Our Unsustainable Secret: Leaded Fuel and City-Owned Fuel Tanks at Santa Monica

UPDATE, 30 MAR 2022:Elected officials in Santa Monica continue to be paralyzed and unable to do the right thing: discontinue leasing out their old tanks for leaded avgas and jet fuel sales, tanks that are decaying and well past their prime. They fear a lawsuit, and the City Attorney is only adding to their fears, by failing to identify who might file, at what venue, and citing what laws or regulations. Lacking any legitimate basis for a lawsuit, the Council is effectively being bullied into paralysis.
Here are two recent items: a letter to the editor by Joseph Schmitz, and a Facebook Post by Charles Blum.

Here’s an excellent OpEd by Alan Levenson, a resident of Sunset Park, printed in the Santa Monica Lookout. His concerns are about toxic lead, still in the aviation fuel used by recreational pilots in small planes, a situation that persists in no small part because FAA resists changes, and because local elected officials are often too intimidated by FAA to lead and serve. This is a national problem, too; there are dozens of posts under the category ‘LeadedAvGas‘. Read on…

We are all aware of the controversial airport that sits behind a fenced area in the southeast corner of Santa Monica. We have heard of the noise problems, the safety problems and the pollution. We know we were promised a great park.

What most have not heard much, if anything, about is the lead. The same lead that has been banned in auto gasoline, paint and toys is used in aviation fuel.

The leaded fuel is burned by most of the small planes that take off and buzz around over neighborhoods. The lead comes out in the exhaust and falls on people, homes, and schools below; it drops like lead at the rate of two grams per gallon. The City need not sell aviation fuel. Storing and supplying fuel is not our responsibility, and it is definitely not a sustainable business.

What most do not know is the City owns six underground tanks, three of which are 36 years old. That’s old for an underground tank; old even when not in earthquake county. The tanks sit above our aquifer; the same aquifer that has already been fouled in the past by Douglas Aircraft and leaking tanks from gas stations in years gone by. The same aquifer that supplies drinking water. Sure, the tanks are periodically checked, but accidents and failures happen.

The City is voluntarily storing and selling a known toxin. Lead has been proven to be unsafe at any level. It has been found in the blood of children around a similar airport, Reid Hillview, in San Jose, CA, at the same levels found in the children of Flint Michigan. A recent air quality study found elevated lead levels in the air around our airport and declared the airport to be the only source of airborne lead in the area.

Last November 2021 Councilmembers Brock and de la Torre proposed the City staff divest from the storage and sale of leaded fuel and the council unanimously agreed (“Santa Monica Could Join in Call for Ban on Leaded Aviation Fuel,” November 5, 2021).

Our Airport Commission also agreed. Even though we are not required to do so, the City staff has recently undertaken a project to sell unleaded fuel from one of our tanks, but our staff has not charted a known course of action to stop the sale or storage of lead in the second and older 12,000-gallon tank.

The City Attorney claims shutting out of the second tank might cause a problem in the future with the FAA or the aviators. Yet we know that in the real and now present that lead is coming out of Santa Monica Airport, exposure to lead reduces the IQ in children, and its effects are permanent.

Lead is a clear and present danger. We know the tanks sit above our aquifer. Lead is the elephant in the room and in our tanks, and that elephant must be shown the door. Santa Monica does not have to participate in this dirty business that should have ended decades ago as it was with cars, paints and toys.

Pilots and aviation businesses alike claim they too would like to get the lead out of aviation fuel. Yet while leaded fuel is available, they continue to use it. We know lead is bad. Even a little lead is bad. No lead is good. Not in our water, our air, our soil or our bodies.

No one is putting a gun to anyone’s head to sell and store leaded fuel at Santa Monica Airport.

It’s not green, it’s not sustainable, and it’s not defensible. In fact, after being asked for a clear explanation as to why we cannot get out of the fuel business we were not shown a convincing answer. We are talking lead, not bacon wrapped hot dogs on the pier. You cannot refuse or hide from airborne lead. Aviation fuel is the serious stuff of industry. Toxic to living things.

Our FAA obligations do not allow the City to ban the total use or sale of leaded fuel at the airport, but in no place do they clearly state the City must provide tanks or the City must sell fuel. It is time to retire our old tanks and get out of the leaded fuel business. It makes sense to get out of the aviation fuel business altogether.

