The Mammoth Yosemite Airport’s (MLH) Airport Layout Plan Updated Narrative (ALPUN) took a major step toward being submitted to the Federal Aviation Administration (FAA) on Tuesday.

The Mammoth Lakes Airport Commission, meeting for one of the last times before it merges with the Mobility Commission to form the Transportation Commission, passed the ALPUN unanimously, with errata and some other language changes added.

The current ALPUN is designed to supersede the 2000 ALP. According to Town Staff’s report to the Commission, the new narrative points out FAA items that need to be either addressed directly, or reviewed for potential modifications or waivers. The ALPUN is an intricate document, made up of input from the Town, airport design and constructions consultants Mead & Hunt, as well as considerable public comments on virtually every facet.

Staff maintains that, per Mead & Hunt’s analysis, that certain reservations expressed by the public about aspects of the airport’s needs, especially if it is to be upgraded from a B-III to C-III facility, must take into account that there really is no airport “standard.” This condition is, staff insisted, common at many airports, and it wouldn’t be unreasonable to expect that the FAA might grant waivers or other considerations.

In terms of forecasting enplanements, Staff pointed out that some of Mammoth’s peer airports’ statistics were used to formulate estimates, which are predicated in part on some key changes in new air service routes. Burbank, for example, has been dropped from consideration, and other routes are being scaled back somewhat. And the growth pattern has been adjusted down several thousand enplanements to appear more conservative, though some of that growth depends on Mammoth Mountain Ski Area’s continuing commitment to subsidies.

Airport Commissioner John Walter noted that MMSA’s winter forecast only doubles the number flights over 20 years.

The ALPUN isn’t without its critics. Stephen Kalish and Owen Maloy, two of the Airport’s most vocal watchdogs, both submitted detailed comment letters, taking issue with everything from runway taxiway separation and safety areas, to hangar locations and a need to address the disposition of the Green Church, which they point out has impacts on the runway protection zone at the end of the runway.

“This ALPUN reminds me of a paper handed in at an exam I once proctored at USC. The girl who handed it in appeared to think she had done well. But when I looked at it, I saw that she had mistaken form for substance. The math was irrelevant and so were the sketches,” Maloy wrote via e-mail.

Kalish suggested that the revised ALPUN “geometry” would not be acceptable to the FAA, adding his concern that the document should be rewritten and rethought to either keep the airport at a B-III status (even at the risk of losing Horizon Airlines and its Q400 plane service) or provide an expansion plan, including moving hangers and taxiways, to upgrade MLH to a C-III facility.

Malloy, who was present at the Commission meeting, seemed to sum up their concerns in public comment.

“There is an FAA process for requesting modifications of standards … you have to address each one with separate documents,” he said. “The way this is being presented — moving the taxiway and hangers — you’re saying you don’t intend to do them. All you have to do is say you plan to meet [the obligations] eventually. Otherwise, you [irritate] the airlines and the FAA, which could bounce [the ALPUN] back.”

The way it’s composed now, parts of the ALPUN don’t comply with FAA rules and can be appealed, says Maloy.  He also posited that the FAA treats runway safety area improvements as “maintenance,” and not a capital improvement item, and suggested that those be removed from the airports Capital Improvement Project list.

Airport Director Bill Manning suggested the narrative was important to find out what the FAA has in mind. “The FAA will tell us what’s required,” he replied, “whether we’ll stay a B-III airport or change. We need to get the FAA’s response.”

One item that Maloy suggested he and Kalish would find favorable was Staff’s incorporating their idea to modify Environmental language such that “required environmental documents will be completed for all airport projects.” As opposed to a previous versions, which only mentioned Environmental Assessments, no specific reference would be made to either EAs or more formal Environmental Impact Reports, since at this point there is now way to determine which will be needed for particular projects.

“It’s being left intentionally open-ended, but I think we need to add that specific language to clarify our position,” Commissioner Thom Heller opined.

“In any case, it goes without saying we’ll follow the law,” Community Development Director Mark Wardlaw added.

Heller’s only other question was whether Manning thought that, given the Town’s precarious budget situation, we could pull off any of the projects. “Are we realistic in saying we’ll be able to meet some semblance of the timeline?” he asked Manning.

“The majority of the funding [for the new terminal expansion] will come from the FAA,” Manning answered. “The new terminal project is top priority, and the rest will have to happen as funding [from the Town and the FAA] becomes available, but yes, projects will be completed.”

Council is expected to also set a date for merging the Airport and Mobility Commissions, though according to Mobility Chair Sandy Hogan, a meeting of the two commissions to work out a smooth transition has yet to be set.

Seats on the Airport Commission are also up for re-election, though 6-year Commissioner Deb Pierrel this week sent a letter to Town Council saying that, “When my current Airport Commission term is up, I will not be seeking appointment to the newly transitioned Transportation Commission, nor any other current commission vacancies.”

Pierrel did express concerns about the merger as it relates to the airport’s future, saying that, “While I understand the mindset behind the commission restructuring, I would like to share one concern I have. The airport is in its infancy, really, and already in need of a new terminal building. It can be a huge benefit to our community and economic development if handled well, with proper oversight. It is a pivotal time in Mammoth fiscally, and my worry is that the Airport, with all of its issues and diverse needs, may not receive the constant and focused oversight I feel it is in dire need of, with a broader reaching commission.”

The Airport Commission will hold a joint meeting with Town Council at 5 p.m. on Wednesday, June 6 to discuss the ALPUN and other airport matters.