Guest Opinion | Keep Eastsound Airport a Rural BII Short Runway

— from Clark Cundy —

Please take time and get some coffee. If you take time to read this, thank you for your time.

In August, 2018 I posted a few ideas about Keeping Eastsound Airport a Rural Airport. Now a few weeks and meetings have gone by and the Port of Orcas/DOWL have posted a ‘preferred’ 20 year vision or plan of Eastsound Airport, for the public to consume and comment on until October 5. I attended the public meeting held by DOWL at the Orcas Center September 19 at 7:30. According to the DOWL schedule, posting comments or ideas after the date of October 5 DOWL and the Port will be moving toward implementation planning so I’m not sure what value any comments people possess in between now and then may have. I was unable to figure out how this particular preference of plans using weighted metrics via public comment, advisory board, DOWL, and the Port responses was arrived at. Also the original purpose of the plan is to rectify insufficiencies with FAA Air Safety Requirements. For a plan that didn’t intend an expansion, the plan goes a long way toward that end. Longer runway, bigger terminal, more tie downs and hangers, Parking lot…. My goal was to view the FAA Safety requirements and see if there were ways to visualize a master plan that could be implemented with the least impact to community and environment possible.

The following are some questions, concerns, and observations I have about the 20 year Master Plan. This letter will be sent to DOWL, Port of Orcas Manager, Commissioners as well as to the local public communication sights.

The Port of Orcas website website has two things of interest to me. One being a voluntary noise abatement procedure pamphlet.

Then on the Port of Orcas Master plan page a listing of people who evidently were invited to be on the Airport Advisory board to help build the new 20 year Master Plan. There really isn’t a public islander component on this committee, this is listed as a technical/tenant committee. Had there been a public component to this committee those public representatives could have, through citizen surveys, meetings, etc, weighed on their own the merits of the original options with the technical people also on the advisory board in an effort for more public consensus and transparency. Then DOWL could have created the Original Options from that. Part of those options then would have been derived from Islanders apart from flying providers plus external business and political interests.

The original Master Plan options provided to the public by DOWL/Port and used to help in the creation of the current ‘preferred’ Master Plan are no longer available on the Port’s websites. So unless you saved those documents for comparative analysis with the current Master Plan a person wanting to do so wouldn’t be able to. There is a short excel version but it’s hard to visualize what it’s telling you without the Airport diagram options in front of you.

The advisory committee list of names can be found here at the bottom. It is highly weighted toward commercial flying interests and local business interests.

• Noise abatement plan: Currently any noise abatement is voluntary and procedures for pilots are after you’re in the air. There’s plenty of noise on the ground before an aircraft takes off or lands but there really wasn’t any best practices for that. It’s good that the port has a pamphlet of best practices for aviators of the airport. It would really help if the pilots actually followed airport egress pdf in the air. There is nothing in the Master Plan figures 1-6 or the Power Point presentation that addresses noise abatement for the future. With the larger planes potentially coming to the airport a quantified noise abatement plan especially for commercial carriers on the ground and in the air are critical to the local neighborhoods and island peace in general. The master plan shouldn’t be implemented without one. I’ve been told that the FAA doesn’t normally fund noise abatement devices on the ground which is probably why DOWL didn’t include one since they were hired and funded by the FAA to start with.

Where we live is in the yellow noise sensitive area on the pamphlet. The hill just above us is about 500’ above mean sea level (MSL) so when the planes fly over our house heading to Friday Harbor they’re not at the 1500 feet Above Ground Level (AGL) as the pamphlets suggested flight level offers. Some mornings at 7:30 a.m. I would guess some of the planes are between 500-700 feet AGL as they go over the hill. We don’t need any alarm clock at 7:30 a.m… The windows rattle and it’s coffee time. Did I mention we are in the yellow ‘sensitive’ area in the voluntary noise abatement plan?… A codified noise abatement plan for commercial carriers at least needs to be written into the ‘preferred’ Master Plan. The commercial carries could really help keep the noise down if they just flew over the water channels. Stay out over the water keeping the flying noise out there. Further if there will potentially be bigger aircraft using the airport that may have reverse thrusters to stop faster causing all sorts of noise with that process. That will happen more often since the new terminal will be located at the South end of the runway, the physical location of the old terminal is far better suited to the airport since it’s located more in the middle of the runway. With the new Terminal location all commercial passenger traffic will be routed to the South End of the runway. So more ground noise on taxi or pilots will land further down the runway when landing to the south. Most commercial pilots will want to cut taxi time down by stopping faster making a bit more noise. There’s good reason to have a noise abatement plan for both ground and air to maintain as much as possible the quality of life in the nearby airport neighborhoods and those in the flight paths.