If an aviation business wants to bring in their own newer safe and up-to-code tanks, then let them bear the costs, as well as the responsibility for the harm they are causing to those on the ground.

There comes a time to stand up for what is clearly right and reject what is not. It is wrong for a responsible and sustainable city to support and participate in the sale and storage of lead and any toxic fuels. There is no safe level of lead in our water or our air. 

We have an obligation to keep the airport open until 2029. We have no obligation to store and sell fuel until then. 

Please get out of the fuel business. Do it for the kids.

Santa Monica: The Quest for Local Control Continues

The last time the City of Santa Monica accepted FAA grant monies was in 1994. But, airport grants are not just for subsidizing the few who use the airport; they are also for imposing restrictions on the airport sponsor (in this case, the City of Santa Monica), so as to perpetuate the airport and also to compel airports to become dependent on more FAA grants. The list of restrictions, called ‘Grant Assurances’, is extensive. One of them, Grant Assurance 22, comes up time and again, used by FAA and aviation interests to confound airport sponsors and activists seeking balance or closure. 

By definition, Grant Assurances remain valid for 20 years; thus, 20-years after a grant is accepted, if an airport sponsor accepts no grants for those twenty years, they have finally earned their freedom from grant-slavery, come clean, and can theoretically regain local control of their local airport. This is what the people of Santa Monica aspired to do eight years ago, in 2014.

The Santa Monica Airport is jammed up against houses and, in fact, the spacing is so deficient residents have had lawn furniture overturned by the blast behind taxiing jets. The lead from leaded aviation fuel continues to be deposited on area homes, because FAA and the aviation industry have stonewalled the replacement of leaded aviation fuel. Indeed, in the 25-years since lead was removed from all U.S. automotive gas stations, there have been thousands of new engines built, put into new small recreational airplane designs, all centered on the consumption of leaded aviation fuel.

Activists have been fighting for health and quality of life for many decades, so it is not surprising that, when the City of Santa Monica finished their last grant obligations in 2014, a ballot measure was added to the November election seeking local control and conversion of the property to a park. The aviation lobbyists spent lots (estimates were 8-times the spending by Local Control proponents,) but they lost. The majority spoke and voter empowerment made it look like residents were going to see a park soon. It was headed that way until late January 2017, when a few City officials, fearful of dragged out legal challenges and an ongoing lack of FAA cooperation, caved to FAA’s pressure and ‘settled’ with a Consent Decree that made airport closure arguably a lot less likely.

The fight goes on. City Council met just last Tuesday, and was given a 94-page packet by City Manager David White, ‘Update on Dispensing Unleaded Fuel at SMO’. They also received 72-pages of citizen comments, all advocating for an end to leaded fuel sales, and preferring a full closure of the four underground fuel storage tanks the City owns. Included was this 3-page PDF investigating the integrity of the fuel tanks.

So, What’s With ‘Grant Assurance 22’?

Grant Assurance 22 is ten pounds of ambiguity under the headline, ‘Economic Nondiscrimination’. It has nine listed elements. Three of them are:

Grant Assurance 22a states: “It will make the airport available as an airport for public use on reasonable terms and without unjust discrimination to all types, kinds and classes of aeronautical activities, including commercial aeronautical activities offering services to the public at the airport.”

Grant Assurance 22h states: “The sponsor may establish such reasonable, and not unjustly discriminatory, conditions to be met by all users of the airport as may be necessary for the safe and efficient operation of the airport.”

Grant Assurance 22i states: “The sponsor may prohibit or limit any given type, kind or class of aeronautical use of the airport if such action is necessary for the safe operation of the airport or necessary to serve the civil aviation needs of the public.”

So, while 22a seems to imply ANY aviation activity has to be allowed without discrimination and on reasonable terms, both 22h and 22i offer exceptions, allowing specific conditions and even outright prohibitions, as needed for safety and efficiency.

