SR 08-14-2018 3K
City Council
Report
City Council Meeting: August 14, 2018
Agenda Item: 3.K
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To: Mayor and City Council
From: Susan Cline, Director, Public Works, Airport
Subject: Minimum Standards for Commercial Aeronautical Services
Recommended Action
Staff recommends that the City Council:
1. Approve the attached Minimum Standards for Commercial Aeronautical Services
(Minimum Standards) that must be met by any person or entity that provides or
seeks to provide commercial aeronautical services, as an addendum to the
existing Santa Monica Airport Leasing and Licensing Policy for the leasehold and
license management of properties at the Santa Monica Airport (Airport or SMO).
2. Extend and clarify the City Manager’s lease-approval authority to lease terms
complying with the Leasing Policy and the Minimum Standards with terms of five
years or less for non-aviation tenants and three years or less for commercial
aeronautical service providers, so long as the leases have an expiration date on
or before December 31, 2028.
Summary
The City of Santa Monica manages 528 direct leasable spaces located at the Santa
Monica Airport. Management of these properties is guided by the Council-approved
Santa Monica Airport Leasing and Licensing Policy (the “Leasing Policy”) (Attachment
A). Staff recommends minor modifications to the Leasing Policy to ensure consistency
with the Consent Decree (Attachment B) and adoption of the Minimum Standards
(Attachment C) as an addendum to the existing Leasing Policy. The proposed Minimum
Standards are based on industry best practices from general aviation airports across
the nation. The City’s adoption and uniform enforcement of the proposed Minimum
Standards would ensure best practices are observed by aeronautical lessees while
complying with its obligations under the Consent Decree without impacting its rights as
the Airport operator.
Discussion
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Since August 8, 2017, the City Manager’s authority to execute leases at the Airport has
been limited to leases complying with the Leasing Policy with expiration dates on or
before December 31, 2022 (Attachment D). Staff recommends extending and clarifying
the City Manager’s lease-approval authority to leases complying with the Leasing Policy
and the Minimum Standards with terms of five years or less for non-aviation tenants and
three years or less for commercial aeronautical service providers, so long as the leases
have an expiration date on or before December 31, 2028. Anything beyond the five-year
term or outside the parameters established by the Leasing Policy and Minimum
Standards would require Council approval. The increased authority for lease approval
would provide greater flexibility to comply with the Consent Decree’s requirements
regarding use of Airport property and obtain leases that would support the City’s goal of
Airport financial self-sufficiency while the Airport continues to operate through
December 31, 2028. Of the 528 leases at the Airport, 400 are for aviation uses while
128 are for non-aviation uses.
The proposed Minimum Standards would assist in ensuring that aeronautical service
providers comply with applicable regulations and requirements while also demonstrating
the City’s compliance with the standards of certain grant assurances that remain in
place as a result of the Consent Decree. As a condition of receiving federal grants, the
Federal Aviation Administration (FAA) requires airport owners to comply with a number
of grant assurances. While the City no longer receives federal grants in connection with
airport operations, under the terms of the Consent Decree that governs airport
operations through December 31, 2028, the City remains bound to comply with the
standards of certain specified grant assurances, including grant assurances 22
pertaining to economic nondiscrimination and 23 pertaining to exclusive rights.
Accordingly, the City must continue to make the Airport available to aeronautical users
on fair and reasonable terms without unjust economic discrimination and may not grant
any aeronautical users an exclusive right to operate at the Airport.
In connection with grant assurances that continue to apply to the Airport under the
Consent Decree, the FAA has encouraged airport owners, such as the City, to adopt
Minimum Standards to establish specific industry benchmarks for various types of
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commercial aeronautical services. Many general aviation airports in the United States
have adopted such Minimum Standards, which generally set forth policy goals,
objectives, and practices for leasing to commercial aeronautical service providers on
airport properties. The main objective of such Minimum Standards is to ensure that
each aeronautical service provider is reasonably fit and willing and able to perform the
services it seeks to provide. This would promote good service and fair competition and
discourage unqualified applicants.
The Minimum Standards would establish uniform baseline requirements that must be
met by providers of commercial aeronautical services at the Airport. They would not
apply to non-aviation tenants of the Airport or to aviation tenants that use hangars and
aircraft parking spaces for personal use. The Minimum Standards would not create any
rights to operate at the Airport that do not already exist under the Consent Decree and
would not detract from the City’s rights under the Consent Decree, which include the
City’s right to close the Airport on or after January 1, 2029.
