Santa Monica’s Airport Subsidies, & the ‘Draft Minimum Standards for Commercial Operations’

This past week, numerous local citizens met with city airport officials, to discuss the DRAFT Minimum Standards for Commercial Aeronautical Services. This 41-page document (archived here) may be well worth reading … not just for those who fear continued air charter operations at the shortened KSMO runway, but also for people at other U.S. airports, seeking to clarify who is to be held accountable for the airport impacts.

Some of the content is mere boilerplate, but other details make it clear that the two key airport regulatory parties (FAA and airport authorities) both tend to ignore area residents while serving only commercial operators. And how is this done? Well, if and when a citizen raises a concern, the airport regulatory party is quick to pretend they are not accountable while also directing all concerned citizens ‘to the other party’. The result is regulatory failure; where safety and environment demand real and timely accountability, instead we find an accountability vacuum.

At Santa Monica, the impacts continue. Although the runway was substantially shortened, jets and charter operations still fly. Area residents remain fearful that the City will allow – or even encourage – the development of increased air charter operations.

‘Minimum standards’ should exist, especially as related to safety and environmental impact. Given how marginally unsafe the shortened runway is for larger, fuel-laden commercial flights, it is absolutely appropriate for the city to refine their minimum standards in a way that shuts down commercial charter operations. But, will they do so?

Submitting suggestions or comments on this Draft

Ben Wang, at the ‘SMO Future’ Facebook group, submitted a table with his suggestions (click here to view the aiReform archived copy).

Readers who wish to may submit their own suggestions. The two key airport officials to contact are:

Something Else to Think About: Who pays for these airport officials?

Mr. Markos is Airport Manager, a position he has held since 2013 (per this news release). After a quick online search, it was not yet clear what his annual salary is. But, that same search revealed that Ms. Lowenthal, as the Senior Advisor to the City Manager on Airport Affairs, earns a $162,036 annual salary. (click here to view the City’s 9/28/2017 press release)

Here’s something to think about. In good form, to justify a high salary, the city’s press release proceeded to identify Ms. Suwenthal’s substantial background, both educationally and professionally. But, that point aside, if senior assistants earn this large a salary, it suggests that the costs to manage KSMO, which frankly caters to just a small group of charter operators, are quite substantial. And these costs have to be born by someone.

These high costs beg a few more critical questions:

  1. what exactly is the full extent of city subsidy for this airport?
  2. if the city subsidies ended, would area residents finally obtain relief from air pollutant, noise, and safety impacts, especially those caused by charter operators and leaded-fuel local flights? In other words, is this subsidy pattern actually perpetuating impacts that destroy health and residential quality of life?
  3. if the city continues the pattern of impact upon nearby residents (both in Santa Monica and in adjacent neighborhoods, such as West LA), where is the money coming from to pay these subsidies?

Did a ‘Vendor Error’ Reveal FAA Arbitrariness on NextGen?

Jondi Gumz’s article in the Monterey Herald, does a very good job explaining the problems people are having with FAA NextGen, not just under south approaches to KSFO, but at major hub airports nationwide. (‘Santa Cruz, San Lorenzo Valley residents surprised by new flight path noise’; click here for the online version, click here for an archived PDF with aiReform analysis).

Here are some points from an analysis of the article:

