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SR-082807-3A~_ ~;Lyof City Council Report Santa Monica City Council Meeting: August 28, 2007 Agenda Item: 3-A To: Mayor and City Council From: Robert Trimborn, Acting Airport Director Subject: Federal Aviation Administration (FAA) Response to the City's Request for Safety Enhancements at the Santa Monica Airport and Direction To Staff. Recommended Action It is Staff's recommendation that if the FAA Proposal remains unchanged after the study session that it be rejected as inadequate to provide a meaningful safety enhancement to the runway. It is further recommended that the City Council direct Staff to explore the implementation of effective safety enhancements for the Airport and report back at the City Council session on September 25, 2007 with a recommendation detailing an appropriate course of action. Executive Summary Based upon the data provided by the FAA and for additional reasons set forth below, Staff recommends that the FAA Proposal be rejected. The FAA Proposal recommends construction of two 155 foot Runway Safety Areas (RSA) 1 comprising of a 130 foot Engineered Materials Arresting System (EMAS)' bed and a 25 foot lead-in to the bed at each end of the runway. Contrary to the City's intent to maximize safety for the residents living adjacent to the Airport and pilots, the FAA Proposal calls for extending the runways closer to the homes; including the construction of the runway extension on the east side of the Airport in a manner that totally negates the ability of the blast wall to deflect aircraft exhaust; narrowing the perimeter road on each side to one lane to accommodate the runway extension; and the creation of 90° drop at the ends of the runway extensions that increases the risk to residents and pilots. In making its proposal, the FAA based its findings on a desire not to adversely affect larger/faster aircraft from continuing to operate at the Airport unimpeded, even though the Airport was not designed for that category of aircraft. Although the City rejected the FAA June 12, 2007 proposal as being inadequate, the FAA Proposal made on July 31, 2007 actually incorporates the same concept, but proposes costly runway extensions which actually increase the danger to pilots and the surrounding residential neighborhoods. At the June 12, 2007 meeting with the FAA in Washington D.C., the FAA proposed runway safety ' EMAS is a crushable concrete arrestor bed that absorbs aircraft energy by crushing under the aircraft weight and capturing the aircraft's landing gear. EMAS is designed to bring aircraft weighing more then 12,500 Ibs to a stop within the boundaries of the airport by preventing an aircraft from overrunning into areas adjacent to the airport. Aircraft weighing less then 12,500 Ibs would not be affected by the EMAS because the aircraft is too light to effectively penetrate the EMAS surface. 2 areas on either end of the runway comprised of 130 foot EMAS beds with a 25 foot lead-in to the EMAS beds. D. Kirk Shaffer, Associate Administrator for Airports, FAA, who made the June 12th proposal on behalf of the FAA, will be present at the August 28th Study Session to answer questions regarding the FAA's Proposal. The FAA's proposal in June 2007 triggered a lengthy discussion regarding the adequacy of addressing aviation safety with a proposal that theoretically addresses only the minimum level of concerns. The meeting ended with the FAA stating it would forward more information and detailed technical analysis to the City as quickly as possible. City staff also requested that the FAA reconsider the use of a runway safety area in conjunction with EMAS. Subsequently, and without prior correspondence or discussion, Staff received a letter on July 31, 2007 from Kirk Shaffer (see attachment #1) detailing proposed RSA's for the Airport. The current FAA Proposal differs from the June proposal primarily in its recommendation that the runway be extended to the mid-point of the perimeter road and closer to the homes at each end of the runway. Staff and the City's consultants have conducted a review and analysis of the FAA proposal and find that the FAA's Proposal's limited degree of safety enhancement is offset by the increased danger it creates by moving the runway closer to the homes; creating vertical walls that endanger pilots on landing and departure; and its 3 interference with the use of the blast wall on the east side of the runway. The FAA Proposal falls short of the benchmarks for appropriate RSA's for the Airport - and in many ways, it actually exasperates the safety concerns repeatedly raised by the City Council. Discussion The following presents a synopsis of the FAA runway safety area proposal followed by a substantive critique by staff. Synopsis of FAA Proposed Runway Safety Areas for Santa Monica Airport Mr. Shaffer prefaced his remarks stating: "Runway safety areas are designed for the protection of aircrews, not to guarantee that an aircraft will never get beyond the safety area. For protection of persons and property near the end of the runway, FAA design standards provide for a runway protection zone that limits the land uses in that area. The runway protection zone is recommended but not required at general aviation airports like Santa Monica Airport." The July 31St RSA proposal submitted by the FAA discusses the installation of a "non-standard" EMAS system with a 40 knot stopping performance comprised of 130' of EMAS with a 25' set back located at each end of the runway. The proposal is designed to minimize the taking of existing runway pavement by 4 creating extensions to the existing runway to accommodate as much of the EMAS as possible. Essentially, the FAA proposes an EMAS installation that would stop an aircraft weighing in excess of 12,500 Ibs that exited the runway at 40 knots or less. It should be noted that a "standard" EMAS installation would stop the same aircraft traveling 70 knots or less. The FAA states that taking usable runway for an EMAS installation is unprecedented and considered acceptable at the Airport only because it is