Russ’s Letter

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Russ Valone


Phone Number

RE: Opposition to the Metroplex Initiative in San Diego

To Whom It May Concern,

Please review and comment on a number of issues I take exception to in the Draft Environmental Assessment (EA) dated June 2015.  To start, as a consultant for the homebuilding industry I have read countless environmental impact reports in my 40 plus years in business and have yet to read one that was as incomplete and as fact less as the Draft EA being relied upon to make major changes to Metroplex operations.  Where minimal scientific data is provided it is provided for Los Angeles and not San Diego.  Therefore I would make two request of the FAA regarding this matter.  One table or totally scrap the proposed NextGen Initiative for San Diego and leave the LOWMA waypoint as part of the departure flight track.  Not accepting that solution I would request a compete Environmental Impact Study that could and would address issues merely glanced over by the Draft EA focusing on monitoring of noise impact of newly affected neighborhoods which will be under the departure flight path, monitoring of increased PAH pollutants in higher concentrations as PAH pollutant will most likely accumulate in the storm water drainage system awaiting rain storm which will result in higher concentrations of PAH’s into the water shed.

While I understand the need to increase departure efficiencies I believe these efficiencies can be accomplished without increasing departures over Point Loma.  Keeping the flight path the way it is with the LOWMA waypoint does not negatively impact anyone not already impacted but elimination of the waypoint will subject many thousands to noise pollution they currently are not subject to.

I understand that the FAA in many analyses of flight path departures the FAA cannot and will not consider noise transfers among communities in its final decision “Noise transfer tends to be a zero sum game; Community A is ecstatic and Community B is furious.  Such split decisions allow the FAA to move forward with its preferred option”.  Fortunately in San Diego, Community B is the Ocean.

Section 5.4 – Historic and Cultural Resource

This section did not fully evaluate the impact on Historical Resources that would accompany the NextGen departure flight changes over Point Loma.  While this section did discuss impact to tribal lands, 4.3.4 Historic, Architectural, Archeological, and Cultural Resources – Historic and Cultural Resources Sub-Categories and concludes no impact.



“The National Historic Preservation Act (NHPA) of 1966 (16 U.S.C. § 470, as amended) requires federal agencies to consider the effects of their undertakings on properties listed or eligible for listing in the National Register of Historic Places (NRHP). Compliance requires consultation with the Advisory Council on Historic Preservation, State Historic Preservation Officers (SHPO), and/or the Tribal Historic Preservation Officers (THPO).  This EA defines historic properties as resources that are listed or eligible for listing in the NRHP or relevant SHPO listings, or that have been identified through tribal consultation for values other than their archaeological qualities. It is possible that changes in aircraft flight routes associated with the Proposed Action could introduce or increase aircraft routing over historic resources and result in potential adverse noise impacts. However, as noted in Section 4.2, the Proposed Action does not involve ground disturbance that could potentially impact archaeological or architectural resources. Thus, the EA does not further discuss these resources.”


The Draft EA is deafeningly quiet on two major National Treasures located on the southern end of Point Loma, the Cabrillo National Monument and Fort Rosecrans National Cemetery.

Changes to flight patterns that eliminate the LOWMA waypoint will result in increased fly overs of Cabrillo National Monument which would result in significant noise impact to the more than 800,000 persons that visit Cabrillo National Monument annually.

Of all of the National Resources in the United States, one of the most distinguished is Fort Rosecrans National Cemetery.  This National Treasure is the final resting place for dozens of Medal of Honor recipients as well as other notable service personnel including but not limited to Major Reuben E. Fleet.  A full list of notables buried at Fort Rosecrans can be accessed by the link below.


The Fort Rosecrans National Cemetery was registered as California Historical Landmark #55[3] on December 6, 1932 and was designated as a Historical Landmark by the City of San Diego on November 6, 1970.  Like the Cabrillo National Monument, this National Treasure would be gravely impacted by increased air traffic departures should the Metroplex Initiative for San Diego Airport be implemented.


5.4.1 Summary of Impacts


“The aircraft noise exposure analysis indicates that there would be no substantial change to the noise environment at any historic resources or tribal land under the Proposed Action compared with the No Action Alternative. Furthermore, any changes in aircraft traffic patterns would occur at altitudes and distances from viewers that would not substantially impair the view or setting of historic resources or tribal lands. Therefore, no adverse indirect effects to historic resources or tribal lands under the Proposed Action would be anticipated for 2015 or 2020.”

Please direct me to that portion of the Draft EA that addresses the altitude of departing flights that will cross over Cabrillo National Monument and Fort Rosecrans National Cemetery and the noise levels generated by those departing flights as I cannot locate this data in the Draft EA June 2015 report or any supplemental documents provided by the FAA and assume that they are unknown because no scientific monitoring was included in the Draft EA.

