Genesis and the Story of the SERFR Arrival (according to FAA)

…But the Community continued to cry out in ever greater numbers.

And their complaints numbered in the thousands,

and then tens of thousands,

and then hundreds of thousands.


Crying out in a loud voice they said
Oh Lord, remove this plague of noise and pollution from above our heads.”
And the FAA said:
“For sooth. This has not happened before within our short memories. Why did the communities never before complain?”
And the Air Traffic Control angels replied saying:
Verily, the number of aircraft popping out of our bottom in ancient times were few. But now the number doth wax greatly.

A brilliant and humorous analysis of how FAA failed to serve the people impacted by NextGen arrival changes, feeding San Francisco [KSFO] from the south. The technical details presented in this are also impressive, and quite informative for anyone burdened with the health and quality-of-life costs imposed by FAA’s worsening NextGen implementation debacle.

Great work is being done by some very talented people at Sky Posse Los Altos.

Created by Ron Rohde, with Sky Posse Los Altos. Click on the image below for a scrollable view; the PDF file may be downloaded.

[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.


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

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

Heathrow Airport Pays Guardian to Create ‘News Content’

20170110scp-about-explanation-of-paid-content-produced-by-guardian-labs-theguardian-comOne of the more disgusting details from the U.S. elections this past year was seeing the death of the journalism profession. We learned how the mainstream media no longer does hard research, no longer asks tough questions, but instead exists only to collect money for delivering spin and propaganda services. Not just for companies, but also for political parties. Evidently, propaganda going mainstream is a problem in the UK, too.

Here’s a copy of a tweet by BackOffHeathrow, a longstanding and vocal opponent of Heathrow airport expansion. Just like is happening under NextGen routes near a few major U.S. airports, the people who live east and west of Heathrow’s two runways are having their homes and lives destroyed. Same impacts, too: stress and distraction by repetitive noise interruptions, and compromised health due to elevated air pollutants and chronic sleep loss.


(click on image to view archived copy of this ‘paid content’)

Why so much misery and destruction? Primarily to accommodate air travel by airline passengers from North America, Asia, and Europe. Many people use Heathrow as an entry-exit point for Europe; many of them pass through Heathrow because the major airlines decided decades ago that they would use this piece of land for sorting their passengers and maximizing their company profits. By far, the biggest airline at Heathrow is British Airways (BAW, Speedbird). Airline profits are improving, while resident quality of life is steadily declining. No wonder so many people are fighting so hard to stop a third runway at Heathrow.

The Airport Paid For This (with your money)…

Notice who paid for this item that looks like a ‘news article’, which is one of a series of ‘paid content’ by the Guardian Labs team. Yes, Heathrow, the airport authority. Where do they get money to buy these services? From the passengers who fly through Heathrow. The airport authority, just like the regulator, can skim money off of the process, and evidently has no accountability or restrictions to preempt using that money beyond what is needed to operate the airport. In this example, they use that money to promote the airport’s expansion, and in opposition to the anti-expansion efforts by impacted airport neighbors seeking sleep and other relief. They use that money to create paid content, aka ‘Fake News’.

…And it is Nothing but Spin and Propaganda

This is a full-fledged program. On the upper left of the webpage it says, ‘Heathrow sustainable mobility zone’. Click on this and it opens up a whole new webpage with many more ‘articles’.

Take a close look at the article title: ‘How Air Traffic Controllers are Helping Clean Up Aviation Emissions’. The spin implies new technologies are being used to reduce the environmental impacts of aviation. It is spin partly because the methods listed in the ‘article’ for reducing impacts are nothing new … techniques and technologies that have already been used for decades. But, more critically, the spin flies right past the real elephant in the room: that for each of us, when it comes to generating CO2, hours spent travelling as a commercial air passenger are the worst hours in our life. Frankly, the only way for one individual to do more damage to the atmosphere, more quickly, is either to take up a new hobby setting arson fires, or have too much money to blow and start zipping about in your own private jet.

Obviously, if the aviation stakeholders here (the regulators and airport authorities and airlines) REALLY wanted to reduce aviation emissions, they would do five things:

  1. the regulator would reduce Heathrow arrival rates, and the airlines would agree to alter their schedules accordingly, so that the four holding stacks for Heathrow arrivals, as discussed in the ‘article’,  would never even be needed again;
  2. they would get the airlines to do a much better job filling the seats on their flights (the passenger load factor for British Airways, is barely above 80%, an absurdly low rate of seat occupancy that greatly increases the per passenger carbon emissions);
  3. they would agree to impose uniform fees that disincentivize use of Heathrow as a hub airport, while also encouraging airlines to fly a larger percentage of their passengers on nonstop-direct flights to their final destinations (for example, impose a steep fee for flying through, or impose fees that are directly proportional to the itinerary distance flown);
  4. they would advocate for imposition of a heavy aviation carbon tax (which should also replace most other aviation fees and taxes) so as to disincentivize hub connections that are not efficiently located along the direct route of flight; and,
  5. they would immediately abandon the third runway at Heathrow — this additional runway, and the industry that profits from it, are just further bad investment to accelerate the fossil fuel destruction of our planet.

