Councilwoman Miscikowski Asks for Answers from FAA & LAWA re Mayor Hahn's LAX Plans

Dear Mssrs. Kessler and Ritchie:

Under the proposed Alternative D of the Los Angeles International Airport Master Plan, the airport will undergo substantial changes which will impact a variety of sectors, including the communities, the airline industry, and the region. The plan is referred to as the "Safety and Security Plan" which reduces substantially the expansion in capacity and site footprint as proposed in Alternatives A, B and C.

While Alternative D has improved based on requests from the communities and from other constituents, it nonetheless raises some important questions. I have reviewed the Supplemental Draft Environmental Impact Report for the Master Plan and have determined that there are some specific issues that need to be further analyzed and addressed.

Security Issues

Alternative D is billed as the "Safety and Security" plan for LAX. The premise upon which the security proposals have been designed is to protect the "primary function" of the airport, which, presumably, is the take-off and landing of aircraft. Therefore, the separation of passengers and vehicles from the Central Terminal Area was a primary design component of Alt D to prevent against bomb or other dangerous activity which would stop air traffic at LAX. While the specifics of the technologies required to implement the security provisions have not been detailed in the Supplement, additional information presented in the accompanying SAIC report relies upon a series of assumptions which lead to the ultimate conclusion that Alternative D is safer than the no project alternative and safer than all of the other alternatives previously presented.

As in other areas of the Supplemental EIS/EIR, Alternative D leads to more questions than answers, particularly in the realm of security. First, the premise of protecting the "primary function" of the airport is one that deserves greater consideration. Alternative D, while claiming to diffuse passengers through separate entry points at the Ground Transportation Center (GTC), the Consolidated Rental Car Facility (RAC) and the CTA, actually makes those locations easier targets for terrorists or others wishing to maximize the loss of life in any one incident. This leads to the question of whether enough will be done to protect airport patrons versus airport operations? In addition, one well-placed explosive device on the automated people mover could just as easily debilitate airport operations and create additional risk to area hotels and businesses located on Century Blvd. just below the people mover. There are any number of scenarios that could be imagined that seem to be ignored by the security proposals contained within the current document.

Further, it is worth noting that the current environmental documents do not fully elaborate upon the technology and construction specifics of the proposed security enhancements. LAWA's own security consultants have acknowledged that their analysis is based on technology that does not yet exist. The electronic scanning of automobiles and trucks upon entrance to parking facilities, face recognition technology, and fast baggage screening at the point of entry at the CTA are components of the security plan that are required to make Alternative D work. If any one of these component parts is not yet developed, is too costly once developed to implement or is not commercially available at the time of construction then the plan does not work and security risks are imminently greater.

SAIC consultants have also stated that while costs for implementation of the security plan are unknown at this time, ultimately the airport would achieve savings through the reduction in security personnel required since technology would replace them. However, the Supplemental EIS/EIR states clearly that there would be "no cost savings for law enforcement personnel" in fact, estimates that security personnel would increase by 162 for airport police and that 12 additional LAPD officers will be required. Is the baseline for this analysis security staffing at LAX pre- or post-9/11? Given that the technologies do not yet exist, how do we even know what will be required to staff and maintain them?

Furthermore, LAWA's original intent was to create a security review after the approval of the EIR. However, the publication of the RAND study was an incentive to accelerate that review and incorporate the SAIC study into the plan release. If the security review was to come after the EIR approval by City Council, that suggests that any terminal structure can be made to be reasonably secure regardless of what was on the land use document. Otherwise, the security review by SAIC would have been incorporated at a very early date. Finally, should this be the case, it begs the fundamental question of why the plan calls for such aggressive construction and development of areas like the GTC to be located at Manchester Square, a mile away from the existing terminals.

There is also no discussion of how phasing of construction will affect the overall security elements. Since the CTA, people mover, and baggage transport facility are among the last components of the plan, how will the airport be protected, assuming the premise adopted by Alternative D, in the interim?

These discrepancies and the lack of detail for the actual implementation of the necessary security technologies are of grave concern. Other risk scenarios must be evaluated in this process.

Manchester Square

Because of the uniqueness and prominence of the proposed GTC at Manchester Square, its discussion deserves special attention. Ground traffic impacts remain a question for the GTC. The community has been assured to a certain point at forums such as the LAX Working Group that traffic impacts would be minimized through the Westchester community because access points to the GTC are limited to the 405/105 freeways, Lennox Blvd. and other points south.

If, however, access to the GTC is largely expected from the 405/105 freeways, then those freeways which already experience overcapacity from non-airport uses will incur additional traffic impact. This suggests that some airport-bound vehicles will approach from north via other routes, like Sepulveda, Lincoln, Centinela, La Tijera, and La Cienega much as they do today, even though the explicit design of the GTC is to make this access inconvenient for travelers.

