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The Pinocchio Chronicles #4: Palomar, County & FAA, #291

County's End Run Around FAA Grant Requirements

Yesterday’s article (#290) asked: Why did county for 20 years fail to install Palomar runway end safety systems (EMASs) and then in 2021 claim an urgent need to lengthen the runway by 800 feet and install EMASs? (See #290, RSAs and EMAS.)

ANSWER: Growing Pinocchio noses: 4 our of 4. The county can’t meet the strict FAA “increasing airport capacity” grant tests but knows a request for a safety project grant sidesteps the strict capacity test.

State law expressly says a runway extension is an airport expansion (PUC § 21664.5) – as does common sense. Longer runways attract larger aircraft carrying more passengers and corporate jets flying to foreign countries – not the use of a Palomar regional airport that the county trumpets. Not the use of Palomar Airport that county agreed to when accepting Carlsbad Conditional Use Permit 172.

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FAA Airport Improvement Program Grants and BCAs

To earn an FAA capacity grant, county must show that after its runway grows, airport revenues grow beyond project costs over the 20-year project life. A Benefit Cost Analysis (BCA) must show actual revenues outweigh out-of-pocket costs.

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A 2018 Palomar Master Plan BCA analysis would not be pretty. For four years, the commercial revenues from Lowe’s and related stores on the airport land south of Palomar Airport road have kept Palomar afloat.

In the last seven years, Palomar has lost its existing and planned airline services. None of these required flights longer than 600 miles (San Francisco, Phoenix, Las Vegas, Mexico). So runway length was not an issue.

And the FAA BCA test only counts actual airport revenue -- not the fancy “economic multiplier” analysis that county proudly waves at Board of Supervisors meetings.

Moreover, even if the Palomar runway grew, more than 90% of the after project revenues would have been generated with no runway extension. Why? Because Palomar with no extension but added EMASs can safely handle 99.5% of its aircraft flights. (Proof in an upcoming article.)

But the real BCA analysis killer is the county’s 800-foot Palomar runway extension cost. County estimates $112 million to $125 million in 2018 dollars. (See 2018 PMP, page ES 11).

An extension requires drilling many deep holes through contaminated landfill for pilings to support a runway deck on grade beams.

In short, county Palomar revenues are poor and its construction costs wildly exceed normal costs – only because the county used the airport as trash dumps despite accepting FAA grants with conditions stating: Use airport land for the airport only and in no way that would compromise the airport.

Conclusion: You could argue that county and the FAA did not install Palomar EMASs for 20 years because they considered Palomar safe. That reasoning is irrelevant. To satisfy the FAA 1000-foot long RSA requirement to serve FAA-rated C aircraft, county should have substituted a 350-foot EMAS 20 years ago for the Palomar non-conforming RSAs.

Why did county really compromise your Palomar safety? Former Supervisor Horn for 15 years repeatedly told county staff to plan for a 900-foot runway extension. An EMAS at runway end would have interfered with that plan.

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