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The Loma Prietan
February 1999Runway Expansion Threatens SF Bay
by Richard Zimmerman
Photos and Graphics by Ted Horsch
The San Francisco International Airport (SFIA), owned by the City and County of San Francisco, is pursuing an expansion plan that would fill up to 1,332 acres of surface area in the Bay according to the Airport's Work-in-Progress Paper #2 (WIP2). That's 2.1 square miles or an area equivalent to over 1,000 football fields.
"We estimate the project would require as much as 200 million cubic yards of fill if the dredge and fill method of construction is used," says David Lewis, executive director of Save San Francisco Bay.
The San Francisco Bay Estuary, called the "most modified estuary in the United States," includes Suisun and San Pablo Bays as well as San Francisco Bay.
The loss of Bay lands has been extensive over the years. Almost 50,000 acres of the Bay and Bay lands have been filled according to the San Francisco Estuary Baylands Ecosystem Goals Project Report (Ecosystem Report). In addition, only about 69,500 acres of tidal marshes and flats remain of the 237,500 acres that surrounded the Bay in 1800.
Habitat loss leads to an increase in endangered species within the estuary. The Ecosystem Report focused on 121 "key species" that live in the Bay or Bay lands. Forty-four of those key species made the lists of endangered or threatened species in 1992.
Obviously a complete review of the mammoth fill envisioned by the Airport, as well as alternatives, should be completed before shoveling dirt into the Bay.
"We can't say what the impact of such a large project would be without more study," asserts Tot Heffelfinger, Bay Chapter member and National Wetlands Committee activist.
Feasibility Study
A feasibility study on runway reconfiguration is underway with a final report expected in January. While the Airport foresees a significant environmental impact due to the project, nothing in the feasibility study addresses environmental concerns directly.
One solution for SFIA's problem is to reduce its air traffic. Better utilization of the Oakland and San Jose Airports could lessen air traffic at SFIA, say environmentalists. A study by the Metropolitan Transportation Commission (MTC) in 1994 concluded that the Bay Area possessed sufficient Airport capacity.
The feasibility study touched on other methods to reduce air traffic at SFIA. Among alternatives mentioned are high speed rail service to Southern California; improved transportation between SFIA and other Bay Area Airports, primarily Oakland, which would make it easier for passengers to use those Airports; and expanding Travis Air Force Base to include civilian planes.
Not surprisingly, the Airport study concludes that the only viable way to achieve its goals is by building runways into the Bay.
No Public Information
There have been three "stakeholder" meetings, chaired by the Airport, to discuss the expansion. Stakeholders include the Loma Prieta Chapter, Save San Francisco Bay, airlines, and the Federal Aviation Authority, among others. Attendance at the stakeholder meetings is by invitation only - the public is not allowed. The meetings are private, Airport Director John Martin says.
San Francisco Mayor Willie Brown said he was "working busily behind the scenes" on the project according to the San Francisco Chronicle.
At the meeting on Dec. 11, 1998, Martin asked two representatives of the San Mateo County Times to leave. He announced at that time that he did not wish for participants to be restrained by the presence of the press and assured attendees that they would not be quoted.
Regional Capacity
At the presentation in December, Wanda Williams, SFIA Deputy Director, discussed Regional Airport Capacity. Williams presented capacity numbers intended to justify expansion. Advocates and adversaries of the expansion questioned the data presented.
The Airport delayed release of a report after the meeting citing "miscalculations that need to be corrected" according to the Chronicle. "The study needs to be refined to make sure it's consistent with other transportation studies," Martin said.
Advocates of the Bay questioned letting SFIA do its own regional analysis. "There needs to be a complete regional analysis by an independent body," said Keith Nakatani of Save the Bay. "The MTC should be leading the analysis. We shouldn't allow fast tracking a project just because of one Airport's perceived need," he added.
The Airport was objective in its analysis, said Martin. He did agree with Nakatani, in part, stating, "There needs to be a more complete regional analysis."
In addition to problems with the current report, past reports have been error prone. The SFIA stated as recently as 1993 that "current runway configurations will adequately handle projected Airport operations well into the next century." The $2.4 billion project under way at the Airport made no provision for runway reconfiguration.
Even as initial plans were being drawn up, the Airport implied that as little as 300 acres of fill would be needed, said wetlands advocate Ralph Nobles. The Airport had "gotten considerably more ambitious."
"The Airport has a real problem with credibility," summarized Will Travis, Executive Director of the Bay Conservation and Development Commission (BCDC).
Approval Process
Any Bay fill must be approved by BCDC. The mission of BCDC is "to prevent the unnecessary filling of San Francisco Bay." The Commission regulates any Bay filling or dredging activities. Approvals for such activities must be obtained before the project starts. The Commission holds public hearings on "major projects" which should include the Airport's plans.