Would it be a ‘reasonable term’ to NOT allow lease of an underground tank past its designed age limit? Should FAA’s view of safety include protecting area residents from lead toxin exposures? Is FAA our friend or our enemy (with us or against us)? What kind of a regulatory agency is it that leans hard with its sole authority but lacks the heart to cooperate with communities impacted by its activities?  Is this the same agency that handed off regulatory action to Boeing for the deadly 737MAX fiasco, and the same agency that grounds all tiny drones in yards to protect manned aircraft (yet is now slowly repealing rules so drones can fly low over crowds of people)? Yup, this is FAA: the U.S. aviation ‘faux-regulator’ captured to serve aviation, and working to protect industry from problematic people.

Oddly, the City Attorney is hung up on Grant Assurance 22, acting and speaking uncomfortably to question its applicability. And, unfortunately, the City Manager appears to be parroting the statements by the City Attorney. As a result, the City’s residents are being subjected to an unsafe, unhealthy perpetuation of aviation privilege that benefits a tiny elite. But these City officials are missing an important reality, so fearful they are of FAA. Both of them should ponder this: if they shut down all the tanks and an aviation lobbyist files a Part 16 complaint (against the City, claiming they are not compliant with grant assurances), their biggest penalty will be placement on the ‘Airport Noncompliance List’ and loss of grant eligibility… neither of which matter, for an airport set to close later this decade.

So, let’s close down the underground tanks. And, thank you, City of Santa Monica, for standing up to the FAA bully.

[ai-RCHIVE] Four Versions of FAA Advisory Circular 91-36

Here’s an example of abusive pilots, that also shows how FAA is a captured federal regulator actually enabling this type of abuse.

Fort Devens is a historic U.S. Army facility in the towns of Ayer and Shirley, roughly 25-miles west of Boston. Years ago, the Moore Army Air Field was closed. According to Wikipedia, part of the land then became a hospital facility, aimed primarily at serving specialized and mental health needs for prisoners.

Back in the early 1970’s, coincident with ‘Earth Day’ and the wave of citizen empowerment toward improving and protecting the environment, FAA was nudged into creating an ‘Advisory Circular’ about small airplane noise. The advisory circulars are not binding or regulatory, but they do spell out what FAA asks the pilot community to do, toward achieving certain objectives. This is how FAA treats pilots: ‘pardon me, would you please try this?’, like royalty. If pilots do not conform to the ‘advice’ contained within an advisory circular, eventually FAA can become compelled to issue actual regulations. Now, if FAA also chose to enforce those regulations, we might achieve a nice balance, between the right of the pilot community to use their aircraft, and the rights of the non-pilot community (aka, all of us residents) to enjoy our homes and yards without excessive noise and aviation air pollution.

Roughly a decade ago, residents around Ayer prevailed in a nuisance lawsuit filed against a group of pilots. Ever since, there has been an extraordinary concentration of low-level small-plane flight activity over the homes of the residents who won that legal action. When these residents complain to FAA, to MassPort (the airport authority), or anyone, they get nothing but deadends.

Check out this disturbing example, posted on Facebook.

Now, about that ‘Advisory Circular’. In the 46-years since it was first posted in 1972, it has been updated three times. The updates are generally unsubstantial, as you can see for yourself. Here are links to archived copies of all four versions of FAA’s Advisory Circular 91-36, ‘VFR Flight Near Noise-Sensitive Areas’. Each version is 2-pages, with minor changes as the Advisory Circular evolved. Version ‘91-36B‘ was signed off in 1982, version ‘91-36C‘ appeared in 1984, and version ‘91-36D‘ (the current version) was signed off in 2004.

Frankly, these four versions of Advisory Circular 91-36 show FAA’s ‘milquetoaste approach’ to NOT managing aviation impacts. FAA has made it clear to rogue operators like this one near Boston: they may bully with impunity, knowing FAA will not impair this perceived ‘right’. The impacts that FAA recognized in 1972 have persisted because FAA refuses to serve and fails to evolve. And so, across the nation, for two generations now, residents have complained and been ignored by an agency that serves only the industry it is supposed to be regulating.