A Classic Image in the War Against Carbon


(click on image to view lots more, tweeted by 'ITryNotToFly')

(click on image to view lots more, tweeted by ‘ITryNotToFly’)

We Should All Be So Brave.

Let’s hope, in this New Year, we continue to see great creative effort and expression by some of the wonderful bloggers fighting for our planet and our future!

One Table Shows the Reality of NextGen

Here’s some data to ponder as we start into a new year: a table, showing commercial operations at each of FAA’s OEP-35 airports, from 2007 onward.

Focus first on the pink column, three columns from the right edge; the airports are ranked in descending order, by the percent decline in annual operations, comparing 2015 with 2007.

Note that the largest declines, at Cincinnati [KCVG], Cleveland [KCLE], and Memphis [KMEM] are huge: down 61%, 53%, and 43% respectively. Note also, the declines are even larger when you compare Total Annual Operations in 2015 vs the various historic peak years for each OEP-35 airport, in the two columns on the far right; for these figures (which include general aviation and military operations data), all airports have declined, ranging from 74% to 2% and averaging 24%.

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

Three facts stand out from this table, and they all strongly contradict the sales pitches that FAA and industry have been collaborating on the past few years:

  1. Note the bright green line across the table. Just under it are five airports: Charlotte [KCLT], Reagan National [KDCA], Miami [KMIA], Seattle [KSEA] and San Francisco [KSFO]. These are the only five of the OEP-35 airports that recorded an increase in commercial operations from 2007 to 2015; i.e., 6 out of 7 OEP airports SLOWED substantially while the national population grew.
  2. The airport identifiers marked in a dark-red background color are the airports that in 2016 had extensive noise complaint histories (documented online, and in the mainstream media) related to route concentrations under NextGen. Routinely, FAA has imposed these routes without adequate public review, abusing the ‘categorical exclusion’ process. Numerous legal actions have resulted.
  3. For all OEP-35 airports combined, commercial operations have steadily declined 11% from 2007 to 2015, nearly every year. This is industry contraction. And furthermore, the vast majority of U.S. commercial airports peaked in the 1990s, some more than two decades ago!

WIth the new year, we’ll see a new adminstration and changes at FAA and DoT. Don’t be fooled by the impending onslaught of yet another round of propaganda. The U.S. NAS is operating at far below historic peaks and continuing to trend downward. Growth is rare, and limited to key airports where airlines are concentrating flights into superhubs that severely impact local quality of life. The only true beneficiaries of NextGen and ATC privatization are industry stakeholders (especially the airline CEOs, FAA officials, lobbyists, and manufacturers, plus a few elected officials), who will narrowly share the profits while completely ignoring the larger environmental costs.

We don’t need oversold technology fixes pitching RNAV and RNP solutions that have been used for decades; technologies that could and would serve us all beautifully, if FAA would assert its authority with balance, and manage capacity at the largest U.S. hub airports. We need airports to serve communities while being truly environmentally responsible. And for that to happen, we need a new era of transparency and accountability at FAA. We need reform.

NASA Research Papers on ATC Automation, from 1972 and 1989

NextGen efficiency improvements are pitched as ‘transformative’, but in fact the alleged changes are nothing new. The bulk of the alleged ‘benefits’ FAA, A4A and Bill Shuster claims NextGen can deliver have been realized for more than two decades. It doesn’t take much effort for online research to reveal substantial evidence of this fact. Here’s a short quote from an interview:


“…we built these descent trajectories to be an idle thrust descent all the way to the bottom . . . . you’re flying at thirty-five thousand and you know the route you’re going to fly. Now imagine you have to pick a time, while you’re flying, to land down there. You’re given the command, OK, close your throttles, never touch them again, but be assured that you’re going to get there without turning the throttles back on again….”

– interview comments by Heinz Erzberger, an ATC researcher at NASA Ames, discussing research back in the 1970s

Read more in copies of these research papers by Mr. Erzberger, from 1972 and from 1989.

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


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:


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.

Exposing a NextGen Fraud: the so-called ‘Conventional’ ZigZag Routes

It is quite clear that, with the election results and the imminent White House occupancy change, coordinated efforts are ramping up to try and push through the latest pet projects: ATC privatization, and accelerated NextGen funding. These efforts are sourced in some backroom ‘collaboration’ between top-level FAA officials, key aviation leaders in Congress, and the industry (the airlines, the manufacturers, and the lobbyists).

