Is Septic at KUAO a ‘Constrained Operation’?

The image above is from p.2-30 of the February 2022 draft version of Ch. 1-3 (83p PDF), as shared with the PAC in the current Master Plan process. Orange markings were added by aiREFORM. Note the five green ‘drain fields’ mapped on ODAV lands.

In the same document, at p.2-39, there is text briefly summarizing Sewer/Septic issues. It states, “Sanitary is provided by individual and shared drain field/septic tank systems. There are at least nine individual drain fields located on ODAV owned property that are shared for both aviation related uses on both private and publicly owned land.” This seems to suggest, ODAV lands are being used for drain fields serving structures on private through-the-fence (TTF) properties; it also suggests, at least four drain fields are not yet shown on this Master Plan diagram.

The density of development at KUAO is surprising, especially on these prime agricultural soils. Most of us in this area, if we own acreage and seek to build, one of our biggest front-end problems is to figure out, ‘how do we handle septic wastes’ and ‘will the soils support a sustainable septic drain field’. Sustainable is a key concept; it is NOT sustainable to need to have septic waste pumped out of holding tanks by a weekly service (the present situation, according to multiple people).

The evolution of Aurora Airport has included a huge shift to large hangars and massive impervious surfaces, to accommodate jets larger and heavier than are supposed to use the runway and taxiway. The extent of impervious surfaces developed at the Aurora TTF parcels begs for answers to these questions:

  1. Where precisely are ALL drain fields, how big, and how plumbed to serve which structures (both on and off ODAV lands)?
  2. What are the actual septic demands, and is the current drain field capacity sufficient to meet that demand? If additional drain fields are needed, what sizes, and where will they fit on FAA’s ALP (the critical document, the Airport Layout Plan)? For each plumbed facility, on and off the airport parcel, people should know: how many fixtures, how many projected employees or visitors with how many projected daily uses.
  3. Are these drain fields legal and safe, by Oregon standards? What do the permits say, and do the as-builts conform with the permit designs? How are they positioned reference drainage ditches and surface water features?
  4. Do any septic line locations impact plans for the investment of public funds into runways, taxiways, or other design elements?
  5. Do any drain field locations impact potential new facilities, such as hangars or FBO buildings?
  6. Is FAA OK with drain fields in locations where emergency equipment may need to respond to aviation accidents?

All of these questions – and the answers – need to be fully incorporated into the current Master Plan record. FAA and ODAV need to press this point, to ensure Century West produces the Master Plan content that truly informs everyone, and aids eventual decision-making.

To Sham or Not to Sham? Ah, yes, another Aurora Airport Master Plan Process…

The current Master Plan process for Aurora Airport is a classic case study, showing how aviation interests work to suppress airport expansion opposition and force their own self-serving pro-expansion agenda. And the aviation interests are not just a few pilots or operators at Aurora. This is a state airport, run by the state of Oregon, via the Oregon Department of Aviation (ODAV). Oversight comes from two entities with a long history of taking care of pilots while making a mess for the rest of us: the ‘Oregon State Aviation Board’ (OSAB) oversees ODAV, and FAA ‘signs off’ on the key steps of the work product, the eventual ‘Aurora Airport Master Plan Update’.

The previous Master Plan process blew up almost twelve years ago. At that time, the contractor and ODAV had a rare moment of good judgment, when on 3/10/2011 they presented a recommendation to the OSAB for no runway extension. The reaction by pilots on OSAB quickly nudged an aggressive campaign by a beehive of other Oregon pilots, and by Fall the ‘preferred alternative’ morphed into a 1,000-ft runway extension. It was a sham. Years later it was realized that, in all the commotion, authorities never got around to formally adopting the plan. Embarrassing, but not a problem; FAA stepped in and is now spending nearly a million dollars in public money, to have a contractor, Century West, create a new Master Plan. The process today and the many returning players echo strongly the horrible events around the 2011 process. It is hard to shake off the feeling this is yet another sham.

“It is beyond dispute that a lengthening of the runway, to allow larger and heavier fuel loads, benefits an elite core of operators and adjacent landowners who sell aviation fuel. Their goal is clearly to make more money selling larger volumes of fuel… and ODAV collects more
airport revenues in the process.”

