: That the Town Council direct staff to formally submit the revised Airport Layout Plan Update Narrative (ALPUN) to the Federal Aviation Administration (FAA) for review and comment, with or without any modifications as directed by the Town Council.

Option 2: That the Town Council provides different direction to staff.

Option 3: That the Town Council takes no action on the matter.

Option 1 would allow the ALPUN to be formally submitted to the FAA for review. Option 2 and 3 would delay the formal submittal of the revised ALPUN to the FAA.

The Airport Land Use Plan applies to the area and land uses surrounding the airport.

Page 2 of 5 VISION CONSIDERATIONS This effort implements the Town’s General Plan Community Vision,

Economy Element, and Policy E. 1 .G. — “Develop facilities that support commercial and charter air carrier service.” Air service is in of itself a strategic initiative of the Town towards achieving a premier year-round resort community with increased visitation and resident and visitor satisfaction. The ALPUN also supports the Vision statement of offering a variety of transportation options that emphasize connectivity, convenience, and alternatives to the use of personal vehicles with a strong pedestrian emphasis.

FINANCIAL CONSIDERATIONS Staff related costs of this work effort are funded by Airport and General funds. The update of the ALP is a one-time effort. Future improvements identified on the updated and FAA-approved ALP will be eligible for financial assistance from the FAA.

STAFFING CONSIDERATIONS Community Development, Airport, and Public Works staff have been directed to work on the ALP Update Narrative.

ENVIRONMENTAL CONSIDERATIONS According to State CEQA Guidelines section 15378(a), a “project” means “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, and that is any of the following: [SI] (1) An activity directly undertaken by any public agency...”

Here, the Town — a public agency — proposes to submit a request to the Federal Aviation Administration (“FAA”) to approve the Airport Layout Plan Update Narrative (“ALPUN”) for the Mammoth Yosemite Airport (the “Airport”). The activities and projects contemplated in the ALPUN could result in a direct physical change in the environment. Furthermore, the Town’s actions taken in connection with the ALPUN are discretionary actions that require the exercise of judgment and deliberation on behalf of the Town. Thus, the Town’s request that the FAA approve the ALPUN is considered a “project” as defined by the California Environmental Quality Act (“CEQA”) and the State CEQA Guidelines.

Once a lead agency determines that an activity it proposes to undertake is a “project” subject to CEQA, the next step is to determine whether the “project” is exempt from CEQA review. (State CEQA Guidelines, § 15061(a).) According to the State CEQA Guidelines, a project is exempt from CEQA if “[t]he project is exempt by statute. . . .“ (State CEQA Guidelines, § 15061(b)(1).)

Page 3 of 5 Staff has reviewed the “project” (i.e., the Town’s request that the FAA approve the ALPUN) in light of the existing statutory exemptions outlined in State CEQA Guidelines section 15260 et seq. Staff has determined that the Town Council’s decision to formally submit the ALPUN to FAA for consideration is statutorily exempt from CEQA pursuant to State CEQA Guidelines section 15262.

Specifically, State CEQA Guidelines section 15262 provides that: A project involving only feasibility or planning studies for possible future actions which the agency, board, or commission has not approved, adopted, or funded does not require the preparation of an EIR or negative declaration but does require consideration of environmental factors. This section does not apply to the adoption of a plan that will have a legally binding effect on later activities.

Here, the ALPUN is, by definition, a feasibility and planning study for possible future actions at the Airport. The ALPUN outlines possible improvement projects that could be undertaken by the Town at the Airport if (1) the FAA finds that the projects are consistent with its goals and policies for the Airport and (2) there is funding available for the proposed improvements. By submitting the ALPUN to the FAA for consideration, the Town is in no way approving, adopting, or funding any of the conceptual improvements outlined in the ALPUN. The ALPUN does not have a legally binding effect on later activities because any improvements to the Airport would be required to undergo design review, site planning, and environmental review. Indeed, as reflected on the face of the ALPUN, even if the FAA accepts the ALPUN, the FAA’s acceptance in no way constitutes “a commitment on the part of the United States to participate in any development depicted” in the ALPUN. The ALPUN will not have regulatory effect and is intended to guide and inform recommendations for improvements to the Airport. Finally, the Town has considered environmental factors in connection with its request that the FAA approve the ALPUN. Specifically, the ALPUN includes a discussion of utilities, drainage, and soil movement.

Environmental analysis of any development project proposed at the Airport will be fully compliant with the requirements of both the National Environmental Policy Act (NEPA) and CEQA.

The FAA’s consideration of the ALPUN is considered categorically excluded under the NEPA Implementing Instructions for Airport projects because Categorical Exclusions, Table 6-1, lists “Conditional Airport Layout Plan (ALP) approval” as a categorical exclusion unlikely to involve extraordinary circumstances.

Page 4 of 5 Thus, for the foregoing reasons the Town’s submission of the ALPUN to the FAA for consideration is statutorily exempt pursuant to State CEQA Guidelines section 15262.

LEGAL CONSIDERATIONS The Town Attorney has been involved in relevant legal questions that arose during the ALPUN process.

RECOMMENDATION Therefore, it is recommended that the Town Council: Choose Option 1 and direct staff to formally submit the revised Airport Layout Plan Update Narrative (ALPUN) to the Federal Aviation Administration (FAA) for review and comment, with or without any modifications as directed by the Town Council.

Attachments

1. Revised/Conformed Mammoth Yosemite Airport Layout Plan Update Narrative, May 2012 (previously distributed and available at http: / /www. ci. mammoth-lakes. ca.us /index. aspx?nid=442)

2. Airport Commission Staff Report, May 22, 2012 (staff report attachments, including Mead & Hunt’s Peer Review Report, are available at http: //www.ci.mammoth lakes. Ca. us/index. aspx?nid=442)

3. Planning Commission Staff Report, June 13, 2012 (staff report attachments are available at http: / /www. ci. mammoth- lakes. Ca. US / index. aspx?nid=442)

Page 5 of 5 A*~rv~ec~i- ~-

~ Agenda Item: 4 Date: May22, 2012 File No.______M~ LRk~ CAL FOR N I A AIRPORT COMMISSION STAFF REPORT

Subject: Airport Commission Recommendation on the Revised Mammoth Yosemite Airport Layout Plan Update Narrative to the Planning Commission and Town Council for Consideration of Formal Submittal to the Federal Aviation Administration

Initiated by: Jen Daugherty, Associate Planner Mark Wardlaw, Community Development Director William Manning, Airport and Transportation Director

INTRODUCTION The purpose of this agenda item is to present the revised Mammoth Yosemite Airport Layout Plan Update Narrative (ALPUN) for Airport Commission review, and for the Airport Commission to make a recommendation to the Planning Commission and Town Council for consideration of formal submittal to the Federal Aviation Administration (FAA).