Seeking Quiet Sleep at Lake Arrowhead

Activist David Caine has written a letter to Dennis Roberts (FAA Regional Administrator for the Western Pacific Region) and David Abney (CEO at UPS). It was published online at Mountain News. Here’s an aiRchived copy of David’s letter:

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

Ontario is a cargo hub in the eastern part of the LA Basin. UPS flies numerous flights into KONT each day, as does FedEx. Well, the problematic ones are the typical ten large arrivals between 1AM and 5AM on most days. These two big operators (the duopoly cargo haulers in the USA) like to operate at night, when there is less air traffic. They get more direct routes from ATC, and they typically push the engines to ‘scream’ across the sky. But, if ATC does not care to protect those sleeping below, the direct routes and screaming engines cause many below to be rudely awoken.

This is a classic example of why people need FAA to perform for the entire nation, not just for commercial aviation concerns. This is why the current situation, with FAA clearly a captured regulator and tone-deaf to citizen impact concerns, is failing all of us. The impacts at Lake Arrowhead were covered before in this aiREFORM Post.

Dennis Roberts is the latest person to serve as FAA’s Western Pacific Regional Administrator. He gave a presentation ‘explaining’ what FAA might do to reduce the impacts. A new arrival route, JCKIE1 STAR, was explained, too. A lot of techno-mumbo-jumbo, but when promises are not kept, it only makes FAA look that much worse.

Can we just be allowed to enjoy our homes and get some sleep??!??

“Lead makes the mind give way.”

So, too, do the intense politics and greed associated with the aviation industry. Even more so when industry ‘collaborates’ with faux-regulators like FAA, to spew out mountains of GWBS (a new acronym, standing for ‘greenwash BS’). But, we all endure; we learn, we share, we activate, we demand change.

There is a lot happening this summer. Not just the continued drive for more over-expansion at hub airports worldwide, but also as regards smaller airports. Miki Barnes at Oregon Aviation Watch has been one of the biggest activists in the U.S., seeking changes at FAA, Port of Portland, and the Hillsboro Airport [KHIO]. OAW recently sent out an email about the ongoing health impacts associated with lead, which remains in the common aviation fuel ‘100LL’ (the LL stands for ‘low lead’). Miki notes:

“The aviation industry is the largest source of airborne lead pollution in the country. The Port of Portland owned and operated Hillsboro Airport (HIO) is a prime example. The majority of the users of this facility are student pilots recruited from overseas and out of state to engage in flight training over the local community.”

So, at Hillsboro, an airport authority (PoP) was created long ago and collects local taxes, but PoP operates with no obligation towards accountability and transparency; furthermore, PoP has predictably evolved into a servant for industry, helping to gin up industry profits by blocking citizens seeking to moderate aviation impacts while also ignoring growing citizen concerns.

Two copies are aiRchived here:

Santa Monica Airport: Last Chance to Comment on Minimum Standards

Airport officials at Santa Monica are in the process of creating ‘Minimum Standards for Commercial Aeronautical Service Providers. These standards can ensure that all potential operators are fairly treated when and if the airport authority denies certain operations. Last week, Airport Director Stelios Makrides issued a statement that the deadline for comments has been extended to June 21st. (click here for an archived copy)

Santa Monica is a very unique airport. It should have been allowed to close down years ago, but FAA has obstructed the will of the local community, solely to protect aviation interests who insist on using this deficient airport facility. How is it deficient? Just take a look at the satellite images and airport map, and note how closely the nearby homes and yards stand, relative to the runway. At Santa Monica, people have had their lawn furniture blown over by the blast from departing jets; REALLY!!

The runway was shortened last year, but now the City is failing to impose needed standards that block unsafe operations by jets and commercial operators. Aviation money appears to be impeding their judgment.

Santa Monica is also notable as an airport where FAA lawyers managed to convince the local elected officials to ‘settle’ legal differences with an inexplicable agreement to extend the life of the airport. Money talks, and rumor has it the elected officials were tired of spending so much money on legal services, trying to exercise their rights against FAA’s industry-serving will. You got it: our money, collected by FAA from we the taxpayers, and spent as FAA sees fit, is arbitrarily used to impede meaningful LOCAL CONTROL by compelling our own elected officials to use our money (local taxes, this time) to fight FAA in the courts.

Below is a copy of a recent letter by Gavin Scott, posted at NoJetsSMO. He summarizes what he observed at the June 5th Airport Commissioner’s Meeting. He also advocates – strongly – for people to submit their own comments right away, before the chance is gone.

