Answers Needed in Santa Monica

For safety and efficiency, we have design standards. Thus, we do not allow school playgrounds to overlap into highways, and we require freeway onramps to be constructed within specs such as gradient, lane curvature, pavement width and quality, signage and markings, etc.

Aviation is no different. In fact, design standards at airports are even more critical, due to higher speeds and larger fuel quantities. A case in point is the last major fatal accident at Santa Monica, on September 29, 2013.


(yellow marks show aircraft position during the crash sequence; large numbers show the groundspeed decreasing from 83 knots to 51 knots at impact; smaller numbers show net distance from runway threshold)

Four died when a Cessna 525 jet, while landing on Runway 21, swerved to the right and collided with a hangar near the west end of the airport. 20130929pic.. C525 crash at KSMO, ramp & smoke plumeThe accident investigation by NTSB failed to establish exactly what happened, though analysis of personal electronic devices did indicate a large dog was allowed to ride unrestrained in the jet’s cabin (could a dog cause this much loss-of-control?). So, all we know is that a local businessman who would fly almost every week between his homes in Santa Monica, CA and Sun Valley, ID, lost control during an otherwise normal landing.

This brings us back to the concept of safety design standards. If you or I are driving down a rural arterial – say, a regular old 2-lane paved highway, and right at the 55mph speed limit – we might suddenly swerve if a tire blows. Design standards exist to ensure we have a ‘clear zone’ so that our ‘errant vehicle’ can be brought to a stop without hitting a fire hydrant, a railroad trestle, a restaurant, or other object that could increase the odds of fatalities and/or serious injuries. By design, we want our ‘errant vehicle’, be it a car or an airplane, to have room to slow down and stop, with nobody getting hurt. With more room, there would not have been four fatalities on 9/29/2013; it would have instead been ‘a close call’, and likely would have triggered a decision by some of the lucky survivors to fly less. The Cessna 525 accident at Santa Monica turned out badly because the jet collided with a hangar built relatively close to the runway. After the accident cleanup, satellite images indicate that the hangar (as well as connected hangar structures, damaged by the fire) was rebuilt. It is not clear whether these structures should have been rebuilt, just as it is not clear if they were allowed to be too close to the Santa Monica runway prior to the accident. But, looking at other U.S. airports, there is evidence that a serious safety design oversight is being perpetuated at Santa Monica.

For example, consider Cobb County, GA [KRYY]. This airport, north of Atlanta near Kennesaw, also has a single runway and a ‘C-II’ Airport Reference Code (the same ARC needed for E135’s to fly scheduled charter service, as JetSuiteX proposes in early 2017).


(portion of the KRYY Airport Layout Plan. Red ellipses added, to identify the 400ft ROFAs, parallel to the north and south of the runway centerline. Not that the current hangars are much further than 400ft distant from the runway.)

But, within the May 2016 KRYY Airport Layout Plan (ALP), it is declared that FAA requires an 800ft wide ‘Object Free Area’ (OFA), thus 400ft either side of the runway centerline. kryy-20161230scp-alp-portion-of-runway-data-table-declaring-ofa-distancesNote, too, that on the ALP, the airport authority declares they are conformant with the OFA distance requirement, a point that is reinforced by online satellite images.


The satellite image further illustrates yet another stark contrast with Santa Monica: look at all the wide open space, not just to enable a safe conclusion to an errant flight, but also to minimize noise and pollutant impacts on airport neighbors (it appears there are no residences close to KRYY; just a rock quarry, office parks, and highways).

So, what’s going on here? Why is FAA allowing and funding airport expansion near Atlanta with safety design standards that appear to be routinely ignored in Santa Monica?

A Few Simple Questions

Here are four questions that both FAA and the City of Santa Monica need to answer, prior to allowing JetSuiteX to begin scheduled 30-passenger charter flights out of Santa Monica:

  1. prior to the accident, what was the distance between the south edge of the destroyed hangar and the runway centerline? Was this distance in compliance with FAA’s design standards for this particular runway?
  2. after the accident, did FAA and City confer as to the wisdom of rebuilding these hangars? Did this reconstruction require FAA to issue a specific exemption from runway setback requirements, so the new structures could continue to penetrate the runway safety areas and obstruction free areas?
  3. given the absence of functional Runway Protection Zones (RPZs) at Santa Monica, was either FAA or City proposed banning jets to mitigate risks? In particular, with roughly 270 residences standing inside the standard RPZ boundaries, where is there ANY FORM of ‘protection’ being achieved?
  4. regarding JetSuiteX, a recent news story includes this line: “We’ll begin operating whether we get permission or not,” Wilcox said. “We can use the existing facilities at the airport.” Has either FAA or the City confirmed this cowboy assertion? Has either FAA or City (hopefully BOTH!) taken immediate action to inform Mr. Wilcox of his errant views and the reality that safety dictates he will NOT operate until both the City and the FAA are assured his scheduled charter flights can meet basic safety standards?