  1. RE: how FAA’s latest action shows they CAN immediately revert to pre-NextGen routes: Think about it … if FAA is able to immediately respond to a vendor error, shifting away from the problematic and impactful NextGen SERFR arrival and back to the legacy Big Sur arrival, why is it taking so long to revert to less impactful pre-NextGen routes at other locations, such as Phoenix? Indeed, out of one side of the mouth FAA has been saying ‘it is impossible to go back’, yet here, they are proving it is absolutely possible, and being done … but only at FAA’s arbitrary discretion.
  2. RE: the explosion of complaints nationwide: It is important to understand, the flood of complaints was not so much due to the application of GPS technologies (which, in fact, have been applied for more than two decades now), but is a consequence of FAA ignoring impacts while using these technologies to increase airport capacity. In a nutshell, FAA is serving the airlines, at the expense of communities. The airlines want increased ‘runway throughput’ at selected hubs, which enables them to densely pack more arrivals into smaller time slots, which can enhance profits. FAA is reducing separation between these arrives, partially by jamming some of the flights lower, to set up parallel streams of closely-spaced arrivals. On the ground, homeowners are being inundated with near non-stop noise.
  3. RE: FAA’s mishandling of the complaints: FAA is just delaying, as that best serves the airlines. This timeline could be expedited, but even if ordered to do so by a court, FAA has shown it will delay, delay, delay. This is one of the main reasons people are so upset about both NextGen and FAA: an indifferent and arrogant bureaucracy, captured by the industry it is supposed to regulate, refuses to even acknowledge the impacts by NextGen, and then refuses to serve the people (instead of just industry). Making matters worse, we lack a functioning Congress to demand FAA clean up its act.
  4. RE: the suggestion that NextGen is ‘new’: FAA has been ‘adopting NextGen’ since roughly 2003, and has been applying the same GPS technologies since the mid-1990s;
  5. RE: the oversold alleged benefits of NextGen: three points to clarify what is quickly summarized at one paragraph of the article:
  • FAA claims that NextGen ‘shortens routes’ and ‘saves time and fuel’, but NextGen actually offers very little improvements, since ATC has been granting long direct routes for many decades now, even back to the early 1970s.
  • FAA claims that NextGen ‘allows planes to fly closer together’, and it is absolutely true that ATC is jamming flights closer together, but the NextGen technologies have little to do with this change. The change is driven instead by FAA’s willingness to accommodate airlines, by reducing spacing (while simultaneously ignoring the impacts on residents below)
  • FAA claims that NextGen ‘avoids delays caused by airport stacking as planes wait for an open runway’. Well actually, NextGen is increasing delays; FAA is overly accommodating the airlines, allowing TOO MANY FLIGHTS in small time windows via tighter spacing, which in turn is forcing ATC to impose delays during the cruise portion of the flight, upstream from the final approach.

KSEA: Beacon Hill’s Fight for Health & Quality of Life

Archived copy of a good article, shared at Facebook, with some footnoted analysis by aiReform. This may help define what we need from our elected officials, to reclaim long-needed local control, so our airports are in balance with our local communities.

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

A Major Victory for Activists: France is Scrapping the New Nantes Airport Project

(click on image to view source)

The fight went on for decades, but now Aéroport du Grand Ouest has been cancelled.

Let’s put this into perspective. Aviation is an industry that provides a small fraction of the world’s population with the privilege of rapid and expansive connection to all points on the planet. The energy-intensity of aviation is extreme; i.e., there is no other human activity (other than war and arson) for which each of us consumes more fossil fuels and generates more climate change impact emissions than air travel. And, it is also a heavily subsidized industry. On top of all that, the governmental agencies charged with regulating aviation – all the way to ICAO – show time and time again, they are captured regulators, serving industry players. These faux-regulators enable excesses by industry players, solely to prop up industry profits; they provide ‘insulation’ and ‘cover’, protecting corporations from ‘problems’ such as local control and regular people.

One of the great activists in Europe, fighting for community quality of life and against excessive airport development, is John Stewart. His work at is extremely valuable to other activists around the world, even here in the U.S. Below is an archived copy of Mr. Stewart’s latest blogpost, discussing Nantes.

Click on the image below for a scrollable view; the PDF file may be downloaded. Alternatively, click here to view the source blogpost by John Stewart, at

The SeaTac-POS ILA: Good or Bad?

‘ILA’ sounds like it has potential to be extremely boring, but from what people are saying around Sea-Tac Airport (KSEA), we all need to know what an ‘InterLocal Agreement’ is, and how much harm it can do. Some are saying that the latest ILA draft is yet another bad act by the Port of Seattle: spending taxpayer money to BUY silence from the tiny few elected officials who otherwise could do the most to help mitigate growing airport impact problems.

In this example, a new ILA has been drafted to expedite further growth of the airport and operations. It was drafted by a ‘JAC’ (Joint Advisory Committee), which is a team of five officials, two representing the Port of Seattle (aka POS, operator of KSEA) and three from the city of SeaTac (which essentially surrounds the POS properties). Of course, it is easy to see the push for an ILA comes entirely from POS; we would never see a small community approach an airport authority and ‘ask’ for an ILA. And, when dealing with POS, the relatively inexperienced officials at SeaTac just cave in when monetary treats are offered; money is the drug, and nobody fails to see who is the dealer and who is the addict.

An Analysis by aiReform

A few hours were spent studying the ILA draft, and comments/highlights were added; all of this is viewable in the scrollable PDF below.

One predominant concern is that an ILA appears to be a way for an airport authority to sidestep addressing problems, such as happen related to over-expansion at KSEA. Instead of meeting with impacted area residents and solving problems – finding the right balance between air commerce and local health and quality of life – POS chooses to ‘pay off’ local elected officials, buying their cooperation. Then, if/when local residents go to their elected body for help, well, that’s been cut off by the ILA.

