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?

Federal Way’s Mayor at PSRC, Expressing Numerous Concerns about KSEA Over-Expansion

Here’s a summary of some concerns opposing KSEA over-expansion, expressed by Federal Way Mayor Jim Ferrell, at a meeting of the Puget Sound Regional Council (PSRC) executive board. Highlights and aiReform footnotes have been added. To view the three attachments in the summary, click on these links:

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

What’s Going On Here?

The pattern observed across the nation is that decision-making behind airport expansions is intentionally dispersed and distorted, so as to create plausible unaccountability for all involved officials. In this example, the industry (especially Delta and Alaska airlines, the two major hub players at KSEA) are getting FAA assistance to push through even more hub development, with two regional authorities offering cover: Port of Seattle, and Puget Sound Regional Council. It needs to be understood that both of these regional authorities are heavily biased toward commerce; they have no meaningful concern for impacts in residential communities, as evidenced by non-mention of these growing problems in Lance Lyttle’s POS slideshow.

What is the Biggest Distortion?

Lance Lyttle’s slideshow, especially the part pretending that the expansion is serving local demand. Quite the opposite, the two major hub airlines are simply adding supply and scheduling huge numbers of passengers THROUGH KSEA, to boost their profits. People in and around Puget Sound have not and will not massively increase their alleged ‘demand’ for air travel, as Mr. Lyttle is implying (i.e., the 41% growth in enplanements in just 5-years is almost entirely to serve people outside Puget Sound). Again, the expansion is solely for airline benefit, and entirely at a cost to local community health and quality of life.

Why is aiReform.com Archiving These Documents?

These documents are being archived to encourage people to study them, and to ensure the records remain available to future airport impact victims who may seek to study the past. It is hoped that this archiving will help people to become more effective in advocating for balance, to protect their homes and communities. Readers are invited to send their comments and reviews to aiReform, which may be included in Updates to this Post.


See also:

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.

JFK: Evidence of FAA & PANYNJ Failure to Manage Capacity & Delays

The two screencaps below look at the ten most congested airports in 2000, as well as the airports for which the most money was spent expanding infrastructure between 1988 and 2002. They are screencaps from slides #17 and #19 of A Historical and Legislative Perspective on Airport Planning & Management, a January 2002 presentation by Alexander T. Wells & Seth B. Young.

In a normal economic environment, actions are taken to mitigate problems. Delays are one such problem. If the aviation sector behaved rationally, regulators (in this case, FAA) and operators (both airports and airlines) would make adjustments to reduce delays, even more so because the delays at the largest hub airports cascade into more delays at other airports.

The data in this January 2002 presentation shows that FAA and airport authorities are not acting rationally to reduce delays and are, in fact, doing exactly the opposite of what they need to do. That is, instead of scaling back excessive operations at the most congested airports, they are doubling down, spending even more money to enable even more over-scheduling (and congestion/delays) by the major airlines.

A look at the major airports serving the NYC-Philadelphia area is revealing. The four main airports all rank in the top-10 delay airports for 2000:

  • Newark (EWR, United hub): ranked #1
  • LaGuardia (LGA): ranked #2
  • Kennedy (JFK, major hub for American/Delta/JetBlue): ranked #5
  • Philadelphia (PHL, American hub being scaled down): ranked #7

The worst-case example is JFK. The role of this airport has always including serving as a major international hub, but, with the formation of JetBlue, a substantial amount of domestic hub traffic has been added. The airlines make higher profits when they increase hub through-traffic, but airline pursuit of higher profits is supposed to be balanced against impacts such as more noise pollution, more air pollution, and more surface road congestion. The airport authority (PANYNJ) and federal regulator (FAA) are supposed to ensure this balance, but they fail; unfortunately, both FAA and PANYNJ are instead focused solely on serving airline profits, and are thus blinded from seeing the impacts, such as under the JFK Arc of Doom.

How bad is the failure by FAA/PANYNJ regarding JFK? Well, notice the last column in the table below.Of the top-ten delay hubs in 2000, only two have seen positive average annual growth in operations, from 2000 to 2017. By far, the largest average growth is at JFK, averaging 1.5% annual growth in operations. Compare that with Philadelphia, which has averaged a 1.3% annual decline in operations. Is the Philadelphia population shrinking while the NYC-area population is exploding, to explain these two trends? No. These trends – and the subsequent impacts – are due to airline scheduling, motivated by airline profits. Philadelphia is scaling down because American absorbed US Airways, and since then, American has been shifting schedule capacity AWAY from PHL and TOWARD JFK, LGA, and DCA (yet another high-impact airport).