Food for Thought: How Drones and Time-Lapse Photography can Reduce Aviation Impacts

Here are a few short videos that show the power of time-lapse photography. Combine this with the close-up agility of drone photography and, well, there’d hardly be a need for manned aerial photography or air tourism. On top of all that, the safety record would improve dramatically; people would not be put at risk paying for rides with profit-driven aviation companies, with a long track record of cutting corners.

Imagine that: experiencing the Grand Canyon or lower Manhattan and NOT hearing a helicopter? Wow!!


‘Fly Now, Grieve Later’ – a Report About Aviation’s Climate Change Impact (47p)


“…Most senior members of the aviation industry do not refute the need to cut emissions, but seek to persuade governments that air travel should be given special treatment….”

– Brendon Sewill, in Chapter One of ‘Fly Now, Grieve Later’

Click here to read the original blog post, or here for an archived PDF copy.

See also:

NASA Research Papers on ATC Automation, from 1972 and 1989

NextGen efficiency improvements are pitched as ‘transformative’, but in fact the alleged changes are nothing new. The bulk of the alleged ‘benefits’ FAA, A4A and Bill Shuster claims NextGen can deliver have been realized for more than two decades. It doesn’t take much effort for online research to reveal substantial evidence of this fact. Here’s a short quote from an interview:


“…we built these descent trajectories to be an idle thrust descent all the way to the bottom . . . . you’re flying at thirty-five thousand and you know the route you’re going to fly. Now imagine you have to pick a time, while you’re flying, to land down there. You’re given the command, OK, close your throttles, never touch them again, but be assured that you’re going to get there without turning the throttles back on again….”

– interview comments by Heinz Erzberger, an ATC researcher at NASA Ames, discussing research back in the 1970s

Read more in copies of these research papers by Mr. Erzberger, from 1972 and from 1989.

[KSMO]: A Video Collection of Speeches at a Protest in April 2007

The content and quality of presentation at this citizen protest is outstanding. The statements and the stories just scream out:

How can FAA and the Santa Monica Airport continue to do the damage being done, not just the noise but the serious health destruction, too?

This protest offers a great example for others, being impacted across the nation by an out-of-control FAA and aviation businesses. Perhaps viewing these will help you to become motivated to reclaim local control of your local airport … to serve the LOCAL COMMUNITY first, and to assure that the airport’s operations are properly balanced with the environment and local quality of life.

Click on the image below for a scrollable view; the PDF file may be downloaded. Click on the links within the PDF to view each video portion, uploaded to YouTube.

[KSMO]: No Runway Protection Zones, in Stark Contrast with Other Airports


The green trapezoid delineates an RPZ at the north end of the Aurora Airport, near Portland, OR. This RPZ, similar in size to what is needed to accommodate charter jets at Santa Monica, measures 500ft by 1010ft by 1700ft long. As is the case nearly everywhere, all obstructions were removed from this RPZ: there are no structures within the trapezoid, and the lines of trees have all since been removed (not even stumps are allowed… they are considered too dangerous).

A Runway Protection Zone (RPZ) is a trapezoidal space, positioned at the ends of all runways, designed to create a safety buffer for when aircraft fail to stay on the runway. Santa Monica has no meaningful RPZs. In fact, despite lots of searching, I have not been able to find any other U.S. airport with hundreds of homes standing inside the RPZ. The vast majority of U.S. airports have ZERO homes standing inside the RPZs.

This graphic illustrates where the Santa Monica RPZs would be, if FAA applied its safety standards there:


In contrast with the RPZ at KUAO, these safety areas at Santa Monica have hundreds of houses. (click on image for larger view)

Nationally, FAA has generally done a good job on RPZs; they have defined the dimensions, and they have firmly and consistently guided airport authorities to comply with these design standards that are needed to protect pilots, paying passengers and airport neighbors. FAA has thus secured safety control at essentially all airports, but NOT at Santa Monica. There, a close inspection of the RPZs shows approximately 270 homes exist in the Santa Monica RPZs that are frankly nonexistent. Here are larger images:ksmo-20161223-500x1000x1700l-rpz-sw-of-rwys-3-21 ksmo-20161223-500x1000x1700l-rpz-ne-of-rwys-3-21Nice homes, in a beautiful area with the finest weather, yet these people endure air pollution, noise pollution, and the constant fear of an off-airport crash. This makes no sense, and it does not have to be this way.

