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
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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.
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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.
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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
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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
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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
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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.
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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
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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
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