Clearly, if FAA wanted to take a decisive action in 2018, to reduce delays, that action would focus on managing capacity, such as by imposing flow rate reductions at JFK, EWR, and LGA. It would also focus on encouraging airlines to shift capacity back to PHL, DTW, PIT, CVG, CLE and other airports that are operating far below what they were designed to serve.

Ponder this fact, too: how is it that when we look at a top-ten list of delay airports from 18-years ago, we see that 80% of those airports have since scaled down while most populations have grown? How is it we are told by FAA and industry that airports and aviation are economic gold-mines, and yet this alleged booming industry is declining nearly everywhere? How much of the FAA/industry sales pitch is hot air and propaganda? Is there anything we are told by these players that reflects reality and nurtures an informed public process, serving everyone and not just corporate interests?

At Sea-Tac, Enplanements (and Impacts) are up 41% in Five Years

A Port of Seattle (PoS) News Release today crows about the airport setting a new annual record with 46.9 million passengers in 2017. (click here to read an archived copy, with aiReform footnotes added). As is the pattern, economic benefits are exaggerated, while environmental impacts are completely ignored.

Back in 2010, PoS went to great expense to draft a Part 150 study. Within that document package was a 44-page ‘Aviation Activity Forecast’. The key graphs within that study are condensed into this scrollable 3-page PDF:

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

You can dive deeper, looking at an archived copy of the 44-page analysis here.

One of the most disgusting statements in the PoS News Release is the leadoff to the second sentence, a classic example of greenwashing, which reads: “Demand for air travel at Sea-Tac Airport increased 41 percent the last five years…” Let’s be clear. The good people in and around Seattle did not suddenly wake up 5-years ago and start spending more money and increasing trips out of Sea-Tac. Nor did the area population explode anywhere close to 41% in 5-years. No, this alleged ‘demand’ is engineered by two airlines – Alaska and Delta – as part of their escalation of hubbing intensity, all in pursuit of slightly higher airline profits. More people fly INTO [KSEA] without ever leaving the airport terminal, either sitting in their cramped seat of rushing to catch another plane at another gate. Lots more people – up 41% in 5-years. This is NOT increased ‘demand for air travel’. And, it also means fewer people are able to get direct flights from origin to destination, without the increasing number of detours through KSEA; in other words, everyone loses, except the airlines and the airport authority.

Clean up your act, PoS: get the excessive growth at KSEA under control, and knock off the greenwashing propaganda, OK?

Hubbing Strategies Increase Impacts, But Do Not Create Sustainable Airline Profits

Airline stocks have been tanking lately, in no small part due to strategy shifts by United. In a nutshell, United is trying to design a broad restructuring of its three domestic-focused hubs in Chicago, Denver and Houston. Why? Because this trio of domestic hubs “…has profit margins that are 10 percent below the inland domestic hubs operated by American Airlines Group Inc. and Delta Air Lines Inc….”

The situation is discussed in this Bloomberg article (click here to view source, or view the archived PDF copy below).

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

What is the most consequential quote in the article?

“As part of its strategy, United is boosting connections in its three mid-continent hubs by an average of 17 percent by adjusting its flight schedules, a process it’s completed in Houston and will commence in Chicago next month.”

In this one quote, United is making it clear that, for all major U.S. hubs, traffic growth is NOT about customer demand; it is airline schedule tweaking, to increase profits, that is causing the huge impact increases at major hubs, especially at KBOS, KJFK, KDCA, and KSEA.

Which airports/hubs are most monopolized?

Here are the main hubs for the four largest airlines:

  • American: Charlotte [KCLT], Dallas-Ft Worth [KDFW], Miami [KMIA], and Philadelphia [KPHL]
  • Delta: Atlanta [KATL], Minneapolis St Paul [KMSP], and Salt Lake City [KSLC]
  • United: Cleveland [KCLE], Washington-Dulles [KIAD], and Houston [KIAH]
  • Southwest: Baltimore [KBWI], Dallas-Love [KDAL], and Chicago-Midway [KMDW]

Most other major airports are either smaller market and dominated by Southwest, or they are duopoly hubs. Four duopoly hubs that stand out are:

  1. Denver [KDEN] – Southwest and United
  2. Chicago O’Hare [KORD] – American and United
  3. Phoenix [KPHX] – American and Southwest
  4. Sea-Tac [KSEA] – Alaska and Delta

Will hub concentration reduce over time?