After the Airport Commission’s recommendation, the Planning Commission will consider the ALPUN in terms of General Plan consistency and will also make a recommendation to the Town Council. The Town Council will then consider the recommendations of both the Airport and Planning Commissions and provide direction to staff regarding the formal submittal of the ALPUN to the FAA. The Planning Commission is anticipated to review the ALPUN on June 13th and the Town Council on June 20th.

A meeting is also being scheduled for the Airport Land Use Commission’s review of the ALPUN for consistency with the Airport Land Use Plan, but has not been set at the time of this report’s publication.

BACKGROUND Since the reintroduction of air service in 2008, the Town of Mammoth Lakes in partnership with Mammoth Mountain Ski Area (MMSA) and the Federal Aviation Administration have made significant progress in securing air service contracts; completing required planning, design, and environmental analyses; and in capital facility improvements. Over time, the partnership has been expanded to include Mono County, and efforts are now underway, with the Eastern Sierra Air Alliance, to broaden the scope of participation and involvement to continue enhancement of commercial air service serving the community.

The original draft ALPUN was completed for the Town in July 2011 by the office of Reinard W. Brandley, Consulting Airport Engineer. The purpose of the ALPUN is to update and supersede the current 2000 Airport Layout Plan (ALP).

The draft ALPUN includes the following information:

• A 20-year aviation forecast and planning framework for the airport.

• New or upgraded airport facilities needed to meet the needs of the 20-year forecast (e.g., new terminal building, extend 1,200 feet to the west, etc.).

• An analysis of what would be required to change the FAA Airport Reference Code (ARC) from B-Ill to C-Ill within the airport’s current footprint. The ARC C-Ill is desired for the ease of airline operators.

• An identification of the current airport obstructions and deviations from FAA ARC C-Ill standards, including identifying those deviations that are proposed to be corrected and those that the Town is requesting FAA to approve as modifications to standards.

The draft ALPUN contains the level of detail necessary for the FAA to adequately consider and review the proposed updated ALP.

Public Input Discussion and evaluation of the draft ALPUN has included extensive public outreach and opportunity to provide input. The Airport Commission has held three public workshops or meetings on the draft ALPUN:

• November 3, 2011 workshop — Overview of the ALPUN and process.

• December 16, 2011 workshop — Focused on the draft aviation forecast, including a presentation by Kent Myers of AirPlanners.

• February 28, 2012 — Presentation of Mead & Hunt Inc.’s peer review of the

draft ALPUN (please see Peer Review Report — Mead & Hunt, Inc., below).

Many comments and questions were raised during these workshops and meetings that have been responded to and incorporated into the revised ALPUN. A total of 283 comments were compiled during this public review process. Peer Review Report — Mead & Hunt, Inc. Throughout the ALPUN process, substantial comments were received on the draft ALPUN. Therefore, the Town initiated a third-party peer review to critique the draft ALPUN and provide technical responses to the extensive and in many cases highly technical, questions and comments received from the public and the Airport Commission. A competitive selection process was conducted, and Mead & Hunt, Inc. was selected by the Airport Commission Ad Hoc Committee (members Hughes and Heller) and Town staff to complete the peer review.

Mead & Hunt’s peer review report includes a general review of the draft ALPUN and a separate Appendix A providing specific responses to the 283 separate comments received. The following conclusions were documented in the peer review report:

• The draft ALPUN is fully in conformance with aviation industry and FAA standards.

• The range of topics addressed in the draft ALPUN is more extensive than normal (i.e., the scope lies somewhere between a typical Narrative Report and an Airport Master Plan).

• The aviation forecast is appropriate to use for facility planning at the Mammoth Yosemite Airport.

• The preliminary design and program of the new terminal are adequate, and the phasing of development is reasonable. Some suggestions were provided for development of the final terminal design.

• Nonstandard conditions or deviations from standards are common at airports.

• It is expected that the FAA will grant modifications to standards or waivers for a specific period of time’.

On February 28th, the Commission reviewed the peer review report, including each of the 283 responses to comments, and provided consensus and direction that have been incorporated into the revised ALPUN.

Federal Aviation Administration The FAA is the decision-making agency that approves the ALPUN, and the Town continues to work with the FAA on an on-going basis. In October 2011, the draft ALPUN was submitted to the FAA for preliminary review. In December 2011, the Town received four issues or comments from the FAA on the draft ALPUN. Comments on the draft aviation forecast were provided by the FAA in March 2012.

Mammoth Yosemite Airport Layout Plan Update Narrative Report Peer Review, Mead & Hunt, February 2012. Town staff has continued to have discussions with the FAA on the draft ALPUN; the revised ALPUN reflects these comments and discussions.

ANALYSIS

Revised Airport Layout Plan Update Narrative (ALPUN) As directed by the Commission, and in response to input provided by the FAA, the draft ALPUN has been substantially revised. Revisions were incorporated to reflect the following:

• Mammoth Yosemite Airport Layout Plan Update Narrative Report — Peer Review, Mead & Hunt, Inc., including Appendix A (responses/recommendations to 283 comments on the draft ALPUN). This report is available on the Town’s website at ______http: / /www.ci.mammoth lakes.ca.us/index.aspx?nid=442). • Airport Commission consensus and direction from the Commission’s February 28, 2012 meeting, during which Mead & Hunt, Inc.’s ALPUN Peer Review Report was presented. • An alternative revised 20-year aviation forecast, which has been reduced compared to the original forecast. • FAA comments and discussions. • Public comments. • Errata/typo corrections.

Attached to this staff report is a revised (clean) version of the ALPUN and a strikeout/underline (redline) version. The redline version identifies the changes from to the original July 2011 draft ALPUN.