The proposed Minimum Standards are based on best practices from general aviation
airports from across the nation. Staff engaged Anderson & Kreiger LLP, a law firm
specializing in federal aviation law, to conduct research on best practices nationwide to
help prepare appropriate and reasonable minimum standards for the City of Santa
Monica. Each of the proposed Minimum Standards is consistent with industry best
practices across the United States.
The proposed Minimum Standards cover a wide range of commercial aeronautical
services conducted at Santa Monica Airport. The Minimum Standards include general
information, application procedures, general operator requirements, and detailed
specialized requirements specific to certain classes of commercial aeronautical service
operators. The Minimum Standards would require all commercial aeronautical service
providers to meet specified insurance and security requirements, pay market rates for
their leases, pay additional fees as established by the City, maintain appropriate
equipment and personnel (permitting subcontracting only with approval from the Airport
Director), meet specified insurance and security requirements, and comply with
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applicable federal, state, and local laws, including noise restricting, environmental, and
anti-discrimination laws and regulations.
Community Outreach
Staff conducted significant outreach prior to bringing this recommendation to Council.
This outreach, summarized below, involved notifying stakeholders that have an interest
in these Minimum Standards, gathering and responding to stakeholder comments, and
obtaining feedback from the Airport Commission.
January 11, 2018 – notices for review and comment sent to 247 recipients
including Airport tenants, aviation groups, representatives of the FAA, and Airport
Commissioners. Notice posted on Airport website.
January 24, 2018 – meeting with all Airport tenants and aviation stakeholder
groups to answer questions about the draft document.
February 6, 2018 – draft Minimum Standards sent for review and comment to
those on the City’s Airport community distribution list, including staff from local,
state and federal elective offices. Recipients were asked to forward the draft
Minimum Standards to their respective airport interest groups and provide written
comments by March 9, 2018.
February 12-23, 2018 – six in-person meetings with members of the Airport
Commission, Friends of Sunset Park, Airport 2 Park, Venice Neighborhood
Council, and Concerned Residents Against Airport Pollution.
March 9, 2018 – 34 comments were received in writing from members of the
community. The majority of the comments relating to areas within the scope of
the Minimum Standards fell under the following areas of concern: insurance
requirements, auditing provisions, environmental requirements, Airport Director’s
waiver authority, security, hours of operation for commercial aeronautical service
providers, and personnel requirements.
June 5, 2018 – staff presented the revised proposed Minimum Standards
including the results of the community and stakeholder outreach to the Airport
Commission for review. The presentation to the Airport Commission included a
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document titled “Responses to Comments – First Comment Period,” which
summarized the relevant public comments received, responded to those
comments, and included a redline of the revised proposed Minimum Standards
showing the changes made from the original draft in response to the public
comments (Attachment E). Based on additional comments received from
stakeholders, including insufficient time to review, the Commission
recommended extending the comment period for an additional two weeks.
June 21, 2018 – deadline for second round of public comment. An additional 49
comments were received during the second phase of the comment period. Staff,
in consultation with the City’s outside counsel, Anderson & Krieger, reviewed all
comments and prepared a document titled “Responses to Comments – Second
Comment Period,” which catalogues all of the comments received, summarizes
and responds to those comments, includes a redline of the revised proposed
Minimum Standards showing changes from the draft presented to the Airport
Commission on June 5, 2018, and includes a redline of the Leasing Policy
showing proposed changes in response to the public comments. (Attachment F)
Based on feedback from the Airport Commission and additional comments received
from stakeholders and community members during the second phase of the comment
period, staff revised the five areas of concern listed in the proposed Minimum Standards
as follows (Attachment E):
1. Insurance Requirements
Staff reviewed and evaluated comments regarding proposed insurance requirements, in
conjunction with the City’s Risk Manager. To develop the recommended insurance
requirements for Commercial Aeronautical Service Operators at the Santa Monica
Airport, the Risk Manager worked closely with the Airport Director to identify the risks
associated with each service contemplated in the Minimum Standards. The Risk
Manager then contacted the City’s Airport insurance brokers to discuss appropriate
insurance lines (e.g., general liability, aircraft liability, pollution liability, etc.) and limits,
and review insurance requirements from other airports of similar size and aeronautical
service makeup. During these discussions, the Airport insurance brokers confirmed
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there are no fixed “industry standards” for aeronautical services insurance requirements
and that there are constraints to the insurance limits that small business owners
providing aircraft-related services can obtain. As a result, it was incumbent on the City
to ensure the Airport risk assessment was thorough and complete, and the insurance
requirements presented in the Minimum Standards document adequately protect the
City and the community it serves while not unduly burdening business owners. It is the
Risk Manager’s position that this has been achieved. Significantly, after reviewing the
second set of public comments, the Airport Director and the Risk Manager determined
that additional risks had been identified, and, after further review of other general
aviation airports’ insurance requirements and further discussion with insurance brokers,
the Risk Manager recommended increases to the Commercial General Liability and
Pollution insurance requirements for certain aeronautical service providers.
