· The Communications Director of the Airfield Development Bureau stated to the Budget Analyst that one of the "communication goals of the runway project" was to solicit information from the public. The Airfield Development Bureau has not done an adequate job of soliciting public input and presenting unbiased information pertaining to the Runway Reconfiguration Project.

· The Airport does not have a policies and procedures manual pertaining to public participation in developing the Runway Reconfiguration Project. In response to the Budget Analyst's request for such a policy and procedures manual, the Airport provided the Budget Analyst with a manual entitled "Press Code." This manual states that "The Press Code is designed to (sic) as a guide for the Airport in dealing with the press and other news media." However, the Press Code makes no reference to responding to or collecting community input. Rather, the Airport's Press Code is for purposes of "dealing with the press," and does not contain policies and procedures with respect to soliciting and considering information from the community. The use of a Press Code is an inappropriate standard for community participation in the planning and development process for the Airport's Runway Reconfiguration Project.

· The San Francisco Planning Department's Office of Environmental Review, which is the lead agency for the Environmental Impact Report (EIR) process, and the Federal Aviation Administration (FAA), which is the lead agency for the Environmental Impact Statement (EIS) process, are responsible for the regulatory requirements in the drafting of the EIR/EIS documents, including public participation requirements. However, the Airport has outlined the "communication goals for the runway project" as including (a) publicly presenting a series of four independent studies on the no-build options (alternatives that would not result in filling in the Bay), (b) presenting information to the public and (c) soliciting information from the public. The Airfield Development Bureau is responsible to the public for considering such input solicited from the public in developing the alternatives for the Runway Reconfiguration Project.

· Public meetings held by the Airport have not typically been structured to engage the community in the decision making process for the Runway Reconfiguration Project. The Airport instead uses such meetings to distribute specific information regarding the Runway Reconfiguration Project as part of a campaign to sway public opinion. For example, while one of the Airport's stated goals for communication with the public is to publicly present a series of four independent studies on the no-build alternatives, the Airport never issued a press release or formally presented a written review of those reports that was commissioned by the San Francisco Bay Conservation and Development Commission. The review provided an independent analysis of the Airport's contracted studies on the no-build alternatives for the Runway Reconfiguration Project. This failure by the Airport to present to the public all available information on the alternatives being considered in the Runway Reconfiguration Project indicates that the public meetings process was managed as an advocacy campaign to sway public opinion rather than as an unbiased education process.

· The Airfield Development Bureau's files show that at the beginning of the Public Information Program of the Runway Reconfiguration Project, the Airfield Development Bureau maintained agendas, minutes and responses to community questions. However, since approximately April of 2000, the Airfield Development Bureau has not maintained any minutes of public meetings. In addition, in interviews with the Budget Analyst, public meeting attendees stated that specific questions raised at such Airfield Development Bureau meetings were never responded to despite assurances by Airport staff that the Airport would respond to such public meetings attendees at a subsequent date. In fact, the Airport could not provide any documentation that Airport personnel have ever responded to questions raised by the public at Airfield Development Bureau meetings since approximately April of 2000. The Airport's failure (a) to maintain minutes of public meetings and (b) to respond to questions and concerns raised by the public at the public meetings indicates the Airport's limited interest in considering public input in the planning of the Runway Reconfiguration Project.

· Federal, State, and local regulatory agencies have requested that each alternative included in the EIR/EIS draft documents be given equal consideration, by both the Airport as well as by the lead agencies, the Planning Department's Office of Environmental Review and the FAA. However, meeting materials, press releases and other Public Information data contain no data that the Airfield Development Bureau gave equal consideration to all of the alternatives. The meeting materials provided by Airport personnel and consultants at public meetings typically focused on the benefits of runway expansion and emphasized drawbacks to the "no-build" alternatives. In fact, none of the materials reviewed by the Budget Analyst audit team listed advantages of the "no-build" alternatives. Rather such materials listed only the disadvantages of the alternatives not require filling in the Bay.

· The Airfield Development Bureau contracted with the ER Group for $100,000 for public affairs in Santa Clara County. Under that contract, the ER Group prepared a report entitled, Situation Analysis Report on Santa Clara County, which examines potential political obstacles to runway expansion at SFO. The report appears to be a form of opposition research, which offers strategies for promoting the expansion of the Airport, despite the fact that the Airport is prohibited to promote any one alternative over the other being considered in the drafting of the EIR/EIS process. The Situation Analysis Report concluded, "gaining political support from the Southbay regarding SFO expansion will be a difficult and time-consuming task. SFO must not only educate potential constituencies, they must avoid the political mire that could come with any political or policy decision made by the City of San Francisco body politic."