Five BCDC members serve at the pleasure of the Governor. Willie Brown "is optimistic that his ally, (Gray) Davis… will appoint five new people… to the BCDC" reported the Chronicle. In addition to BCDC approval, an Environmental Impact Study (EIS) and an Environmental Impact Report (EIR) must be prepared.
The National Environmental Policy Act (NEPA) requires an EIS for projects that are Federal, deemed to be "major" and that will have a "significant impact on the environment."
The California Environmental Quality Act (CEQA) requires an EIR at the state level for the same reasons. Usually, since the EIR requirements are more rigorously defined, projects combine the two reports.
The EIS/EIR process starts with the naming of a public agency as the "lead agency." The City and County of San Francisco will be the lead agency for the state while the FAA will perform that function for the Federal Government.
The lead agencies then perform an Initial Study. The initial study is to determine if further, more detailed environmental studies, are needed. If more study is needed, a certainty in the case of the Airport expansion, work begins on the EIS/EIR.
The EIS/EIR, in contrast to feasibility studies, are disclosure documents available to the public. Public comment is sought at a series of meetings.
"Environmentalists have learned a required public review produces the best results," said Lewis.
An EIS/EIR provides the public, as well as state and local agencies, with detailed information on the possible environmental effects of a proposed project. A portion of the EIS/EIR must list methods by which significant environmental effects might be avoided or minimized. In addition, alternatives to the project must be studied.
If a project is deemed to have significant environmental impact, mitigation is considered. Denying a project is one way to mitigate environmental effects. Another method might be to trade off the loss of wildlife habitat at a project site by restoring habitat in another location.
The Airport is promoting an idea put forward by Nobles to acquire the Cargill Salt Ponds in the south Bay as a mitigation of the expansion. Cargill vehemently opposes the idea.
"Any discussion of mitigation is premature" says Debbie Ruddock, Loma Prieta Chapter Director. "Mitigation is designed to reduce environmental impact. We don't know what the impact of this project would be at this time."
"SFO's offer to fund an enormous wetland restoration project is laudable, but irrelevant. Mitigation cannot be used to buy a permit," says Travis.
Runway Rational
SFIA, at the stakeholders meeting, stated the reasons for the runway reconfiguration as:
Delay Reduction
The current runway configuration at SFIA consists of four runways. The separation between parallel runways is 750 feet. While simultaneous landings can take place on parallel runways in good weather, Federal Aviation Authority rules for landing aircraft restrict the Airport to one runway in bad weather which can lead to increased delays.
Instrument flight rules, used during bad weather, are in effect about nine percent of the time at SFIA according to the Work-in-Progress Paper 1# (WIP1) distributed to the stakeholders.
In good weather, states the WIP1, SFIA can accommodate a maximum of 105 planes an hour; bad weather can reduce that to as few as 65 planes per hour depending on which runways can be used. These numbers include takeoffs and landings.
Peak demand at SFIA is 45 to 55 landings per hour said Dan Blythe of the FAA. Because SFIA's runways intersect, landings and takeoffs cannot occur at the same time.
The feasibility study proposes new runways separated by 4,300 feet. No current aircraft need that separation.
Noise Reduction
A primary motivation for moving runways out into the Bay is noise reduction. Noise at Airports is a major problem for those who live near Airport flight paths. Shifting runways further into the Bay reduces the number of people in the "CNEL 65 noise level region" from around 5,000 to 300, according to SFIA.
CNEL is defined as Community Noise Equivalent Level and is based upon the length and time of the event as well as the actual noise level. However, according to an article in the San Jose Mercury News, the noisiest airplanes are due to be phased out by the year 2000, reducing the number of people in the noise impact zone. A significant decrease in noise levels at Airports is therefore expected within the next year.
A program costing $120 million to insulate homes that border SFIA is also under way. That program plans to reduce to number of homes subject to excessive noise to zero by the year 2000.
The combination of quieter airplanes and noise-insulated homes would make moving the runways to achieve noise reduction seem exorbitant when measured against the deterioration of the Bay. In addition, according to the Chronicle, environmental law specifically prohibits using noise as a reason for building runways in the Bay.
Ability to Handle New Large Aircraft
New large aircraft, carrying up to 1,000 people, represent a future dream of SFIA. These aircraft are not yet being built and no airline has ordered one.
Besides, the modification is not a requirement for handling the large planes. "...NLA operations could be accommodated without building all runways to NLA standards," states the WIP2 report.
Finally, Martin made an important point at a meeting with Peninsula Conservation groups last fall. "This project would meet our needs until 2020," Martin stated. The project might take up to ten years and $2 billion to complete, according to Martin and WIP2. That means the expansion into the Bay only has an expected lifetime of ten years before another solution must be found.
"We should look for the other solutions now," says Ruddock. "The Bay should not be sacrificed for the short-term advantage of SFIA."
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