ALPUN Revisions Many revisions to the ALPUN were made to improve clarity and consistency. A few of the more substantial changes are listed below: • The aviation forecast was revised at the request of the Commission (please see section below).

• An executive summary was added to summarize the major ideas and requests included in the draft ALPUN. • An introduction was added to provide additional context and background. • The deviations from FAA standards table was moved to the ALP Sheets (Sheet

3 — Data Tables), for ease of FAA review. The deviations table was separated to clearly identi1~y which standards are proposed to be corrected as funding

0~ becomes available and which standards the Town is requesting modifications to standards. • The ALP sheets have been revised to reflect numerous comments and corrections. • General aviation is addressed separately (Section 10-6). • The title of Chapter 5 was changed from “Ideal Airport and Alternative Site Development Study” to “Alternative Site Development Study” and the chapter was moved to an appendix (Appendix C). • Letters from MMSA, Mammoth Lake Tourism, and the airlines are provided in Appendix A.

Although changes were made to reflect the responses to the 283 comments contained in Appendix A of the peer review report, many comments did not require revisions to the ALPUN; these items were clarifications of airport information, the ALPUN process, or simply the commenter’s opinion.

Revised Aviation Forecast The Airport Commission requested that the 20-year aviation forecast be revised to be more conservative. The revised aviation forecast was developed by Reinard W. Brandley, Consulting Airport Engineer (“Brandley”) for the Town. Brandley considered various data during the development of this revised forecast, including enplaned passengers, aircraft operations and fleet mix, local considerations, airport constraints, Mead & Hunt’s peer review report, forecasts prepared by the MMSA’s airline consultant, Kent Myers of AirPlanners, and forecast growth at airports serving similar markets. The Kent Myer’s forecast and peer market airport evaluation are described below.

Peer Airports Comparison Study The comparable airports evaluated include Yampa Valley Airport (Steamboat Springs, Colorado), Eagle County Regional Airport (Vail, Colorado), Aspen-Pitkin County Airport, and Montrose Regional Airport (Telluride, Colorado), Glacier Park International Airport (Montana), and Friedman Memorial Airport (Idaho) (ALPUN Table 3-2). These airports serve major skiing facilities similar to MMSA and many also serve summer recreation facilities and national parks similar to Mammoth and the Eastern Sierra. Therefore, Brandley determined that the growth pattern for the Mammoth Yosemite Airport will be similar to that at these comparable resorts provided that MMSA continues the airline subsidy program, along with the summer subsidies from the Town, County, and Mammoth Lakes Tourism.

Kent Myers/MMSA Forecast Brandley also considered the forecasts prepared by Kent Myers of in the development of the Mammoth Yosemite Airport forecast. Mr. Myers revised the original MMSA forecast by incorporating new data and reflecting a less aggressive growth pattern (ALPUN Table 3-1). Actual numbers for operations in the years 2008-2012 were included, showing the numbers of operations and seats that were contracted with the airlines. Mr. Myers’ revised forecast reduced total annual aircraft seats in 2027-2028 from 247,820 to 217,488 seats (a reduction of 30,332 seats) or 12%.

This reduction was the result of the following modifications:

• San Jose - With the additional flights from San Francisco, the San Jose flight was a challenge; therefore, the San Jose flights were eliminated from the forecast (i.e., too many seats flying from the Bay Area).

• San Francisco - Seats were reduced for the San Francisco service because of a change from an airbus (124 seats) to a regional jet aircraft with 66 seats.

• San Diego - Seats were reduced for the San Diego service because of a change from a Q400 (76 sears) to a regional jet aircraft with 66 seats. The type of aircraft used is driven by airline selection (e.g., operates the Q400 and the aircraft uses to serve Mammoth Lakes is a regional jet).

• Burbank/San Luis Obispo - Flights were reduced because summer service was eliminated.

• Facility Limitations - The forecast reflects a more realistic timeframe for a new terminal, which will limit the number of planes that the existing facilities can accommodate. For example, service to Portland (PDX) was originally forecasted to initiate in 2012-2013 and is now forecasted to start in 2015- 20 16, when a new terminal may be in place.

• Initiation and Expansion to New Markets - The start-up time for success in new markets is more conservative. For example, the PDX flights are forecasted to start with 16 winter flights in 2015-2016, increase to 32 winter flights in 2016-2017, and maintain the 32 flights through 2019-2020 (for four years) before an increase in number of flights in 2020-202 1. In comparison, the Mr. Myers’ original forecast only provided PDX one year of 32 winter flights before increasing the number of flights. The initiation and expansion of summer service has also been revised to be less aggressive.

MMH/Brandley Forecast Utilizing this new information, Brandley’s revised the aviation forecast through 2030 (ALPUN Table 3-4). The forecast shows enpianements of approximately 140,000 in 2030 (reduced from 170,000 enplanements in the original forecast). Airport Capital Improvement Program The Airport Capital Improvement Program (ACIP) is included as Appendix D to the revised ALPUN. The ACIP shows the short- and long-term capital improvements intended to implement the ALP. The ACIP is a flexible document that can be submitted to the FAA as often as necessary to stay current with the needs and funding of the airport. In other words, project can be moved out of sequence from what is shown in the ACIP. The ACIP assists the Town and FAA plan, coordinate, and prioritize funding for short and long-term airport projects.

OPTIONS ANALYSIS

Option 1: That the Airport Commission finds that the revised Airport Layout Plan Update Narrative (ALPUN) is adequate and recommends the revised ALPUN be submitted to the Federal Aviation Administration (FAA), with any modifications, following consideration by the Planning Commission and Town Council.

Option 2: That the Airport Commission provides different direction to staff.

Option 3: That the Airport Commission takes no action on the matter.

Option 1 would allow the ALPUN to proceed to the Planning Commission and Town Council for direction regarding submittal to the FAA. Option 2 and 3 may delay the Planning Commission and Council review of the ALPUN.

VISION CONSIDERATIONS This effort implements the Town’s General Plan Community Vision, Economy

Element, and Policy E. 1 .G. — “Develop facilities that support commercial and charter air carrier service.” Air service is in of itself a strategic initiative of the Town towards achieving a premier year-round resort community with increased visitation and resident and visitor satisfaction.