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

Airport Reference Materials: Annual Enplanements, ATADS Operations, Tonnage, AIP Grants, and NPIAS Lists

There is now a newly-completed and extensive collection of searchable/downloadable PDFs with valuable information on U.S. airports. All data was collected from online sources, either FAA or vendors who do outsource work for FAA.

Many of the tables are grouped by state and ranked by a factor such as enplanements. Alaska is top of the list, and a huge aviation state, so be sure to scroll down a few pages to see Alabama and the other states where NextGen abuses are causing so many problems (Massachusetts, Maryland, New York and Washington are good studies).

Here is a short index, with links:

Much more will follow, as these resources make it easier to expose how deeply FAA is captured, in service of industry players. Readers are encouraged to spend some time studying parts of this data collection; if you see something that really jumps out (for waste, abuse of authority or outright fraud by FAA) please share it on.


UPDATE, 4/13/2018: — correction to original posting… ATC staffing data was inadvertently not included. The Consolidated Airport Data for 844 Airports table has been updated, and one more table has been added (the more extensive data table showing annual ATC staffing for 263 FAA-staffed towers).

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?

NextGen Abuses at California’s Lake Arrowhead

Click here to read an archived copy of the 12/21/2017 Mountain News article by Heidi Fron (or click here to view the source article), and be sure to read the two ‘open letters’ seeking to fix these NextGen abuses! Both Jim Price and David Caine did a great job defining the impacts and articulating the need for FAA to revert to the less-impactful, pre-NextGen routes.

Here’s an embedded video of a TV news story that discusses the Lake Arrowhead impacts:

Seven months later and there has been no improvement. Just like we’ve seen around the nation: Delay – Delay – Delay.

As one more resource, click here for a brief analysis of the role of Ontario’s airport, and how NextGen changes are expanding the impacts at what is generally a fairly sleepy airport with a pair of huge runways.

To Understand NextGen, Just Follow the Money

There is nothing complicated about FAA and NextGen. Just follow the money, and recognize that FAA does not serve the people, they serve the industry, providing cover for wholesale environmental abuses that are destroying community quality of life as well as the health of many people. Very many people at FAA benefit immediately, and in retirement (with higher pensions, plus consulting or FAA-contractor gigs), with NextGen implementation. The benefits for the environment are effectively nil, and in many cases the net result is an INCREASE in impacts, solely to help the airlines shorten the flight by a minute or two.

As for the NextGen technology, well, the alleged technology changes are just a fraudulent sales pitch, oversold by FAA employees all too eager to knowingly dupe Congress and the rest of us, too. The 12/18/2017 flight mentioned by David Caine is a prime example of this fraudulent sales pitch. This cargo Boeing 767 took off from the UPS headquarters at Louisville, KY, then flew essentially a straight line (great circle route) to pick up the EAGLZ Arrival into Ontario. Here’s a screencap showing the whole route, as well as the altitude and speed profile: (source: FlightAware)

People need to understand this fact: essentially all U.S. commercial flights (cargo, as well as passenger) have been able to do these long great circle routes since the 1970s. Even before the 1970s, inertial navigation systems enabled these routes, and since then, there has been a long series of technological advances that included a heavy emphasis on aviation use of GPS navigation in the 1990s.

Think about it this way: what exactly is the efficiency gain for this particular flight, KSDF-KONT, that FAA can offer UPS? The route is already as direct as can be. The only efficiency gains are minor shortcuts for UPS, but at great cost to residents, both those near the airport in Louisville, and those under the Ontario [KONT] arrival track. People in Lousville [KSDF] suffer because ATC allows (actually, directs!) UPS to short-cut their turns right after takeoff; people at Lake Arrowhead are awakened unnecessarily because ATC allows (again, actually directs!) UPS to fly a more direct and lower ‘finish’ into KONT.

By the way, this is the case for most all commercial flights within the U.S.: so long as traffic congestion is not a factor (and congestion is not a problem for cargo flights that take off around 4AM, a key reason why the industry focuses on night flying), the system is already very efficient. The delays NextGen is supposed to help reduce happen when the airlines over-expand at a handful of hubs, and schedule far too many flights, solely to build profits. And, if we have learned anything from studying the multiple NextGen debacles, it is that these alleged ‘transformational changes’ do NOTHING to resolve airline congestion. Indeed, congestion will only be reduced if/when FAA reclaims its role as a regulator, not just an industry cheerleader/enabler.