The final treasures which need to be addressed though not a national treasure are educational treasures.  Point Loma Nazarene University is located just north of Fort Rosecrans Nation Cemetery.  Increased noise levels resulting from increased departure traffic over land resulting from the elimination of the LOWMA waypoint will significantly impact this learning and teaching institution that was not built to mediate higher noise levels.  Furthermore, increased over land air traffic will impact several other schools not currently impacted by noise they include, Sunset View Elementary Dana Middle Schools, Silver Gate Elementary  and Warren Walker Elementary School.

Eliminating the LOWMA waypoint becomes an intense safe issue.  Under the current LOWMA waypoint departure path Point Loma is flown over only once per departure.  Under the NextGen Initiative Point Loma will be flown over twice with many of those flights not only over homes but also over schools.



Proposed NextGen Action Flight Tracks


Section 5.8 – Air Quality

In the Draft EA section 5.8.3 it states, “Any operational changes that could result in an increase in fuel burn would occur at or above 3,000 feet AGL.  Procedures above 3,000 feet AGL are considered a de minimis action and would have little if any effect on emissions and ground concentrations, and are presumed to conform to all SIPs for criteria pollutants. Therefore, no further air quality analysis is necessary, a conformity determination is not required, and the Proposed Action would not result in a significant impact to air quality. The No Action Alternative would not result in a change in the number of aircraft operations or air traffic routes; therefore, no impacts to air quality would be anticipated.”

First off, as stated in Section 5.71; In comparison to the No Action Alternative, the Proposed Action would result in a relatively small increase in aircraft fuel burned: 0.33 percent increase in 2015 and 0.33 percent increase in 2020.  Since there is a .33 percent increase in fuel burn it is impossible to have “no impact to air quality”.   I would argue that there will be increased impact to air quality.  Assuming 48,269 POGGI 5 departures and then assuming only two gallons of fuel per departure, a total of 96,538 gallons of fuel would be burned.  A .33 percent increase in fuel burn would result in 318 gallons of additional fuel burned especially since most of the PAH’s will be deposited on land as opposed to water.

It is also stated in Section 5.8.3; “Under the Proposed Action there would be a slight increase in fuel burn (0.33 percent in 2015 and 0.33 percent in 2020) when compared to the No Action Alternative. While increased fuel burn corresponds with an increase in emissions, operational changes that could result in an increase in fuel burn would occur at 3,000 feet AGL or above and would not result in an increase in emissions and ground concentrations”.  This is impossible.  With planes that once flew over water now flying over land, there must be significant increases in ground concentrations of PAH’s.

What scientific methodologies were employed to come to the FAA’s conclusion?

Furthermore the Draft EA is mute on the potential for increased concentrations of PAH’s in the water shed.  Have there been any measurements taken on the volumes of PAH’s in the storm drainage system utilizing departure patterns that include the LOWMA waypoint?  How many metric tons of PAH’s would be discharged in 1.25 miles of departure assent that will take place as planes fly over land as opposed to water with the elimination of the LOWMA waypoint?  How many metric tons of PAH’s will be deposited on land by increasing the fanning arch?  What percentage of that PAH residue would make its way into the storm drainage system?  These are big questions given the California Air Resources Boards (CARB) commitment to limiting the amounts and increases of pollutants into the water shed.

With a storm what elevated concentrations of PAH’s would make their way into the offshore environment at higher concentrations than are generated by normal over water departures where fuel residue is dispersed daily? Doesn’t any increase in pollutants into the water shed violate the Federal Clean Water Act and anti-degradation policies?

Once again the Draft EA does not address increased concentrations of PAH’s in the water shed as a result of changes to the flight path over Point Loma as opposed to keeping the LOWMA waypoint and directing flights over water instead of land.


A key reason behind removal of the LOWMA waypoint is fuel cost savings to the airlines; these cost savings are not directly addressed in the Draft EA.

The only way that the Draft EA attempts to shed some light on fuel cost saving is in combining several sections together which would allow for an analysis of costing.

Table 1-2 assumes 1,497,617 IFR per annum throughout the Southern California Metroplex.  Though not in the Draft EA, purported saving from implementing the NextGen procedures would result in a savings of $7.8 million throughout the SoCal Metroplex.  Assuming $7.8 million in saving for 1,497,617 IFR’s the net cost equates to $5.21 per operation.

