[KLMO]: Shifting the Model

Citizens for Quiet Skies, in Longmont, CO, has fought heroically to bring balance and moderation to the skydiving noise impact by Mile Hi, at Vance Brand Airport [KLMO]. The group took their concerns to the state courts, and then took it further to an appeal. In the process, CFQS has helped to illuminate yet one more reason that aviation impacts are out of control: the court systems (just like the faux-regulators) are biased towards accommodating commerce, and too quick to defer to FAA and federal authority.

I ran into this quote by R. Buckminster Fuller:

“You never change the existing reality by fighting it. Instead, create a new model that makes the old one obsolete.”

He makes a good point. When you study aviation impacts, you see ample evidence that, no matter where it is (a skydiving issue in exurbia, an air tour issue at Grand Canyon, a NextGen impact near a major hub airport, and so forth), the present imbalance is carefully sustained – and even expanded – via the carefully coordinated use of propaganda tools. The Av-Gov Complex uses propaganda tools to frame the issues favorably for air commerce while also keeping the average person from seeing the relevant truths.

Led by lobbyists and with ample faux-regulatory cover provided by FAA, the Av-Gov Complex created the present model, and they are being damned careful to control any efforts to change that model. But, facts and truths are problematic to those who are corrupt and self-serving; if we persist, as Kim and others have in Longmont, eventually we can shift the model and restore the balance. The noise impacts are real and problematic, just as the aviation operator profits are real and narrowly focused; but we can change the model to include other important factors, such as safety.

Shifting the Model to include SAFETY

One relevant truth about skydiving is this: skydive operators consciously choose to offset their climbs, so that the noise impact is not happening over the actual airport but instead is happening many miles from the airport. This decision shifts the noise impact onto people who may have no idea why, starting on a certain sunny day a few years ago, they now always hear lots of droning airplanes diminishing the best weather-days of the year.

There are safety consequences of this decision that are often overlooked. In particular, a skydiving plane doing repetitive climbs far from the airport drop zone poses a higher midair-collision hazard to other small planes passing through the airspace.

klmo-20170110scp-vfrmap-airport-vicinity-with-5nm-radius-circle-added

VFR sectional centered on KLMO. The red circle has a 5 nautical mile radius. Many of the skydiving climbs happen outside this circle, to the south and west. (click on image to view sectional and other images at VFRmap.com)

In the Longmont example, FAA’s aeronautical charts include a symbol at KLMO to alert pilots that this is a skydiving airport … but, if the climbs are far from the airport, even the most safety-conscious pilot, passing through may not see the skydive plane until it is too late. And the edge of the Front Range is a heavily-flown airspace for small planes.

A proactive FAA would judiciously constrain the skydive operator on where they must conduct their climbs, flying within a clearly charted climb zone positioned over and adjacent to the charted drop zone. For example, they might require climbs within a 2-mile radius of the airport center, or the drop zone coordinates. If the weather was marginal within that defined climb zone, the operator would simply have to stay on the ground, which eliminates both safety risks and noise impacts. If the repetitive noise generated within the defined climb zone increases noise complaints to those near the airport and under that airspace, then FAA would have the hard data they need to further constrain the operator’s annual permit letter, imposing hour-limits per day, alternate days off, and other noise mitigation strategies.


See also:
  • 1/28/2017 – the next CFQS meeting, at 10AM at the Longmont Public Library (click here for further info)
  • 1/6/2017 – a recent OpEd in the Longmont TimesCall

City of Santa Monica Rejects JetSuiteX ‘COP Application’ for Part 135 Charter

For a month now, an air charter operator based in Irvine, CA and affiliated with JetBlue, has been selling seats online for scheduled passenger flights to begin at Santa Monica in early February. Weeks ago, the CEO of JetSuiteX, Alex Wilcox, told reporters he believes the City cannot stop this proposal. This despite the fact that the airport is crowded dangerously close to dense residential neighborhoods, and there is no indication the City is prepared with the level of crash-fire-rescue support needed for scheduled flights carrying up to 30 passengers.

Here’s a PDF of the application for a Commercial Operations Permit, signed by JetSuiteX COO Michael Bata:

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

And, here’s the City’s response letter signed by Airport Director Stelios Makrides, rejecting the application as incomplete, and requiring a valid Environmental Assessment:

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

For the past month, FAA has been suspiciously (and negligently?) quiet on this matter. What’s needed next is for FAA to break this silence and take action.

FAA is the final federal authority and routinely usurps local authority, to effectively run airports from a distance and for the industry, often with severe negative impacts upon the local community. If they are to be responsible, FAA needs to immediately issue an Interim Cease & Desist Order against JetSuiteX, Delux Public Charter, and Atlantic Aviation, to ensure no scheduled air charter operations begin at Santa Monica without all required permits. This should be easy for FAA to do; after all, FAA has recent experience issuing Interim Cease & Desist Orders related to Santa Monica.

Answers Needed in Santa Monica

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

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

ksmo-20130929-c525-crash-while-landing-rwy21-fig-22-from-video-study-distance-groundspeed-on-satview-ntsb

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

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

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

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

kryy-20161230scp-alp-w-portion-of-runway-marked-up-for-rofas

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

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

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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?

[KSMO]: A Video Collection of Speeches at a Protest in April 2007

The content and quality of presentation at this citizen protest is outstanding. The statements and the stories just scream out:

How can FAA and the Santa Monica Airport continue to do the damage being done, not just the noise but the serious health destruction, too?

This protest offers a great example for others, being impacted across the nation by an out-of-control FAA and aviation businesses. Perhaps viewing these will help you to become motivated to reclaim local control of your local airport … to serve the LOCAL COMMUNITY first, and to assure that the airport’s operations are properly balanced with the environment and local quality of life.

Click on the image below for a scrollable view; the PDF file may be downloaded. Click on the links within the PDF to view each video portion, uploaded to YouTube.

Skycatcher Failed to Catch On

Other Posts have pointed out how many aspects of U.S. aviation have been in decline for decades, yet are not talked about: TRACON operations, commercial flight operations, ASPM-77 airport operations, airline fuel consumption, the shrinking NAS, for example … all have seen substantial declines for nearly two decades. Now, here’s a similar Post, focused on General Aviation – the manufacture of small planes for recreation, small business use, etc.

In the latest sign of how far U.S. general aviation has fallen, Cessna has decided to destroy the unsold inventory of it’s model ‘Cessna 162 Skycatcher’. Within the details of this story, there is a lot to be seen about how the political system serves money and special interests, while impeding changes that would best serve everyone. All the posturing on Capitol Hill, the new laws to incentivize sales and prop up an industry in decline, the indifference as U.S. manufacturers moved production overseas to cheapen their labor costs, the false boosterism of how great aviation is for the economy … and yet it all came down to just a sad story about the recycling of some very expensive airplane pieces.

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

[KSMO]: No Runway Protection Zones, in Stark Contrast with Other Airports

kuao-201205-rpz-rwy-17-on-satview-w-dimensions-showing-trees-later-removed

The green trapezoid delineates an RPZ at the north end of the Aurora Airport, near Portland, OR. This RPZ, similar in size to what is needed to accommodate charter jets at Santa Monica, measures 500ft by 1010ft by 1700ft long. As is the case nearly everywhere, all obstructions were removed from this RPZ: there are no structures within the trapezoid, and the lines of trees have all since been removed (not even stumps are allowed… they are considered too dangerous).

A Runway Protection Zone (RPZ) is a trapezoidal space, positioned at the ends of all runways, designed to create a safety buffer for when aircraft fail to stay on the runway. Santa Monica has no meaningful RPZs. In fact, despite lots of searching, I have not been able to find any other U.S. airport with hundreds of homes standing inside the RPZ. The vast majority of U.S. airports have ZERO homes standing inside the RPZs.

This graphic illustrates where the Santa Monica RPZs would be, if FAA applied its safety standards there:

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In contrast with the RPZ at KUAO, these safety areas at Santa Monica have hundreds of houses. (click on image for larger view)

Nationally, FAA has generally done a good job on RPZs; they have defined the dimensions, and they have firmly and consistently guided airport authorities to comply with these design standards that are needed to protect pilots, paying passengers and airport neighbors. FAA has thus secured safety control at essentially all airports, but NOT at Santa Monica. There, a close inspection of the RPZs shows approximately 270 homes exist in the Santa Monica RPZs, meaning that the RPZs are, frankly, nonexistent. Here are larger images; try to count the houses yourself:ksmo-20161223-500x1000x1700l-rpz-sw-of-rwys-3-21 ksmo-20161223-500x1000x1700l-rpz-ne-of-rwys-3-21Nice homes, in a beautiful area with the finest weather, yet these people endure air pollution, noise pollution, and the constant fear of an off-airport crash. This makes no sense, and it does not have to be this way.

How Does Santa Monica Compare With Other Airports?

The PDF below presents a compilation of satellite views, comparing airport RPZs for Santa Monica with thirteen other airports in five western states (California, Oregon, Washington, Idaho and Nevada). Each of the airports selected for comparison is noted for heavy use by air charters and private bizjets. Two especially notable conclusions from this analysis are:

  1. homes are virtually never allowed to stand within RPZs, as it is just too dangerous. So, why hasn’t FAA either bought out the homes in the Santa Monica RPZs or, far more pragmatically, simply shut down jet operations there?
  2. if FAA shut down jets at Santa Monica, the capacity to absorb them at larger and safer airports in nearby Van Nuys [KVNY] and Burbank [KBUR] is enormous. As is typical throughout the U.S., both of these airports were built to accommodate traffic levels that have since declined by half.
Click on the image below for a scrollable view; the PDF file may be downloaded.

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

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

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

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

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

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

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

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

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

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

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

[KLMO]: Oral Arguments Today, in the Colorado Court of Appeals

A classic example of the sacrifices commonly made by aviation impact activists is happening today, in a Denver courtroom. A single airport operator, Mile-Hi Skydiving, makes money by using their fleet of skydiving planes, outfitted to climb faster AND make more noise. So as not to annoy the actual near-airport residents, the planes are flown a few miles away and the climbs, which commonly drone on for 15- to 20-minutes, impact the residents below. The problem came many decades after the airport was built, coinciding with aircraft purchases and modifications by Mile-Hi owner Frank Casares.

As is nearly always the case, FAA is doing nothing to help resolve the problems. Indeed, doing the quite the opposite, FAA is enabling the operator (Mile-Hi) and ensuring these impacts will persist and even worsen. Just as they do at East Hampton, Santa Monica, Mora, and a dozen or so NextGen-induced noise canyons (e.g., [KLGA], [KPHX], [KCLT], [KSEA], [KBOS]), FAA is  obstructing every effort for meaningful LOCAL CONTROL of local airports. Somehow, we are supposed to suspend rational thinking and believe that, if the local City Council wanted to impose reasonable restrictions on the lease they have signed with Mile-Hi, it would compromise safety to have them execute quieter climbs or limit their operations to say a 6-hour block each day? Likewise, FAA (and the industry they protect from the Public!) expects us to believe this total capitulation to the profit-motives of a single skydiving operator is critical for our National Airspace System (NAS) integrity?

Bullshit. Shame on you, FAA et al, for continuing to obstruct reasonable attempts toward local resolution. Sleep, and the quality of our home environments, is important … far more necessary than your propping up the narrowly distributed profits of operators like Frank Casares. Let’s bring some balance back to these situations: more LOCAL control at our local airports.

Thank you, Kim, Citizens for Quiet Skies, and the others who have bravely spoken up to fix this local problem. Against a hostile local press, a corrupt and commerce-biased state court system, you fight on. And your battles help many others, from East Hampton to Santa Monica to Mora.

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

[KSMO]: Grossly Incompatible with the Community Around It

It has been a busy Fall at the Santa Monica Airport [KSMO], where FAA is flexing its administrative-legal muscles, intervening to delay city efforts to evict two private operators. The City wants to take over fuel sales and other airport services (known as ‘FBO services’), but the private FBOs do not want to accept that their leases are expired, nor do they want to give up lucrative profits. Just like FAA does not want to adhere to the agreement they struck with the city, in 1984, which meant the city could outright close the airport in July 2015.