The site footprint of the GTC as outlined in the land use plan raises further questions. If passengers are just moving through the GTC with no concessions or amenities, does it need to be of the large size as suggested on the plan's maps? What uses are called for in a facility the size of the GTC other than security devices? Alternative D is unclear on this. And if efficient passenger throughput can be achieved in a smaller facility, can it occupy either a smaller footprint in Manchester Square, or can it be located elsewhere? All of these issues raise the question of whether the GTC as located at Manchester Square will provide truly adequate security mitigation consistent with the costs associated with this aspect of the project.

OTHER ISSUES

The draft documentation provided on Alternative D raises some significant additional concerns. One issue that appears to be under-addressed are the potential environmental impacts of the construction of the underground baggage transport facility. Some areas of the plan refer to the baggage facility as a part of the current proposal while others identify it as a potential future development. It seems that regardless of whether it is in or out of the current proposal, it should be evaluated as a part of the Master Plan. Placing a baggage transport system underground will have significant impacts - both during and after construction. How far below grade would this system need to be? What are existing physical limitations - both man made and natural that would affect the feasibility of this system? If the system is never implemented, how and where do the TSA requirements of 100% baggage screening get addressed? Currently there is little to no discussion of the myriad of issues including construction impacts, geological impacts, impacts of the water table, impacts on public utilities, relocation of public and other utility lines, and excavation requirements just to name a few.

Cost

If the LAX Master Plan calls for limited or no capacity expansion plus safety and security improvements, then a cost of $9 billion is inconsistent with the basic goals of the "Safety and Security Plan." Surely these laudable goals could be accomplished at a lower cost. Could not basic security and safety measures be implemented at LAX for $2 billion, while reducing gates to limit capacity, increasing airfield safety, proving connectivity to public transportation and making LAX the crown jewel of a truly regional air transportation system?

While no new taxes will be used to fund the project, we will have to rely on bonding measures for part of the project's financing. The capital markets recently issued LAX the highest bond rating for any airport in the U.S. and LAWA's financial team is to be commended for their extraordinary work in helping to mitigate to devastating effects of 9/11 on the airport and the industry. However, the bonds needed to meet their corresponding part of the plan's financing will place substantial financial burden on LAWA and its tenants, and may threaten its current bond rating which has allowed the City to save millions of dollars per year in interest charges by refinancing existing debt at lower rates.

The airline industry will be a substantial source of funding for this project. Assessments to the airlines will come in the form of passenger facility charges (PFCs) and sources. Currently, airlines at LAX enjoy low cost-per-enplanement (the cost of putting one passenger onto an airplane) as compared to other airports, due in part to the fact that LAWA has less debt service that it is currently passing on to the carriers. Cost-per-enplanement will nonetheless quadruple or quintuple at LAX as these assessments are incurred.

After the events of September 11, 2001 and due in part to the general economic downturn and subsequent reduction in business and pleasure travel, the airline industry is facing devastating economic impacts. As an industry that inherently has very high operating costs and capital investment requirements, the airlines are highly sensitive to fluctuations in their revenues.

Some airlines are currently in bankruptcy proceedings while others hover perilously close. Furthermore, some of the airlines currently operating at LAX, who represent a significant portion of the U.S. domestic and international travel markets, have expressed concern that they cannot incur these costs over the project's horizon and continue to provide service at LAX as their customers demand. While there has been some communication between the airlines and the planners, the airlines still feel that their concerns over project cost are unheard.

Other Alternatives Should be Examined

Of all the project iterations to date, one concept that has never been given enough thought is improving and enhancing the airport within the current physical layout. Creating transportation improvements like adding ATCS systems to more intersections, improving connectivity with public transportation, making security upgrades that will need to be done in the interim anyway, making runway modifications such as the South runway proposal, and terminal changes within the current physical layout can all be accomplished quickly and will have a real impact. These changes, combined with a consolidated transportation access location and a rental car facility could ultimately lead to a safer, more efficient airport that works better in the context of the surrounding community, truly caps growth, and costs significantly less than the soaring costs for Alternative D.

The RAND analysis of security identifies significant infrastructure improvements that can be done now, with existing technology, that will have a direct impact on the safety of airport patrons and airport operations. There are other proposals, such as the previously mentioned extension of Avion Blvd. as a dedicated cargo road and consolidated rental car facility that will significantly improve transportation access to LAX. The rental car facility alone will decrease over 1 million shuttle trips currently occurring because there are multiple rental car locations in and around the airport today.

By ignoring other options and issuing comparisons based on a "do nothing" alternative, we do a disservice to everyone. There is no question that "doing nothing" is not an option. This Master Plan should be one that achieves something real, at a reasonable price and not one that seems to raise more questions than it answers.

I urge your further consideration of these issues as you work to complete a true Master Plan for the future of LAX.