In a letter dated Jan. 22 to LB's the Mayor and Councilmembers cc'd to the City Attorneys office, Michael LoGrande cites what he calls "significant issues and potential unmitigated environmental impacts found in City of Long Beach's reliance upon Jacobs Engineering's Feasibility Study ("Study") evaluating the viability of constructing a Federal Inspection Services facility ("Facility") at Long Beach Airport ("Project"). Mr. LoGrande's letter challenges attempted reliance on a 2003 Environmental Impact Report (EIR) to avoid performing a new EIR before the City (i.e. City Council) authorizes measures (agendized for the Jan. 24 Council meeting) prerequisite to allowing a customs facility that would enable international passenger and/or cargo operations at LB Airport.

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In his letter dated Jan. 22, Mr. LoGrande writes in pertinent part:

...[D]espite the City's heavy reliance on its consistency with FEIR 37-03, neither Jacobs nor the City provides the original FEIR 37-03 evaluation to confirm any of the Study's conclusions and assumptions. Specifically, the following:

• Whether the Project poses new impacts or if new mitigation measures have been developed since 2006 (Study, p. 16).
• Whether the buildout studied under FEIR 37-03 is "apples to apples" to the buildout proposed for the Facility (Study, pp. 19, 26). Whether previously studied buildout was in the same location as the proposed sites (Study, pp. 26-30).
• Whether the future modification to the "airfield layout plan," requiring Federal Aviation Administration approval, was previously studied (Study, pp. 16, 20). Whether said modification would increase impact to existing receptors or expose new sensitive receptors?
• Whether air impacts would be greater than the noted incremental increase in air emissions (Study, p. 17), considering the increase traffic demand posed by Homeland Security, TSA agents, and other staff operating within the Facility.
• Whether operations at the Facility (400 passengers per hour) fall within the operational activities previously studied (Study, p. 24).
• Whether similar facilities recently developed at comparable airports (i.e. Fresno Yosemite, John Wayne) experience greater than expected noise impacts, induced traffic trips, etc. (Study, p. 25).
• First, the Study notes that international flights may be heavier aircraft (accommodating more fuel and luggage) and therefore have a "slightly greater" noise characteristics of domestic flights (Study, p. 18; App-B, p. 22). However, no detail is given about what is “slightly,” nor whether these noise impacts would be exacerbated if international flights extend beyond those destinations the airport expects to serve (i.e. Canada, Mexico, Central America) (Study, p. 18). I am curious to what was experienced at Yosemite, John Wayne, and other airports on this issue.
• Second, while the City states international flights are unlikely to replace domestic flights since the airport traditionally operates at roughly 80 percent "slot utilization" (Q&A, p. 1; Study, p. 9), recent activity has shown slot utilization close to 100 percent with "all 50 slots scheduled on certain days in January 2017" (id. at p. 15). This may suggest that historical data is less reliable than expected and that the relatively small airport may lose service to domestic locations.
• Third, the Study’s 37,681 sq.ft. does not seem to compute (App-B, p. 4). If FEIR 37-03 evaluated 102,850 and 73,769 has already been built, only 29,081 sq.ft. remain; if you account for the 24,826 sq.ft. of future terminal improvements already approved, only 4,255 sq.ft. remain (id). While math was never my strength, these calculations need to be clarified.

Mr. LoGrande's letter asks that the Jan. 24 Council agenda item be continued "until a full Environmental Impact Report can be publicly reviewed in compliance with CEQA and all applicable City, State and Federal regulations," alleging that "reliance upon an outdated environmental analysis for an entirely different project is deceiving to the public."

In a publicly released Oct. 4, 2016 memo, the City Attorney's office acknowledges only that "if the Noise Ordinance is invalidated at some time in the future, the essential terms and existing regulatory conditions at the Airport would continue" until the City conducts and the Council approves some currently unspecified level of CEQA review, possibly including "mitigation" of new impacts resulting from reducing neighborhood protections or other changes to the ordinance...

...[I]f there is a successful challenge to the Noise Ordinance, the City could re-institute a sound attenuation program to install sound installation in homes and other noise sensitive uses located in high noise impact aras. Under this type of program, the Airport would typically provide examples and demonstrations of replacement doors and windows, ventilation systems and other sound insulating construction. The City would then contract with the property owner to install the insulation in return for an aviation easement...[Source: City Attorney Oct. 4, 2016 memo, p. 6.]

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