• Master Plan Figure 1: For the first 8 years nothing really changes and we remain a no build B-I airport except for an apparent land acquisition at the north end of the airport. So at this stage in the Master Plan it seems all the current safety violations remain intact? I didn’t see where in the Power point or diagrams where any safety violations would be addressed in the next 8 years. 8 years, I had to let that sink in a little. I was wondering just how bad can the safety violations really be if the Port is willing to accept this plan with the current Mt. Baker Road risk assessment? DOWL representatives kept repeating how bad and sad it would be if someone were killed if the Mt. Baker safety violation remained intact. And it would be a definite tragedy. In their plan, however, they have allowed for eight years of that risk to remain at Mt. Baker Road.

At the front end of the presentation DOWL representatives were stressing that the time frames of the plan could change at any time. Why in a Eastsound Airport safety and risk assessment would you as a consultant group be willing to suggest an 8 year waiting period of a listed major risk at the airport where you were suppose to fix the safety violations to start with? I can only assume that there is no liability to them with that suggestion and probably not much risk. It’s up to the Port to accept that risk as is obvious anyway since the Mt. Baker Road has been a violation for quite a while. This kind of thinking makes my head spin…

This is minor but I’m wondering why when you’re driving Mt. Baker road Westbound by Schoen Lane you see a ‘Low Flying Aircraft’ sign, to warn you to at least look before proceeding…But if you’re driving Eastbound on Mt. Baker road there is no such sign to offer those motorists the same advantage… Why is that? Mt. Baker Road being a major Airport safety violation for the Port in any of the plans offered seems to disregard Eastbound drivers?

• Master Plan Figures 2-3 and 5: Transition from BI to BII airport designation. The two big takeaways for me here are, runway is longer, and displaced thresholds are added at the ends of the runway. This makes the runway pavement longer now from 2,901 to 3,255 feet without newly included thresholds length included. According to the displaced Threshold definition I found ‘a displaced threshold or DTHR is a runway threshold located at a point other than the physical beginning or end of the runway.’ If you include the threshold length the runway length approaches 3,400 feet.

We were told the main impetus for all these safety changes are the Cessna 208’s wingspan that our providers now use. Cessna 208 aircraft need wider runways not longer than Eastsound Airport already has, Cessna 208’s wingspan is 2 feet wider than a BI airport is supposed to handle. Cessna 208’s can take off in 2,055 ft and land in 1,625 ft according to the spec sheet from Textron. Eastsound airport is already 2,901…Plenty of existing runway. And they weigh in at maximum takeoff weight at 8000 lbs. So the added runway length is not needed to support our provider’s aircraft or fix any of the safety requirements. So why the added length in the runway? I asked this question at the meeting and we went off topic in short order.

I then asked what kind of BII aircraft could be supported by a 3,400 runway and none could be named. I thought that interesting. I then added I saw a Cessna Citation CJ2+ a jet aircraft tied down at Eastsound in it’s current configuration? So really, what kind and class of aircraft are being invited to Eastsound Airport with the added length and why? I’m left to guessing the answer because in the new airport Master Plan runway length is not a FAA requirement to fix the safety violations the Master Plan is supposed to be addressing. Runway width and taxiway separation does need to be addressed but really that’s it. With the runway and taxiway separations the FAA is requiring the Airport to be in perfect spec creates the need for the old terminal and the bi-plane hanger to be removed and relocated. DOWL and the Port seem to not want to try getting a Mod to Standard (MOS) from the FAA to leave the old terminal. That is not be considered. Personally, I think the building could be upgraded/remodeled larger with the same architectural flavor to keep it retro and rural.