2. Airport Directors’ Waiver Authority
After review of public comments, the Minimum Standards were modified both to place
stricter limits on the Airport Director’s waiver authority and to impose procedural
requirements intended to ensure transparency of the waiver process. In particular, the
Minimum Standards were revised to make clear that certain requirements would not be
subject to waiver by the Airport Director, including insurance, airport security,
nondiscrimination, and legal compliance requirements. In addition, the Minimum
Standards were revised to make clear that any waiver by the Airport Director must be
justified by clear circumstances rendering the waiver in the City’s best interest, must be
presented to the Airport Commission and approved by the City Manager (or in certain
limited circumstances the City Council), and must be recorded in a publicly available log
that provides the basis for the waiver, the date of its presentation to the Airport
Commission, and the date of its final approval or denial.
3. Noise Restrictions
The Minimum Standards would not alter the pre-1990 noise restrictions currently set out
in the Municipal Code, which are grandfathered and cannot be changed without
compliance with the Airport Noise and Capacity Act of 1990 (ANCA). The Minimum
Standards would require compliance with these noise restrictions. In response to public
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comments, the Minimum Standards were revised to make clear that the Airport Director
may not waive compliance with these noise restrictions and would require certain
Operators to provide pilots with information on the Airport’s Fly Neighborly Program,
which suggests operational methods to decrease noise levels over residential
neighborhoods.
4. Hours of Operation
The Minimum Standards would not alter the Airport’s hours of operation, which are set
by the Municipal Code. In response to public comments, the Minimum Standards were
modified so that they would not require Operators to provide services during later
evening hours, which might be viewed as encouraging operations during these hours.
5. Audit Requirements
In response to public comments, the Minimum Standards were revised to require
Aircraft Charter, Air Taxi Operators and Air Transportation Arrangers, for each flight
providing commercial air transportation, to provide the Airport Director, on request made
within 180 days, a report stating the type of aircraft, the number of passenger seats, and
the number of passengers actually carried. This information would provide the Airport
Director with information necessary to ensure that aircraft operations do not go beyond
the scope of those permitted by Operators’ lease or license agreements and to assist in
enforcement of the Airport’s noise restrictions. Staff declined to impose additional audit
requirements that would require the provision of information not typically required or
needed at general aviation airports.
Airport Commission
On July 23, 2018, staff presented the additionally revised proposed Minimum Standards
reflecting the second round of public comments to the Airport Commission. The Airport
Commission recommended that City Council adopt the revised minimum standards with
consideration of three additional areas:
Provide more specific safety information to pilots rather than just the Fly
Neighborly program;
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Consider higher insurance levels for limited liability companies; and
Flag air transportation arrangers as an issue to be considered moving forward.
Past Council Actions
Meeting Date Description
08/08/17 (Attachment D) Council-approved Leasing Policy
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of the
recommended actions. While there is no reliable way to project the possible impacts of
the adoption of the Minimum Standards, the proposed standards would allow all
commercial aeronautical service providers to compete at the Airport on a level playing
field.
Prepared By: Stelios Makrides, Airport Manager
Approved
Forwarded to Council
Attachments:
A. AIRPORT LEASING AND LICENSING POLICY
B. Consent Decree
C. Minimum Standards for Commercial Aeronautical Service Providers
D. August 8, 2017 Staff Report
E. Responses to Public Comments-First Comment Period
F. Responses to Public Comments-Second Comment Period
G. Written Comments
SANTA MONICA CITY COUNCIL AIRPORT LEASING AND LICENSING POLICY
Purpose. The purpose of this Airport Leasing and Licensing policy is to establish
and declare City policy on matters related to airport leasing. This Leasing Policy
shall be used by the City Manager to analyze leasing and licensing issues, to
present leasing and licensing recommendations to the City Council, and to
render leasing and licensing decisions under the authority granted by the City
Council.
By adopting the Airport Lease Policy, the City Council seeks, to the extent
consistent with the Consent Decree signed by the City of Santa Monica and
the U.S. Justice Department on behalf of the Federal Aviation
Administration, to have an airport tenant mix that:
Is harmonious with the nearby built environment by protecting the health
and safety of Airport neighbors.
Maintains a sustainable Airport Fund that is independent from the General
Fund and other subsidies.
