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SR-100907-8ACity Council Meeting: October 9, 2007 Agenda Item: ~'~" To: Mayor and City Council From: Robert Trimborn, Acting Airport Director Subject: Implementation of Safety Enhancements at the Santa Monica Municipal Airport and City Council Direction to Staff Recommended Action In order to help protect the safety of Santa Monica Municipal Airport neighbors and users and reduce potential liability risks to the City, it is recommended that Council direct staff to prepare for Council consideration an ordinance which would conform usage of the Airport to the Category A and B aircraft, which the Airport was designed to accommodate and also direct staff to promote Airport safety through other means, including legislative advocacy. Executive Summary The City of Santa Monica owns and operates the Santa Monica Municipal Airport -- one of the oldest continuously operating airports in Los Angeles County. As its proprietor, the City is responsible for maintaining a safe Airport facility. The Airport's unique physical characteristics mandate scrupulous attention to safety issues. Residential neighborhoods surround the Airport on three sides and are located 1 in very close proximity to the runways. Only approximately 300 feet separate family homes from either end of the runway. Additionally, the Airport sits on a plateau which drops off steeply just past the end of the runway into the Sunset Park neighborhood just west of the Airport and into the Mar Vista area to the east of the Airport. Compounding this tenuous situation, there are no runway safety areas at the runways' ends. These two circumstances -the lack of safety areas and the proximity of homes at the runway ends -- make the possibility of an overrun particularly dangerous. These physical realities also necessitate careful attention to Airport usage, which has changed dramatically over the course of the Airport's history. The Airport was designed for A and B category aircraft, which travel at relatively slow approach speeds. However, an exponentially growing number of the aircraft now using the Airport are in the C and D categories -which mean that they are significantly faster. Federal safety standards for C and D aircraft, accordingly, require significantly longer runway safety areas than for A and B category aircraft. The Airport does not currently meet the standards for Category A and B aircraft and does not even come close to meeting the standards for C and D category aircraft. This rapidly escalating disparity between Airport design and Airport usage puts the safety of neighborhood residents, pilots, passengers, and others at risk. It also exposes the City -which is responsible for the Airport - to possible legal risk. As acknowledged by the Federal Aviation Administration (FAA) in its nationwide campaign to upgrade runway safety areas, and as demonstrated by recent aircraft overruns at other airports, the lack of adequate safety areas is a critical safety issue. 2 To address these realities and risks, Council approved a conceptual plan for enhancing Airport safety through the creation of runway safety areas at the ends of the .runways and through limiting usage to conform to the Airport's physical realities. The FAA challenged the legality of this plan, and Council directed staff to work with the FAA to achieve Airport safety. During a presentation to the City Council on August 28, 2007, D. Kirk Shaffer, Associate Administrator for Airports for the FAA, pledged to continue the dialogue with the City to resolve the gap between the City and the FAA on the best proposal to make the Airport safer. However, five years of effort have produced no adequate result. Regrettably, during a recent telephone conversation between Mr. Shaffer and City Manager P. Lamont Ewell on September 27, 2007, Mr. Shaffer informed the City that the FAA continued to stand by the same inadequate position that the City Council rejected. Therefore, staff recommends that Council take the next step forward in implementing its previously approved conceptual plan for promoting safety and reducing risk by conforming Airport usage to current federal safety standards. That step would be a direction to staff to prepare for Council consideration an ordinance which would conform aircraft usage to the Airport's design layout. Additionally, staff seeks direction on proceeding with efforts to achieve safety through legislative change and any other available means. 3 Background The Airport's defining physical characteristics are its location on a plateau, and its proximity to homes which surround the Airport on three sides. Immediately to the west of the Airport boundary (the direction in which planes predominantly take off) the plateau drops off about 30 feet. Directly below the runway end is 23`d Street, a busy, but narrow, two-lane arterial road which feeds into the Santa Monica Freeway. Just over 300 feet from the runway end, single family residences line the opposite side of 23rd Street. The runway's west end sits above the roofs of the closest homes. There is no safety area at the western end of the runway. A high performance plane overrunning the runway would likely careen into the neighborhood below. And, the steep topography drastically limits any opportunity for enhancing safety by creating an extension of the runway which might serve as a buffer at the western Airport boundary. At the runway's other end, the Airport is also bounded by another busy arterial -Bundy Drive -which is situated approximately 30 feet below the runway's elevation. Across Bundy Drive from the east end of the runway, there is a dense residential neighborhood with a gas station to the south of those homes. Like the western end, the eastern end of the runway includes no safety area. The risks posed by these physical realities are greatly exacerbated by the shift in Airport usage. A dramatic increase in faster aircraft traffic has occurred during the last two decades. Indeed, use by C and D aircraft has grown exponentially from about 800 4 annual operations in the mid-1980's to over 9000 annual operations in 2006. Since C and D aircraft are faster than the aircraft for which the Airport was designed, they substantially increase the likelihood of a catastrophic runway overrun. As acknowledged by the FAA, and as demonstrated by recent accidents, aircraft overruns are not just a hypothetical problem, but rather a critical safety issue. As stated by the FAA in its guidance on the use of Engineered Materials Arresting Systems (EMAS) for runway safety