Draft EIR, SMF General Plan

Context and Predicate:

These observations and critique of the Draft Supplemental EIR of the SMF Master Plan Update were preceded by a May 22, 2020 emailed solicitation to participate in General Plan revisions from J. Glen Rickelton, Airport Planning and Environment Manager, Sacramento County Department of Airports. Rickelton’s message was directed to a group of individuals who, as a voluntary ad hoc association of residents, engaged the airport in 2018 and 2019. These community advocates sought changes in contemporary departure practices, specifically those affecting inhabitants south and east of the airport. As such departures pass over residential communities early in takeoff, residents beneath experience significant noise pollution, typically to the extent that “normal” enjoyment of home life is denied. Also, engine failure in 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. 

 Failure to Involve Interested Parties:

The engagement efforts initiated by residents were inconclusive. However, on January 17, 2020 counsel retained by the City of Sacramento filed with Federal aviation authorities a request that the city be involved in the development of anticipated changes in departure procedures and any associated environmental analysis recommended by the airport. Specifically, the City requested the opportunity to comment before the specified procedures were finalized and implemented. Therefore, to the degree that the Master Plan update and Draft EIR is intended to interlock, relate, be dependent on or justify the outcome of 1/17 referenced practices, the outside counsel retained by the City of Sacramento (or the City Attorney’s office itself), should be a party to and should have been given an opportunity to participate in the development of the Draft EIR for the SMF Master Plan Update.  Despite soliciting contributions from other entities (page 1-21), there is no evidence that the airport reached out to the officials or the retained counsel specifically identified as interested in airport environmental assessments.  

 Public Meeting “Substitution” and short Master Plan response period:

According to the Rickelton’s May 2020 email, and the title page of an associated PDF presentation, a “virtual” master plan presentation and opportunity for community feedback was being offered. This characterization posed several problems. Firstly, the period of public feedback was shockingly constrained to a single calendar week of seven days announced at the beginning of and taking place over a three-day holiday weekend! This alone hardly constituted a serious effort to (quoting the Rickelton communication directly) “maintain open lines of communication and demonstrate the Department’s commitment to planning with stakeholders.” A normal and reasonable standard for public feedback is 45 days, as in the adoption of rules under the Administrative Procedure Act. Further, while public gatherings were constrained during the medical emergency posed by Covid-19, this did not prevent substitutions, such as a virtual town hall or a phone forum, with appropriate planning and sufficient notification, which was not attempted in this case. It is unclear why the matter had to be so rushed as to shockingly foreshorten public notice and comment, probably contrary to statutory requirements.

 Reality is, the airport did not in this instance and, based upon the evidence of past practice relative to responding to individual noise complaints, does not sufficiently engage the stakeholder public and interested groups in decision-making affecting the local community. 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.  When replying to the expressions of noise and safety concerns by individual residents, airport responses are typically so dismissive, deflective or off-topic as to dash any hope of remediation or follow-up. If the airport intends the “community to be a part of the success and growth of our Airports,” as the Director of Airports has been quoted, then a great deal more effort to cultivate community involvement is needed. “Direct, up front notification” (Rickelton letter) of a handful of participants in an inconclusive engagement that took place in the past and was, moreover, discontinued by the airport, can in no way substitute for a full-throated initiative, reversing practices which have only contributed to discourage public involvement up to this point. To so shamelessly act insults the community and undermines good governmental practice.

 Critically Missing Goal:

Closure of the west runway in 2019 was 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 is 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 is negligence on the part of airport officials. West runway closure specifically resulted in a dramatic intensification of risks and noise to nearby Natomas residents for a significant period of time. While the possibility of a catastrophic event taking place might seem statistically rare, events have occurred which suggest differently. A La Guardia 2009 departure which, after striking a flock of geese, was forced to ditch into the Hudson River is the prototypic scenario.  The same bird species responsible for the engine failures of the La Guardia flight inhabit the wetlands discussed in the Draft EIR, but their presence is never mentioned. The bird species in question is not only seen to migrate at the same altitude and paths taken by departing flights, they inhabit Natomas all year long, as opposed to seasonally. To ignore and leave unmentioned catastrophic risks because they are inconvenient to contemplate or discounted as statistically uncommon is especially irresponsible because Natomas is exposed to exactly the very same hazards that the La Guardia flight encountered. Moreover while catastrophic concerns have been repeatedly brought to the attention of the airport, they have yet to be included in mitigation or preventative measures made widely known to the community.  

 Noise Contours versus Actual Noise Pollution:

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.  Air traffic actually bifurcates into two lobes, one southeast and the other directly east roughly along Del Paso Road.  Both past and present actual paths were accurately reflected on pages 2 and 3 of the previously referenced 1/17 City letter to the FAA. Reality is, flight paths bank toward and then pass directly over Natomas residential communities, instead of—in conformity with the east contour border depicted on the compatibility map–over land deliberately set aside for noise abatement and which in an emergency would be preferred if a flight is aborted proximate to liftoff.  Also the FAA has recently acknowledged that the 65 dB metric repeatedly relied upon in the Draft EIR when determining acceptable levels of noise pollution is being reassessed as it has become increasingly clear that unacceptable levels of aircraft noise take place at much lower decibel levels. The responsible manner in which to approach this difficulty in the Draft EIR 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.

 Public concerns brushed aside in SMF master plan adoption

In a late Friday (6/5/2020) website posting, SMF responded to thirty-seven discrete written submissions commenting on revisions of the SMF master plan then underway. While not publishing original submissions, from the summaries prepared by airport staff it was clear that at least 34 of the 37 expressed safety and noise concerns, frequently with multiple observations, points and requests, including a request for an extension of the comment period. As the seven days allotted for comment, according to the airport, was an “extended” multi-day “online workshop” and “additional public review and comment” will be provided later, during environmental review, the airport made no accommodation for comment extension. Safety and noise concerns ended up walled off as “aspects of the airport beyond the basic scope of the master plan.” Compartmentalizing noise and safety, and then separately conducting environmental review, guaranteed that at no single point of decision-making would such concerns be 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. And as the Draft EIR leaves unaddressed the previously expressed community objections and process abuse, the feared compartmentalization has clearly taken place.

Other Draft EIR Shortcomings, Omissions and CEQA Failures

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, May 24, 2021, [email protected]