· Although the FAA considered the draft documents pertaining to the EIS to be exempt from the Sunshine Ordinance and instructed the Airfield Development Bureau not to release the subject documents, the Sunshine Task Force found that the failure to release such documents was in violation of the Sunshine Ordinance.

· A coalition of environmental groups filed a civil action in San Francisco Superior Court against the City of San Francisco and Airport officials to force disclosure of the documents concerning the Airfield Development Bureau's work on the draft EIR/EIS. On April 2, 2003, Superior Court Judge Garcia ruled that the Airport was required to release the documents to the public in accordance with the Sunshine Ordinance. The Airport reports that the subject documents were released to the environmental groups on April 7, 2003.

· The Airport withheld and delayed critical information from the Budget Analyst audit team. Budget Analyst audit staff originally requested a list of documents that the Airfield Development Bureau stated were under the FAA's control on October 16, 2002. Budget Analyst audit staff repeatedly requested that list of documents. Finally, on April 25, 2003, over six months after the initial request, Airport staff provided the requested list to the Budget Analyst.

· The Airport should develop and implement policies and procedures for community involvement in the planning of major projects. Such policies and procedures should require that community concerns and questions are documented and responded to in a timely manner and that community involvement is integral to the planning effort for major projects at the Airport. In addition, the Airport should conduct evaluations of the public meetings held by the Airport in order to determine the effectiveness of the public meetings process and in order to continuously improve the public meetings process.

Public Participation in the Environmental Review Process

Both the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA) have guidelines on noticing and public participation for projects with significant environmental effects, such as the Runway Reconfiguration Project. In fact, the CEQA guidelines note that CEQA's guiding policy is, "Public participation is an essential part of the CEQA process." The San Francisco Planning Department's Office of Environmental Review, which is the lead agency for the Environmental Impact Report (EIR) process, and the Federal Aviation Administration (FAA), which is the lead agency for the Environmental Impact Statement (EIS) process, are responsible for defining the scope of work in conjunction with the other regulatory agencies involved, including public participation requirements, and directing the URS Corporation in its work on the EIR/EIS documents. Therefore, this report does not review compliance with the regulatory requirements for public participation. Rather, this report reviews the Airport's efforts in public participation for the Runway Reconfiguration Project. The Airfield Development Bureau is responsible for planning, managing the environmental review process and providing administrative support to the lead agencies. In addition, the Airport has outlined the "communication goals for the runway project" as including (a) publicly presenting a series of four independent studies on the no-build options (alternatives that would not result in filling in the Bay), (b) presenting information to the public and (c) soliciting information from the public. "Soliciting information" would indicate a responsibility to collect and utilize community input in addition to disseminating information. The Airfield Development Bureau is responsible to the public for considering such input solicited from the public in developing the alternatives for the Runway Reconfiguration Project. It is also important to note that the Airport has repeatedly stated in interviews with the Budget Analyst audit team, through press releases and through the Airport's website that non-build options "will be considered at the same level of detail as the "build" alternatives in the ongoing Environmental Impact Report." In fact, throughout the drafting of the EIR/EIS documents, Federal, State, and local regulatory agencies have requested that each alternative included in the process be given equal consideration by the Airport and the lead agencies.

Public Information Program

Although the Airport initiated Public Information efforts from the inception of the Runway Reconfiguration Project, the Airport has not consistently documented the input from the public and has provided no documentation to demonstrate that such community input was considered by Airport personnel in the planning process for the Runway Reconfiguration Project over the last three years. Members of the Airport staff have stated that the Public Information Program is intended to "educate the public" on the Runway Reconfiguration Project. However, the Airport has no written policies or procedures outlining public participation in policy and planning for the work of the Airport or for the Runway Reconfiguration Project.