With the new Cargo Hanger going in on the West side (figure 4) of the runway further mitigates possible Cessna 208 wingtip conflicts with passenger aircraft making leaving the old terminal even more of an option and retain shorter taxi times. What will the new building be used for and who will its tenants be? It’s bigger, more tiedowns, has ugly metal hangers nearby that will need to be built by private money, more parking lot, de-icing area (I was wondering how many de-icing opportunities KORS had last year for UPS or Kenmore Air), and the open space is gone forever. I think the SE corner should remain open space and donated to the community into perpetuity. There was some talk in the meetings I went to of having a US Customs port to service the boating and air traveler needs. Oddly, Friday Harbor just opened up one this summer, KING 5 has a news video of it, and a new airline from Canada North-star Air has started scheduled flights. I can only imagine that North-Star Air would like and Orcas Stop added as well. A suggestion here would be to conserve Boarder service by making the new Friday Harbor check-point the only one for the San Juans. A conservation of resources and money. Passengers coming from Canada could check in at Friday Harbor and then North-Star Air could continue to Eastsound Airport and drop the checked in passengers off. That is unless the Aircraft at North-Star Air need a longer runway than we already have to support that class of Aircraft. North-Star flies Islander Super Q aircraft that only need 1,600 feet of runway to take off on to clear a 50’ obstacle. So that’s not the reason for the installation of a longer runway.

In the June airport Master Plan F meeting at the Fire Station there was a sort of off the cuff remark about potentially creating a US Customs port of entry at Eastsound airport to facilitate aircraft and boat traffic. In a Jan. 19, 2018 newspaper article the Port suggested exactly that. DOWL didn’t cover any of that aspect of the new expansion at the last meeting I went to. Does the island community want a permanent Federal presence on the island all the time? And what does that bring with it. One thing it brings with it are US Customs Aircraft. Here’s the link: www.cbp.gov/border-security/air-sea/aircraft-and-marine-vessels. So the new bigger BII faster aircraft, Cessna Citation, Beechcraft King Air Series 200 (as long as the crew kept the max takeoff weight under 12,500 lbs)., two drones plus Border Patrol Boats probably in Brandt’s Landing

Personally I don’t want a US Customs or ancillary ICE or Border Patrol port on Orcas. Nothing has been said as to whom the tenants will be in the new terminal building or what that intent is or was. I do think the Port/DOWL need to be as clear with the community as possible on the net effect of having Customs and Boarder Patrol point located on Orcas. As far as the Island Community goes I think we as Islanders at least need to know the answer to the US Customs entry port question or who the new tenants might be, so we go in with our eyes open.

Potential New Risks: Longer runway length may invite pilots to use the displaced threshold as runway length. According to the Displaced Threshold definition it’s okay to do this on takeoff but not landing. Is the community willing to take this added risk?

Example: A question for the community is how far do we want to go with the type of aircraft served. Driving by the airport the other day I observed a Cessna Citation cj2+ at the tie downs. I have a picture but didn’t post it due to the fact that the call numbers are on the tail. This is a jet aircraft. It has a maximum takeoff weight of 12,500 lbs, Takeoff distance 3,360 ft and Landing distance 2,980 ft. Please remember that Eastsound airport runway is currently listed at 2901 plus blast zones. The new Master Plan runway length is listed as 3,255 on figures 2-3. This plane does have a lower approach speed but why was it here? So do we as a community want to support that way of thinking, with the added risk when it involves a jet aircraft? Safety left to individual pilot discretion? We could play ‘what if’ on a bunch of different levels but I think the point is taken. If the runway pavement is lengthened to include displaced thresholds it may invite pilot behaviors and risk we don’t want. It’s hard enough already to get pilots to use the voluntary noise abatement policy for departures and arrivals. To me, letting those type of Aircraft into Eastsound creates a new Safety Risk that can only be fixed by an even longer runway.

The new displaced thresholds don’t help with the RPZ Safety violation at the south end of the runway and Mt. Baker Road at all, in fact it makes that worse due to the new runway length being added moving further south the current pavement, especially if you include the displaced thresholds. Master Plan wise it’s okay only if Mt. Baker Road is moved or the Safety violation mitigated. Mainly because the Master Plan will be using runway length without threshold, but Mt. Baker road is closer to pavement end and pilot wise its left to the pilot’s discretion on threshold use. If you take the Master Plan to the next step the plan does move Mt. Baker road and the RPZ further south, at that point, but until Mt. Baker’s safety violation is mitigated or the road is moved a potentially worse safety hazard than before. This could accelerate the time window and the need to move Mt. Baker road sooner than the 20 year time frame. That would be sometime within figure 2 time frame 8-19 years.
Figure 4: This upgrade looks good to me and provides separation of Cargo aircraft from passenger aircraft. It also provides an updated facility for cargo workers moving orders in and out of the airport. Grass tie-down for camping next to small general aviation planes are also provided.