So, what’s in this Aurora Airport Master Plan, for people impacted by airports elsewhere in the United States? A LOT!! So often, for someone being run around by rogue pilots and out-of-control airports, one of the most empowering tools is simply understanding the process. Not just the process as written up ad nauseam in boring FAA and contractor prose, but also HOW the process is played by the critical players: the airport authority, the FAA, and the pro-airport community (mostly pilots and aviation commercial interests).

This aiREFORM Post is the first in a series that will dive into the history and details of Aurora Airport, not just to help a few Oregonians seeking to tamp down over-expansion at Aurora, but also to educate others far from the rich farmlands of the Willamette Valley.

Click here to view a letter sent to two people seeking citizen engagement in this Master Plan process: Sarah Lucas (an ODAV aviation planner) and Brandy Steffen (a contractor at JLA Public Involvement).

Answers Needed in Santa Monica

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

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


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

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

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

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


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

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


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

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

A Few Simple Questions

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

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

New Aerotropolis Article, by Rose Bridger & GAAM

Another great article by Rose Bridger, who has published a 22-page slideshow called: “Climate Change, Concrete, Capitalism & the Airport City – What’s really going on at Manchester Airport, and with aviation worldwide.” A PDF version is presented below, with some very nice graphics (best viewed using the pop-out feature):

This pop-out view is scrollable, and the PDF copy may be downloaded.

How FAA is Sabotaging the Citizen Involvement Process on ‘OAPMs’

Suppose you live in Southern California, maybe near the airport in Santa Monica. And, suppose you are highly responsible, the kind of person who doesn’t just take the time to vote but also sacrifices even more of your precious personal time to participate in important decisions by your government. You make it a habit to stay informed and involved.

One day, a news item announces that FAA has a big airspace redesign project: the SoCal Metroplex OAPM.**OAPM = ‘Optimization of Airspace & Procedures in the Metroplex’. You read the article and see that FAA has posted documents online and will have public ‘open houses’ at libraries and other locations, to answer questions and to enable citizen awareness of the proposals. At the end of the ‘open houses’, FAA has set a deadline for you to offer your concerns, suggestions, etc.

You are a busy person, with a job and a home and a family, but you nonetheless make time to do what you feel is your civic duty. You go online and find a slick webpage (created by a contractor for FAA) with an overview and more links. You click on the ‘Documents’ link and find another slick page, this one with links to 57 documents totaling 793 megabytes. Some of the links point to PDF files so large (the largest three are 70MB, 83MB, and 84MB) that you cannot even bear the long wait time to finish a download. You nonetheless wait through the slow downloads and open a few of the links.

You then wade through hundreds of pages, filled with aviation acronyms and other gobbledygook. You are bright and curious, and try your damnedest to make sense of what you are reading, and yet many pages are filled with information that appears to be completely irrelevant. Not just irrelevant to your small area of concern (how will these changes impact my home and my family, here in Santa Monica?), but even for the larger area of focus identified in FAA’s 57 online documents (the entire SoCal Metroplex, spanning from the Salton Sea to Solvang, and from Victorville to Tijuana).

You plow ahead and formulate a few questions. You attend a local Open House, where you find a team of FAA employees and aviation professionals awaits, ready to answer your questions. They eagerly focus on the claimed benefits, especially the claimed reduction in fuel consumption, but they grow quiet on some of your questions. You become perplexed when you realize: they are refusing to answer any questions related to the environmental impacts of their proposed changes. It is as if the proposal is all about enhancing capacity while blindly ignoring the environment. You depart the Open House and maybe, just MAYBE, you still have enough energy left to write and submit a comment before the deadline. Or, perhaps more likely, you simply shake your head and wonder: Why is this such a broken process?

The Laws…

Rest assured: it was never intended that the process would evolve as it has, to narrowly serve only the regulator and the regulated, at the expense of the much larger Public. And it is not you; it is the process that has gone nuts.