Since 1998 and through December 31, 2002, the Airport has expended $2,222,889 on Public Information including $1,668,052 for personnel and $554,837 for outside consultants. Since October of 1999, the Airfield Development Bureau has seconded (a) Cabellon and Associates for public information services under the Luster/GKO contract (October of 1999 through April of 2001), (b) Bay Relations for San Mateo public relations under the ADEC contract (December of 1999 through October of 2000) and the DMC contract (May through July of 2002), and (c) Keri Smith for communications services under the ADEC and Luster/GKO contracts (May of 2000 through August of 2001). Orgmetrics provided public outreach services as a subcontractor to Environmental Science Associates commencing in 1999. Furthermore, the Airfield Development Bureau has entered into the following three prime contracts for public relations, communications, and outreach services related to the runway reconfiguration project:

· Solem and Associates (Contract 7031.1 from November of 1999 until September of 2001, for a total budget of $340,000). Solem and Associates provided public affairs services.

· ER Group, LLC (Contract 7033.1 from July of 2000 to April of 2002, for a total budget of $100,000). The ER Group developed a public affairs program in Santa Clara County and the East Bay.

· Bay Relations (Contract 7032.1 from October of 2000 until July of 2002, for a total budget of $120,000). Bay Relations developed a public information program for San Mateo County.

The Airfield Development Bureau also received public affairs assistance for five regional forums held between May and August of 2001 from three seconded subconsultants under the DMC contract: GCI Kramer (logistics, May to October of 2001), NCG Porter Novelli (media relations and communications outreach, May of 2001 through April of 2002), and Dan Schnur (Bay Area strategy for community outreach, May to December of 2001). However, since September of 2001, the activities of the Airfield Development Bureau have been limited to the completion of the environmental and planning work necessary for the preparation of its EIR and EIS documents and all public relations, marketing, and lobbying contracts have been suspended.

Public Meetings

The Airfield Development Bureau's Files on Public Meetings Are Incomplete

The Airfield Development Bureau's files for public meetings held by the Airport on the Runway Reconfiguration Project are incomplete and the Airport was unable to provide a comprehensive list of public meetings held despite repeated requests by the Budget Analyst's Office. The Airport reported, and Public Information Program files indicated, that the Airfield Development Bureau held approximately fourteen Stakeholder meetings beginning on June 5, 1998 and ending on February 15, 2002. All subsequent Stakeholders meetings have been cancelled by the Airfield Development Bureau¹. The Airport held a series of six regional community meetings in June and July of 1999 in order to collect public input on the scope of the EIR/EIS process. In addition, the Planning Department's Office of Environmental Review, which is the lead agency for the EIR process, and the FAA, which is the lead agency for the EIS process, also held five public workshops on the alternatives to be considered in the EIR/EIS processes in April and May of 2000². In the summer of 2001, the Airport reports that the Airfield Development Bureau held four public forums with policy makers in San Francisco, Oakland, San Mateo and San Jose.

The Airport declined to provide the Budget Analyst audit team with public meeting minutes, agendas or meeting materials and directed the Budget Analyst audit team to the Public Information Program's files for all requested information on the public meetings process. A review of the Airfield Development Bureau's files for communications shows that documentation and maintenance of a record of community participation and input broke down in 2000 and was virtually abandoned in 2001 and 2002. The majority of files for Stakeholders meetings from 1998 until 2000 contain planning information, agendas, attendance lists, minutes and questions raised at the meetings, which were responded to in writing. The Airfield Development Bureau's files for 2000 show a decreasing responsiveness to Stakeholder and community input and questions. The majority of files on the public meetings process from 2000 onwards are not in good order. Files for public meetings held in late 2000 or after show, and Airport personnel confirm, that the Airfield Development Bureau discontinued taking minutes on public comments and also stopped responding to questions from the community in writing.

Public Meeting Attendees are Dissatisfied with the Airport's Responses and the Airport Declined to Provide the Budget Analyst's Office with the Agendas and Minutes for All Public Meetings Held for the Runway Reconfiguration Project

Interviews with public meeting attendees indicate that specific questions raised at meetings were never responded to despite assurances by Airfield Development Bureau staff that they would respond to them at a later date. The files for the public meeting process contain no evidence that Airfield Development Bureau personnel have responded in writing to questions raised at public meetings since April of 2000. For example, the file for the Stakeholders meeting held on February 7, 2001 is the last to contain any questions from the community, although there is no indication that any response was made to the questions included in the file. Files for the rest of 2001 and 2002 contain no agendas, no minutes and no lists of attendees. The Airfield Development Bureau's Public Information Program files show no indication that community comments were even recorded after February of 2001. In addition, it appears that the Airport never conducted surveys or evaluations on the public meetings process. Key personnel were unaware of any surveys or evaluations having ever been conducted during public meetings. Despite repeated requests, the Airport declined to provide the Budget Analyst's Office with the agendas and minutes for all public meetings held for the Runway Reconfiguration Project.