essential to achieve the 40 knot performance provided in FAA specifications for non-standard EMAS installations. Further the FAA stated that taking more runway was not justified, because a larger EMAS was not required to meet FAA specifications. Non-standard EMAS installations are relatively common at other airports throughout the United States including locally Burbank Airport and Newark Airport in New Jersey -the fundamental difference is that these EMAS systems were installed at the end of (and not over) an existing runway. The primary difference between the July 31St proposal and the one presented by the .FAA in June is the extension of the at grade runway "platform" to accommodate the proposed EMAS beds. The platform at each end of the runway would be extended (through the addition of infill and use of retaining walls) to the inside lane of the existing perimeter road. The perimeter road would remain in its 5 current location but be reduced to one lane for several hundred feet at each end of the runway. This would result in the addition of the following approximate distance of the at-grade platform designed to support an EMAS system off each end of the runway: Runway Length of Extension 21 100' 3 40' Total length of Runway Extension of 140' "at-grade" platform suitable for EMAS installation beyond the current ends of the runwa The above actions would effectively increase the existing runway platform from 4,973' to 5,113', thereby moving the at runway grade platform. closer to the perimeter of the Airport and the residential areas off either end of the runway. Further engineering work is needed to determine the exact design of the runway extensions, but effectively both runway platforms would terminate at 90° drop-offs approximately 15' above the perimeter road. Installation of the proposed EMAS systems (which totals 310' in combined length) in the newly configured runway would result in an overall usable runway length reduction of approximately 150'. The FAA asserts that the reduction of 150' from the existing runway length would not have a significant impact on existing aircraft operations. 6 The FAA determined that installing the proposed EMAS on the existing runway would reduce the runway length by 250' - 300' (depending on the exact placement of the EMAS system) and begin to have a considerable effect on current aircraft operations. The FAA analysis considered a flight adversely affected if it was required to lose a significant amount of fuel payload as a result of the reconfigured runway. FAA considered a flight adversely affected if it results in: • a 500 Ib reduction in fuel • a loss of a passenger • an impact on reserve fuel • a reduction in fuel that would reduce range by more than 200 nautical miles • requiring an aircraft operate at less than 60 percent of its useful load • the need to make an intermediate fuel stop on the way to its final destination with at least a 60 percent load FAA argued that operations of any aircraft below 60% of its useful load are analogous to not being able to derive substantial benefit from the aircraft's capabilities and while some flights only require operation with small loads or a small number of passengers, an airport change that limits all flights of that aircraft to low payload is clearly a restriction on use of the airport. The FAA asserts that the proposed 130' EMAS bed with no setback from the runway end can stop aircraft weighing in excess of 12,500 Ibs leaving the runway at 40 knots, with at least the main gear coming to a rest in the EMAS bed. The FAA provided additional data indicating that the EMAS bed will slow an aircraft leaving the runway at speeds higher than 40 knots, although the reduction in speed diminishes as the speed increases above 40 knots. Certain large/fast aircraft types would .exit the EMAS bed at the speeds indicated if entering the EMAS bed at 50 knots, 60 knots, and 70 knots respectively: Leave runway/enter EMAS Exit EMAS (in knots) 50 knots 5 to high 20's 60 knots low 30's to low 40's 70 knots high 40's to high 50's The FAA states that the proposed EMAS bed would stop or significantly slow all of the larger aircraft types using the Airport. In order to supplement the benefits of the EMAS installation, the FAA recommended that: 1) The City, with the cooperation and assistance of the FAA, implement a joint education and information program with FAA based. on the Flight Standards Service Information for Operators (InFO). 8 2) The City consider the feasibility of a property acquisition program to remove homes from the RPZs, even if the program removes only a few homes and does so over time. Such a program would be eligible for FAA grant funding. It is the position of the FAA that the extension of each runway end along with the addition of a minimal EMAS installation at each end of the runway, will provide the significant safety benefits with a relatively small reduction in runway length. The FAA closes by stating: "the i30 foot EMAS installation would stop aircraft type using SMO that leaves the runway at a speed up to 40 knots, and slow an aircraft moving faster than that. Additional measures, whether in the form of a larger EMAS installation or use of declared distances to effectively shorten the runway, would provide a diminishing enhancement of safety along with an increasingly adverse effect on normal operations at the airport. Accordingly, such measures were not considered to meet the objectives outlined above." 