Another general concern is how the city is enabling POS to entirely self-regulate, in exchange for annual cash payments; not too hard for POS to do, since they collect property taxes from residents throughout the Seattle area. Also, with the intended expedited processes, the window for citizen input is essentially shut tight; just not enough time for you or me to read a draft and submit a meaningful concern or suggestion.

In a democratic society, it almost feels like an ILA should be illegal. Federal agencies like FAA should be pressing for rules that protect people against the excesses of ILA’s such as this one. Not surprisingly, FAA remains mute; after all, they serve the airlines first.

People need to take a close look at this, identify what fails, and demand better governance. Airports should serve communities, not airlines.

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

WaPost OpEd: “For the Love of Earth, Stop Traveling”

An opinion piece in the Washington Post lays out the simple answers: air travel consumes far too much energy, creates far too much environmental damage, per person. Good points.

The simple solution is for more of us to voluntarily travel, a lot less. The government would help, a lot, if they would impose a very steep aviation carbon tax, with all revenues going to reducing other personal taxes and/or funding far more energy-efficient transportation modes, to replace the energy-efficiency of aviation.

Check out this archived opinion piece, as well as the telling reader comments.

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

Santa Monica Update: Air Quality Study Needed, During Runway Closures

In the U.S., one of our greatest advocates for resolving aviation impacts is Marty Rubin. Marty has been fighting the right fight for decades now, against a city (Santa Monica) whose elected officials appear to be corrupt to no end (…well, most of them; a few have been great!). His website, CRAAP, recently forwarded the posting below, which is a blogpost by staff at Mike Bonin’s website.

For those not in the LA area, here’s the deal: this airport is run by the City of Santa Monica, but has HUGE impacts upon people who reside in homes outside the City’s boundaries … in old and very established residential communities like West LA. In a just world, a higher level regulator, such as FAA, would guard against gains for some with uncompensated losses for others. But, here in West LA, FAA is failing their role. In these neighborhoods, even beautiful homes are subjected to aviation fumes and jet blast, with homeowner’s having no evident right to fix these impacts. Why? Because of FAA’s refusal to serve EVERYONE, not just the aviation industry! But, then again, this is what we expect from a captured regulator.

Here is a copy of the blog and Councilmember Bonin’s letter to the Santa Monica City Council. (click here to view the source)

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

See also:

A Work-Around to FAA’s Failed Noise Models

This Post looks at how a simple and economical noise study for a large park and natural area suggests a better way to study airport noise. It essentially presents a work-around to two root problems in how FAA and industry ‘collaborate’ to obstruct aviation noise activism:

  1. that FAA knowingly uses noise metrics and noise models that work great for the airlines – since they completely fail to define and mitigate aviation noise impacts, but work terribly for people – since they consistently fail to objectively quantify noise and impacts; and,
  2. that, whenever citizens approach FAA or airport authorities with their concerns, and seek hard data to help define and fix the problems, both FAA and airport authorities routinely withhold that data, and instead work to confuse and disillusion these activists.

The Boston (Logan) Noise Impacts

In recent years, FAA has become extremely accommodating to hub airlines, by no longer pushing back against excessive flight scheduling. At Boston Logan [KBOS], the airport configuration allowing the highest capacity in terms of ‘runway throughput’ or operations per hour, includes using the parallel runways 4L and 4R for arrivals. KBOS has major hub operations by JetBlue, and minor hub operations by American and Delta. So, with FAA intensifying the use of runways 4L and 4R for arrivals, even in crosswind and slight tailwind conditions, they are imposing an enormous noise and air pollutant burden on communities under the straight-in arrival corridor.

The impact upon communities below, such as Milton, has been intense. People are losing sleep (the short term impact) and breathing more aviation pollutants (which will cause serious long-term health impacts). They are complaining to both FAA and the airport authority, Massport, as well as to their elected reps and local community officials. Their complaints continue to be broadly ignored by the key authorities – FAA and Massport – both of whom routinely reply that ‘nothing has changed’ and ‘the perceived impacts are not significant by our standards’. Needless to say, this mishandling by FAA and Massport only infuriates and further sensitizes the impacted communities.

Something has to change. FAA/Massport must stop pretending to comply with federal and state environmental impact assessment processes, which they do by using worthless impact models. Frankly, these models were designed to create an illusion that impacts are objectively measured, and they were also designed to bias the conclusions to ensure validation of any and all airport operational expansions. We need a new model that is objective; a model with people collecting REAL noise data and compiling it into impact contours may be the best way to go.