No, not likely at all. The level of industry scheduling collusion, and the absence of real regulatory oversight, ensure this trend toward hub concentration will continue to intensify. As an example, look at the hub concentrations for 2013 data, at this aiReform Post. Note that nothing has changed: at the bulk of these 77 airports, monopolies and duopolies have only strengthened in the past four years.

CBS News Story about Long Island Impacts, features Plane Sense 4 LI Activists

Thank you, newyork.cbslocal.com, for giving coverage to the abuses under the Arc of Doom. Here’s an embed for their recent 2-minute+ news video:
The root problem is a captured federal agency (FAA) that has working with lobbyists and the airlines to slowly make a disaster for airport neighbor communities; they have created new regulations and technologies being used to channel flights into narrow and repetitive routes. Meanwhile, and with intent, they are ignoring impacts upon people.

This problem can be fixed. Residents could see very substantial relief if FAA/Congress worked to take away incentives that airlines like Delta and JetBlue use, to fly ever-larger number of passengers THROUGH the congested NYC airports. This hubbing practice adds a sliver more to airline profits, while immensely amplifying noise and air pollutant impacts. Address the flawed incentives, and you trim away the excessive flights. If FAA cannot do this on their own, Congress needs to step up and force FAA to do it.

FAA’s ‘Noise Portal’: A good idea, or a way to shut down Noise Complaints?

Last November, FAA filed a statement in the Federal Register, seeking comments from the general public about a proposal for FAA to create a new ‘Noise Portal’. on the surface, it seems like a good idea, though only a good idea if FAA actually intends to collect complaints and take action to address them. But, it also seems like a TERRIBLE IDEA, if FAA’s actual intent is to force the general public to use only FAA’s ‘Noise Portal’ to pigeon-hole their growing concerns.

Here is one of the public comments, submitted by a citizen impacted near Sea-Tac:

“15 minutes per complaint????
FAA is not a regulatory agency, its a shill for the airline industry. By making it so long to file a complaint, it is just further stifling the public interest. This is ridiculous, clearly a blatant attempt to silence dissent.”

Here is a letter by the interim Executive Director at Port of Seattle. He makes some fairly good points, though those of us who know how unresponsive POS has been to area noise concerns will shake our heads, knowing there is plenty of POS hypocrisy at play here. Anyway, here is a copy of the letter, followed by a copy of a short point-by-point analysis by aiREFORM…:

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

…and, here’s the point-by-point analysis of Mr. Soike’s letter to FAA:

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

Click here for an archived copy of the Federal Register filing, or click here to view the source at Federal Register, which includes a link to view comments. Try and make sense of this, if you can; it appears that FAA employee Barbara Hall has a job filing multiple items with Federal Register, to solicit public comments. Oddly, though, the public comments appear to be batched together into one folder at web location, thus combining an unmanageable diversity of public comments.

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.

FAA/Industry’s Own Data Exposes ‘Greener Skies’ as an Environmental Fraud

This Post looks at data in two online documents, presenting further evidence of the ‘Greener Skies’ fraud that FAA, Port of Seattle, and industry players are foisting on the Public. For all intents and purposes, this is the same fraud being pushed throughout the U.S., and by industry and Congress as well, under the NextGen label.

The data are at:

  1. Projected average day fuel burn on approaches, with no change: 2.64M lbs
  2. Projected average day fuel burn WITH RNAV/RNP changes: 2.61M lbs.

These figures were presented in units (pounds) that make the numbers impressively ‘bigger’, but also make it harder to intuitively comprehend. To correct this, the figures are converted in this table (to gallons, then to annual consumption):

Fuel burn (lbs) Converted to gallons Gallons per year
No Change 2,640,000 388,200 141.7M
‘Greener Skies’ 2,610,000 383,800 140.1M
Difference: 30,000 4,400 gal/day 1.6M gal/year

So, the proposal is expected to achieve a savings of 1.6 million gallons annually … at an airport that sold 487.1 million gallons that year. In other words, this proposed savings is less than one third of one percent of total fuel sold at Sea-Tac. Now, to the airlines, this (~0.3%) translates to more profits; indeed, the two dominant players at KSEA, Delta and Alaska, might each save around $1,000,000 per year in fuel. But, the costs shifted onto neighborhoods and health far exceed these added corporate profits.

