Comments to Planning Commission Regarding Airport General Plan and Draft EIR

Control # PLER2020-00037- Natomas/Rickelton. Sacramento Planning Commission 8/2/2021

The concerns of West Natomas inhabitants south and east of the airport have not been adequately acknowledged or addressed in either the Draft Supplemental EIR for the SMF Master Plan Update or the Updated plan itself.?

Subsequent to 2015, “South-flow” departures—the SMF takeoff pattern when prevailing winds are from the south and west (aka “off-shore,” or “Delta Breeze”)–pass in concentrated flight routes over residential communities early in takeoff.?Consequently, residents beneath experience significant noise pollution, both in terms of loudness and frequency, typically to the extent that “normal” enjoyment of home life is denied.?Also, engine failure during liftoff is an added concern, as a flight so afflicted—especially with total power failure–would be over residential areas at low altitude.?This renders problematic chances of safely returning to the airport, or avoiding homes, schools or businesses in the event of extreme aircraft distress and crash.??

The May 2020 opportunity for community feedback on the General Plan update was announced by email, but took place only over a single calendar week of seven days commencing at the beginning of and extending through a three-day holiday weekend!?To so severely foreshorten public notice and comment was probably contrary to statutory requirements and was certainly not in the interest of full community involvement.?Despite this foreshortening, 34 of 37 responding residents requested that the general plan revision encompass the noted noise and safety matters.?This the airport brushed aside with the assertion that “noise is outside of the scope of the plan update,” but would be reviewed in the subsequent environmental process. This promised review has not occurred aside from the inclusion of comments submitted during the Draft EIR review period (PC Attachment 3), and cursory remarks contained on Draft EIR page 9-5. To displace the entire onus of noise and safety onto Federal aviation authorities is a convenient excuse for inaction and a dismay for many living in Natomas.

As previously predicted, compartmentalizing noise and safety by the airport and other county officials has guaranteed that at no single point of decision-making has such concerns been taken into account with respect to overall airport operations.?From past experience Natomas residents know that activities within the scope of the general plan, especially changes in departure practices absent efforts to mitigate effects of same, can actually impact residents enormously.?When recently a runway closure for upgrades resulted in a dramatic intensification of noise and risk, the airport made no known effort to solicit community input on mitigation steps to lessen such impacts.?This amounts to walling off aspects of the airport beyond the basic scope of government decision-making.?Closure of the west runway in 2019 is an example of the kinds of airfield adjustments included on page 7 of the PDF Master Plan presentation. However, the goal of safety maximization for residents adjacent to the airport did not appear among the construction planning goals stated on page 3 of the PDF General Plan presentation, nor was it addressed in the Safety topics of the Draft EIR.?This is, however, a subject directly within the scope of the planning effort and its omission can be seen as negligence on the part of airport officials.??

With respect to south-flow departures, the noise contours depicted on the compatibility map of the 2020 PDF General Plan presentation and the Draft EIR are misleading and unrepresentative of reality, while at the same time analytically relied upon throughout (as page 9-5 in effect admits).?Air traffic actually bifurcates into two lobes, one southeast and the other directly east roughly along Del Paso Road.?The responsible manner in which to approach this and other noted difficulties in the Draft EIR (PC attachment 3) is not to rely on misleading and outdated noise contours or questionable metrics, but rather to accurately ascertain the actual problems, environmental and otherwise, which have been identified by Natomas residents.

The discussion of airport associated air pollution fails to take into account the odors residents can experience both when aircraft are taking off and when passing overhead.?In the case of north-flow departures, it is not unusual for southern West Natomas residents to be exposed to the odor of drifting fumes from aircraft propelled into nearby neighborhoods by a prevailing northerly breeze.?Also, similar levels of noxious odor can drift down to those below from south-bound flights, especially when near-calm wind conditions prevail.?This pollution is intense enough to force residents to minimize breathing or close up homes until fumes dissipate.?With respect to take off noise, the Draft EIR also fails to address the north-flow take-off engine noises which can be carried into residential Natomas by the wind.?This problem is particularly noticeable when the East Runway is used for departures.?Also, anyone familiar with roads between West Natomas and the airport can attest to the degraded condition of Power Line road between Bayou and Del Paso.?This stretch of roadway already suffers severe shoulder deterioration.?Nevertheless, the Draft EIR fails to address this matter under the relevant topic.??

Something has gone wrong in both the General Planning and CEQA compliance process in this instance.?The Draft EIR acknowledges on pages 9-5 and 9-6 departure concentration changes which have affected West Natomas but makes no effort to identify the associated consequences, environmental or otherwise.?Rather than full public involvement, the airport purposely truncated community participation in the General Planning process.?Overall, despite significant progress in the discussion of a variety of other matters, the Draft EIR’s other deficiencies are such as to constitute inadequacy from the standpoint of CEQA compliance.?Ignoring and dismissing the identified matters for yet another decade will not make them disappear, nor will it improve public confidence in government’s ability to be open and honest about decision-making or provide desirable safety margins.

Ellery Kuhn

July 31, 2021

[email protected]??