Comports with any applicable legal requirements and protects the City’s
rights that relate to leases at the Airport.
Continues to provide opportunities for arts, education, and culture,
including, but not limited to, the Artist Space Program administered in
conjunction with Cultural Affairs Division.
Establishes practices and procedures for evaluating potential leasehold
interests, and for lease management and administration.
Fosters uses and practices that are sensitive to the environment and
protect the health of Airport neighbors and users and protect the City from
future environmental damage exposure.
General Provisions. The majority of the Airport revenue is derived from
leases. To help support the Airport’s fiscal self‐sufficiency, all rents, fees, and
charges must reflect fair market value. To achieve the goals of the Leasing
Policy, the policy shall be managed in a manner consistent with the following
standards:
SECTION A: USES
1. Authorized Uses: Authorized uses include: (a) uses required by the Consent
Decree; and (b) low intensity uses that are compatible with surrounding uses,
serve the adjacent community, and are consistent with the City's
environmental goals and policies. Examples of uses in category (b) include,
but are not limited to: parks and open space, arts/cultural, creative space,
professional theaters, museums, artist studios, art galleries, photograph
studios, uses customary or incidental to the production or distribution of
motion pictures, educational facilities, professional and general offices,
public or private schools existing prior to September of 1984, warehouses,
self‐storage/public mini‐warehouses, and restaurants with 500 square feet of
floor area or less.
2. Conditionally permitted uses: Parking and automobile storage lots and
structures. Restaurants with over 500 square feet of floor area. Theaters.
New public or private schools or educational institutions.
3. Prohibited Uses: Prohibited uses include: any use involving the
manufacture, processing, storage, or treatment of products, which by
nature of the operation is likely to be obnoxious or offensive to the
surrounding environment; construction of new general office buildings; any
use not specifically authorized as a permitted or conditionally permitted
use; and high intensity uses that are incompatible with the surrounding
residential uses.
SECTION B: TERMS AND CONDITIONS
1. Term for Hangars. All hangars shall be leased on a month‐to‐month basis.
2. Term for Tie‐Downs. All tie‐downs shall be leased on a month‐to‐
month basis.
3. Term for Aeronautical Service Providers. Consistent with the terms
of the Consent Decree, aeronautical service providers may be offered
up to three‐year lease terms that comport with this Leasing Policy and
the Minimum Standards for Commercial Aeronautical Services at
Santa Monica Municipal Airport (the “Minimum Standards”), so long
as the expiration date of the lease does not extend beyond December
31, 2028.
4. Term for Non‐Aviation Tenants. Lease terms may be month‐to‐month or
longer. However, no lease shall have a term that goes beyond December
31, 2028.
5. Environmental Responsibility. New requests to lease and existing leases
shall be reviewed to assess potential negative effects on the
environment. The City may require environmental studies or testing as
appropriate and necessary, and any needed remediation shall be
performed prior to establishment of new uses. All lessees shall be
responsible for any environmental contamination, resulting from their
prior use, as a condition to a renewed or extended lease. Environmental
clean‐up will be required as a condition of any renewal or extension. At
the time of the application, an assessment of the proposed use will be
conducted, and appropriate insurance and/or remediation requirements
will be incorporated into the lease based on proposed usage.
6. Rates. All new and renewed leases will be leased at prevailing market
rates and rates will be adjusted to stay current with market conditions
and as new/renewed leases arise.
7. Percentage Rent Provision. In addition to a base rent, the City may elect
to require that certain leases include a percentage rent provision, which
can be differentiated by categories of sales. The City shall have the right
to audit tenant's financial records to ascertain that the gross sales figures
reported by the tenant are accurate.
8. Existing Tenants. All existing airport tenants will be given the opportunity
to submit a lease application to the City. The City is under no obligation
to offer lease agreements. Submitting an application to the City does not
obligate the City to enter into lease negotiations, offer a lease
agreement, or execute a lease agreement. The decision to execute a
lease agreement will be made solely within the City’s discretion as
landlord and property owner.
9. Whole Building Leases. Whole building leases may, at the City’s
discretion, be subject to public Requests for Proposals intended to
optimize leasehold occupancy and the self‐sustainability of the airport.
Tenants under a whole building lease shall be responsible for
maintenance and repair of said buildings.
10. Transfer of Interest. Space sharing is prohibited without the written
consent of the City, and granting or withholding consent will be
conditioned on express standards and conditions set forth in the lease.
11. Lease and License Areas. Operation and improvements to lease and
license areas are subject to the City’s standard regulatory rules, review
and approval process.
12. Triple Net Leases. The City may require tenants to pay all property taxes
and assessments (including Possessory Interest Tax), insurance, and
utilities.
