— from Margaret M. Manning —

August 3, 2018 To the Commissioners of the Port of Orcas:

Please consider the following comments for the Port of Orcas Airport Master Plan:

I am a full-time resident of Orcas Island who has owned property here since 2000 and who has lived here for more than 10 years. My husband and I practice health care regulatory law.

We use the airport frequently, both for business and vacation connections on Kenmore Air. I use Kenmore Air to commute to medical appointments in Seattle, where I receive all my medical care. Our firm depends on UPS/Aeronautical Services and FedEx for business correspondence and for items purchased online.

To date, we have been fortunate enough not to have required medical air evacuation for ourselves, our family, or our guests, but we subscribe to both services available and consider them critically important to island residents.

I was aware of the initial meeting but was out of town for it. I sought information on the Port website and found nothing helpful, and certainly nothing to indicate that the Port might be considering radical changes in the airport and the neighborhoods affected by it. I was unavailable for the next two meetings but reviewed the alternatives when they finally became available. I have fundamental concerns about the public communications used by the Port in this process, and about most of the changes that are being proposed for your consideration.

I have extensive experience in federal regulation and in both defending and opposing actions supposedly mandated by law. My initial question in any such action is WHY is this action being proposed? I have heard several conflicting and unpersuasive claims in this respect: That the airport is not compliant with FAA standards, (“In its present configuration, Orcas Island Airport does not meet the safety standards required to service aircraft currently using the airport such as the Cessna 208B Caravan.”) and specifically that the taxiway and runway are too close together, presenting the prospect of two Caravan-type planes’ wingtips colliding and that Mount Baker Road presents a threat to vehicles (usually, a school bus full of innocent children) passing under landing planes.

My first thought was, how can our Port operate an airport that is noncompliant with federal mandates? Is our airport unsafe? Should I stop flying on Kenmore? And what has changed over the past ten years to suddenly put us all in terrible jeopardy? The answer seems to be nothing much. Orcas Island Airport OBVIOUSLY meets safety standards require to service aircraft like the Caravan. It is doing so this very day. Are we supposed to believe that Kenmore sends its planes into mortal danger daily? It appears to me that the airport has operated without an incident that could be put down to airport safety defects for decades. The service by Kenmore, San Juan Airlines and FedEx doesn’t seem to have changed markedly for as long as I’ve been here.

The reason everyone is speaking in terms of “noncompliance with safety standards” (which is, of course, a fairly easy “scare” sell to concerned citizens) is that the FAA generally requires compliance with ITS standards if the airport wants FAA grant money. We are all to assume that the availability of grant money (soon a possible $1 million a year) is non- negotiable, and that our island must change to insure an uninterrupted flow of said grant money. (We’ve seen this phenomenon all too often: bureaucrats see grant money and go chasing it without serious consideration of the strings attached. That’s why we have an almost $3 million Interstate style concrete bridge in Deer Harbor, replacing a simple wooden bridge that was sufficient in the opinion of the residents there and the first responders asked about it.)

The bottom line appears to be that our airport is safe as it is. We might have to shell out some money to maintain it in the future without FAA help, but that discussion apparently wasn’t even considered by the consultants because their marching orders were to provide plans that would allow the Port to provide the requisite FAA grant assurances. (How much would it cost? How much per taxed parcel? Are there waivers for grant assurances?)

Is there a safety issue? On the field, we have a handful of Caravan flights a day. (I was told that there are no data about commercial or general aviation use, now or over the past ten years, which I find incredible.) It seems that, on average, Kenmore air runs three flights in here on Caravans a day and FedEx, one or two (I only have ever seen an afternoon FedEx.) I’m told there are now two locals who own Caravan-class aircraft. We are supposed to believe that four or five planes might collide on taxi and takeoff. I find that proposition almost ludicrous. First, they land on a regular schedule, perhaps two a morning, one at midday, and two in the afternoon.

Three of the flights are operated by the SAME company, and surely they are aware of each other and of Fed Ex’s schedule. I think we have more risk from earthquake and liquefaction at the field during an operation than of two Caravans “swapping paint.” Yet we are presented as feasible options major realignment of the airport, including taking land of adjacent property owners and moving our iconic terminal. Once again, we seem more motivated by the opportunity to “get grant money” and build a shiny new facility that no one I have spoken to wants.

Is there a safety issue with Mount Baker Road? Has there ever been a reportable incident? Where is the report? Vehicles spend mere seconds in the runway zone. Pilots are trained to land carefully, and following the instruments will never crash into the roadway. Despite these facts, we are being told that we must move the major highway on the island, and divert it through a roundabout (!) and several turns to save ourselves? Sorry, but that makes no sense. Nor does having traffic pour into Enchanted Forest Road near the schools. Our County has a longstanding commitment to rural character, and to avoiding suburban or big city infrastructure. It is a conscious trade-off from technical perfection.

Do we need new facilities at the airport? Not to my knowledge. I have heard that Aeronautical would like a bigger facility. And perhaps FedEx wants an indoor facility. So build one in the existing parking lot and rearrange parking. The de-icing facility seems particularly odd. Who flies in that weather?? And how have they managed it in the past?

I thought I also saw an alternative proposal to shorten the runway to make the Mount Baker Road issue disappear. But that would seem to threaten the availability of Caravan traffic. A bit spiteful, that seems. We need Caravans. Caravans have flown here safely for decades.

Perhaps I misunderstand the law and the facts. It would be good to have the populace educated about them then. The recent meeting supposedly designed to do so was a disaster. I recommend that the Port call another meeting and have it in a building that accommodates 200-300 people, because that will be the number who have questions and comments. And have the meeting after regular working hours so the people with regular jobs can attend. Also, have someone with better public relations skills chair the meeting. Be prepared to hear every person out, and be prepared to provide hard data about utilization or explain why it does not exist.

Either way, you should hold the September meeting already scheduled in a very large facility. The fire hall room is insufficient. The Port conference room is certainly too small. Perhaps Orcas Center or Odd Fellows Hall would suffice.

And you should make all the public comments available on the Port website right away. This is the least that the consultants could do to assist public participation.

Thank you for listening.

P.S. Doesn’t the Port have responsibility for other forms of access such as boat? Why is the Port website focused solely on the airport?

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