The public meetings process was not generally structured to encourage broad community participation and input in the planning process for the Runway Reconfiguration Project. For the Stakeholders meetings, the Airport collected a list of people who had expressed interest in noise impacts of the Airport or in the Runway Reconfiguration Project and notified those individuals of the Stakeholders meetings by mail in addition to posting notices for at least some of the meetings on the Airport's website. The majority of the meetings for which records are available in the Airfield Development Bureau's files were held on weekday mornings in the vicinity of the Airport, in nearby hotels or at the Airfield Development Bureau's Spruce Street office. The meeting sites were typically outside of the City and not very accessible by public transportation from the City. In addition, the formats for the meetings held by the Airport were generally structured around Airport personnel presenting information to the public and not collecting and utilizing comments from the community members present.

The Airport solicited and collected contact information from interested community members to be added to a database to receive information on the Runway Reconfiguration Project and receive notice of meetings. The Airfield Development Bureau's Public Information Program files contain records of emails that indicate that in at least limited cases Airport personnel have removed the contact information for those opposed to runway expansion and/or the work of the Airfield Development Bureau from the community list and recruited "pro-runway" individuals to attend Stakeholders meetings. In the professional opinion of the Budget Analyst, it is inappropriate to manipulate a public meetings process by removing individuals from the public notice database because the Airport does not like what they have to say about the Runway Reconfiguration Project. In addition, Airfield Development Bureau files contained correspondence from community members and groups that concerns of the community were not adequately addressed at the public meetings. The files held no indication that those concerns were responded to by Airport staff.

Policies and Procedures

The Airport Does Not Have Written Policies or Procedures Outlining Public Participation in Policy and Planning for the Work of the Airport or for the Runway Reconfiguration Project.

After repeated requests from the Budget Analyst for the Airport's policies and procedures for Public Information as they relate to the Runway Reconfiguration Project, the Airfield Development Bureau provided a copy of the Airport's Press Code as indicative of the Airport's policies for Public Information. The Press Code outlines the Airport's policies and procedures for "dealing with the media." In the professional opinion of the Budget Analyst, a Press Code is an inappropriate standard for involvement of the public in planning of the Runway Reconfiguration Project. Using a Press Code, which is a policy for disseminating information only and not for collecting information, as the procedure for community participation indicates that the Airport considers the public process for the Runway Reconfiguration Project to be more like a media campaign to sway public opinion than a forum for collecting and utilizing community ideas or concerns in the planning of the Runway Reconfiguration Project outside of the regulatory requirements being handled by the Office of Environmental Review and the FAA. Since the Airport and the FAA have not selected an alternative, it would be inappropriate to advocate publicly for one alternative over the other alternatives being considered in the drafting of the EIR/EIS documents. The Airport now states that the Press Code was not used as the standard for the Public Information Program.

Airfield Development Bureau "Communication Goals for the Runway Project"

While the Airport has no written policies and procedures for collecting and using community input and has not maintained complete records of the public meetings process, the Airport has outlined the "communication goals for the runway project" as: (i) "publicly present a series of four independent studies on the no-build option" and (ii) "an aggressive campaign to present and solicit information to the general public." The Airfield Development Bureau has not done an adequate job of meeting these stated communication goals for the Runway Reconfiguration Project. The "four independent studies on the no-build option," referenced above, are: Reductions in Flight Operations as an Alternative to Runway Reconfiguration at San Francisco International Airport, prepared by Charles River Associates (April 2001), Upland Airport Alternatives, prepared by J. Laurence Mintier & Associates (June 2001), San Francisco - Oakland Airport Connector: An Initial Investigation, prepared by Lea and Elliott, (June 2001) and Potential Future Contribution of Air Traffic Management Technology to the Capacity of San Francisco International Airport, prepared by the Independent Technology Panel (August of 2001). The Airport outlined tasks required for the public meetings as including various logistical details, "daily phone calls to ensure our supporters attended forum," and "write and distribute talking points for our supporters." However, the list of tasks for the public meetings does not include recording community members comments or responding to questions raised at the public forums. This oversight indicates a pattern of managing the public meetings process as a campaign to sway public opinion and not as a forum for public comment to be used in the planning process. The Airfield Development Bureau was unable to provide an adequate explanation of why the bureau did not develop or implement a policy for community involvement.