STAFFING CONSIDERATIONS Community Development, Airport, and Public Works staff have been directed to work on this matter.

FINANCIAL CONSIDERATIONS Staff related costs of this work effort are funded by Airport and General funds.

vi ENVIRONMENTAL CONSIDERATIONS The ALPUN is considered exempt under the California Environmental Quality Act and categorically excluded under the National Environmental Policy Act (NEPA) Implementing Instructions for Airport projects under the following provisions:

CEQA exempts Feasibility and Planning Studies (Section 15262): “A project involving only feasibility or planning studies for possible future actions which the agency, board, or commission has not approved, adopted, or funded does not require the preparation of an EIR or negative declaration but does require consideration of environmental factors. This section does not apply to the adoption of a plan that will have a legally binding effect on later activities.”

NEPA Implementing Instructions for Airport Projects, Chapter 6, Categorical Exclusions, Table 6-1, lists “Conditional Airport Layout Plan (ALP) approval” as a categorical exclusion unlikely to involve extraordinary circumstances.

RECOMMENDATION Staff recommends Option 1: That the Airport Commission finds that the revised Airport Layout Plan Update Narrative (ALPUN) is adequate and recommends the revised ALPUN be submitted to the Federal Aviation Administration (FAA), with any modifications, following consideration by the Planning Commission and Town Council.

Attachments* 1. Revised/Conformed (Clean) Airport Layout Plan Update Narrative, May 2012 (previously distributed) 2. Redline of the Revised Airport Layout Plan Update Narrative 3. Peer Review Report, Mead & Hunt, Inc. (previously distributed) *A11 attachments are available on the Town’s website at http://www.ci.mammoth-Iakes.caus/index.aspx?njd=442

‘3 3

Town of Mammoth Lakes Planning Commission Recommendation Report CAL I FOR N I A

Date: June 13, 2012 Case/File No.: NA Place: Council Chambers, 2” Floor Project: Airport Layout Plan Minaret Village Shopping Center Update Narrative Mammoth Lakes, CA 93546 Time: After 2:00 p.m. Location: Mammoth Yosemite Airport Agenda Item: 1 General Plan: Airport Appeal Status: NA Specific Plan: NA Applicant! Town of Mammoth Lakes Zoning: Airport Owner: Environmental CEQA Categorical Exclusion and Review: NEPA Categorical Exemption

A. EXECUTIVE SUMMARY

1. Subject/Requested Actions Planning Commission recommendation to the Town Council regarding the revised Mammoth Yosemite Airport Layout Plan Update (ALPUISJ) General Plan consistency and formal submittal of the revised ALPUN to the Federal Aviation Administration for review and comment.

2. Required Findings to Support Requested Actions • Is the revised ALPUN consistent with the General Plan, including the General Plan’s Vision, goals, policies, and growth assumptions?

3. Report Summary The ALPUN describes the development criteria and rationale for the existing and proposed facilities necessary for the operation and development of the airport. The draft ALPUN was prepared by the Town’s Consulting Airport Engineer in July 2011 and has undergone extensive public input, including a peer review by Mead & Hunt, Inc. The draft ALPUN has been substantially revised to incorporate Federal Aviation Administration (FAA) comments and direction, peer review report recommendations, Airport Commission direction, a revised air service forecast, and public comments.

Staff recommends that the Planning Commission choose Option 1 and find that the revised Airport Layout Plan Update Narrative (ALPUN) is consistent with the General Plan and recommend that the revised ALPUN be submitted to the Federal Aviation Administration, with any modifications, following Town Council consideration.

Report Prepared By: Report Approved By: Jen Daugherty, Associate Planner Mark Wardlaw, Community Development Director

Report Page 1 B. ANALYSIS

1. Background Since the reintroduction of air service in 2008, the Town of Mammoth Lakes in partnership with Mammoth Mountain Ski Area (MMSA) and the Federal Aviation Administration (FAA) have made significant progress in securing air service contracts; completing required planning, design, and environmental analyses; and in capital facility improvements. Over time, the partnership has been expanded to include Mono County, and efforts are now underway, with the Eastern Sierra Air Alliance, to broaden the scope of participation and involvement to continue enhancement of commercial air service serving the community.

On May 22~’, after completing extensive review and holding four public meetings on the subject, the Airport Commission recommended that the revised ALPUN, with modifications, be submitted to the FAA following consideration by the Planning Commission and Town Council. The Airport Commission’s modifications are incorporated into the attached ALPUN errata sheet.

After Planning Commission’s recommendation, the Town Council will consider the recommendations from Planning Commission and Airport Commission and provide direction to staff regarding submission of the ALPUN to the FAA for review and comment. The Town Council is anticipated to consider this item at their regular meeting on June 20th

A meeting is also being scheduled for the Airport Land Use Commission’s review of the ALPUN for consistency with the Airport Land Use Plan, but has not been scheduled at the time of this report’s publication. The Airport Land Use Plan was prepared in 1986 and established land use regulations for land surrounding the airport. The County will move forward with updating this Plan after the ALPUN process is completed and the FAA has approved the ALP.

2. What is an Airport Layout Plan Update Narrative (ALPUN)? The ALPUN, including the Airport Layout Plan sheets, describes the development criteria and rationale for the existing and proposed facilities necessary for the operation and development of the airport. The FAA is the decision-making agency that approves an ALP.

The ALPUN contains the following elements:

• Basic Aeronautical Forecasts.

• Basis for the proposed items of development.

• Rational for unusual design features and/or modifications to FAA Airport Design Standards.

• Summary of the various stages of airport development and layout sketches of the major items of development in each stage.

The ALPUN has the following primary functions:

• It serves as a planning document for the airport sponsor and FAA for facility improvements at the airport (i.e., Airport Capital Improvement Program or ACIP).

Report Page 2

Ic • Approval by the FAA is necessary to receive financial assistance from the FAA1.

• The ALP creates a blueprint for airport development by depicting proposed facility improvements.

• It is a public document that serves as a record of aeronautical requirements, both present and future.

• The ALP can be a working tool for the airport sponsor.

FAA guidelines and standards evolve over time and an ALP should be regularly updated.