How Does Santa Monica Compare With Other Airports?

The PDF below presents a compilation of satellite views, comparing airport RPZs for Santa Monica with thirteen other airports in five western states (California, Oregon, Washington, Idaho and Nevada). Each of the airports selected for comparison is noted for heavy use by air charters and private bizjets. Two especially notable conclusions from this analysis are:

  1. homes are virtually never allowed to stand within RPZs, as it is just too dangerous. So, why hasn’t FAA either bought out the homes in the Santa Monica RPZs or, far more pragmatically, simply shut down jet operations there?
  2. if FAA shut down jets at Santa Monica, the capacity to absorb them at larger and safer airports in nearby Van Nuys [KVNY] and Burbank [KBUR] is enormous. As is typical throughout the U.S., both of these airports were built to accommodate traffic levels that have since declined by half.
Click on the image below for a scrollable view; the PDF file may be downloaded.

[KSEA]: One Way FAA can Use NextGen to Optimize Noise Mitigation

Here’s a tip for how to very effectively expose FAA’s NextGen failure: study how ATC handles arriving flights during low-traffic time periods. For example, at the SeaTac Airport [KSEA], where Delta’s decision to start up a new hub in 2012 is causing substantial growth in annual airport operations, the arrivals stay busy through most of the day, but there are a few hours each night when you can find only one arrival being worked. So, the question is, what is the shortest arrival routing ATC will issue when working a single, all-alone arrival, and how does that arrival route change with the addition of more arrivals?

When you study the empirical flight data, you quickly find the answers, and they consistently show: FAA’s largest impediment to system efficiency is simply TOO MANY FLIGHTS. In other words, if FAA really cared to optimize safety and efficiency, they would focus on managing capacity, keeping operations per hour below thresholds that precipitate delays and congestion.

Consider a Recent Arrival: United 505 from Denver

One example of this was United 505, which arrived after 2AM on Tuesday, December 20th. First, notice the overall flight on the satellite view below: as has been the case for many decades, they flew a straight line from Denver, with no zig-zags. Notice, too, that the only significant distances were added at Denver and at Seattle, as needed to accomplish transition to and from the enroute portion of the flight.

How Can FAA Better Use the NextGen Technologies?


(VFR sectional with a red curve added, depicting an optimized noise mitigation approach over Puget Sound and Elliott Bay. Crossing altitudes at 8000ft and 3000ft are added, red text on green background.)

The residents of Seattle are lucky to have a large water body that aligns well with their main commercial airport. But, the basic design elements needed to optimize noise mitigation were not fully considered when FAA was selling NextGen. Key design elements should have included:

  1. keep the arrivals high as long as possible. (way back in the 1970s, FAA actually had a noise mitigation program called ‘Keep em High’!)
  2. for the final ten miles, set up each arrival for a continuous rate of descent, optimally at around 300-ft per mile flown. (thus, arrivals should be designed to cross a fix at roughly ten-miles from the runway end, and 3,000ft above airport elevation)
  3. for the distance from 20-miles to 10-miles from the runway end, design a higher rate of descent, perhaps 500-ft per mile flown. (thus, arrivals would descend from 8,000ft above airport elevation to 3,000ft above airport elevation, during this 10-mile portion of the arrival; with this design, commonly used flight automation systems would enable pilots to easily comply with the designed optimized descent profile and route)
  4. plan to have ATC accomplish sequencing, spacing and speed management to the point where the final 20-miles of the approach begins. (in this case, roughly mid-channel over the Vashon ferry route, at an altitude nominally 8,000 feet MSL)

Interestingly, this proposal is quite similar to one of the approaches that FAA designed and implemented, the RNAV (RNP) Z Runway 16R Approach:ksea-20161204cpy-rnav-rnp-z-rwy16r-ifr-plate
For years, in an extended and heavily-coordinated pitch to sell the NextGen program in Seattle, FAA and others pushed the idea that all arrivals from the west side (from California, Oregon, Hawaii, coastal BC & Alaska) would be routed inbound over Elliott Bay during the predominant south flow landings at SeaTac. This was a good idea, but FAA did not go far enough. I.e., when FAA designed this approach procedure, they focused solely on the portion from the middle of Elliott Bay to the runway; they should have also focused on how each flight would get to that point in Elliott Bay (look for ‘SEGAW’ in the plate above). A truly optimized approach would define fixes and precise altitudes, starting between the fix VASHN (on the approach plate above) and the Fauntleroy ferry dock; such an optimized approach would route each arrival over-water and eventually over the vicinity of the stadiums, and would include speed and altitude profiles easily achieved by today’s air carrier fleet. Note that the profile view for the current deficient approach procedure (above) starts at fix WOTIK, which is at a 6-mile final and well south of Spokane Street.