Sunshine Ruling

On April 23, 2002, the Sunshine Task Force heard a complaint regarding the Airfield Development Bureau's refusal to release documents related to the drafting of the EIR/EIS. The Airport claimed that it could not release the documents subject to the Freedom of Information Act (FOIA) and that the subject documents were under the control of the FAA because of "nondisclosure" requirements of the Airport's MOU with the FAA. The FAA considered the draft documents pertaining to the EIS to be exempt from the Sunshine Ordinance and instructed the Airfield Development Bureau not to release the subject documents, At that time, the City Attorney's Office advised the Sunshine Task Force that the Sunshine Ordinance does not have discretion to release the documents and to nullify nondisclosure requirements imposed by Federal law. The Sunshine Task Force disagreed and adopted a motion that on the grounds the requested documents were created by City participation and City funding, the Sunshine Ordinance did in fact apply, and that failure to disclose the requested records was a violation of the Sunshine Ordinance. The Sunshine Task Force motion found that the FOIA exemption does not preclude the Airport from abiding by the Sunshine Ordinance. The Airport continued to refuse to release the subject documents.

On August 8, 2002, a coalition of Bay Area environmental groups filed a civil action in San Francisco Superior Court against the City of San Francisco and Airport officials to force disclosure of the documents concerning the Airfield Development Bureau's work on the draft EIR/EIS. The non-profit groups involved in the civil action are: San Francisco BayKeeper, the San Francisco League of Conservation Voters, and Arc Ecology. At a San Francisco Superior Court hearing held an October 31, 2002 before Judge James McBride, the City challenged the petition and requested that the case be dismissed based on the grounds that since the FAA was not a party to the case, the legal action was subject to dismissal because the documents in question were under the control of the FAA. The City's challenge was in the form of a procedural motion called a "demurrer," with the related motion to dismiss, and did not go to the actual merits of the case.

The Airfield Development Bureau is Ordered to Release Documents Withheld from the Public

At that time, Judge McBride ruled that the case could go forward in Superior Court without the participation of the FAA as a party. A subsequent hearing on the case was held on February 18, 2003, presided over by Judge David Garcia. On April 2, 2003, California Superior Court Judge Garcia ruled in the petitioners' favor, requiring the City to release the documents to the public in accordance with the Sunshine Ordinance.

Budget Analyst audit staff minutes from the entrance conference on October 16, 2002 state that Airfield Development Bureau staff would provide a list of the documents under the FAA's control that were the subject of the civil action. However, the Airfield Development Bureau failed to provide the Budget Analyst's Office with the list of the subject documents despite repeated requests. Airfield Development Bureau staff also stated that "we do not recall agreeing to provide a listing of those documents." The Budget Analyst audit team repeatedly requested access to either the subject documents or a list of the subject documents. The Airfield Development Bureau stated several times that it does not possess nor control the documents and in one case stated that it "does not have a listing of any documents other than the ones that were transmitted to your office in October 2002," implying that the Airfield Development Bureau had no knowledge of any documents not available to the public.

On April 4, 2003, the Budget Analyst's Office received a memo from the Airfield Development Bureau staff dated April 3, 2003 stating that the documents in question "are not received by ADB and we would not be able to provide these documents without the express consent of the FAA," despite the prior ruling of the San Francisco Superior Court. These statements by Airfield Development Bureau indicate that staff were either unaware of the proceedings of the San Francisco Superior Court, which the Budget Analyst believes is unlikely, or willfully chose to violate the ruling of the Superior Court.

On April 25, 2003, Airport staff provided a list of documents related to the EIS drafting that have not been made available to the public or received by the Airport. The Airport stated that the documents, which were prepared by URS and are in the custody of the FAA, have not been provided to the Airport. However, the Airport states that Office of Environmental Review and Airport personnel review the documents in the FAA's offices in the work to prepare the EIR/EIS draft documents. Airport personnel further state that in accordance with the MOU between the FAA and the Airport, the FAA and the Office of Environmental Review determine the adequacy of the work products for contract management purposes.