3. Mammoth Yosemite Airport ALPUN The Mammoth Yosemite Airport ALPUN was completed in July 2011 by the office of Reinard W. Brandley, Consulting Airport Engineer. The purpose of the ALPIJN is to update and supersede the current 2000 ALP for the Mammoth Yosemite Airport. The draft ALPUN includes the following information:

• A 20-year aviation forecast and planning framework for the airport. The aviation forecast includes increases in the number of flights to existing markets, the addition of new markets, and the use of aircraft with additional seats. The aviation forecast shows an anticipated 140,000 enplanements at the Mammoth Yosemite Airport in 20302. There were 26,196 enplanements in 2011~.

• New or upgraded airport facilities needed to meet the needs of the 20-year forecast. Major facilities considered include a new terminal building, extending the runway 1,200 feet to the west, and improvements to correct certain deviations from FAA standards.

• An analysis of what would be required to change the FAA Airport Reference Code (ARC) from B-Ill to C-Ill within the airport’s current footprint. ARC C-Ill requires more stringent physical airport standards than B-Ill, but C-Ill is desired to increase the ease of C-Ill aircraft currently flying into the airport.

• An identification of the current airport obstructions and deviations from FAA standards, including identifying those deviations that are proposed to be corrected and those that the Town is requesting FAA to approve as modifications to standards. These deviations are listed on Sheet 3, Data Tables, of the ALP.

The draft ALPUN has undergone extensive public input, including a third party peer review by Mead & Hunt, Inc. The peer review was conducted to critique the draft ALPIJN and provide technical responses to the extensive and in many cases highly technical, questions and comments received from the public and the Airport Commission; 283 comments were addressed during the peer review process.

Additional requirements must be met to receive FAA funding for specific projects. 2 An enpianement is one passenger arriving to and exiting from the airport. An airport receives $1 million in discretionary FAA grant funding each year when an airport achieves at least 10,000 annual enpianements. Report Page 3 The draft ALPUN has been substantially revised to incorporate Federal Aviation Administration (FAA) comments and direction, peer review report recommendations, Airport Commission direction, a revised air service forecast, and public comments.

4. ALPUN General Plan Consistency The Mammoth Yosemite Airport is located within the Town’s Urban Growth Boundary and is subject to the Town’s General Plan. The General Plan includes goals and policies related to the airport:

• Community Vision

o “Being a premier, year-round resort community based on diverse outdoor recreation, multi-day events and an ambiance that attracts visitors.”

o “Offering a variety of transportation options that emphasize connectivity, convenience and alternatives to use of personal vehicles with a strong pedestrian emphasis.”

• Economy Element

o Intent — “The challenge.., is to increase visitor occupancy midweek and shoulder seasons. The strategy is to provide air service, additional amenities and attractive meeting facilities.”

o Policy E. 1 .E. — Re-establish year-round scheduled air service and continue charter air service at Mammoth Yosemite Airport.

o Policy E. 1 .F. — Establish and maintain air service connecting the Mammoth Lakes area with destination visitor markets.

o Policy E. 1 .G. — Develop facilities that support commercial and charter air carrier service.

• Mobility Element

o Intent — “Overall, mobility will be improved through measures such as: increasing and improving available transportation options [and] upgrade the Mammoth Yosemite Airport terminal to allow for regional air service.”

o Goal M.3. — “Emphasize feet first, public transportation second, and car last in planning the community transportation system while still meeting Level of Service standards.”

o Policy M.2.F. — Establish convenient and energy efficient access to the Mammoth Yosemite Airport. • Land Use Element:

o Airport Designation — “This designation allows aviation, fueling, and fixed-base operator services at Mammoth Yosemite Airport.”

Report Page 4 o Policy L. l.A. — Limit total peak population of permanent and seasonal residents and visitors to 52,000 people.

• Zoning Code — Airport Zone: “The (A) airport zone is included in this title to implement the Mammoth Lakes Airport Layout Plan, and the goals and policies in the Mammoth Lakes General Plan related to airport facilities.”

• Destination Resort and Economic Development Strategy (DRCEDS)

o Key Resort Goal — Annually increase Town visitation and occupancy rates.

o Key Strategic Initiative — Tourism: Filling beds during midweek and shoulder seasons.

o Key Strategic Initiative — Air Service: Providing commercial air service.

The ALPUN is consistent with these General Plan goals, policies, and supporting documents because it considers possible future increases in air service operations and improvements of existing facilities to increase visitation and enhance the resident and visitor experience. Expanded air service can increase visitation and occupancy rates, including midweek and shoulder season visitation.

The ALPUN forecast is consistent with the General Plan build-out and population at one time (PAOT) because the aviation forecast is used as a planning tool for discussing potential future improvements at the airport. PAOT, or the amount of people in town, is driven by the number of units, rooms, andlor beds available in town, and the Town continues to review each development application in the context of PAOT and the Project Impact Evaluation Criteria (PIEC) to ensure General Plan build-out is not exceeded. Furthermore, the Final EIR for the General Plan Update calculated PAOT utilizing existing and potential new units, rather than the number of flights or enplanements.

5. Environmental Analysis According to State CEQA Guidelines section 15378(a), a “project” means “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, and that is any of the following: [~J] (1) An activity directly undertaken by any public agency. . .

Here, the Town — a public agency — proposes to submit a request to the Federal Aviation Administration (“FAA”) to approve the Airport Layout Plan Update Narrative (“ALPUN”) for the Mammoth Yosemite Airport (the “Airport”). The activities and projects contemplated in the ALPUN could result in a direct physical change in the environment. Furthermore, the Town’s actions taken in connection with the ALPUN are discretionary actions that require the exercise of judgment and deliberation on behalf of the Town. Thus, the Town’s request that the FAA approve the ALPUN is considered a “project” as defined by the California Environmental Quality Act (“CEQA”) and the State CEQA Guidelines.

Once a lead agency determines that an activity it proposes to undertake is a “project” subject to CEQA, the next step is to determine whether the “project” is exempt from CEQA review. (State CEQA Guidelines, § 15061(a).) According to the State CEQA Guidelines, a project is exempt from CEQA if

“[t]he project is exempt by statute.. . .“ (State CEQA Guidelines, § 15061(b)(1).)