$7,800,000 / 1,497,617 = $5.21

San Diego accounts for 186,650 of the annual IFR’s.  Assuming a 50/50 split between departures and arrivals and that 52% of the departures would be southbound heading toward POGGI 5 the net savings for the 48,269 POGGI 5 departures would be $251,398, a relatively insignificant amount.

48,269 * $5.21 = $251,398

However according to the Draft EA there would be a .33 percent increase in fuel consumption under the NextGen new flight path scenario that eliminates the LOWMA waypoint, thus there is no fuel cost savings.  Please enlighten me if my mathematics is incorrect, as I could find no direct analysis as to cost savings incorporated into the Draft EA.


Has the FAA done a fiscal impact analysis to determine losses in tax revenues to San Diego City/County as a result of property devaluation of the homes that will be under the flight path with the elimination of the LOWMA waypoint?

As a real estate analyst I conducted an analysis of the potential impact to property values and property tax revenues to San Diego City/County as a result of increased air departure traffic in areas which heretofore had not been impacted by air traffic noise.  Since it would be extremely difficult to address overall property value losses on all homes on the southern end of the Point, my analysis focuses only on property values/taxes losses associated with homes sold over the next 10 years.  Over the past several years, housing values in the southern portion of Point Loma defined as the neighborhoods south of Narraganset Avenue increased over 35 percent from $841,051 in 2010 to an average of $1,136,377 through the end of September 2015, Table 1.

Table 1

Southern Point Loma Single Family Detached Resale Values and Sales Volumes


In our analysis of property values and property tax loss we wanted to take a very conservative approach.  As noted earlier values over the past six years have increased 35.1 percent or 5.8 percent per annum as compared to 6.5 percent per annum over the past 15 years and 7.5 percent annual over the past 25 year.  Our analysis indicates that the southern portion of Point Loma has registered an average of 237 detached homes sales annually.  For this analysis we assumed only 200 homes sales per annum, additional sales would only increase tax revenue loses.

Assuming the five percent increase in property values over the next 10 years, the average price of a resale single-family detached home on the southern end of Point Loma would be $1,193,196.  Assuming 200 transactions the gross assessed property values of these 200 transactions would be $238,639,139 which equate to $2,386,391 in property tax revenues.  By 2025 assuming the same five percent annual increase in values the 200 sold that year would sell for an average of $1,851,038 yielding a gross assessed value of $370,207,630 which equate to $3,702,076 in property tax revenues from those 200 home sales.

Next we focused on the value differential for single family homes located north and south of Narragansett Avenue, homes north of Narragansett Avenue being considered impacted by departure flight operations while homes south of Narragansett Avenue, not so much.  The first analysis looked at all detached homes north and south of Narragansett Avenue which yielded a 48 percent differential in values, $661,455 vs $447,610.  However part of that differential must be attributed to the differential in average home size 2180 vs 1578.  A note however is the differential in price per square foot $303.48 vs $283.71.  As a general rule, as average home size get smaller, the average value ratio (price per square foot) gets higher due in part to the wet-core factor in a home, baths and kitchens. An analysis of the differential in values between the northern and southern portions of the Point indicates an outside impact on values, i.e. airplane takeoff noise, Table 2.

Table 2

Aggregated Single Family Detached Home Values South of Narragansett Avenue.

Next we focused on homes sold since 2010.  This analysis yielded a 46 percent value differential; $998,397 vs $$681,882, however again part of the differential can be attributed to home size differentials, Table 3.

Table 3

Aggregated Single Family Detached Resale Values South of Narragansett Avenue

Homes Sold 2010 – September 2015

Therefore in order to produce a more apples to apples comparison we focused on the value differential north and south of Narragansett Avenue but only for homes offering over 2000 square feet of living space.  This analysis yielded a 35 percent differential in values, Table 4.

Table 4

Aggregated Single Family Detached Resale Values for Homes

Sold 2010 – September 2015 and

Restricted to Homes Featuring More Than 2000 Square Feet of Living Space

Using an average of 200 home sales for the southern portion of the Point and using current 2015 home value of $1,136,377s shown on Table 1, and assuming a 10% decrease home values as a result of increased noise from the NextGen Initiative flight path which eliminates the LOWMA waypoint, San Diego City/County stands to lose $1.5 to $3.0 billion in loss property values which translates into $15 to $30 million in loss property tax revenues to the San Diego City/County over 10 years?  Taking those compounded tax revenues losses out an additional 10 years to 2035, the City/County stand to lose between $71 and 142 million in loss tax revenues.

Is no fuel cost saving worth $15 to $30 million in loss property tax revenues over the next 10 years and upwards of $142 million over the next 20 years? Dollars that could go to fix public streets, hire first responders, pay pension.  My guess is that the San Diego City/County would find those losses unacceptable.