Results of Community Participation

It is difficult to determine from the Airfield Development Bureau's files what influence community input may have had on the work of the Airfield Development Bureau. The files on the Public Information Program contained no reports on community comments from the years 2001, 2002 or 2003. Interviews with key staff would suggest that community input from the meetings held by the Airport did not have much influence on the work of personnel and instead that the effort of the Airport was handled like an advocacy campaign rather than a public participation program. Several Airport staff members indicated that they believed the Airport had done a good job of "educating the public" on the runway project. However, none of the interviewed staff members indicated that they had used information collected from community meetings in any meaningful work in the planning of the project. Because the Airport never conducted surveys or evaluations on the public meetings process, it is difficult to determine any effectiveness or benefit from the Airfield Development Bureau's Public Information Program.

CEQA and NEPA Requirements for Public Participation

As stated previously, the Office of Environmental Review is the lead agency for the EIR process and the FAA is the lead agency for the EIS process. As the lead agencies, the Planning Department's Office of Environmental Review and the FAA are responsible for ensuring proper noticing and public participation in the preparation of the draft EIR/EIS documents and final EIR/EIS documents.

The results of the five public meetings held by the Office of Environmental Review and the FAA in April and May of 2000 are not reviewed here as they were organized and managed by those agencies and no records of those meetings are held in the Airfield Development Bureau's Public Information Program files. This audit also does not review compliance with the provisions of CEQA and NEPA as that compliance is being managed by the lead agencies for the EIR/EIS processes. The notice for the six regional community meetings held by the Airport in June and July of 1999 in order to collect public input on the scope of the EIR/EIS process, stated that "the Airport will keep a record of the input from its community meetings as well as other meetings, and report that to the FAA for their scoping process." The Airfield Development Bureau's Public Information Program files do not contain any evidence of such a report to the FAA, however the URS Corporation prepared and submitted a report entitled Public Information Meetings Summary, which was a compilation of public comment at those meetings. The Airfield Development Bureau has apparently concluded that the efforts of the Office of Environmental Review, the FAA and the contractors working on the EIR/EIS documents are sufficient compliance with the requirements for public notice and participation.

The Airfield Development Bureau Indicated that it Had No Knowledge of Regulations on Public Participation

The Budget Analyst audit team repeatedly requested information on the Airfield Development Bureau's knowledge of regulatory guidelines on public participation in the EIR/EIS process. The Airfield Development Bureau repeatedly declined to provide any information regarding regulations on public participation and finally responded that they did not have any policy guidelines for public affairs, community involvement and publication of documents from any of the regulatory agencies involved in the EIR/EIS process.

Equal Consideration for Each Alternative

As stated previously, regulatory agencies have requested that the Airport and the lead agencies in the EIR/EIS drafting process ensure that each alternative included in the drafting of the EIR is considered in equal detail. In addition, the Airport has repeatedly stated in interviews with the Budget Analyst audit team, through press releases and through the Airport's website that non-build options "will be considered at the same level of detail as the "build" alternatives in the ongoing Environmental Impact Report." However, several of the regulatory agencies that must ultimately approve the process and approve the Airport's and the lead agencies' selected alternative have expressed concern that the Airport had not given each of the alternatives equal consideration throughout the review process. In addition, the review of the Airfield Development Bureau's Public Information Program files, public meetings materials, and press releases indicates that each of the alternatives was not given equal consideration in the presentation of information to the public. The Airport typically used public hearings and meetings as an opportunity to distribute targeted information on the Runway Reconfiguration Project.

Meeting Materials and Press Releases Do Not Indicate that Equal Consideration Was Given to Each Alternative in the Public Information Program

The meeting materials provided by Airport personnel at public meetings typically focused on the benefits of runway expansion and emphasized drawbacks to the "no-build" alternatives. The review of those materials presented at public meetings further indicates a one-sided campaign to sway public opinion and not an effort to solicit community input. None of the materials reviewed by the Budget Analyst audit team listed benefits of the "no-build" alternatives.

A review of Airport press releases shows a pattern of releasing information biased towards runway expansion over the "no-build" alternatives immediately prior to public meetings or other strategic events. The press releases indicate the Airport's efforts to manipulate community participation in the public meetings and sway public opinion towards build options. The timing of the release of reports highlighting drawbacks to "no-build" alternatives indicated that the Airport presented reports as part of a campaign to sway public opinion against the "no-build" alternatives.

An example of the campaign strategies used in the Public Information Program is the release of the report entitled, Reductions in Flight Operations as an Alternative to Runway Reconfiguration at San Francisco International Airport, which was prepared by Charles River Associates in April of 2001. On April 24, 2001, the Airport issued a press release titled, "SFO Officials React to Independent Report on Alternatives to Reduce Delays Without Runway Separation." At the following Stakeholders meeting, held May 18, 2001, the Airfield Development Bureau presented the Charles River Associates report and outlined the drawbacks to using "demand management" techniques. The presentation stated that "demand management" would result in fewer air travel options, passenger inconvenience and higher fares 100 percent of the time. In conjunction with the presentation, the Airfield Development Bureau distributed press clippings to attendees from articles regarding the Charles River Associates report that had appeared in local papers.

Further, while one of the Airport's stated goals for communications with the public is to publicly present a series of four independent studies on the no-build alternatives, the Airport never issued a press release or formally presented the review of those reports that was commissioned by the San Francisco Bay Conservation and Development Commission and provided an independent analysis of the Airport's contracted studies on the no-build alternatives. This failure by the Airport to present all available information on the alternatives being considered in the Runway Reconfiguration Project further indicates that each of the alternatives was not given equal consideration in the presentation of information to the public under the Airfield Development Bureau's Public Information Program.

Regional Support and San Francisco Voter Approval

The Airfield Development Bureau has not surveyed participants in the public meetings process on the runway options or invited participants to evaluate the public meetings process. This lack of surveying and evaluating further indicates the one-way communication pattern employed by the Airport in the Runway Reconfiguration Project. In November of 2001 San Francisco voters approved Proposition D, which requires voter approval of any project that would fill over 100 acres of the Bay, by a margin of 74.4 percent to 25.6 percent. Proposition D did not specifically mention the Runway Reconfiguration Project. All of the build alternatives currently under consideration do require more than 100 acres of bay fill. Therefore, if the Airport selects any one of the current runway build alternatives for the Runway Reconfiguration Project, the project will require San Francisco voter approval in addition to regulatory agency approval before construction may begin. This voter approval requirement will necessitate a simple majority vote to approve a runway build alternative for the Runway Reconfiguration Project.

The Airfield Development Bureau did contract for a report entitled, Situation Analysis Report on Santa Clara County, analyzing "current positions of interested parties relative to SFO expansion." The report, produced by the ER Group, LLC, which was contracted for $100,000 to work on the Public Information Program for Santa Clara County and the East Bay, was not included on any of the lists of documents provided by the Airfield Development Bureau to the Budget Analyst audit team as reports available to the public. Instead, the Situation Analysis Report on Santa Clara County, appears to be a form of opposition research, which examines potential obstacles to runway expansion at SFO. The report begins by stating, "the following situational analysis breaks down current positions of interested parties relative to SFO expansion," and concludes, "gaining political support from the Southbay regarding SFO expansion will be a difficult and time-consuming task. SFO must not only educate potential constituencies, they must avoid the political mire that could come with any political or policy decision made by the City of San Francisco body politic."

Conclusion

The Airfield Development Bureau has not done an adequate job of meeting the stated communication goals for the Runway Reconfiguration Project. The Airport does not have a policies and procedures manual pertaining to public participation in developing the Runway Reconfiguration Project. In response to the Budget Analyst's request for such a policy and procedures manual, the Airport provided the Budget Analyst with a manual entitled Press Code. This Press Code is a policy manual for "dealing with the press," and not for collecting information from the community. Clearly, the use of a Press Code is an inappropriate standard for community participation in the planning and development process for the Airport's Runway Reconfiguration Project. The Airport now states that the Press Code was not used as the standard for the Public Information Program.

The San Francisco Planning Department's Office of Environmental Review and the Federal Aviation Administration are responsible for the regulatory requirements in the drafting of the EIR/EIS documents, including public participation requirements. However, the Airport has outlined the "communication goals for the runway project" as including (a) publicly presenting a series of four independent studies on the no-build options (alternatives that would not result in filling in the Bay), (b) presenting information to the public and (c) soliciting information from the public. The Airfield Development Bureau is responsible to the public for considering such input solicited from the public in developing the alternatives for the Runway Reconfiguration Project. The Airfield Development Bureau has a responsibility to the public to consider such input solicited from the public in developing the alternatives for the Runway Reconfiguration Project. Efforts of the Airfield Development Bureau to meet the communication goal to "solicit" public input have been inadequate.