Noise Modeling at Blue Hills Reservation

The Blue Hills Reservation includes 125-miles of trails on 7,000 acres. A prominent water body in this natural area is Houghton’s Pond, which happens to be under the straight-in approach to runways 4L and 4R, at approximately 11-miles from the landing threshold.

Friends of the Blue Hills is a local non-profit organization that coordinates volunteers and works to preserve and protect this wonderful natural resource. A recent Post at their blog announced a great project. It looks like Boston University is doing a noise study; professor Richard Primack and doctoral student Lucy Zipf appear to be crowd-sourcing the use of an iphone app by volunteer hikers, to compile an actual noise map of the trails for most or even all 7,000 acres of Blue Hills Reservation.It will be very interesting to see what they produce. Seemingly, if the app-devices are synchronized, they could create a noise contour map that would show actual noise levels at any one time. Further, a collection of maps could be created, so that noise impacts for varying conditions can be compared.

How This Might Be Used For Aviation Noise Impacts

The app and methodologies could easily be applied to a residential community, such as Milton (or Des Moines, WA; or Cabin John, MD; or Palo Alto, CA; etc.). What’s to stop a local activist group from staging a grid of 4- or 6- or even dozens of devices at mapped street locations in Milton, and compiling the data into maps that show REAL decibel-level impacts? What’s to stop that same group from creating reference maps on days where there are no runway 4R and 4L arrivals, to establish a definitive baseline noise level?

Let’s watch this project and see if it offers a smart and economical work-around, so we can move beyond the ongoing data obstruction by FAA and airport authorities.

Boston noise activist groups:

The Third Head of the NextGen Hydra: How FAA is Jamming Arrivals Closer Together

Three months ago, the ‘Dissecting NextGen’ presentation was made in Des Moines, to help people better understand the impacts of NextGen around Sea-Tac International Airport [KSEA]. Included within that presentation was discussion of ‘Hub Concentration’ and ‘Route Concentration’, as two of the main changes that are causing NextGen impacts. Well, continued research in the past months has revealed a third head to this monster: efforts by FAA to alter rules, to reduce spacing between arrivals, even setting up side-by-side arrivals to closely-spaced parallel runways.

FAA is using two main strategies to reduce arrival spacing:

  • Wake Recat: short for ‘wake recategorization’, this is the reduction of minimum safe distances behind larger aircraft that create wakes. Without getting into too much detail, a series of fatal accidents decades ago forced FAA to impose longer distances between successive flights on the same route, called ‘wake turbulence separation’. But, in time, with pressure to remove capacity limitations, the rules are being modified to shorter distances.
  • Simultaneous Dependent Approaches to Closely Spaced Parallel Runways (CSPR): many of the main hub airports rely on use of parallel runways that are spaced even less than half a mile apart. ATC can accommodate a lot of flights on/off parallel runways, primarily by using one runway to land and the other to takeoff. But, when weather deteriorates, especially if visibility is reduced or the ceiling (altitude of lowest cloud layer) gets to be too low, capacity plummets. So, FAA has been working with airlines to develop new ATC procedures that allow flights to be spaced much closer together when set up for landing on two or more parallel runways. [click here to view archived copies showing the evolution of FAA Order JO7110.308B since 2008]

What’s Bugging People?

Although most airports continue to be far below historic traffic levels, there are a dozen or so main hub airports where the ‘Final Four’ airlines (American, Delta, Southwest and United) schedule excessively. These are the airports where people are upset. They are seeing more flights, and they are seeing/hearing flights that are lower, often slower, seemingly louder (which is a given, for lower flights), and often turning closer to the airport than ever before. They are also seeing surges of flights — both departures and arrivals, in rapid succession, sometimes even side-by-side. It is scary to some, and deeply disturbing to many. Even retired air traffic controllers cannot believe what they are seeing. It is as if these few airports have acquired a meth or steroid addiction.

Authorities insist nothing has changed, but they are totally wrong. Well, not just wrong: they are lying, and they know it. At these few hub airports (Sea-Tac is the one growing the most in recent years, due to Delta’s 2012 decision to create a new hub), traffic volume is up, especially during the surges that happen in relation to expanded hubbing. But, there are also forces that are pushing arrivals closer to the ground. For example, with wake recat, the key thing to understand about aircraft wakes is they descend; i.e., the hazard that can flip a smaller airplane slowly drifts downward toward the ground, so ATC works hard to keep the trailing aircraft at least slightly above the leading aircraft. But, if ATC is trying to bring both aircraft in to land, on parallel runways, than ATC needs to push the lead aircraft down lower ASAP. Why? Because, if the lead aircraft is not descended low enough, the trailing aircraft will end up too high, unable to finish the approach. This results in a go-around, which carries higher risks and makes both flight crews and ATC do a lot more work.