Report PageS

Is Staff has reviewed the “project” (i.e., the Town’s request that the FAA approve the ALPIJN) in light of the existing statutory exemptions outlined in State CEQA Guidelines section 15260 et seq. Staff has determined that the Town Council’s decision to formally submit the ALPUN to FAA for consideration is statutorily exempt from CEQA pursuant to State CEQA Guidelines section 15262.

Specifically, State CEQA Guidelines section 15262 provides that: A project involving only feasibility or planning studies for possible future actions which the agency, board or commission has not approved, adopted, or funded does not require the preparation of an EIR or negative declaration but does require consideration of environmental factors. This section does not apply to the adoption of a plan that will have a legally binding effect on later activities.

Here, the ALPUN is, by definition, a feasibility and planning study for possible future actions at the Airport. The ALPUN outlines possible improvement projects that could be undertaken by the Town at the Airport if(1) the FAA finds that the projects are consistent with its goals and policies for the Airport and (2) there is funding available for the proposed improvements. By submitting the ALPUN to the FAA for consideration, the Town is in no way approving, adopting, or funding any of the conceptual improvements outlined in the ALPUN. The ALPUN does not have a legally binding effect on later activities because any improvements to the Airport would be required to undergo design review, site planning, and environmental review. Indeed, as reflected on the face of the ALPUN, even if the FAA accepts the ALPUN, the FAA’s acceptance in no way constitutes “a commitment on the part of the United States to participate in any development depicted” in the ALPUN. The ALPUN will not have regulatory effect and is intended to guide and inform recommendations for improvements to the Airport. Finally, the Town has considered environmental factors in connection with its request that the FAA approve the ALPUN. Specifically, the ALPUN includes a discussion of utilities, drainage, and soil movement.

Environmental analysis of any development project proposed at the Airport will be fully compliant with the requirements of both the National Environmental Policy Act (NEPA) and CEQA.

The FAA’s consideration of the ALPUN is considered categorically excluded under the NEPA Implementing Instructions for Airport projects because Categorical Exclusions, Table 6-1, lists “Conditional Airport Layout Plan (ALP) approval” as a categorical exclusion unlikely to involve extraordinary circumstances.

Thus, for the foregoing reasons the Town’s submission of the ALPUN to the FAA for consideration is statutorily exempt pursuant to State CEQA Guidelines section 15262.

C. OPTIONS

Option 1: That the Planning Commission find that the revised Airport Layout Plan Update Narrative (ALPUN) is consistent with the General Plan and recommend that the revised ALPUN be submitted to the Federal Aviation Administration (FAA), with any modifications, following Town Council consideration.

Report Page 6

10\ Option 2: That the Planning Commission finds the revised Airport Layout Plan Update Narrative (ALPUN) is not consistent with the General Plan.

Option 3: That the Planning Commission takes no action on the matter.

Option 1 would allow the ALPUN to proceed to the Town Council for direction regarding formal submittal to the FAA. Option 2 and 3 would delay the Town Council’s review of the ALPUN and formal submittal of the ALPUN to the FAA.

D. RECOMMENDATIONS Therefore, it is recommended that the Planning Commission choose Option 1 and find that the revised Airport Layout Plan Update Narrative (ALPUN) is consistent with the General Plan and recommend that the revised ALPUN be submitted to the Federal Aviation Administration (FAA), with any modifications, following Town Council consideration.

Attachments

Attachment 1: Revised/Conformed Mammoth Yosemite Airport Layout Plan Update Narrative, May 2012 (previously distributed and available at http://www.ci.mammoth-Iakes.ca.us/index.aspx?nid—442)

Attachment 2: Revised ALPUN Errata Sheet, June 4, 2012

Attachment 3: Airport Commission Staff Report, May 22, 2012 (staff report attachments, including Mead & Hunt’s Peer Review Report, are available at http://www.ci.mammoth lakes.ca.us/index.aspx?nid 442)

Attachment 4: Public Comments (received since May 22, 2012 Airport Commission Meeting; all comments on the Revised ALPUN are available at http://www.ci.mammoth lakes.ca.us/index.aspx?nid=442)

Report Page 7 ATTACHMENT 1 Revised/Conformed Mammoth Yosemite Airport Layout Plan Update Narrative, May 2012 (previously distributed and available on Town’s website at http://www.ci. mammoth lakes. ca.us/index.aspx?nid=442J

z~ ATTACHMENT 2 Revised Airport Layout Plan Update Narrative Errata Sheet, June 4, 2012

zz Mammoth Yosemite Airport

Revised/Conformed Airport Layout Plan Update Narrative — May 2012

Errata Sheet1

1. Delete “facilities” in first paragraph, last sentence of Executive Summary; page ES-i.

2. Add “up to” before “seven daily flights” in second paragraph of Executive Summary; page ES-i.

3. Add “or other future class of 124 seat aircraft” after “B 737 and A3i9 class” in second paragraph of Executive Summary; page ES-i and throughout.

4. Clarify “deep-seated distress” (i.e., wearing out of runway) in last sentence of #1 Runway; page ES-2.

5. The southern row of tie downs (approximately 22 tie downs per ALP Sheet 4) is recommended to be abandoned when the apron is expanded to meet FAA standards (not 7 or ii tie downs); correct for consistency; pages ES-2 and iO-6.

6. Provide more detail under #7 Land regarding “acquire additional land from these agencies for the development of the airport”; page ES-3.

7. Delete “the” before “high minimums” in #9 Deviations from Standards, second to last sentence in first paragraph; page ES-3.

8. Correct hangars information as follows:

a. 91 hangars constructed by FBO that were sold (not 90).

b. 22 units are l0feetx36feet(not30feet).

c. 20 units are 50 feet x 48 feet (not 60 feet).

d. 16 units are 60 feet x 56 feet (not 15 units).

Page 2-8 and throughout.

9. Replace “regression” with “qualitative” in Section 3-3.4, first sentence; page 3-5.

10. Replace “parallels” with “is similar to” in Section 3-3.5.3, third paragraph; page 3-8.

ii. Table 3-2: Clarify that the 13,185 population identified for Mammoth is the County’s population; page 3-16.

12. Table 4-2 (page 4-3 and ALP Sheet 3):

1 Airport Commission modifications from May 22, 2012 incorporated. Additional errata also included from public comments received after May 22, 2012.