areas, aircraft overruns do occur, sometimes with devastating results. This admonition has been borne out by recent overruns at Santa Barbara, Burbank, Teterboro and Midway Airports. The accidents at Santa Barbara and Teterboro involved the same type of aircraft that operate at SMO. Because of the increasing use of SMO by C and D aircraft, and the risks this poses, the City Council requested recommendations to improve Airport safety. In response, staff worked with consultants to develop a proposal and also undertook discussions of various safety enhancements with the Federal Aviation Administration. In 2002, the City and its consultant developed an Aircraft Conformance Program, which would implement FAA standards by limiting Airport usage to aircraft which could safely stop within runway safety areas that would be created for A and B aircraft under the Program. The Airport Commission held public hearings on the Plan in 2002 and staff met with FAA representatives to discuss it. However, in October of 2002, before the Plan could even be considered by Council, the FAA challenged the Plan's legality by initiating an administrative complaint against the City. The City filed a written answer in opposition 5 to the FAA's complaint but accepted the FAA's offer to continue discussions on safety enhancements. In December of 2002, the Council received and approved the Plan and directed staff to continue working with the FAA and to evaluate any options for implementing the Plan. Discussion Since Council approved the Conformance Program, City staff has engaged in 5 years of lengthy and exhaustive discussions with FAA staff and officials. Over the course of those discussions, the FAA has recognized that the Airport is uniquely situated in a constrained and highly urbanized environment and has also recognized the shift in Airport usage to faster planes. Nonetheless, the FAA has refused to permit implementation of its own safety standards for aircraft with those higher approach speeds. Throughout the discussions with the City, the FAA has continued to assert that the City's proposed Program for ensuring safety would be unlawful. This assertion is purportedly based on federal law and various documents including the Santa Monica Airport Agreement between the FAA and the City which governs Airport operations until the year 2015. However, the Agreement states that "The Airport will be capable of accommodating most kinds of general aviation aircraft, generally consistent with Group II Design Standards set forth in FAA Advisory Circular 150/5300.46 dated February 24, 1983." Those standards define an airport suitable for the less demanding A and B aircraft, not the C and D aircraft that currently utilize the Airport. Those standards were used in formulating the 1984 Airport Layout Plan, referenced in the 6 1984 Agreement, which established the Airport's current design. Thus, contrary to the FAA's assertions, the 1984 Agreement set forth a plan to accommodate and serve aircraft in the A and B category, not in the C and D category. The FAA's disregard for the true parameters established by the 1984 Agreement has yielded the current situation in which operationally demanding aircraft -which FAA insists must be accommodated at the Airport -- have almost no safety margin for landing or departing from the runway. The City's options for addressing this situation include adopting local legislation and working to secure federal legislation that would enhance safety. As to local legislation, the City's options are limited because federal law does not permit the City to make physical changes to the Airport without FAA approval. However, the City does have proprietary power to make and enforce reasonable safety standards to protect the safety of residents and airport users. Therefore staff requests authorization to return to Council with an ordinance conforming Airport usage to Airport facilities, at least pending a legislative solution or other resolution ensuring Airport safety. As to federal legislation, Council members noted at the August 28th meeting that federal legislation could clarify the obligation to implement the federal runway safety standards at general aviation airports such as Santa Monica. 7 Following the August 28, 2007 meeting, Representative Henry Waxman and his staff began the process of seeking legislative options to assist the City. In a colloquy in the House of Representatives on September 20, 2007, Representative Waxman, House Transportation and Infrastructure Committee Chairman James Oberstar and Ranking Member John Mica all agreed to bring the parties together to find a solution to the safety concerns raised by the City. Representative Waxman has indicated his intention to seek a solution "that is consistent with FAA design guidelines for the Santa Monica Airport and adequately addresses the safety needs for all aircraft categories that use the airport." (Congressional Record, September 20, 2007, H10640). In anticipation of this meeting, staff seeks direction concerning its participation in the process and the goal for the City either through legislation or settlement with the FAA. Consistent with past City Council decisions and Congressman Waxman's stated intentions, staff recommends authorization to work with federal representatives on legislation that would permit the implementation of safety options for all categories of aircraft. Irr particular the safety options should include safety enhancements designed to capture any aircraft using the Airport. In summary, staff requests authorization to return to the City Council with an ordinance limiting use of the Airport to aircraft that operate safely within the capacity of the Airport's facilities and consistent with the standards for an ARC B-II airport; to seek runway safety enhancements that address all categories of aircraft through the authorization of safety enhancements that result in stopping any aircraft overrunning the end of the runway without loss of life or property damage; and to explore legislative 8 options to address the safe operation of aircraft using the Santa Monica Municipal ', Airport. Budget/Financial Impact There are no current financial costs. Staff will return with an estimate of costs when the City Council formally approves the implementing steps for the runway safety enhancements at the Santa Monica Municipal Airport. Prepared by: Robert D. Trimborn, Acting Airport Director Approved: Forwarded to Council: Robert D~Trimborn Acting Airport Director 9 Additional attachments available for review at City Clerk's Office.