A little deeper research reveals another interesting fact: the alleged fuel savings of Greener Skies are massively dwarfed by annual increases at an airport scheduling more arrivals than the gates can handle. Here’s the data, from page 18 of the 2016 Annual Report for ‘Sea-Tac Fuel Facilities LLC’, showing year-to-year changes far greater than the comparatively measly 1.6 million gallons saved:

  Gallons Consumed Year-to-year Change 1.6M as a percentage…
2014 487.1M
2015 544.8M 57.7 (a 12% increase) 2.8% of increased consumption
2016 586.3M 41.5 (an 8% increase) 3.9% of increased consumption

The improvements are nothing when compared to the consumption growth trend. Here’s a chart showing the trends, in both annual fuel consumption and annual operations: And, here’s an analogy: imagine the public view if we were funding a drug-treatment program that was successfully helping 3% of addicts while the number of addicts was growing at such a huge rate. Would we smile if, for every three treatment successes, there were 97 new addicts? Of course, we would not. Only an idiot (or a con-artist) crows ‘success!’ about a failure.

Three realities stand out from this:

  1. The enormous sums spent pitching Greener Skies and eventually signing off on the proposal were all framed around being pro-environment. It was a massive marketing/propaganda campaign to get out into the communities, present alleged benefits, pretend to engage people to ‘help’ identify and resolve problems, all while parading the idea that FAA, POS and industry care deeply about the environment, air quality, climate change, etc. And yet, these numbers show clearly: there were to be no meaningful environmental improvements. FAA, POS and industry players all knew this fact, even before the Greener Skies briefings and publications that wrapped up in 2012. They also knew (and still know!) that this was all just a big dog-and-pony show, funded by the people and served onto the people.
  2. A full five years after the FONSI signoff, FAA’s controllers at Seattle TRACON are not even using the RNP procedure down the center of Elliott Bay that was the key component of Greener Skies, the one element supposed to enable the bulk of the environmental benefits. It is as if the entire Greener Skies public engagement process was just an exercise in propaganda.
  3. The figures presented in the 2012 Greener Skies EA may not even reflect reality. Look closely. The data source documents used in this Post, when combined, show FAA/POS claimed that 487.1 million gallons of jetfuel were pumped in 2014, while also claiming 141.7 million gallons were consumed by west side arrivals on the short descending flight portions between the arrival gates (HAWKZ to the southwest, and MARNR to the northwest). Carefully note, these estimates were ONLY for west side arrivals, and did not look at fuel consumption for east side arrivals. Now, here’s the problem: these portions of these flights are the most fuel-efficient phases for each flight, and are allegedly flown at or close to engine-idle; these portions also represent a small fraction of total flight distance. And yet, the numbers used to calculate potential fuel savings declare the fuel consumption on these relatively short descending flight segments represent nearly a third of the fuel pumped at Sea-Tac? And, bear in mind, Sea-Tac is a major international hub, serving flights across the Pacific Ocean and to Europe. It defies logic; there is no plausible explanatio. FAA and POS need to confirm the numbers, and they need to explain: how is it that the airlines operating in and out of Sea-Tac can allegedly burn so much fuel on these arrivals yet so little fuel on climbouts and enroute to and from all other airports around the world?

CONCLUSION:

Greener Skies was (and still is) both a fraud and a side-show ‘act’, using erroneous estimates while pretending to create benefits that STILL do not exist! And the impacts, using the questionable numbers provided by PoS/FAA, are astounding: they are saying, in 2014, arrivals to Sea-Tac consumed 2.6 million pounds of jetfuel PER DAY while on approach, creating noise and air pollution that we are all supposed to ignore.


See also:
  • 2/25/2011 – ‘Greener Skies Project’ presentation by Doug Marek (FAA, 11-pages)
  • 11/01/2012 – GreenerSkies, Final Environmental Assessment Documents, archived at aiREFORM