9 Staff Critique of FAA Proposed Runway Safety Areas for Santa Monica Airport Staff's overall impression of the current FAA Proposal and associated analysis by the FAA is that the FAA Proposal favors aircraft access while not adequately addressing safety. The FAA Proposal attempts to preserve as much runway as possible in order to provide access for the current aircraft fleet mix while providing a modicum of safety enhancements that are expensive to implement and only meet the minimum FAA safety standards for the most demanding aircraft using the Airport. The FAA Proposal attempts to preserve as much runway as possible so that the larger/faster aircraft would still be able to operate at the Airport with minimal disruption. It is Staff's position that while a given safety enhancement option could affect overall aircraft operations at the Airport, a decrease in the distance an aircraft could operate is not an exclusion from the Airport. The shorter operational distance that an aircraft can fly for the .convenience of the passengers does not prevent an aircraft from safely operating at the Airport. Aircraft operated at reduced takeoff/landing weights due to a given runway configuration have greater operational safety margins. Safety has to be viewed in the overall perspective of the safe operation of the aircraft and safety for the residential areas surrounding the Airport -not whether or not an aircraft can reach a given destination non-stop. in The proposed runway platform extensions for the EMAS installations at each end of the runway are problematic for several reasons: 1) The ends of the runways are moved closer to residential areas. 2) The runway "platform" would end at 90° drop-offs 15 feet above the service road and not to the existing slope. 3) An aircraft. undershooting the runway, no matter to what degree, would impact a vertical'wall. 4) An aircraft exiting the end of the runway at any speed would be faced with a 15' vertical drop off virtually ensuring a catastrophic event. 5) The proposed configuration drastically reduces the effectiveness of the blast wall at the east end of the runway. 6) The cost of the platform installation could range upwards of millions of dollars. 7) The construction of the platforms would require an EIR/EA that could take over a year to complete, further delaying critically needed safety enhancement. 8) The construction of the platforms would take months to complete and have an adverse impact on normal day-to-day operations of the Airport. 11 9) The FAA Proposal for the eastern end of the runway is located in the City of Los Angeles and could therefore require approval through the regulatory process of the City of Los Angeles, all of which would cause significant delays in implementation. The FAA's proposed EMAS/runway safety area provides a limited degree of safety enhancements and is deficient in the following regards: 1) The RSA proposal does not meet FAA standards for the minimum safety area requirements for Airport's designation as a B-II airport (300' RSA). 2) The RSA proposal does not meet FAA standards for the minimum safety area requirements for a D-II category airport (1,000' RSA). 3) The proposed EMAS installation would only affect aircraft weighing 12,500 Ibs and above -lighter aircraft would not be affected by the EMAS. 4) The proposed EMAS installation would not provide a safety enhancement for 85% of the aircraft currently using the Airport. 5) The. non-standard EMAS installation would capture only 50% of the compliant aircraft (i.e. those weighing 12,500 Ibs or more) leaving the ends of the runway (A "standard" EMAS installation would stop the same aircraft traveling 70 knots or less) 12 6) Compliant aircraft entering the EMAS bed at speeds greater then 40 knots would exit the EMAS bed at unacceptably high speeds, fifteen feet above the service road and closer to the airport boundary and the residential areas then the current runway configuration Runway Protection Zone The FAA suggests that the City consider removing incompatible land. uses (i.e. residential homes) inside a Runway Protection Zone (RPZ). An RPZ is a trapezoidal area "off the end of the runway end that serves to enhance the protection of people and property on the ground" in the event an aircraft lands or crashes beyond the runway end. An RPZ begins 200' off the end of the runway and extends outward 1,000' encompassing approximately 14 acres off either end of the runway (in Santa Monica to the west and Los Angeles to the east). The cost and complexity of residential property acquisition in these areas would be substantial and extremely disruptive to these long-standing neighborhoods and as such, Staff cannot recommend this course of action. It should be noted, that removal of incompatible land uses in the RPZ will have little effect on safe- guarding the lives and property aboard the aircraft. The designation of the Airport in 1984 as a facility for less demanding aircraft in the A and B categories with approach speeds below 121 knots was reflection of 13 the aircraft fleet that used the Airport at the time. In 1984 aircraft based at the Airport could have been accommodated with a runway. of 3200 feet. Analyzing transient aircraft using the Airport, the 1983 Airport Layout Plan found that a runway of 4500 feet would have been sufficient. Although the FAA indicated in its July 31St letter that the critical aircraft for planning purposes is the Gulfstream IV, it was not one of the aircraft on which the 1983 planning was based. Criticizing the Cities of Los Angeles and Santa Monica for not creating RPZ's overlooks the fact that the current safety concerns are the result of the FAA permitting the use of the Airport by aircraft beyond the design capacity of the field, without any public process or safety review. While the most demanding aircraft using the Airport currently is in the more demanding category of D-II, that was not the case when in 1984 when the FAA approved an Airport Layout Plan recognizing that the Airport is designated in the B-II category. Summary The safety enhancements requested by the City are intended to address an aircraft fleet which has evolved over time with the permission of the FAA. As a B-II airport, Santa Monica Airport was not designed for the larger and faster categories of aircraft. Although the FAA Proposal is based upon a critical aircraft that is in the larger and faster categories of aircraft, the proposed safety 14 enhancements do not adequately address the safety concerns of then; aircraft if they leave the ends of the runway at speeds greater than 40 knots. T!~e runway safety enhancements are required by the Airport and should not be .'eferred to accommodate the operational convenience of the larger and faster ,i~craft that have changed the aircraft fleet using the Airport. Therefore, if the July 31,.2007 FAA Proposal remains unchanged after the workshop of August 28; %-007, it is recommended that the City Council reject the FAA Proposal and direct Staff to explore the implementation of effective runway safety enhancements. Budget/Financial Impact The cost of the proposed Runway Safety Area improvements have nc: ';een fully defined pending the outcome of the data gathering process. Hoy, •,;er, staff estimates that the current FAA proposal could exceed $5 million .'ollars to implement. Prepared by: Robert D. Trimborn, Acting Airport Director Approved: Forwarded to CounciL• Acting 15 Attachment #1 July 31, 2007 Letter to Robert Trimborn from D. Kirk Shaffer, Associate Administrator for Airports, Federal Aviation Administration Attachment #2 July 31, 2007 FAA Runway Safety Area Proposal Diagrammatic Layout Attachment #3 August 14, 2007 Letter from Representative Jane Harman to Marion C. Blakey, FAA Administrator lb Attachment #1 L, J U.S. Deportment of Transportatlon Federal Avialbn Adminishalion July 31; 2007 Associate Administrator 8001ndependence Avenue, S~FJ for Airports Washington, nC 20591 Mr. Robert Trimbom Airport Manager, Santa Monica Airport Off ce of the Airport Manager 3223 Donald Douglas Loop South Santa Monica, CA 90405 Dear Mr. T At our meeting on Tune 12, we presented our view that it should be possible to obtain a significant safety enhancement at Santa Monica Airport (SMO) through the use of a compact engineered material arresting system (EMAS) at each end of the runway. With some grading, which we believe to be feasible, this can be done in a way that minimizes any adverse effect on the use of the airport. At the meeting, we also agreed to consider two other factors: the performance of a 40-knot EMAS bed for aircraft entering the bed at speeds higher than 40 knots, and the use of declared distances in addition to the EMAS. We obtained the EMAS performance information from ESCQ the manufacturer of EMAS, and that information was also provided to the City. That information showed that an EMAS bed will substantialty slow an aircraft slightly above the design stopping speed of the EMAS, but the slowing effect diminishes as speed increases. No system can guarantee that there will never be an incident of some kind, however, and we believe that reducing runway length further to protect against an increasingly narrow set of conceivable circumstances is not warranted. Runway safety azeas are designed for the protection of aircrews, not to guarantee that an aircraft will never get beyond the safety area. For protecrion of persons and property near the end of the mnway, FAA design standards provide for a runway protection zone that limits the land uses in that area. The runway protection zone is recommended bnt not required ai general aviation airports ]ike SMO. We appreciate the presentation at the meeting by Coffman Associates on the estimated impacts of various proposed actions on operations at the airport. We considered that information, as well as our own analysis of essentially the same operations data. We also considered both the benefits and operational effects of using 300-foot deelazed distances in addition to an EMAS installation. After considerafion of alT the information provided by the city on Tune 12 and the additional information obtained since then, we believe the following measures will be a real enhancement of safetyat SMO. The measures will affect some individual flights, but will not affect the general use of the airport and its value to the Southern California region. The attached paper explains the decision in more detail, but in summary it is: 17 a The goal, which we believe is feasible, is to install an EMAS unit with 40-knot performance with the minimum taking of existing runway pavement. Taking runway for an EMAS installation is unprecedented and is considered acceptable in this case only because it is essential to achieve the 40-knot performance provided in FAA specifications. Taking more runway is notjustified, because a larger EMAS is not requited to obtain an installation that meets FAA specifications. ® We believe That with feasible grading, an EMAS bed can be installed at each end of the runway with a total reduction in runway length of less than 150 feet. Obviously engineering work will be required to confirm the exact numbers. o Grading of each runway end ko provide additional Level land at the end of the runway, to the extent possible without moving the perimeter road (although possibly reducing the perimeter road to one lane at the runway ends}. ® Installation of a 130-foot EMAS bed with a setback of 25 feet from the runway end at each end of Runway 3-21. Total distance required for the two EMAS beds would be310 feet. e The 25-foot setback at the far end of the runway would be considered to be a "stopway" which, under FAA standards, can be included intake-off run available {TORA) and landing distance available (LDA) as calculated by pilots for operation at the airport. ® The use of declared distances would provide a virtual runway safety area for airaaft too light to benefit from the EMAS. Most of those aircraft do not require the full runway for most operations, so there would be little adverse effect, but also little real benefit. For aircraft heavy enough to benefit from the EMAS, the EMAS itself provides a system that meets FAA performance specifications, and the impact on operations that would result from further shortening of the mnway through declazed distances is not necessary. We look forward to any further comments you and your consultants have on this paper, and to speaking to the City Council on August 28. If you have any questions, feel free to call me at (202) 267-9471. Sincerely D.ICir Shaffer Associate Administrator for Airports iR Attached is a paper discussing our conclusion on the review of the rumvay enhancements at Santa Monica Airpor[. Attachment iQ SMO Runway End Enhancements Santa Monica Airport (SMO) is an important general aviation reliever airport for Los Angeles International Airport and a populaz and valuable airport in its own right for business and recreational aviation in the Southern California Region.. The single 4987 X I50' runway safely accommodates all aircraft currently using the airport, including the Gulfstream G-IV. However, the airport's location and terrain make it impossible to achieve a standard runway safety area (RSA) at the runway ends. RSAs are designed to provide a safe stopping area for aircraft that leave the runway pavement. Also, the cities of Santa Monica and Los Angeles have elected not to implement a mnway protection zone (RPZ) beyond either mnway end by removing residentiai and other non-compatible land uses. RPZs are provided in FAA airport design standards to avoid concentrations of persons in the azeas immediately off the end of a mnway. Recommended Enhancements On these facts, the FAA sought to identify mnway end safety enhancements at SMO that would, to the extent passible: (I) make an actual improvement in safety for aircraft crew and passengers; (2) reduce the likelihood of an overmruring aircraft reaching a residential area; (3) have a minimal adverse impact on the utility of the airport, (4) avoid moving the runway touchdown point and beginning of the takeoff roll closer to the communities at each end of the mnway than they aze now, and {5) be feasible from an engineering and cost standpoint. After consideration of the views of the City of Santa Monica, airport users, and the communities near the airport, and consideration of recent developments in aircraft arresting technology, we believe the following actions will meet all of the above objectives: 1. Add land at each end of the runway through addition of fill and use of retaining walls, to extend tlurough the inside lane of the perimeter road at each end. The perimeter road will remain in the current location but be reduced to one lane for several hundred feet at each end of the mnway. We estimate this action could result in approximately the following distances of level Land off each end of the runway: Runway 21 100' Runway 3 40' Total 140' 2. Install a 130' engineered material arrestig system (EMAS) at each end of the mnway, using as much Land as is available at each end, and using existing runway only fo the extent necessary. 3. Mark the threshold of the mnway at each end 25' from the end of the EMAS bed. This provides a setback to minimize jet blast damage to the EMAS bed on Takeoff. ~n Effect on Runway length The above actions would have the following effects on runway length: ExisGngrunwaylength: 498T STEP 1 Total length of existing runway plus available land (after earthwork to level terrain): 4987' +140' 512T Length of EMAS beds: 130' at each end STEP 2 Remaining runway pavement with a 130' EMAS at each end: 5127' -260' 4867' STEP3 Runway length. Runway pavement minus 25' setback between the EMAS bed and the runway threshold at each end. This would be the new published ntnway length: 4867' -50' 4817' STEP 4 Actual Distance availablefor takeoffand landing. Runway pavement minus 2S for EMAS setback between the EMAS and the threshold, but without deducting the 2S setback at the far runway end. This number represents ffie actual length of pavement from the mnway threshold to the EMAS bed at the faz end of the runway. Because the 25' setback at the far end of the runway is considered "stop way" that can be included in calculations for landing and takeoff, this number would also be the published landing distance available (LDA) and the accelerate-stop distance available (ASDA) on takeoff: 4867' -25' 4842' 71 Impact on Airport Operations and Utility There is no disposable or excess runway at SMO. The existing fleet mix already uses the existing nmway with significant weight penalties. SMO's 5,000-foot runway is needed #o accommodate not only existing jet operations, but also smaller aircraft types. Any reduction in runway length will affect some operations at the airport. The greater the reduction, the more operations are affected and the greater the adverse effect. A reduction of less than 150 feet from the existing runway length is not expected to have a significant impact on operations, either on ogerating weights or on the possible stage lengths of flights from the airport. A loss of 100-150 feet from a runway with a length of 4,987 feet appeazs operationally acceptable, yet with EMAS provides a safety benefit that exceeds that of a 300-foot declared distance, at least for aircraft at or above about 12,500 lb. Even at this small reduction in runway length, however, some operations would be affected, including the Gulfs[ream G-N on take-off onlong-range flights, the G-N landing below 50,000 Ib, and the Learjet 45 take-off at 20,000 tb. By taking into consideration realistic operational variables and matching them to the actual fleet mix at SMO, and by taking into account real data and real operational considerafions, the FAA determined that reducing runway length 250-300 feet begins to have a significant effect do current operations. The City estimated less than 300 flights a yeaz aze affected, loolcingpnly at 5 aircraft types, limiting impact to flights over 1,500 natrtical mites, and considering only takeoffs. Moreover, the City took the position that there would be an adverse effect only if the operator was required to cancel an intended operation. FAA analysis considered a flight adversely affected if that flight were required to lose a significant amount of fuel or payload (e.g. 500 Ib in fuel, a passenger, an impact on reserve fuel, or reduction in fuel that would reduce range by more than 200 nautical miles}, operate at less than 60 percent of useful load, or would need to make an intermediate fuel stop on the way to its final destination with a[ least a 60 percent load. Operations of any aircraR below 60% useful load aze analogous to not being able to derive substantial benefit from [he aircraft's capabilities. While some flights only requue operation with small loads or a small number of passengers, an airport change that limits ad1 flights of that aircraft to low payload is cleazly a restriction on use of the airport. Moreover, FAAairport planning guidance defines the recommended length of a runway as a function of many factors, one of the most notable being a nmway length to accommodate the critical aircraft and the longest nonstop distance to be flown by that aircraft from the airport, The runway length at SMO already limits the operations of aircraft types that commonly use the airport, so any loss of runway is important. A loss of just a few hundred feet has an impact on the accelerate-stop distance requirements of several B-II and turboprops as well as turbojets. In addition, Part 135 air taxi operations and Part 91K fractional operations already require a reduction in runway Length for calculation of runway available. As a result, if the runway were shortened by even 300 feet, Part 135 operations would effectively have available only 2,812 feet for landing and Part 91K operations would have available only 3,749 feet. This effect would cleazly apply to many of the aircraft using SMO, including smaller types until now considered by the City to be unaffected by a shorter runway. 77 The analysis conducted by the FAA showed that 2,000 to 3;000 operations a yeaz would be adversely affected. Short- and medium-haul flights by lazge types generally were not affected, although some current operations to cities Iike Seattle, Denver, and Chicago by medium and smaller type aircraft would be affected. Longer-range flights beyond the mid-west to theeast-coast would be substantially affected by the loss of 300 feet of runway for many types. To put this impact in perspecfive, the FAA Airports planning guideline for substan$al use is 500 annual operations a yeaz, and FAA Air Traffic uses the effect on one operation per day as the threshold of significant impact, or 365 annual operations. The conclusions of our analysis of the impacts on airport users remained the same through several different methods of analysis, and were supported by the comments of airport users who responded to a proposal presented at an FAA/City meeting in December 2006. While user comments unanimously opposed the December proposal, some comments by users indicated they were willing to sacrifice a small amount of runway to obtain the benefits of a basic EMAS installation. - Several users indicated they would accept a 165-foot EMAS installation (130' EMAS bed and 35' setback) on the departure end of runway 21, for a loss of pavement of slightly less than 165'. No users supported the loss of more runway in order to provide a larger EMAS bed or declared distances. EMAS effectiveness A 130' EMAS bed with no setback from the runway end can stop the following aircraft types leaving the nmway at 40 knots,.with at least the main geaz coming to a rest in the EMAS bed. G-IV @ 576001bs CL-600 @:37,000Ibs Falcon 900;@ 35,500 ltis Leaz 35 @.17,000 lbs ' ER:T-135. at 41,500.1bs :Hawker 125 @ 20,500Ibs These aireiaft types represent frequent operations at SMO, and the weights listed aze representative of actual aircraft operating weights for SMO operations (as opposed to maximum certificated weights}. The weights indicated were derived primarily from users, aircraft manufacturer input, and FAA's own reseazch. The EMAS bed will slow an aircraft leaving the mnway at speeds higher than 40 knots, although the reducfion in speed diminishes as the speed increases above 40 knots. For example, the aircraft types listed immediately above would exit the EMAS bed at the speeds indicated if entering the EMAS bed at 50 knots, 60 knots, and 70 knots respectively: Leave runwav/enter EMAS Exit EMAS (in knotsl 50 knots 5-high 20's 60 knots low 30's to low 40's 70 knots high 40's to high 50's 7Z In sum, even a compact.130-foot EMAS bed would stop or sigiuficantly slow all of the larger aircraft types using SMO. Additional measures th order to supplement the benefits of the EMAS installation, the FAA recommends that: • The City, with the cooperation and assistance of the FAA, implement a joint education and information progam with FAA based on the Flight Standazds Service Information for Operators (~O)~ ® The City consider the feasibility of a property acquisition program to remove homes from the RPZs, even if the progam removes only a few homes and does so over time. Such a progam would be eligible for FAA gant funding. Conclusion. Itt sufnmazy, the addition of a small amount of land at each runway end through earthwork, and the addition of a compact EMAS installation at each end of the runway, could provide the significant safety benefits of an EMAS with a relatively small reduction in runway length. SpeciScatly, distance available for takeoff and landing would be reduced from the 4,987 feet available now to 4842 feet, a reduction of 145 feet. The 130-foot EMAS instatlation would stop any aircraft type using SMO that leaves the runway at a speed up to 40 knots, andslow an aircraft moving faster than that. Additonal measures, whether in the form of a larger EMAS installation or use of declared distazices to effectively shorten the runway, would provide a diminishing enhancement of safety along with an increasingly adverse effect on normal operations at the airport. Accordingly, such measures were not considered to meet the objectives outlined above. 7d Attachment #2 July 31, 2007 FAA Runway Safety Area Proposal Diagrammatic Layout L5 COMMnTEE ON HOMELAND SECURITY ~.'' $Ue<oNmm~c.~ ' Ni£LLIGEACE.I TOgMAiiON$ WNWC. Auo Trnnoxism Rw: P55 ESS.w-m CN,UR $VamummEa ox ,,nn((~~yy~~~~//~~TT~~ ~~ii~~++~=T p,p • ~i i q p.,~ F ~ ggp,y p~ 6ogGEq, MAartiME, Arvo l.VttlYdflSEwTJ YY ®lYBHt°1 Jl-S1W~d3tSn1tl1~1V GCO6aL CCCNiFI,eEggOplSm awE DOG COALITION 36TI-I DISTRICT, CALIFORNIA NnnmuL sE<ugrc rronx~NG GwP £0.CHAIR August 14, 2007 CONGRESSIONAL SPACE POWEq CAUCUS COCHA1fl Marion C. Blakey AdministLator Federal Aviation Administration 800Independence Ave, SW Washington, D.C. 20591-0001 Dear Administrator Blakey, I am writing to express my deep disappointment with the FAA's decision regattling runway safety measures for the Santa Monica Aippor[ (SMO). After months of input from SMO officials and the surrounding community, I believe that the FAA's recommendation to mitigate the risks of runway overshoots is insufficient to guazantee the safety of airport usets or the neighboring residents. Over the last year the length of the proposed Engineered Material Arresting System (EMAS) has been shortened from a 250-foot proposal in December, to a 165-foot bed in March, tonow a 130- footbed with a 25-foot setback at each end. Additionally, despite requests from SMO officials that declared distances be applied as well, ao declared distances were included in the decision. According to the FAA and to the manufacturer of the EMAS beds, this 155-foot total EMAS bed is guaz~ahteed to stop aircraft landing at a speed at or below 40-knots. At SMO, planes traveling at this speed encompass only 50 percent of runway ovemms. That leaves half of all aiicraft operations at the airport in danger of continuing through an EMAS bed, down an embanlanent where they threaten to cross busy sweets and enter nearby residential neighborhoods. Such an incident could be tragic. Continued access to the airport needs to be balanced with safety for all -pilots, passengers and neighbors alike. I do not believe that the current FAA recommendation meets this standazd. I hope we can continue to work togetherto design safety enhancements that provide greater confidence to all. CAMNIITTEE ON ENEgGYANO CDH1MEflCE - S0000.xMfilE¢Ge~ TE~CaGMEVHCaiiGN3 IenEnxn $U8C0.NMiTiEE ON EnrM.y mio Ala QuALrtv NEW CEMOCRAT COALITION R gazds, J E HARMAN ELSEGUNOa: [1 2321 flO5ECgANS AVENUE SUrrt 3210 ft aEGUNCO, CA 90245 PHONE: (310)643-3636 Fax: {310)843-6945 gE$PONa TO: wASHINOTON. ~(':. Q 240U RAVbUflN HOUSE OfFICE aUILGING wdsHING4GN, DC 20515 PIroNE (2027225b220 fAx: (2021226-1290 W tMiNGTGN: 544 NOflTH AVALON aOULFIAfiO Surre 30J 'NnMWGTOrv, CA 90164 PHONE. {3101649-6282 FPX: {310} 5436250 Websito: vx~vi,hause.goNharmaa PflIN1FCCN PECVGECPAPEP 26 ~/~/off 3-~- While continuing negotiations with the FAA, the Ciry of Santa Monica could start considering whether it should ask the U.S. Congress to pass an act such as the following: COMMUNITY HEALTH AND SAFETY ACT FOR NEIGHBORHOODS NEAR SMALL AIRPORTSr 1.0 PREAMBLE 1.1 The case for action by the U.S. Congress includes: 1.1.1 Whereas the federal government has made progress in establishing uniform policies, standards, and procedures for protecting community health and safety for neighborhoods near large- and medium-size airports since the early 1970s, it ha yet to establish uniform policies, standazds, and procedures for addressing emerging concerns about community health and safety for neighborhoods neaz small airports. 1.1.2 Whereas neighborhoods neaz medium and large airports often include heavy concentrations of commercial uses, neighborhoods near small airports often have a heavy concentration of residential uses. 1.1.3 Whereas during prior decades the operations at small airports where dominated by aircraft that were relatively small and slow, the frequency of operations by relatively large and fast aircraft is rising at many small airports and is likely to increase further in the future unless airport operators are allowed to control growth in operations. 1.1.4 Whereas the risks for community health and safety tend to increase with aircraft size and speed, the design of an aircraft can be adjusted to reduce such effects by accepting reductions in performance and/or increases in costs. 1.1.5 Whereas regulatory authorities such as the U.S. FAA require the large- and medium-size aircraft that operate at medium and lazge airports to be designed to accept some compromises in performance and cost in exchange for improvement to community health and safety, such regulatory requirements are less stringent (ornon-existent) for aircraft that operate at small airports. ~ Prepared by Jean Gebman, former member of the Santa Monica Airport Commission (1998 - 2005). Dr. Gebman holds engineering degrees with specialization in aeronautical engineering from Syracuse University (B.S., 1997), University of Michigan (M.S., 1998) and University of California Los Angeles (PhD, 1974). The material in this draft reflects the personal views of Dr. Gebman. Although many colleagues and associates have contributed concerns and ideas reflected in this draft, Dr. Gebman bears sole responsibility for contents of this draft. August 27, 2007 Outline and partial draft for discussion 2- 1.1.6 Whereas the regulatory authorities such as the U.S. FAA have raised regulatory standards for new aircraft in areas that effect community health and safety at medium and large airports, the application of such standazds at small airports has not kept pace with medium and large airports. 1.1.7 Whereas community health and safety also can be affected by factors such as terrain, environment, type of land use, and type of construction, the federal government's policies, standards and procedures must be sensitive such factors. 1.1.8 Whereas the operation of medium-size, high-speed aircraft at small airports with residential neighborhoods near active runways has created conditions and circumstances not found at medium and large airports, there is a need for special attention by the FAA to operations at such airports. 1.1.9 Whereas the operation of any airport will expose neighboring communities to some amount of risk for community health and safety, a fundamental duty of regulatory authorities such as the U.S. FAA is to establish those policies, standards and procedures that are required to assure that no neighborhood is exposed to unreasonable levels of risk to community health and safety. 1.1.10 Whereas the U.S.FAA appears to be in remiss of fulfilling the foregoing duties in the instance of Santa Monica Airport, citizens of Santa Monica are calling upon the U.S. Congress to establish a Community Health and Safety Act to compel the U.S. FAA to cure the aforementioned deficiency. 1.2 Purpose. The purpose of this act includes: 1.2.1 Small airports. Focus on the assessment and management of risks to community health and safety in neighborhoods near small airports. 1.2.2 Equity. Establish equitable shazing of reasonable levels of risk to community health and safety in neighborhoods near airports. 1.2.3. Due process. Establish uniform policies, standards and procedures for objective assessment of concerns about the possibility of unreasonable levels of risk. 2. DEFINITIONS 2.1 Airports 2.1.1 Large airports 2.1.2 Medium airport 2.1.3 Small airport 2.2 Aircraft August 27, 2007 Outline and partial draft for discussion 3- 2.2.1 Aircraft size 2.2.1.1 Lazge aircraft 2.2.1.2 Medium aircraft 2.2.1.3 Small aircraft 2.2.1.4 Very small aircraft 2.2.2 Aircraft speed 2.2.2.1 High 2.2.2.2 Medium 2.2.2.3 Low 2.2.2.4 Very low 3.0 COMMUNITY EXPOSURE TO AIRCRAFT NOISE 3.1 For Part 3 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 3.1.1 Whereas small airports may have nearby residential neighborhoods with ambient noise that remain relatively low compazed to the perceived noise levels of some aircraft, the disruptive consequences of aircraft noise can be very significant for residents of such neighborhoods. 3.1.2 Whereas tolerance for noise varies widely within the general population because tolerance can be influenced by many factors (including the onset time, duration, peak level, and frequency) assessment of community noise exposure must be sensitive to such factors. 3.1.3 Whereas the U.S. FAA's approach to noise management has evolved since the early 1970s in response to concerns about noise near large airports, that approach may not be well suited to small airports. 3.1.4 Whereas the City of Santa Monica and the federal government settled a dispute that included the city's management ofaircraft-related noise fora 30-year period ending in 2015, and whereas that settlement allows the City of Santa Monica to levy fines for noise violations and whereas subsequent federal legislation effectively has limited the ability of other communities to establish similar programs for aircraft-related noise, the City of Santa Monica has unique authority at least unti12015 for regulated aircraft-related noise. August 27, 2007 Outline and partial draft for discussion -4- 3.2 Purpose. The purpose of Part 3 of this act includes: 3.2.1 Require the U.S. FAA to include provisions in the Federal Aviation Regulations that: 3.2.1.1 Protects the right of the City of Santa Monica to continue a noise regulation program such as was in place on January 1, 2007. 3.2.1.2 Extends similar rights to other operators of small airports. 3.2.2 Require the U. S. FAA to allow small airports to increase the number of noise monitoring sites for enforcement purposes from two (2) sites now permitted at Santa Monica Airport to as many as ten (10) sites by January 1, 2009. 4.0 COMMUNITY EXPOSURE TO AIR POLLUTION FROM AIRCRAFT 4.1 For Part 4 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 4.1.1 Whereas small airports may have nearby residential neighborhoods that are close enough to experience increased air pollution due to airport operations, including aircraft operations, and whereas a wide variety of chemical compounds are included in the exhaust from aircraft engines and aircraft-related power units, neighbors of small airports have expressed concerns about the potential influence of such chemical compounds on the health of family members, including those who are young, elderly and/or ill. 4.1.2 Whereas many of the chemical compounds found in aircraft-related exhausts have yet to be studied sufficiently by the federal government to support establishment of maximum exposure levels that are health-based, neighbors of small airports have expressed concerns about the rising frequency of operations and the increased sizes of aircraft operating at their neighboring airports. 4.1.3 Whereas some types of aircraft engines are very inefficient when operating at idle/taxi power settings, the amount of air pollution emitted during ground operations (idle/taxi) can dominate the adverse influence on air quality at locations near an airport. 4.1.4 Whereas some chemical compounds such as ultra-fine particulates have been found to be most threatening to public health shortly after their emission from engines, neighbors close to small airports have expressed concerns about their unknown levels of exposure and the potential health implications of such exposure. 4.2 Purpose. The purpose of Part 4 of this act includes: 4.2.1 Build a base of knowledge that can be used to control any adverse affects of aircraft-related emissions on the health of neighbors residing near small airports. August 27, 2007 Outline and partial draft for discussion -5- 4.2.2 While developing the necessary base of knowledge, related data, and analysis models: 4.2.2.1 Identify those small airports that may have the highest risk of adversely affecting the health of neighbors. 4.2.2.2 For such at-risk airports (Section 4.2.2.1) establish interim limits on the growth of operations and consider reducing current operating levels. 5.0 COMMUNITY EXPOSURE TO AIR TURBULENCE FROM AIRCRAFT 5.1 For Part 5 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 5.2 Purpose. The purpose of Part 5 of this act includes: 6.0 COMMUNITY EXPOSURE TO AIRCRAFT ACCIDENTS 6.1 For Part 5 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 6.2 Purpose. The purpose of Part 5 of this act includes: 7.0 NATIONAL PROGRAM FOR HEALTH AND SAFETY IN NEIGHBORHOODS NEAR SMALL AIRPORTS 7.1 For Part 7 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 7.2 Purpose. The purpose of Part 6 of this act includes: 8.0 INDIVIDUAL AIRPORT PROGRAMS FOR HEALTH AND SAFETY IN NEIGHBORHOODS 8.1 For Part 8 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 8.2 Purpose. The purpose of Part 7 of this act includes: August 27, 2007 Outline and partial draft for discussion -6- 9.0 AIRPORT REALIGNMENT AND CLOSURE COMMISSION 9.1 For Part 9 of this act, the case for action by the U.S. Congress includes the following conditions and circumstances. 9.2 Purpose. The purpose of Part 9 of this act includes: August 27, 2007 Outline and partial draft for discussion Additional attachments available in City Clerk's Office.