An Example: A 13-hr Arrival Stream to Runways 4L & 4R at Boston

Boston offers an example of how badly communities are being impacted. Here, we have densely populated communities and a dominant regional airport, [KBOS], that effectively monopolizes commercial aviation.  Three airlines schedule excessively at KBOS: JetBlue, American, and Delta. JetBlue is the dominant hub airline with a schedule that generates a large number of through-passengers (thus imposing much larger impacts on the area, to accommodate the added flights).

To gain airline support for NextGen, or at least to ensure the airlines will not oppose NextGen (which would kill FAA’s chances of getting Congressional funding), FAA has sold out on their responsibilities to protect communities and the environment. FAA has apparently told the airlines that they can expect increased runway throughput, which FAA will achieve by abolishing all noise mitigation procedures and creating new flight procedures that turn lower and as close as possible to the runways. NextGen is being used as a decoy or cover; by claiming NextGen is all new and fancy, FAA tricks everyone – including Congress – into not noticing that what is REALLY happening is simply the wholesale abandonment of FAA’s past responsibilities to protect the environment and community health. And, by the way, NextGen is NOT all new and fancy; most of it has existed and been used for decades; the alleged benefits are just a fraudulent sales pitch.

Clearly, when you study what FAA has imposed at ALL NextGen airports, the game plan is to maximize runway throughput. This accommodates the ideal all airlines want: unrestricted scheduling to tweak profits higher using expanded hub operations. So, with this in mind, at an airport like Boston, FAA focuses on using the combination of runways with the highest capacity per hour, which at Boston is to have arrivals land on the parallel runways 4L and 4R. Just like happens when new freeway lanes are added, the airlines are quick to eat up the increased capacity; supply defines and expands demand. At Boston, FAA is now heavily relying on 4R and 4L to ‘accommodate’ the expansion by JetBlue, Delta and American. So much for quality of life under the intensified approach corridor. Milton does not really need to get sleep, do they???

A recent 13-hr arrival stream to Boston’s 4L and 4R

And, of course, FAA applies the same strategy at all airports where airlines want to expand hub-related profits: they use runway combinations that maximize capacity, even if wind and other factors might argue against these decisions. It’s called ‘choosing runways to traffic’, and it’s a way to be overly accommodative to airlines.

The result is streaming arrivals: nearly nonstop impacts on the ground, one arrival after another after another, sometimes even paired arrivals that are nearly side-by-side. As shown in this table, summarizing arrivals per hour on the intensified approaches to Boston’s runway 4L and 4R, the impact is relentless. Note the busiest hours are non-stop, averaging as little as 1.2-minutes between flights. [click here to view the entire stream in a data table]

And, adding insult to injury, when people notice and ask what has changed, both FAA and the airport authority (Massport, in this example) play with them: they say nothing has changed.

How Do We Kill This Monster?

FAA is simply out of control. And, Congress is doing squat to correct this problem. We need leaders in Congress to:

  1. demand that FAA serve the people ahead of the corporations, and this requires an emphasis on both transparency and accountability;
  2. demand that FAA cease spending our money to propagandize for the industry; this regulatory capture has gone on far too long;
  3. pass legislation that strongly disincentivizes airline hubbing – one of the simplest changes would be to formulate a new set of fees and taxes, the heart of which should be a very steep aviation fuel tax;
  4. and, pass legislation that restores local control, so that local communities have a real voice, and can impose reasonable curfews and capacity limits, and can say ‘NO!’ to airport over-expansion.

NextGen: “A Virtual Highway, and the Traffic Never Stops”

A good opinion piece related to NextGen impacts (and ongoing FAA failures) near the Baltimore-Washington Airport [KBWI]. This airport serves as the hub for Southwest, in the DC area (NOTE: the two other major airports serving the DC area are Dulles [KIAD] and Reagan National [KDCA]; United hubs at KIAD, and American dominates at KDCA]. There is some misinformation in the Op/Ed, as happens in a world run by money and set on crafting and pitching propaganda, but they also make some great points.

Here is an archived copy, with aiREFORM footnotes added:

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