Figure 6. Brandt’s landing is heavily impacted by the plan with regard to property acquisition, and at the last public meeting DOWL stated that some agreement might be attained with the owners of the landing to facilitate the taxiway and dig more ditch to move the docks. The Airport commissioners have evidently signed a document stating and stored by the state that they will not use Eminent Domain for the airport property acquisitions. They should post a copy. For me if the landowners are willing then that’s a zero sum deal. The Brandt landing business will remain with new dock space. Again, all of this is for FAA spec’s of a two foot wingspan violation supposedly and creating a taxiway to the north end of the runway with the runway built to spec. I haven’t heard any figures as to how much all of this will cost the US taxpayers but it will be pretty substantial. And keep in mind that the Customs and Boarder Patrol Boats will probably be moored there with any security and fencing that goes along with that too.

In previous plans there was a fuel farm that could include JetA…I’m assuming that the 100 octane will still be available for the general aviators, but Eastsound Airport, I don’t believe, should offer JetA at any level. Offering JetA will only entice the larger aircraft that use Jet fuel. When pilots are playing around with weight and runway length both coming and going it’s best not to offer anything to come in light with. There probably wouldn’t be much, if any, Return on investment for local users of JetA to justify the expense of that part of the new fuel farm installation. If there’s a Customs and Boarder Port here the Port will probably be required to install JetA tanks and then if memory serves the Port will also need to apply for a government fueling contract permit or license. Since we are in earthquake country any breach of the fuel tanks the fuel could end up in the aquifer. I haven’t seen what kind of fuel or what kind of capacity or location the Port/DOWL are proposing.

In the DOWL presentation at Orcas Center there were statistics based on speculation of future airport traffic deplanements, etc., to help justify the new airport expansion. The FAA shouldn’t be the entity dictating to the community how much airport capacity Orcas Island should endure over time. The Island community should be the entity that dictates it’s own airport destiny. In the DOWL power point presentation there are a lot of statistics on growth into the future. The community in the capacity planning of how much and what kind of air traffic it wants should take precedent over FAA speculation and not be subservient to them. The community should be able to pick the level of capacity that the airport should run at and what islanders are willing to accept as the safety risks, noise, air pollution, et. al, that goes along with that. In the meantime all the business interests involved should be able to continue to make money.

Since the safety violations were the supposed reason for the new airport Master Plan I’m for keeping the existing runway length at 2901 and removing the blast zones that are being used as added runway length…That will maintain all the service we are now used to having by providers like UPS and Kenmore Air, but help keep the larger faster aircraft out. Personally I want nothing to do with a Federal Customs or Boarder Patrol point here on Orcas. There are two already around locally, Friday Harbor and Bellingham. There are strings with that set up as there were strings with the FAA grants and loans that KORS had starting accepting way in the past. Now the FAA is sitting in the catbird seat telling the Port of Orcas its either take more money and do what we want or repay everything we’ve given you in the past, which isn’t really a financial option. So mitigate their financial power by just fixing the safety violations and not building a terminal and runway to support Customs and Boarder Patrol.

To me Mt. Baker road Safety Violation has three options.

• Do nothing and accept the risk, that violation has been there for years without event. Even if you move Mt. Baker Road it’s still in the glide or takeoff path. I don’t think moving it solves much other than achieving an FAA spec number. There’s still the risk of a vehicle being hit by the larger faster aircraft now using the longer runway. It’s a matter of FAA spec. An arbitrary number picked out of the blue.
• Using modern tech for aircraft detection and location on departure and landing (maybe the current GPS landing system could be used), place two lights on the side of the road (no barricades, bells or whistles), for westbound and eastbound traffic. The plane is only actually over Mt. Baker road for a couple seconds so normal traffic you get a green light, a plane on approach or takeoff you get a yellow light, and when an aircraft passes a certain point, a few seconds say 10 you get a red light. Traffic stops momentarily then goes again…Safety violation solved. This type of system was offered in the original set of options but wasn’t mentioned in the ‘preferred’ plan.
• Dig a tunnel. Violation solved.

So the ‘preferred’ Master Plan runway is wider, longer, terminal is bigger, more tie downs, new bigger better cargo hanger. Maybe the initial intention was not to expand the Airport but it looks like that’s exactly what happened. The unintentional consequences of the Master Plan morphed into unintentional Airport Expansion and the original now dubious intent of the Master Plan to fix Safety Violations has had scope of project creep to now include options for potentially a Federal Customs and Boarder Patrol station. The community really needs to discuss this Master Plan Scope Creep before letting all that in here. Once here we will be hard pressed to have it removed.

That’s my 2 cents.