The Airfield Development Bureau's files show that at the beginning of the Public Information Program of the Runway Reconfiguration Project, the Airfield Development Bureau maintained agendas, minutes and responses to community questions. However, since approximately April of 2000, the Airfield Development Bureau has not maintained any minutes of public meetings. In addition, in interviews with the Budget Analyst, public meeting attendees stated that specific questions raised at such Airfield Development Bureau meetings were never responded to despite assurances by Airport staff that the Airport would respond to such public meetings attendees at a subsequent date. This failure by the Airport to maintain minutes of public meetings and to respond to questions and concerns raised by the public at the public meetings indicates the Airport's limited interest in considering public input in the planning of the Runway Reconfiguration Project.

As stated previously, several regulatory agencies have requested that the Airport and the lead agencies in the EIR/EIS drafting process ensure that each alternative included in the drafting of the EIR is considered in equal detail. In addition, the Airport has repeatedly stated in interviews with the Budget Analyst audit team, through press releases and through the Airport's website that non-build options "will be considered at the same level of detail as the "build" alternatives in the ongoing Environmental Impact Report." However, meeting materials, press releases and other Public Information data provide no documentation that the Airfield Development Bureau gave equal consideration to all of the alternatives. The meeting materials provided by Airport personnel and consultants at public meetings typically focused on the benefits of runway expansion and emphasized drawbacks to the "no-build" alternatives.

The Airfield Development Bureau contracted with the ER Group for $100,000 for a public affairs program in Santa Clara County. Under the contract, the ER Group prepared a report entitled, Situation Analysis Report on Santa Clara County, which examines potential political obstacles to runway expansion at SFO. The report appears to be a form of opposition research, which offers strategies for promoting the expansion of the Airport, despite the fact that the Airport is prohibited to promote any one alternative over the other alternatives being considered in the drafting of the EIR/EIS process.

In addition, the Airport withheld and delayed critical information from the Budget Analyst audit team. Budget Analyst audit staff originally requested a list of the documents that the Airfield Development Bureau stated were under the FAA's control on October 16, 2002. Budget Analyst audit staff repeatedly requested that list of documents. Finally, on April 25, 2003, over six months after the initial request, Airport staff provided the requested list to the Budget Analyst.

The Airport should develop and implement policies and procedures for community involvement in the planning of major projects. Such policies and procedures should require that community concerns and questions are documented and responded to in a timely manner and that community involvement is integral to the planning effort for major projects at the Airport. In addition, the Airport should conduct evaluations at public meetings on the effectiveness of the public meetings process in order to continuously improve the public meetings process.

Recommendations

The Airport Commission should:

2.1 Develop written policies and procedures outlining public participation in policy and planning for the work of the Airport. Such policies and procedures should require that community concerns and questions are recorded and responded to in a timely manner and that community involvement is integral to the planning effort for major projects at the Airport.

2.2 Conduct surveys and evaluations at public meetings on the effectiveness and benefit of the public meetings process. Such evaluations should be utilized to improve the public meetings process.

2.3 Require that the Public Information Program be conducted in a participatory manner and not as an advocacy campaign to sway public opinion.

Costs and Benefits

These proposals would create an ongoing process for the community to participate in the planning process of the Runway Reconfiguration Project and would better prepare the Airport for the possibility of the Project going forward to a construction stage. Any additional staff time spent developing a policy for collecting and utilizing community input in an effective manner should be absorbed by existing Airport staff, or the Airfield Development Bureau should submit a specific budget request to improve the Public Information process for consideration by the Board of Supervisors.

¹ Upon cancellation of the June 21, 2002 Stakeholders Meeting, the Airport posted a letter on its website stating that the Airport would "suspend all future such meetings for Stakeholders until further notice. This is due to the proposed reduction in the Airport Development Bureau's budget for outreach to be voted on by the Budget Committee of the San Francisco Board of Supervisors on Thursday, June 20. While we apologize for this short notice and inconvenience to your schedule, we wanted you to be aware of the efforts by some members of the San Francisco Board of Supervisors to prevent your continued involvement and participation in this critical and complex environmental document."

² The five public workshops held by the Planning Department's Office of Environmental Review and the FAA were held in conjunction with the Notice of Preparation of the EIR, as required under the California Environmental Quality Act (CEQA).