In the big picture, there are two fundamental elements needed for the effective functioning of Democracy and representative government:

  1. maximum informational transparency (in the timely release of quality reports and draft documents),
  2. and the assurance that individual citizens have an opportunity to meaningfully participate in the decision-making process.

To protect the people against agency regulatory capture, many federal laws have been deliberated and passed by Congress. Not least of these laws is the Administrative Procedures Act (APA). The APA was passed in the 1940’s, aimed at bringing the evolving over-reach of numerous federal agencies back under control. Aimed at ensuring, no matter how simple or complex a proposed new rule was, agencies were not allowed to operate in a vacuum, and citizens were empowered to make meaningful contributions. Essentially, it is a check-and-balance; our past Congress’ passed laws that empowered our federal employees to create changes, but to protect our rights and ensure an effective process, Congress also passed laws requiring an open process engaging the public.

Wonderful concept, isn’t it? The problem, though, is this is only a ‘concept’, because in reality FAA (and more than a few other federal agencies) have slowly developed strategies for subverting the process. FAA is the regulatory agency with the authority to regulate airlines, manufacturers, and other aviation entities. But, FAA is a captured agency, and as such routinely serves the interests of the airlines and others FAA is supposed to be regulating.

…And How FAA is Subverting the Laws

FAA is knowingly ‘fixing’ the outcome of the reviews for changes in airport procedures and airspace design, by using the following strategies:

  • overwhelm the individual citizen with documentation, so that it is impossible for a responsible citizen to dedicate enough of their personal time to completing a thorough review. For example, a typical airport Master Plan, even for a very insignificant rural airport with little traffic, commonly measures 300-500 pages; it is hard for even a very intelligent citizen to sort through the document, even just to establish which pages are relevant and which pages are irrelevant.
  • further overwhelm the individual citizen by expanding the scope of the changes being proposed. By doing this, even the sharpest citizen (and what are the odds they are also blessed with limitless time and obsessive research skills?) will find it impossible to produce any kind of focused, specific comments. In the example of the current SoCal OAPM, the only people who MIGHT be able to process all the data are the FAA contractors who earned millions in public funds creating that webpage with 57 links to 793 MB’s of PDF files. And, don’t forget: FAA and its contractors are all biased toward approving the proposals!
  • be selective with FAA’s answers to citizen questions. By routinely ignoring the environmental questions, the agency (and, also, the aviation professionals who are ‘collaborating ‘ with FAA in this selective ‘non-answering’ policy) will nudge concerned citizens toward self-doubt. Some may even begin to question whether they are too sensitive about a problem the so-called experts cannot even recognize.
  • drag it all out forever. Delay, and delay some more, so that the process cannot possibly engage the ongoing attention of a concerned citizen. They can come to a long series of presentations, and hear the same garbage. Each time, the citizen is allowed to express his or her concern. After doing so a few times, they may just get the intended message: “WE ARE NOT REALLY LISTENING! So, move along and shut up, and accept we will do what we want at this airport!”
  • Divide and conquer. The larger Public is horribly disserved, but FAA does their job very well (that is, their REAL job, which clearly is ‘serving aviation interests’) when they find ways to get those who question airport projects to instead fight among themselves. Even good, smart and dedicated people have their limits. Stress them with noise and leaded exhaust and jet fumes, then do little to mitigate the problems; eventually, passions will flare and more citizens will give up.


Don’t Rehab La Guardia Airport. Close It.

A well-reasoned NYTimes Op/Ed by George Haikalis, a civil engineer and transportation planner, correctly notes that closure of LaGuardia Airport needs to be seriously considered. The billions of passenger taxes we might spend on upgrades to the KLGA terminal and other airport facilities would much better be applied to high-speed rail access to JFK and Newark. Both of those major airports have long parallel runways and much higher capacity. Plus, closing LaGuardia not only simplifies the gnarly tangle of air traffic control routes in New York City (which would greatly shorten the JFK approaches), it also brings huge noise relief to tens of thousands of residents. AND, it opens up 680 acres of land for urban redevelopment, much of it waterfront land. The possibilities are great, and need to be widely discussed.

