Will FAA buy half a cake?

How compliant does Mammoth-Yosemite have to be? 

Mammoth Lakes’ Airport Commission met Tuesday afternoon to hear a breakdown of the third-party peer review of the Town’s Draft Airport Layout Plan Update Narrative.

Prepared by the architecture and design firm of Mead & Hunt, the report evaluated the status of aviation forecasts, as well as airfield modifications and terminal expansion designs.

According to Mead & Hunt, the Narrative Report is fully “in conformance with aviation industry and Federal Aviation Administration (FAA) standards.” It did acknowledge that the Narrative is “more extensive than is common,” falling somewhere between a typical narrative and a full Airport Master Plan.

Mead & Hunt consultant Jeff Hart opined that the Narrative’s aviation forecast component is “aggressive, but not unreasonable,” when measured against a peer resort such as Aspen. Other criteria being similar, Mammoth is currently running about 200,000 enplanements behind Aspen, but by that same token has considerable growth potential.

“Resorts usually tie in their business plans with enplanements,” Hart noted. Commissioner John Walter, however, said he remains critical of the forecasting, which he suggested was based in part on 100 percent success rates that are “overly optimistic.”

A major focus of the Narrative, said M&H’s report, is how to address airfield features that don’t meet FAA standards for C-III aircraft. Most airports have “non-standard” conditions, which are due to the “evolving role of an airport, and/or the result of the FAA changing or adding standards over time.”

While the FAA doesn’t grant permanent modifications or waivers for such conditions, temporary or “bridge” waivers might be allowed to buy time for corrections.

“A lot of ‘fixes’ don’t seem financially feasible, let alone easy,” commented M&H Senior Planner David Dietz. “It’s going to be a lot more of the FAA deciding what are the important bits and how much they’re going to fund to accomplish them.”

Rejection of the ALP altogether is, he added, unlikely. The FAA, he elaborated, might ask to “show” a possible feature, but without a specific timeline if it’s deemed unlikely to ever happen. MMH, for instance, meets the standards for one feature most important to the FAA: the runway safety area (RSA). Sonoma County Airport, for example, is facing $40 million in RSA correction issues.

Mead & Hunt said MMH is facing its own challenges, but nothing on that scale. If it were, given a 10% match from the Town, “$4 million is a lot to come up with,” Dietz pointed out.

Dietz also outlined his take on the FAA’s role in the Airport going forward. “[The Town and Commission] have already established your vision,” Dietz said. “The FAA has no regulatory authority over the airport. It’s more of a soft, advisory or guideline type input, more zoning than code. But, if you take their grant money, then you have to do what they want.”

“It’s good to know that the RSAs are in compliance,” Commissioner Lee Hughes said, but added he wonders about including taxiway and hanger locations in the ALP at this time.

Commissioner Walter said he’s also concerned about disregarding the FAA’s previous informal [Narrative] comments. “We might be making it harder to [address] them if the FAA requires them in the future,” he said.

“It’s a tough issue at a lot of airports,” Dietz replied. “We didn’t find any practical alternatives [to hangar relocation and similar issues]. You might be asked to drop things from the ALP to keep the options open and keep things on a certain level of ‘non-standardness.’ The question will be is the FAA interested in half a cake?”

Hangar locations, Dietz submitted, aren’t likely to be an issue. “Worst case for upgrading from B-III to C-III aircraft classification is you need to run a grader and remove some brush.” MMH, he added, is already technically operating at C-III status anyway, with daily service by C-III class Bombardier Q400 planes already in existence.

M&H’s report indicated that for the next 15 years or so, it’s highly likely that MMH would continue to be served by Q400 and CRJ-700 aircraft. They also posited that market conditions and financial arrangements might also bring in slightly larger, but compatible aircraft such as the Airbus 319 (American has ordered 100) and the Boeing 737-700 or -800 models.

He also told the Commission it’s not about the runway, which he said is not an issue, but rather the terminal. “It’s all about peak loads, not daily but hour by hour. Can you handle 125 passengers on any given plane, as opposed to 75?” Dietz asked rhetorically. “The terminal needs to be expandable into the future. It’s not crazy to err on the side of flexibility.”

During public comment, Stephen Kalish questioned what happened to a 2006 ALP and whether it was rejected by the FAA at the time. He also questioned whether the RSA areas near the runway and their related grading conform to FAA standards.

Dietz responded that RSAs are typically fully vegetated, which isn’t the case in Mammoth and never will be. “An RSA isn’t intended to be like the runway,” he said, adding that only obstructions are to be removed. As to the 2006 ALP, Dietz replied that older ALPs don’t typically inform newer ones. “They’re a snapshot of where we are today … what’s the vision of the future.”

According to Airport Director Bill Manning, the ‘06 ALP was not really a plan, but requested by the FAA as part of an Environmental Impact Report process begun in 2005. It was, he added, “not rejected … it was just never signed.”

The draft Narrative Update will undergo changes from several comments along with basic corrections, and a version for approval will then be taken up by the Commission. From there it will be submitted to the FAA for its review.

“Once the ALP is approved, that will determine what projects are fundable,” Dietz explained. “The only question at that point will be whether to use FAA grant dollars or go for discreationary funding, which you’ll have to compete for on a regional basis.”

Walter said he would “reluctantly” support the draft Narrative, though “it’s more gamesmanship than laying out where we’re going to be in a few years.”