6/4/12 Page lof 2 a. Consider adding “Q400” to the design aircraft for Runway Future (i.e., Q400, B737, and A319).

b. Revise Runway Object Free Area — Width for consistency with ALP Sheet 3.

c. Revise Line of Sight Distance for consistency between Table 4-2 and ALP Sheet 3.

13. Chapter 7 Environmental: Clarify that the required environmental studies will be completed for all airport projects and delete “Environmental Assessment” and “EA”; Chapter 7 and throughout.

14. ALP Sheet 2:

a. Change USFS “Easement” to USFS “Special Use Permit”

b. Show U.S. Highway 395 and Airport Road as existing paved roads.

c. Add an identification number for the Green Church.

d. Revise the Runway Protection Zone (RPZ) for consistency on Sheets 2 and 5.

15. ALP Sheet 3:

a. Identify existing gradient for last 25% of runway in FAA requested modifications to standards table.

b. Correct typo in Airport Data Table for future Airport Elevation (“7.146.5.3”).

c. Correctly identify the Taxiway Wingtip Clearance in Runway Data Table for the B-Ill and C-Ill aircraft (i.e., they should have different clearance dimensions).

16. ALP Sheet 11:

a. Correct Parcel No. 7 description in table.

b. Revise east hangars to be drawn similarly to west hangars on Sheets 5 and 11.

c. Add acreages for all items in table.

17. Add references to the modifications to standards tables on ALP Sheet 3 throughout the ALPUN.

18. Include airport use by Mammoth Lakes’ locals and those living in the Eastern Sierra region throughout the ALPUN.

19. Remove the “winter only” focus in the forecast; Chapter 3.

6/4/12 Page2of2

z~.1 ATTACHMENT 3 Airport Commission Staff Report, May 22, 2012 (Staff report attachments, including Mead & Hunt’s Peer Review Report, are available at http: / /www.ci.mammoth lakes.ca.us/index.aspx?nid=442)

zc ATTACHMENT 4 Public Comments (Received since May 22, 2012 Airport Commission Meeting; all comments on the Revised ALPUN are available at http://www.cimammotli lakes.ca.us/index.aspx?nid=442) From: Stephen Kalish To: Jen Daugherty Re: More corrections for revised draft ALPUN/ALP Date: May29, 2012 sent via email to

Jen Daugherty:

There remain at least several dozen not-insignificant errors in the revised draft ALPUN/ ALP, even after the errata sheet and additional changes proposed at the Airport Commission meeting last week.

As it is more likely that MMH will receive approval for a B-li airport rather than for either B-Ill or C-Ill, the missing deficiency table discussed by the Airport Commissioners must include existing B-Ill deficiencies. in addition to restoring a complete and accurate deficiency table, Sheet 3 should include a column for B-Ill standards in the Runway Data Table, the Deviation to Standards to be corrected as funds become available table, and the Deviation to Standards that the town proposes to request Modifications to Standards table. Action items: this table should be added back into the ALPUN, and should contain standards for B-Ill, and the proposed B-Ill standards column should be inserted in the three tables on Sheet 3 of the ALP.

The Town needs to insist that Brandley sign the ALP sheets before submitting them to the FAA for review. His stamp means nothing if not signed. Maybe advising him of this now will get the town a better work product.

The following specific errors ought to be corrected immediately, along with an updated errata sheet to identify the corrections:

IN TABLE 4-2:

• Table 4-2 omits relevant standards for both a B-Ill airport and a C-Ill airport that need to be added to the table. These out-of-compliance standards were previously identified both in the written comments emailed by FAA’s Novak to Manning on 12/12/2011, and in my written comments on the revised draft submitted 5/20/2012: taxiway to taxi-lane, and taxi-lane to apron or fixed or moveable object. Action item: these standards need to be included in Table 4-2. • The stated taxiway wingtip clearance of 34’ cannot possibly apply to an . Action Item: this needs to be corrected in Table 4-2, for future aircraft.

ELSEWHERE IN ALPUN:

• Per the information I provided staff last week, the Hot Creek Hangars were never sold, and by the terms of the lease with the Town may never be sold before the 50 year lease term expires and they are turned over to the town. Action Item: this needs to be corrected in the ALPUN.

The proposed errata change for number of tie-downs that must be abandoned for a C-Ill airport is wrong. I identified the correct number of tie-down rows in my comments of 5/20/2012. Mead & Hunt wrote that the majority of tie-downs would have to be relocated. Five hundred feet can be scaled off of any of the drawings, and staff can easily verify that more than two rows—meaning more than twice as many tie-downs as the errata sheet proposes—will need to be abandoned. Action item: correct the errata sheet for tie-downs and then correct the ALPUN.

IN THE ALP SHEETS:

• Sheet 2:

o The boundary of the USFS Special Use Permit is misrepresented. Staff has copies of the SUP with attached property map, so there can be no doubt that the Sheet 2 boundary is incorrectly drawn. Action Item: correct the boundary.

o All commercial development areas are not shown, although Brandley showed them on the 2006 ALP drawing. This request for correction was previously made and apparently ignored. Please advise me if the leases have been rescinded; otherwise they need to be included on Sheet 2. Action Item: include the roadsign leased areas and the restaurant/retail leased areas on the ALP Sheet(s).

o Highway 395 (existing paved road) is not shown per the Legend. If the road is intended to be relocated with the next five years, as shown on the sheet, then that is news to me and needs to be disclosed and discussed in the ALPUN. (In light ink, it is shown dashed, suggesting movement.) Action Items: show Highway 395 as an existing paved road on Sheet 2, per the Legend; if it is proposed to be relocated, also show that visibly by matching the color in the Legend; finally, if it is proposed to be relocated, discuss in the ALPUN.

Kalish corrections for May 2012 ALPUN/ALP May 29, 2012 z& o In inventory, list the Green Church and identify it with a number. Action Item: add Green Church to Inventory and identify on drawing. o Action Item: show proposed enlarged RPZ at end of existing 7000’ runway, consistent with the drawing of same on Sheet 5 [for RJW 09].

Sheet 3:

o Runway Data Table:

~ Verify the maximum certificated take-off weights for the B-737 and A31 9. Action Item: if wrong, correct, and if needed, show a future 150 foot wide runway.

~ Include Gradient for first/last quarter of R/W for ADG C aircraft. Be sure to determine if standard is for effective or maximum gradient to meet standard and provide the appropriate existing and proposed gradients for either effective or maximum gradient for first/last quarter of runway forADG C aircraft. Action Item: add a row for this category and provide accurate data in the columns.

~ The future plan for full runway line-of-sight as shown in this table is inconsistent with the future runway half-light-of-sight proposed in Table 4-2. Action Item: determine which is correct, and make the tables consistent.

~ Add rows for taxi-lane information, per action item above.

~ Add a column for B-Ill standards, per action item above.

~ Add a footnote that the RSAs require grading and compacting to standards. Action Items: add the footnote, and discuss in ALPUN.

o Airport Data Table:

~ Action Item: fix the typo in future airport elevation by deleting “.3”.

o Deviations to Standards table.. to be corrected in the future:

~. Previously this sheet showed aircraft parking 10 feet closer to the runway. Action Item: verify correct distance and correct if needed.

~ More hangars need to be removed to meet C-Ill standard. Action Item: change Proposed Action for aircraft parking to remove three (3) rows of tie-downs, or two (2) rows with a request for Modification to Standards from 500 feet to 485 feet.

Kalish corrections for May 2012 ALPUN/ALP May 29, 2012 zo~ Add a row for RSA grading between B-Ill limit and C-Ill limit to south of runway. Action Item: add the row and propose corrective action if airport upgraded to C-Ill.

~ Add a row for RSA grading, east and west ends of runway. Action Item: add a row and propose corrective action to bring into compliance for either B-Ill or C-Ill airport.

~ Add a row for FAR 77 intrusion by east hangars. Note: this is distinct from hangars deviating from C-Ill R/W object free area. Action item: add a row, and propose corrective action.

~ Identify Green Church as in RPZ. Action Item: change the Category “Other” to “RPZ”.

~ Add a column for B-Ill standards, per action item above.

Deviations to Standards requests for Modifications to Standards table:

~ Determine if RIW 09’s maximum gradient in first quarter of R/W meets standard. Action Item: verify and include in data table if necessary.

~ There is no mention in either of the deviation tables of the taxi-lane deficiencies from standards. Action Item: add rows and include the necessary request for deviations, if you don’t propose moving the taxi-lanes and hangars.

~ The footnote about the pole having solar powered lights is irrelevant in the category runway object free area deficiency. The (temporary and expired) mitigation was for a FAR 77 violation. Action Item: remove the footnote.

~ Add a column for B-Ill standards, per action item above.

“Missing” Table:

~ There is no table anywhere in the ALP sheets listing FAR 77 intrusions. And installing obstruction lights (as proposed) requires either Modifications to Standards or else obstruction studies, or both, so all of the FAR 77 intrusions need to be cataloged, and should be included in the Deviations from Standards requests for Modifications of Standards table, unless FAR 77 violations are treated separately. Action Item: include a table on one of the

Kalish corrections for May 2012 ALPUN/ALP May 29,2012 eleven ALP sheets of all FAR 77 intrusions, and be sure to include the east hangars in the list, and proposed corrective actions.

• Sheet 5:

o The east and west hangars should be drawn the same. Action Item: draw the west and east hangars the same on this sheet, and also on Sheet 11.

• Sheet 11:

o Acreage of east hangars is not shown in table. Action Item: include acreage.

o Land leased for commercial roadsigns is not shown on drawing. Identify lease land for roadsigns, as was done on the 2006 ALP sheet, per action item above.

o The perimeter dimensions of the airport need to be referenced to an airport marker. Action item: provide a dimension (it’s 250’) between the runway centerline and the south property line.

o Draw the west and east hangars the same, per action item above.

If you determine that I have any facts wrong, I would appreciate your feedback. Otherwise, I believe it appropriate that all of the action items identified above be implemented.

Note: The above inventory of action items is not a full review of the revised draft ALPUN, but is primarily a review of Table 4-2 and the accompanying ALP sheets 1 through 11 (May 2012 version).

Additional significant issue: The proposed future runway elevation increased by 6.5’ between the July 2011 draft ALP and the May 2012 revised draft ALP. Presumably this reflects the town’s airport consultant’s considered professional opinion on how to construct a runway extension that retains required runway line-of-sight while satisfying other airport requirements. On initial review, the elevated 1200’ long runway extension shown on the May 2012 sheets does not appear to be workable. If this is sound engineering, Brandley’s office should have a transverse section drawing through the proposed extended end of Runway 09 showing that it is indeed feasible. This drawing needs to be inspected, produced, evaluated, whatever, to determine if this is a legitimate proposal or not. That the hill is now proposed to rise 14’ above the old stopway in front of some of the west hangars which are built at grade level approximately 20’ lower in elevation raises alarms. Since the elevated runway would sit on a newly constructed hill covering nearly 50 acres, and require hundreds of thousands

Kalish corrections for May 2012 ALPUN/ALP 5 May 29, 2012

31 of cubic yards of earthen fill, in will undoubtedly cost considerably more than the $4.63M total cost projected by Brandley in Appendix D. This, too, needs to be corrected. Action items: determine if the newly proposed 14’ tall hill can be built while providing a parallel taxiway extension and leaving the west hangars in place. Produce a transverse section of the proposed runway extension end, showing proposed taxiway elevation and hangar and apron elevations. Setting aside for now the runway to parallel taxiway separation standard requirement for C-Ill—or imagine the runway extension being for an ARC B-Ill airport,— answer the question of whether or not the transverse gradient works for west hangars to apron to taxiway extension at its western terminus elevation, to runway extension at its highest elevation to Highway 395. If so, provide high point elevation of west Taxiway “A” extension, and actual west hangar apron elevation at foot of hangar door perpendicular to the proposed runway high-point! end of 7146.5’. Redo the projected cost shown in Appendix D for the runway extension project. Note: I have also written Ray Jarvis requesting that he take a look at this civil engineering question.

Thanks,

Stephen Kalish kaIjar~qnet.com 831.295.3969

Kalish corrections for May 2012 ALPUN/ALP May 29, 2012

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