The Op/Ed has generated lots of great comments, including this one from a Canadian. His point is spot on. New York is one of the world’s greatest cities, and for crying out loud, enjoying a good bagel while awaiting an airplane boarding call should be an easy and pleasant experience … especially in New York City!

“There is a little coffee and snacks stand in a hallway in the terminal that also serves bagels. A few years back I ordered a bagel and asked to have it toasted. The one employee, who was behind the cash, pointed me to a toaster placed precariously on one edge of the counter. This wasn’t one of those ones where you can put in several bagels at a time on a chain and watch them disappear and then come out toasted from the bottom, but one of those spring loaded ones many of us have at home. So I lined up behind two other people who were also toasting their bagels until it was my turn. After my bagel popped out it was time to butter it. Security being what it was I was given a plastic knife that was far too bendy to easily lift the frozen butter out from the butter packages I was given and spread it on the bagel, all the while trying to share a tiny space of counter with other bagel buttering customers.
This should not be a major factor in deciding whether to keep La Guardia (although let’s hope they factor it in to any planned upgrades), but this is my chance to say what I should have said then: NEW YORK, YOU ARE ONE OF THE WORLD’S GREAT CITIES. IT’S TIME YOU GOT DECENT BAGEL BUTTERING FACILITIES IN YOUR AIRPORTS!”

FAA’s Airport Reference Codes

The Airport Reference Code (ARC) is a coding system developed by the FAA to relate airport design criteria to the operational and physical characteristics of the airplane types that will operate at a particular airport.

The ARC has two components relating to the airport design aircraft. The first component, depicted by a letter, is the aircraft approach category and relates to aircraft approach speed. The second component, depicted by a Roman numeral, is the airplane design group and relates to airplane wingspan. In the case of Design Group I, an additional designation of “small aircraft only” relates to aircraft with gross weights of 12,500 pounds or less.

Generally, aircraft approach speed applies to runways and runway length related features. Airplane wingspan primarily relates to separation criteria and width-related features.

Airports expected to accommodate single-engine airplanes normally fall into Airport Reference Code A-I or B-I. Airports serving larger general aviation and commuter-type planes are usually Airport Reference Code B-II or B-III. Small to medium-sized airports serving air carriers are usually Airport Reference Code C-III, while larger air carrier airports are usually Airport Reference Code D-VI or D-V.

Category Approach
A < 90
B 91 – 120
C 121 – 140
D 141 – 165
E 166 or more
I to 48
II 49 – 78
III 79 – 117
IV 118 – 170
V 171 – 213
VI 214 – 262

In order to determine the appropriate ARC for an airport, a “design aircraft” is first determined. The design aircraft is typically the most demanding aircraft (in terms of an airport’s physical features) that conducts at least 500 annual operations at the airport.

Table – FAA Airport Reference Codes for some Representative Aircraft
Approach Speed (kts)
wingspan (ft)
Cessna 150
Piper PA-28-140 Cherokee
Piper PA-28R Cherokee Arrow
Beech Bonanza V35B
Cessna Centurion
Beech 55 Baron
DeHavilland Canada DHC-7 Dash 7
Cessna 182 Skylane
Cessna Stationair6
Beech 60 Duke
Cessna Citation V
Beech King Air F90
Beech 100 King Air
Cessna Citation CJ2+
Embraer EMB-110 Bandeirante
Cessna Citation CJ3
Embraer EMB-120 Brasilia
DeHavilland DHC-8-100 Dash 8
Fokker F-27 Friendship
Learjet 24
Learjet 25
Challenger 601
Cessna Citation Ten
Embraer ERJ135
Embraer ERJ145
Gulfstream G350
Bombardier Q400
Fokker F-28 Fellowship
Embraer 170
Gulfstream G500
Gulfstream G550
British Aerospace BAE-146-200
Embraer 190
Boeing 737-400
Boeing MD-90
Boeing BBJ
Boeing 727-200
Boeing 767-300
Gulfstream IV
Boeing 747-200
(source: FAA Advisory Circular, AC150/5300-13A, Airport Design)

For an example of how ARC is considered in the process of updating an airport Master Plan, see: