2017-01-06: ‘Accountability Check’

Below is a sample of a recent query to FAA, and a reply by an FAA official. This example relates to NextGen impacts in western Long Island, near the [KJFK] and [KLGA] airports. The original query was directed to Carmine Gallo, FAA’s Regional Administrator, but passed on to Rick Riley at the FAA HQ Noise Ombudsman Office.

You can judge for yourself … how well did the FAA official do in the reply?

  1. Did he or she answer any questions?
  2. Did he or she inform and educate?
  3. Did he or she clarify who is accountable, or did he or she identify who is responsible?
  4. Did he or she go a step further and identify the problem, then take action to actually FIX THE PROBLEM?
  5. …or, did he or she just return a mumbo-jumbo form letter response, with added platitudes and pro-aviation propaganda, while obscuring accountability and kicking the can down the road?

View copies at these links: Query, Reply. Here’s how the impacted homeowner judged Mr. Riley’s email reply:

We need our questions answered from the FAA &/or the PA and we need them now!! No more shifting blame. Someone needs to take responsibility!!

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.

[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 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.

Scheduled Charter Jets at Santa Monica: ‘Are You Kidding Me?’

Recent news articles report that a charter operator hopes to start flying 30-seat Embraer E135 jets on scheduled flights out of Santa Monica [KSMO]. Rumor has it they are already selling tickets. This sounds crazy, because there is no evidence that the operator has first obtained an approval for these operations, at an airport that appears to not conform with FAA’s runway safety design standards, as required for this type of operation and aircraft.

FAA requires airports to provide emergency equipment and design elements that will adequately protect the public. A first step in this process is to assess the airport and assign an Airport Reference Code, or ARC. The ARC is defined by the size and speed of the most demanding aircraft to use the airport at least 500 times in a year. The Embraer E135 has a maximum takeoff weight nearly 42,000 pounds, a 67 feet 9 inch wingspan, and an approach speed around 130 knots. FAA considers the E135 to be a ‘C-II’, and the airport has to be designed accordingly.

For safety, all airports have a defined Runway Protection Zone (RPZ), typically a set of trapezoidal areas delineated reference the approach end and departure end of the runway. The RPZ for a C-II airport, as would serve the E135, can be seen on airport master plans across the nation, and measures 500ft and 1000ft on the ends, by 1,700ft long. An RPZ is ideally OWNED by the airport authority, and is to be clear and level to accommodate errant flights; the ONLY structures allowed are those necessary for the airport, such as lighting and navigational aids.

Just to get an idea of how incompatible and unsafe the KSMO runway geometry is, here is a trio of satellite images. The first is a screencap showing the approach end of KSMO Runway 21, with a thin red 500ft circle added, centered on the end of the runway; lots of houses, and yet the full C-II RPZ extends roughly 1,400ft further to the east!

ksmo-20161221scp-apch-end-rwy-21-w-500ft-radius-into-surrounding-homes

Bing satellite view with 500ft radius circle added. It strongly appears that, if FAA were to serve the entire Public (not just the airport operators who are enabled by FAA’s shoddy performance), FAA would not allow scheduled E135 flights at KSMO without first buying out hundreds of homes and moving Bundy Drive far to the east.

The second screencap of a satellite view shows what the same 500ft circle looks like at Hayward [KHWD], where the nearest homes are approximately 800ft from the end of the runway. Notice how wonderfully clear, flat and open the area is, to safely contain any accidents that can and do happen … and notice the contrast with KSMO.khwd-20161221scp-apch-end-rwy-28l-w-500ft-radius-nearest-home-800ft

The third image shows what FAA wants – (and what the Public needs!) – at all certified airports: runways away from homes, with full RPZs. This example shows the Tallahassee, FL airport [KTLH] in comparison with KSMO; both at the same scale, one airport on wide open flat land, the other airport wedged in between mature residential neighborhoods.ksmo-20161221scp-satview-comparison-ksmo-v-ktlh-bing-comSo, an air charter operator may already be selling tickets for scheduled jet flights out of KSMO, and the FAA is saying nothing.

Are you kidding me!?!!!!!?!

Where is the safety regulation here? Where is the application of all the Airport Design standards in Advisory Circular AC 150/5300-13A? Doesn’t FAA have to ensure Part 139 is followed for these 30-seat charter flights?

Is FAA Failing in Their Safety Oversight of Allegiant Air?

On May 11th this year, we were deeply embroiled in the election primaries, with growing evidence that the U.S. election system is in a flat-line failure mode. So, it is not surprising that the 20-year anniversary of the ValuJet crash in the Everglades might have gone unnoticed, at least by some of us.

The crash took 110 lives, and deeply scarred thousands more. The investigation of the crash exposed cultural failures at FAA, and led DoT Inspector General Mary Schiavo to abruptly resign in July of that year (she was THAT disgusted with the inside politics and cover-up, not just by FAA but by the White House, too). The crash and victims were recalled in a Miami Herald article. Subsequent news articles this year have looked at Allegiant Air, noting its many connections back to ValuJet, and presenting evidence that FAA is AGAIN being lax in safety oversight.