We are told NextGen is ‘transformational’, with implications of great efficiency gains. That’s BULLSHIT! The ONLY benefits are to the aviation operators and FAA personnel, while real people are bearing ever increasing costs.

And a Closing Question

Why are FAA’s controllers and managers complicit in this fraud? Well, more planes in their airspace eventually help air traffic controllers (ATC) to nudge total workloads (and the number of sectors and controllers at that ATC facility) to the next pay level. When controllers see nice pay raises, management gets raises, too. Ultimately, for all of them, retirement pensions rise, too. Paradoxically, per controller productivity (number of flights handled per hour, per controller, for example) continues to decline, and work complexity continues to be reduced by more and more automation. Despite all this, FAA pay and  benefits continue to grow. Go figure.

People and Communities Would Benefit, if We Disincentivized Hubs

Interesting discussion about community impacts and port authority overdevelopment at Sea-Tac [KSEA], in this Quiet Skies Puget Sound Facebook Post.

(click on image to view source Facebook discussion)

Here, one of the area residents being victimized by Sea-Tac overexpansion suggests what really is the easiest solution: spread the flights out, so people are served locally, by their own local airport.

So, how do we make this change? The key to getting there includes changing the current system of fees/taxes to economically disincentivize hubs. For example, the U.S. Congress and FAA need to do three things:

  1. end ticket charges (especially the PFCs) that incentivize airport over-development. With airport PFCs, FAA/DoT collects billions of dollars each year, which are then reallocated into airport development projects. Much of this money goes to rural airports with nearly zero traffic (such as the recent debacle at Mora, MN), and the funds are generously doled out with near-zero local matches required. Airports like Sea-Tac are thus motivated to develop far beyond what the actual airport property and surrounding neighborhoods can stand.
  2. impose a steep carbon tax with at least half of revenues going away from aviation, such as to high speed rail. Indeed, the aviation sector provides an excellent opportunity to trial such a tax, while also funding new programs that are far more energy-efficient.
  3. establish a user fee system based on two key factors: direct-miles (between origin airport and destination airport), and aircraft seating capacity. Apply this fee system to all commercial flights (passenger and air cargo) as well as to all higher performance aircraft (e.g., bizjets, and flights by fractionally-owned aircraft). Thus:
      • for any origin-destination pair, a 200-passenger jet would pay twice the fee as a 100-passenger jet, and a 400-passenger jet would pay 4-times as much.
      • a 30-passenger bizjet would pay the same aviation user fee, whether it is chartering one elite passenger of 28, whether it is flying IFR (in the ATC system) or just out on a high-performance VFR hop.
      • passenger ticket fees/taxes would be proportional to itinerary distance. E.g., a passenger ticket from Seattle to Boston via Atlanta would pay 25% higher fees due to 25% higher distance (2,712 NM through ATL versus 2,161 NM direct SEA-BOS); likewise, a SEA-LAX-BOS itinerary would pay 43% higher fees than a direct SEA-BOS itinerary (hubbing via LAX, in this example, increases distance flown from 2,161 NM to 3,091 NM).
      • and, of course, this all would apply to commercial helicopters, too. A helicopter doing an urban air tour, or a helicopter charter hop from KSMO to Staples Center, would pay the fee, subject to a hefty minimum user fee per operation.
      • similarly, it would apply to commercial skydive operators, whose noisy aircraft would also be subject to a hefty minimum user fee per operation.

This simple set of proposed fees/taxes would not only reduce hub pressure at places like KSEA, KJFK, KCLT, KPHX, and KBOS; it would also all but eliminate system delays, and reduce environmental impacts. Plus, this system would strongly incentivize the airlines to offer more direct flights. This would mean less travel time for the consumers who fund this system, and would be a Win-Win for nearly everyone. The only losers would be the airlines and airport authorities who have gone too long, abusing too many, under the current flawed fee/tax system that maximizes consumption.

Just one thing is required: an elected Congress willing to work together, to order FAA reform: to totally revamp the fee/tax system, replacing it with only a carbon tax and a direct-miles fee.