In a recent email, Nelson Hernandez, the Senior Advisor to the Santa Monica City Manager, offered yet another update on the city’s progress. He noted that, “…on August 23, Council directed the City Manager to establish a city-owned FBO by December 31, or as soon as practicable….” He then added, there is ample precedent for airport authorities (in this case, the City of Santa Monica) setting up their own FBO services at an airport, instead of letting an out-of-state operator reap the hefty profits. He noted three airports: “…in the last two years, Fort Wayne, Greenville, and Chattanooga, created their own City FBO for similar financial reasons….” He was referring to airports in Fort Wayne, IN [KFWA], Greenville, NC [KPGV], and Knoxville, TN [KDKX].

Out of curiosity, I did some online research and confirmed that, yes, all three of these airports have city-operated FBOs. And, all three appear to be very healthy airports. Nelson’s list of three airports included one with an FAA control tower [KFWA] and two with no control tower [KPGV] and [KDKX]). Here’s the data on these three airports, with [KSMO] added for comparison:

    • KFWA: 70 based aircraft, a 12,000ft runway and an 8,000ft runway. FAA data shows the airport had 36,100 landings and takeoffs in 2015, down 71% from its peak year (124,000 ops in 2000). [3,400 acres, surrounded by farmland]
    • KPGV: 71 based aircraft, a 7,200ft runway, and a 5,000ft runway. Form 5010 shows 48,200 annual operations in the year ending 5/30/2016 (this is a rough estimate, as there is no tower). [872 acres, surrounded by forest, farmland and limited residential development]
    • KDKX: 167 based aircraft, and a single, 3,500ft runway. Form 5010 shows 68,400 annual operations in the year ending 4/30/2013 (this is a rough estimate, as there is no tower). [200 acres, surrounded by a river, a large quarry, and farmland]
    • KSMO: 249 based aircraft, and a single 5,000ft runway. FAA data shows the airport had 90,200 annual operations in 2015, down 62% from its peak year (234,800 ops in 1991). [215 acres, surrounded by dense residential neighborhoods; and, within the airport, substantial footage is presently subleased to non-aviation business uses, generating profits for the FBOs.]

I noticed something else, too, which was a bit startling. You’ll see it starkly presented in the three image-pairs below. When you look at how Santa Monica’s runway is shoe-horned into the neighborhoods, and when you compare it to the ‘airport normality’ of these other three, far less crowded airport locations, it just jumps out at you. And, when you look at the series of images showing how many houses were removed in recent years for a runway expansion at a very slow Greenville airport, you just have to wonder how in the world people can coexist with business jets so close to their Santa Monica homes. I mean, if FAA moves people out of their homes in Greenville, what is it about Santa Monica homeowners that makes them less at risk than North Carolinians? And given that there are so many Santa Monica homes, would it not make the most sense to simply close the airport??

Clearly, each of these three airports is far more compatibly located than is the Santa Monica Airport. In fact, looking at these three, I just have to say: if I was the new FAA Administrator, I’d be quick to ask my new highly-paid subordinates:

“Why are we NOT working with the city to expedite closing this airport? After all, it is grossly incompatible with the community (look at all those houses, and so close to the runway!), it is clearly a health hazard, and we have plenty of other LA Basin airports and longer, safer runways to serve the business jets and general aviation, all of which are far below their historic high traffic levels. So, when are we going to start serving everyone, not just our buddies who employ us after we retire?”

20161201scp-ksmo-vs-kdkx-sat-views-w-rwy-lengths-comparing-airport-compatibility-impact-on-people

20161201scp-ksmo-vs-kpgv-sat-views-w-rwy-lengths-comparing-airport-compatibility-impact-on-people

20161201scp-ksmo-vs-kfwa-sat-views-comparing-airport-compatibility-impact-on-people


UPDATE, 12/6/2016: — per a request, click here for a PDF version of this entire Post.

KSMO: City Moving Forward on Evictions of Main FBOs – Atlantic Aviation & American Flyers

“…This morning the City filed unlawful detainer actions against Atlantic Aviation and American Flyers. As you know, both companies were given 30 day notices to vacate on September 15; both failed to vacate by the required date of October 15. Please see the attached press release for more detailed information….”

– Nelson Hernandez, Senior Advisor to the City Manager

Click here for further info (archived copy of the City’s news release)