City of Santa Monica Rejects JetSuiteX ‘COP Application’ for Part 135 Charter

For a month now, an air charter operator based in Irvine, CA and affiliated with JetBlue, has been selling seats online for scheduled passenger flights to begin at Santa Monica in early February. Weeks ago, the CEO of JetSuiteX, Alex Wilcox, told reporters he believes the City cannot stop this proposal. This despite the fact that the airport is crowded dangerously close to dense residential neighborhoods, and there is no indication the City is prepared with the level of crash-fire-rescue support needed for scheduled flights carrying up to 30 passengers.

Here’s a PDF of the application for a Commercial Operations Permit, signed by JetSuiteX COO Michael Bata:

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

And, here’s the City’s response letter signed by Airport Director Stelios Makrides, rejecting the application as incomplete, and requiring a valid Environmental Assessment:

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

For the past month, FAA has been suspiciously (and negligently?) quiet on this matter. What’s needed next is for FAA to break this silence and take action.

FAA is the final federal authority and routinely usurps local authority, to effectively run airports from a distance and for the industry, often with severe negative impacts upon the local community. If they are to be responsible, FAA needs to immediately issue an Interim Cease & Desist Order against JetSuiteX, Delux Public Charter, and Atlantic Aviation, to ensure no scheduled air charter operations begin at Santa Monica without all required permits. This should be easy for FAA to do; after all, FAA has recent experience issuing Interim Cease & Desist Orders related to Santa Monica.

EPA’s Online Resources

20170108scp-epa-regions

(map and table, showing EPA’s ten administrative regions)

The U.S. Environmental Protection Agency (EPA) was created in 1970 “…for the purpose of protecting human health and the environment by writing and enforcing regulations based on laws passed by Congress.”

The effectiveness of EPA has been questioned by practically everyone; pro-commerce types swear EPA is too onerous, while pro-environment types insist EPA consistently falls short in protecting the environment.

Back in 1970, the year of the first ‘Earth Day’, our Congress was as constructively focused on environmental issues as they have ever been. Sadly, most Congress’s since have served commerce far ahead of people, passing laws, bending rules, and granting targeted exemptions that always further undermine EPA. This includes in the area of aviation impacts. Congress has consistently redistributed authority away from EPA and into FAA, on critical environmental matters including aviation noise and leaded aviation fuel. And, Congress has also consistently federalized authority; they’d rather strip local officials of their basic rights to run their local airports to serve the needs of their local community, and instead give that authority to faceless and unaccountable FAA bureaucrats.

A regulatory agency can be constrained by laws, but the most fundamental power is in information. Thus, even a defanged EPA can empower people, so that each individual can understand environmental impacts and effectively advocate for their family, to protect their environment. EPA can serve us – and they do, with work such as their ‘Citizen Science for Environmental Protection’ Program (selected content copied and archived here). But, and especially in the present political landscape, it is UP TO EACH OF US to do the work beyond the data: we have to take that data, formulate the message, and advocate the change.

So, for example, we can look at reports such as this one, showing diminished air quality and other impacts in the neighborhoods to the north of SeaTac Airport [KSEA]. We can also look at the December 2016 report done by the National Advisory Council for Environmental Policy & Technology, ‘Environmental Protection Belongs to the Public – A Vision for Citizen Science at EPA’.

Where Do We Go Now?

If we take away one lesson from the politics of 2016, it should be this: a Democracy is doomed to fail, where the people are not actively engaged in the decision-making process. We cannot expect to achieve the ideals we want and need as a nation (or as a small, local community), if people do not participate. We cannot be distracted; we cannot be lazy; we must guard against the manipulation of voting data and other forms of election fraud; and, we must not allow the selective disenfranchisement that is happening due to ‘the new Jim Crow’ discriminatory laws. Similarly, we cannot expect to benefit from the sound application of science where many of our elected leaders are collaborating with lobbyists seeking to discredit science; climate change denialism is a good example of this failure.

With that in mind, there is a glimmer of hope for the new administration. The GOP has championed de-federalization and expanded LOCAL authority in all matters. Thus, it is conceivable that we may be surprised; Trump, Ryan, McConnell and others may shrewdly use aviation as an example, demonstrating how to reduce bureaucracy, save money and localize control while de-federalizing the authorities that FAA has increasingly abused.

2017 versus 1961

(click on image to watch 'The Best of Boris Badenov' on YuTube')

(click on image to watch ‘The Best of Boris Badenov’ on YouTube’)

Here we are, fifty-six years later.

We are still watching as the same old manipulative mainstream media delivers crafted stories to dupe a captive citizenry. With their help, we continue to believe that we are ‘in the know’, about yet another Presidential transition.

In both times, Boris Badenov was and is the bogeyman, and war hawks still haunt us with their sabre-rattling. But, in terms of quality and class of the Presidency itself, we could not see a starker difference. The 1960’s version is reflected in the speeches below; the newer and devolved version impales us with crude talk of ‘hand size’ by one man, while the other man’s declining Whitehouse tenure convincingly argues that today, both parties serve ONLY the money that empowers the oligarchs.

This contrast was brought to my attention inadvertently. I was researching the fight for local control at Santa Monica’s airport, trying to delve deeper into understanding the sides and why the ongoing delays. I was shown a recent chain of emails. In one interesting exchange, a city official mentions this quote by JFK while excusing off the city’s slower pace of change, a pace that continues to flabbergast those residents who are most impacted by the noise and air pollutants:

“Others may confine themselves to debate, discussion, and that ultimate luxury — free advice.  Our responsibility is one of decision — for to govern is to choose.”

Now, on the face of it, this JFK quote seems to say, ‘our job goes beyond debate; our job is to govern, to act, to resolve problems’. Thus, it seems like an odd quote, coming from a city official defending the city’s failure to enact long overdue changes. Be that as it may, I researched a bit deeper and came to the actual speech. Wow … what an incredible presentation about the importance of individual liberty and local control in our system of government. And a perfect bookend to a similar speech by Eisenhower. Both speeches speak to the need for governance by and for THE PEOPLE; both speeches point toward the threats to liberty by ascending unaccountable bureaucracies, such as FAA has clearly become.

Two Great Presidential Speeches, by Ike and JFK

At the start of 1961, President Eisenhower warned us about the rise of the Military-Industrial Complex, and the threat against individual liberties. One year later, his successor, President Kennedy, was equally eloquent about the same concerns, speaking at Independence Hall on July 4, 1962. You can listen to the embed video below, or view a black-and-white video archived by JFKLibrary.org here.


Below is a PDF of transcript of JFK’s speech:

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

A Classic Image in the War Against Carbon

Image

(click on image to view lots more, tweeted by 'ITryNotToFly')

(click on image to view lots more, tweeted by ‘ITryNotToFly’)

We Should All Be So Brave.

Let’s hope, in this New Year, we continue to see great creative effort and expression by some of the wonderful bloggers fighting for our planet and our future!

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.

ksmo-20130929-c525-crash-while-landing-rwy21-fig-22-from-video-study-distance-groundspeed-on-satview-ntsb

(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).

kryy-20161230scp-alp-w-portion-of-runway-marked-up-for-rofas

(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.

kryy-20161230scp-satview-of-airport-vicinity

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!!

PANO | LA – 10K from SCIENTIFANTASTIC on Vimeo.

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

QUOTE

“…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:

QUOTE

“…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

kuao-201205-rpz-rwy-17-on-satview-w-dimensions-showing-trees-later-removed

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:

ksmo-20161223-rpzs-rwys-3-21-v2-labels-added

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, meaning that the RPZs are, frankly, nonexistent. Here are larger images; try to count the houses yourself: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.