As has always been the pattern, the Av-Gov Complex will knowingly lie to sell their schemes. One of the most graphic lies of the present cycle is variations of this graphic:


This misleading graphic is liberally posted in news articles, FAA reports, etc. It implies that today’s air navigation systems are primitive, needing to upgrade via a progression from zigzag routes (left image) through RNAV routes and eventually RNP routes. An important fact being hidden, though, is that RNAV and RNP routes already exist, as they have for years. (SOURCE: pg.7 of FAA’s SatNav News, Summer 2011 edition)

Time and again, this image is pushed to help brainwash the Public (and especially Congress) to believe the current ATC system is incredibly archaic and shockingly inefficient, with flights zigging and zagging all across the continent. They pitch NextGen as ‘transformative’, while ignoring and concealing the facts that:

  1. commercial passenger flights have been flying mostly direct flights for decades, and thus these graphically presented zigzags are a complete lie;
  2. RNP & RNAV procedures have been available and usable by these flights for roughly two decades, and thus the whiz-bang NextGen changes are not really changes (we can accomplish the expensive NextGen goals by smartly using what we already have); and,
  3. an entirely new class of delays has been recently invented – enroute delays, at altitude; typically 100-200-miles from the destination airport, these are used to smooth out arrival surges because FAA refuses to restrict appropriate arrival rates to accommodate known airport capacity limits.

FAA et al need to be called out on this misinformation. It turns out, you will find two versions of this deceptive diagram in Chapter One of nearly every recently completed ‘Environmental Assessment’ for various airspace changes around the nation. Here are some examples, from recent OAPMs (Optimization of Airspace and Procedures in the Metroplex); look at the identical content in any of these cookie-cutter documents, at these pages:

  1. June 2013: Draft EA for DC OAPM (216p; see pages 6 and 14 in chapter one, marked pages ‘1-6’ and ‘1-14’)
  2. March 2014: EA for Atlanta OAPM (122p; see pages 1-6 and 1-14)
  3. July 2014: Final EA for NorCal OAPM (134p; see pages 1-5 and 1-11)
  4. December 2014: Draft EA for Charlotte OAPM (118p; see pages 1-5 and 1-11)
  5. August 2016: Final EA for SoCal OAPM (144p; see pages 1-6 and 1-12)

[KSMO]: Are FAA Attorneys Bluffing on their ‘Cease & Desist Order’?

The fight in Santa Monica continues to heat up. City officials have labored for nearly four decades, and patiently endured one FAA delay tactic after another, in their quest to assert local control so they can best manage their local airport. Now, an official at FAA Headquarters in Washington, DC, has issued an ‘Interim Cease and Desist Order’. For what it’s worth, here is a copy of the City’s official response:


(text of email by City officials; minor edits may have been added, but only to clarify)

The Order appears authoritative and very threatening, but a closer inspection suggests it is just another bluff by an out-of-control federal agency. Here’s the closing declaration, at page five of FAA’s 15-page document, signed by Kevin Willis, an FAA Director at the Office of Airport Compliance and Management Analysis, on 12/12/2016:

(click on image to view an archived copy of FAA's entire 15-page 'Cease & Desist Order' package)

(click on image to view an archived copy of FAA’s entire 15-page ‘Cease & Desist Order’ package)

‘Cease & Desist’ … hmm, my first thought was, roughly,

“…where does FAA have the authority to issue a ‘Cease & Desist Order’, intervening in the relationship an airport authority has with an airport tenant? I mean, by this logic, FAA should also have the right to dictate all sorts of airport management details, not at all related to aviation safety.”

Evidence That This is Just a Bluff

FAA’s authority to issue the Order is cited as footnote one, on the bottom of page 1 which reads: “This Order is issued pursuant to 49 U.S.C. § 46105 and 14 CFR § 16.109.” So in the probably 100-200 man-hours that went into drafting this Order, FAA’s legal team offered not one but two cites. But, is either cite valid?

I’ll lead off with the second cite. According to GPO’s eCFR website, FAA’s second cite DOES NOT EXIST. I.e., per the screencap below, 14 CFR § 16.109 is a ‘reserved’ section of the CFR framework, meaning there is no language to be consulted.


Two screen-captures by aiREFORM, from the current/valid electronic CFR (Code of Federal Regulations) website. These show that there is no valid 14 CFR section 109.

And note, too, this is NOT an out-of-date version; the GPO website declares this eCFR is current as of 12/12/2016 … the same date as Mr. Willis’s signature!

And now let’s consider the other cite. FAA cited 49 U.S.C. § 46105, but their error is immediately revealed by simply reading the language of the law. The actual section contains these words: “…a regulation prescribed or order issued by (…) the Administrator of the Federal Aviation Administration with respect to aviation safety duties and powers designated to be carried out by the Administrator (…) takes effect within a reasonable time prescribed by the (…) Administrator.”