Below is a recent news article, critical of both Allegiant and FAA. In the pages that follow, aiREFORM provides an archived collection of articles and other documents related to Allegiant Air. The records are presented in chronological order on the following pages, mostly as scrollable PDF files.

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.
ksea-20161220at0229scp-ual505-arr-f-kden-crossover-s-of-ksea-for-elliott-bay-to-s-flow

How Can FAA Better Use the NextGen Technologies?

ksea-20161220scp-optimized-route-and-profile-over-elliott-bay-to-s-flow-vfrsectional-marked-up

(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.

[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.

With FAA, ‘Collaboration’ is Just a Slick Euphemism for ‘Propaganda Campaign’

Time and again this year, the mainstream media has been shown to be fully collaborating with those they report on, thus effectively serving not as objective journalists but as servant propaganda agents. We’ve seen this in politics (yes, 2016 has been a big and very troubling year!), and we’ve seen it in the lobbying efforts of certain industries, aviation included.

The key to these propaganda campaigns is to ALWAYS frame the message (using carefully selected keywords), and coordinate the delivery of information. In the context of our U.S. Congress, in its present and ongoing state of oligarchy-serving dysfunction, it is critical that opposition voices are tamped down; that is, it would be problematic if any of the aviation stakeholders spoke up against the objective. So, within the group of stakeholders/players who are coordinating the propaganda campaign, each must find an aspect of the program that serves their own narrow interests, and accept that personal benefit as sufficient for their agreement to remain quiet about aspects they dislike. This is precisely what has evolved with NextGen and ATC Privatization; this is how we end up with the air traffic controllers’ union, NATCA, doing a reversal this year and now declaring that union leaders are onboard with both proposals.

The current propaganda campaign for the U.S. aviation system focuses on two things:

  1. ATC privatization – the ‘real goal’ is to further insulate this safety/regulatory function from accountability and transparency, making it that much harder for impacted citizens to resolve aviation-related problems. Many in industry like this idea, for obvious reasons (it creates ‘business opportunities’); top officials at NATCA see a chance to remove controllers from federal salary caps and the age-56 mandatory retirement, so thousands of the most senior controllers today would earn more than $180,000 per year (and build much larger retirement pensions).
  2. NextGen investment – as happens with most matured agencies, there is a constant need to project a message that helps the agency mission appear relevant and worthy of further funding. So, every few years, FAA dreams up a way to spend money, coordinates with ‘stakeholders’ to ensure their non-opposition, then carefully maneuvers Congress, seeking billions for a new so-called ‘transformative’ program. It is all smoke-and-mirrors and pork, benefitting not just industry players but also FAA officials who retire, collect pensions, and become consultants and lobbyists for those same industry players.

Any effective propaganda campaign requires consistent and frequent restatement of key bits of disinformation. I.e., if you repeat a lie long enough, it effectively becomes fact. This truism is understood and abused by both major political parties in the U.S., just as it is understood and abused by accountability-averse agencies, FAA included. So, what are the key bits of disinformation FAA is using…?

  1. use the words ‘increasingly congested’ … even when you know it is just a bald-faced lie (see the data analysis within the Post, The Incredible Shrinking NAS … that FAA & the Av-Gov Complex Don’t Talk About; on average, for the 504 U.S. airports with control civilian control towers, annual operations are now down 45% from the peak years at each airport. DOWN 45% … but does the mainstream media tell us this statistic?
  2. distract the citizens with snazzy graphics and jargon that pretends to be selling something new and incredible [even when the actual change is minimal to none]
  3. tack on the latest buzzwords, such as ‘transformative’, ‘collaborative’, and of course ‘NextGen’.
  4. make sure it appears that the message is organic, authentic, and sourced NOT in the agency (FAA) but in the real world (the airlines, the airline lobby, the unions, the manufacturers). [again, this is just illusion… there is a huge amount of coordination going on behind the scenes, with FAA and the other parties very carefully designing the campaign, and orchestrating who says what and when]

Here’s a recent example: a news article with warm and fuzzy airport growth hopes at the St. Paul Downtown Airport [KSTP], near Minneapolis. This is an airport catering primarily to elite personal and business travel, such as using charter bizjets. The airport management expects roughly a hundred elite sport fans to use KSTP in early 2018, for their flight to watch the Super Bowl. The article more than implies that the airport is a money-generator. But, as shown in this aiREFORM analysis, and as is so typical across the nation, annual operations at this airport peaked in 1990 and have since declined 70%. The federal monies spent there are essentially maintaining infrastructure that is increasingly underused.

So, when you read articles such as this, be sure to consider the long history of spin and propaganda by FAA and other Av/Gov Complex players.