The Pinocchio Chronicles #9: Palomar, County & FAA, #296

A little knowledge is, well, a little bit. Better to know more.

At the May 5, 2021 Board meeting, Supervisor Jim Desmond (JD) and Airport Director Cameron Humphres (CH) failed us.

CH said a Palomar runway extension is not an airport expansion. JD said Carlsbad’s Conditional Use Permit 172 language, which limits county development of McClellan-Palomar (Palomar) Airport, is defunct. JD & CH need to correct the record at the next Board meeting.

Background: Carlsbad Conditional Use Permit (CUP) 172 Conditions 8 & 11

In 1980, County accepted Carlsbad CUP 172 terms.

CUP 172 Condition 8 requires county to seek Carlsbad approval when expanding Palomar. Condition 11 says county can operate a “General Aviation Basic Transport” airport.

What is an Expansion?

Carlsbad MC § 21.04.140.1 says: “'Expansion' means to enlarge or increase the size of an existing structure or use … . "

Lengthening the Palomar Runway by 800 feet as county proposes both enlarges the runway and Palomar airport capacity to handle larger aircraft traveling further. Not surprisingly, California Public Utilities Code § 21664.5 says runway extensions are airport expansions.

Yet contrarian County Airport Director Cameron Humphres ignored both provisions at the Board of Supervisors meeting. He said that runway extensions were not an airport expansion because Palomar Master Plan improvements will remain within the airfield fence line.

Wrong.

CUP 172 covers the Palomar Airfield on the northwest corner of El Camino Real and Palomar Airport Road. Extending the runway on the northwest corner will require new and more FAA-required navigational towers on the northeast corner of ECR and PAR near wildlife habitat. Across El Camino Real and outside the CUP 172 and airfield boundaries.

So even under the flawed Humphres test, which contradicts both Carlsbad and state law, the county Palomar Master Plan runway extension expands Palomar airport.

What is a “General Aviation Basic Transport” Airport?

The U.S. air system includes about 3300 airports. The FAA calls it the National Plan of Integrated Airports System. NPIAS for short.

The FAA 2021 NPIAS Plan classifies airports. See faa.gov, search NPIAS, click Current NPIAS, then click Appendix C: Statutory and Policy Airport Categories Used in the NPIAS.

A “General Aviation” airport is a “public airport that does not have scheduled service or has scheduled service with less than 2,500 passenger boardings each year.”

A “Basic” airport “link(s) the community to the national airport system. These airports support general aviation activities, such as emergency response, air ambulance, flight training, and personal flying. Most of the flying at basic airports is self-piloted, for business and personal reasons using propeller driven aircraft.”

Thus, in 1980 county and Carlsbad agreed Palomar would operate as a small community airport unless county applied for and was granted a Carlsbad CUP 172 amendment. And the 2021 FAA NPIAS plan expressly retains the category of General Aviation Basic transport.

Supervisor JD and Airport Director Cameron Humphres: Correct the Record

Please correct your CUP 172 misinformation.

First, the CUP 172 Condition 11 classification remains a valid FAA classification; the General Aviation Basic Transport language is not defunct.

Second, even if CUP Condition 11 disappeared, Condition 8 -- Palomar expansion without Carlsbad approval – remains. It is misleading for a county supervisor to imply that CUP 172 is defunct and hence not relevant.

Third, admit that county’s plan to extend the Palomar runway is both legally and factually a Palomar Airport expansion.

The county updated Palomar Master Plan (PMP) and PMP EIR now being redone -- as a result of the Superior Court finding defects in county’s first attempt -- should reflect the facts above.

Otherwise, it will be clear that the county wants to mislead the public and the court.