‘NextGen Fixes’ Tend to be Slow, and Tend to Serve to Advance the Propaganda

Thankfully, some progress has been seen for the [NextGen impact case] at [KSFO], but the repetitive noise impact problems persist nationwide, and in fact, appear to be worsening. In almost all cases, the rare ‘NextGen-fixes’ have three key elements:

  1. the NextGen-fixes further crystallize FAA’s ongoing delay tactics; i.e., just getting to the time when an announcement can be made with a new NextGen-fix eats up months and even years. Moreover, the declared ‘solution’ consistently contains absurdly long timelines for each subsequent goal or step.
  2. the NextGen-fixes tend to help the Public nowhere near as much as they serve FAA and the elected officials. The announcements make elected officials look like they are serving their constituents, thus bolstering their incumbency chances … even though these same officials could and should be far MORE aggressive in demanding performance and immediate corrective actions by FAA. And,
  3. the NextGen-fixes continue to sell NextGen as a solution, when in fact it is the problem. I.e., the news releases and other documents are constantly laced with keywords and quoted lines from FAA’s fraudulent NextGen salespitch.

Here’s a short (just over 1-minute) home-video showing and explaining the impacts FAA’s NextGen SERFR arrivals are having on residents between Santa Cruz and San Francisco.


(click on image to view source video at Facebook)

[KSMO]: Are FAA Attorneys Bluffing on their ‘Cease & Desist Order’?

The fight in Santa Monica continues to heat up. City officials have labored for nearly four decades, and patiently endured one FAA delay tactic after another, in their quest to assert local control so they can best manage their local airport. Now, an official at FAA Headquarters in Washington, DC, has issued an ‘Interim Cease and Desist Order’. For what it’s worth, here is a copy of the City’s official response:


(text of email by City officials; minor edits may have been added, but only to clarify)

The Order appears authoritative and very threatening, but a closer inspection suggests it is just another bluff by an out-of-control federal agency. Here’s the closing declaration, at page five of FAA’s 15-page document, signed by Kevin Willis, an FAA Director at the Office of Airport Compliance and Management Analysis, on 12/12/2016:

(click on image to view an archived copy of FAA's entire 15-page 'Cease & Desist Order' package)

(click on image to view an archived copy of FAA’s entire 15-page ‘Cease & Desist Order’ package)

‘Cease & Desist’ … hmm, my first thought was, roughly,

“…where does FAA have the authority to issue a ‘Cease & Desist Order’, intervening in the relationship an airport authority has with an airport tenant? I mean, by this logic, FAA should also have the right to dictate all sorts of airport management details, not at all related to aviation safety.”

Evidence That This is Just a Bluff

FAA’s authority to issue the Order is cited as footnote one, on the bottom of page 1 which reads: “This Order is issued pursuant to 49 U.S.C. § 46105 and 14 CFR § 16.109.” So in the probably 100-200 man-hours that went into drafting this Order, FAA’s legal team offered not one but two cites. But, is either cite valid?

I’ll lead off with the second cite. According to GPO’s eCFR website, FAA’s second cite DOES NOT EXIST. I.e., per the screencap below, 14 CFR § 16.109 is a ‘reserved’ section of the CFR framework, meaning there is no language to be consulted.


Two screen-captures by aiREFORM, from the current/valid electronic CFR (Code of Federal Regulations) website. These show that there is no valid 14 CFR section 109.

And note, too, this is NOT an out-of-date version; the GPO website declares this eCFR is current as of 12/12/2016 … the same date as Mr. Willis’s signature!

And now let’s consider the other cite. FAA cited 49 U.S.C. § 46105, but their error is immediately revealed by simply reading the language of the law. The actual section contains these words: “…a regulation prescribed or order issued by (…) the Administrator of the Federal Aviation Administration with respect to aviation safety duties and powers designated to be carried out by the Administrator (…) takes effect within a reasonable time prescribed by the (…) Administrator.”