Note the qualifier, “…with respect to aviation safety duties and powers designated…” FAA’s current action against Santa Monica has nothing to do with ‘aviation safety duties’, and FAA’s legal team has failed to actually cite any real authority. If you want to look even further, see this archived PDF copy of the entire Chapter 461, which contains all sections, from 46101 through 46111. It is a searchable copy, so it is easy to quickly establish: Chapter 461 contains neither the term ‘cease’ nor the term ‘desist’, and the cited § 46105 contains no real authority.

Now, just to be clear, I am not a lawyer. BUT, as a forced-to-retire FAA ATC whistleblower, I have plenty of experience with FAA’s bluff and bluster. FAA pays plenty for their hundreds of inside attorneys, and these civil servants are expected to distort and deceive at will, in support of the true and not-so-ethical FAA mission. If my quick legal assessments are flawed, please show me my error. And if they are not flawed, clearly, it is time for FAA to get off their bureaucratic butts and let the People in Santa Monica get on with owning AND controlling their local airport.

UPDATE, 12/20/2016: — a week has passed and nobody has yet provided even a flimsy legal basis for FAA’s administratively issuing an ‘Interim Cease & Desist Order’ against the City of Santa Monica. The most substantial response I have yet seen was sent by Chris Harshman, and a screencap is provided below:

ksmo-20161220at1641scp-wow-email-from-c-harshman-packetlaw-comHere’s what I sent back to Chris:ksmo-20161220at1728scp-reply-email-to-c-harshmanChris did make one good point in his email. He identified my error in interpreting the CFR nomenclature. The Code of Federal Regulations are an extremely deep and tangled set of rules. When I researched my blogpost, I could not find a 14 CFR § 16.109 and ended up finding a list that looked like it was regarding 14 CFR § 16.109, but was actually declaring that 14 CFR Part 109 was reserved. The online version is viewable here (and I archived a copy, all 31-pages, here).

Of course, we also have the problem that the preamble for the 31-pages of 14 CFR Part 16 says that “…provisions of this part govern all Federal Aviation Administration (FAA) proceedings involving Federally-assisted airports….” This strongly suggests that Part 16 cannot be applied against Santa Monica, because Santa Monica dropped their addiction to airport federal assistance many decades ago.

Thankfully, all of this confusion is easily solved. We just need FAA to start serving ALL OF US, not just the elite aviation interests. Airports serve communities, not businesses; airport impacts need to be properly balanced against health, residential quality of life, and other issues. Attorneys can help make this happen… IF they choose to serve more than just the mighty dollar.

FAA Continues their NextGen Disinformation

At FAA’s ‘Optimization of Airspace & Procedures in the Metroplex (OAPM)‘ webpage, which is marked as last modified on 6/27/2016, there is a link to a video uploaded to FAA’s YouTube page. As has been the practice for FAA and others trying to dupe the Public into buying NextGen, the video is filled with disinformation.

Here’s an example. The two images below are screencaps, showing consecutive slides in FAA’s video, at times 1:07 and 1:13. The first is a satellite view of a hilly, minimally developed and predominantly forested land area; the second is a blue graphic with FAA’s splashy declarations alleging ‘transformative’ benefits of NextGen.


(a fraudulent and intentionally deceptive image provided by FAA, at time 1:07 in the video)


No explanation is necessary, but what the hell. Lies annoy me, so I love to skewer them with facts. Here goes… the satellite view presents the direct green line and a zigzag red line route. The clear intent of this green vs red graphic is to impress upon us that our commercial airliner will become amazingly more efficient if, via NextGen, we let them fly those direct ‘greenlines’.

The problem is, it is utter bullshit. Our commercial passenger planes have been flying direct routes (the equivalent of these greenlines) for more than four decades. Thus, this graphic implies a change that will not happen, an alleged benefit never to be gained.


June 2014: Huerta hawking NextGen in Houston)

And, furthermore, study that satellite view. It’s fuzzy, but it offers enough detail, including roads and granularity related to both vegetation and topography, that anyone who studies aerial imagery can see: this land area is no more than 10- or 20-miles across. A commercial jetliner would NEVER be able to fly the red zigzag route as the turns are far too tight. But, of course, that does not stop FAA from pushing this kind of NextGen disinformation. All for the money.

And think this one step further: as stated by FAA,  those red lines represent a ground-based route; thus, there have to be navigational stations at the locations where the red lines bend. Out in the middle of this area of hills and hollers. Yeah, right. I wish FAA would show more respect for our intelligence, and for our money.

Michael Huerta: you’ve been FAA Administrator through all of this. Are you going to tell your FAA employees to clean this up, or are you just going to leave the NextGen mess for the next Administrator?