Note the qualifier, “…with respect to aviation safety duties and powers designated…” FAA’s current action against Santa Monica has nothing to do with ‘aviation safety duties’, and FAA’s legal team has failed to actually cite any real authority. If you want to look even further, see this archived PDF copy of the entire Chapter 461, which contains all sections, from 46101 through 46111. It is a searchable copy, so it is easy to quickly establish: Chapter 461 contains neither the term ‘cease’ nor the term ‘desist’, and the cited § 46105 contains no real authority.

Now, just to be clear, I am not a lawyer. BUT, as a forced-to-retire FAA ATC whistleblower, I have plenty of experience with FAA’s bluff and bluster. FAA pays plenty for their hundreds of inside attorneys, and these civil servants are expected to distort and deceive at will, in support of the true and not-so-ethical FAA mission. If my quick legal assessments are flawed, please show me my error. And if they are not flawed, clearly, it is time for FAA to get off their bureaucratic butts and let the People in Santa Monica get on with owning AND controlling their local airport.

UPDATE, 12/20/2016: — a week has passed and nobody has yet provided even a flimsy legal basis for FAA’s administratively issuing an ‘Interim Cease & Desist Order’ against the City of Santa Monica. The most substantial response I have yet seen was sent by Chris Harshman, and a screencap is provided below:

ksmo-20161220at1641scp-wow-email-from-c-harshman-packetlaw-comHere’s what I sent back to Chris:ksmo-20161220at1728scp-reply-email-to-c-harshmanChris did make one good point in his email. He identified my error in interpreting the CFR nomenclature. The Code of Federal Regulations are an extremely deep and tangled set of rules. When I researched my blogpost, I could not find a 14 CFR § 16.109 and ended up finding a list that looked like it was regarding 14 CFR § 16.109, but was actually declaring that 14 CFR Part 109 was reserved. The online version is viewable here (and I archived a copy, all 31-pages, here).

Of course, we also have the problem that the preamble for the 31-pages of 14 CFR Part 16 says that “…provisions of this part govern all Federal Aviation Administration (FAA) proceedings involving Federally-assisted airports….” This strongly suggests that Part 16 cannot be applied against Santa Monica, because Santa Monica dropped their addiction to airport federal assistance many decades ago.

Thankfully, all of this confusion is easily solved. We just need FAA to start serving ALL OF US, not just the elite aviation interests. Airports serve communities, not businesses; airport impacts need to be properly balanced against health, residential quality of life, and other issues. Attorneys can help make this happen… IF they choose to serve more than just the mighty dollar.

[KLMO]: Oral Arguments Today, in the Colorado Court of Appeals

A classic example of the sacrifices commonly made by aviation impact activists is happening today, in a Denver courtroom. A single airport operator, Mile-Hi Skydiving, makes money by using their fleet of skydiving planes, outfitted to climb faster AND make more noise. So as not to annoy the actual near-airport residents, the planes are flown a few miles away and the climbs, which commonly drone on for 15- to 20-minutes, impact the residents below. The problem came many decades after the airport was built, coinciding with aircraft purchases and modifications by Mile-Hi owner Frank Casares.

As is nearly always the case, FAA is doing nothing to help resolve the problems. Indeed, doing the quite the opposite, FAA is enabling the operator (Mile-Hi) and ensuring these impacts will persist and even worsen. Just as they do at East Hampton, Santa Monica, Mora, and a dozen or so NextGen-induced noise canyons (e.g., [KLGA], [KPHX], [KCLT], [KSEA], [KBOS]), FAA is  obstructing every effort for meaningful LOCAL CONTROL of local airports. Somehow, we are supposed to suspend rational thinking and believe that, if the local City Council wanted to impose reasonable restrictions on the lease they have signed with Mile-Hi, it would compromise safety to have them execute quieter climbs or limit their operations to say a 6-hour block each day? Likewise, FAA (and the industry they protect from the Public!) expects us to believe this total capitulation to the profit-motives of a single skydiving operator is critical for our National Airspace System (NAS) integrity?

Bullshit. Shame on you, FAA et al, for continuing to obstruct reasonable attempts toward local resolution. Sleep, and the quality of our home environments, is important … far more necessary than your propping up the narrowly distributed profits of operators like Frank Casares. Let’s bring some balance back to these situations: more LOCAL control at our local airports.

Thank you, Kim, Citizens for Quiet Skies, and the others who have bravely spoken up to fix this local problem. Against a hostile local press, a corrupt and commerce-biased state court system, you fight on. And your battles help many others, from East Hampton to Santa Monica to Mora.

Click on the image below for a scrollable view; the PDF file may be downloaded.