13. Commercial Operations Permit (COP). Prospective tenants proposing to
use the Santa Monica Airport to engage in an activity that requires a
business license from the City are required to acquire a commercial
operations permit issued by the City Manager. All COPs will be presented
to the Airport Commission for their recommendation and comment prior
to City Manager’s approval.
14. Master Tenants. Master tenant agreements are to be phased out in an
orderly transition.
15. Sub‐Leasing. New sub‐leasing shall be prohibited. Existing sub‐tenancies
shall be subject to an orderly phase‐out at the sole discretion of the City.
16. Insurance. Airport lease agreements shall minimize the City’s financial
and economic risk, by incorporating reasonable indemnification and
insurance provisions.
17. Daily and Transient Users. Daily and transient uses shall be permitted.
SECTION C: PERFORMANCE STANDARDS
1. Compatible and Harmonious. All lessees shall use the airport and any airport
property in a manner that is compatible with City policies and with the
adjacent residential uses; to encourage activities that complement adjacent
residential and commercial uses; to establish practices that are sensitive to
the environment and protect the City from future environmental exposure;
and for aeronautical service providers, comply with the Minimum Standards.
2. All City‐owned buildings appropriate and suitable for leasing may be subject
to a public procurement and solicitation process to identify prospective
tenants and licensees whose financial and professional experience, and
products and/or services are consistent with the Leasing Standards set forth
herein.
3. All prospective tenants must submit a Lease or License Application to the
City. Information contained in the Lease Application shall describe the
proposed use for the available space; provide information about the
respondent; provide references; describe in detail the financial capability of
the respondent to perform; and set forth preliminary terms and conditions.
4. Hangars
a. Hangars that have a land lease agreement with the City will be on a
month‐to‐month tenancy under a City approved lease agreement
which will be updated as deemed necessary by the City.
5. Recruitment for artist day studios will adhere to the criteria set forth by the
Cultural Affairs Division of Community and Cultural Services Department.
Candidate tenants for available Artist Day Studio space are required to file
Program applications for screening purposes, and qualifying artists are
selected only from the screened waiting list.
SECTION D: MAINTENANCE AND TENANT IMPROVEMENTS
1. All leaseholders shall be responsible for maintaining their facilities in
attractive and safe condition, in compliance with applicable building and life
safety codes and all applicable environmental laws, ordinances, regulations
and other city standards.
2. Facilities will be inspected prior to new or extended leasehold occupancy and
refurbished, by the City or tenant (at the City’s election), to a decent, safe
and sanitary condition appropriate for use. If tenant makes improvements to
the facility as a mutually agreed upon condition of a lease, the City must first
review and approve the proposed design and scope of work. All necessary
building permits must be obtained and the work must be inspected for
compliance with applicable code(s). Appropriate rental credits for the
approved work performed may be negotiated as part of the lease. Any
Tenant Improvement Credit that exceeds two months’ worth of tenant
monthly rent must be approved by the Airport Director.
3. Each tenant or licensee will be responsible for interior maintenance and
repair at its sole expense, and the City generally will retain responsibility for
maintenance and repair of roofs, building exteriors, landscaping and common
use parking for all Airport‐managed leaseholds unless otherwise specified in
the lease or license. Tenants who lease whole buildings from the City will be
responsible for any and all maintenance, repair and improvements including
roofs, building equipment and exteriors of the facilities as well as interior
maintenance and repairs.
4. Tenants shall respond to the City’s written inquiries regarding any complaints
or issues. Tenant will provide an action plan for improvement if so requested
by the City.
5. As applicable, the above requirements may be incorporated in leases,
licenses and other agreements. In addition, the City may add to any Lease or
License further or different or additional operational and performance
standards as the City concludes are appropriate to the particular Tenant’s
operation.
6. Upon confirmation that the proposed tenancy is consistent with this Leasing
Policy, a lease agreement will be prepared for review by the City Attorney
and execution by the prospective tenant before being referred to the City
Manager for approval. Leases for terms greater than terms specified in these
guidelines require City Council approval.
SECTION E: LEASE APPROVALS AND DELEGATION OF AUTHORITY
1. The City Manager has the authority to negotiate and execute month‐to‐
month leases, leases with aeronautical service providers, and leases that
expire prior to or on December 31, 2028, provided the City Manager finds the
proposed use is consistent with this Leasing Policy, the Minimum Standards,
and the Consent Decree. To be valid, such leases must be on the basis of
written agreements prepared and approved as to form by the City Attorney.
Leases for terms of occupancy of more than five years or with an expiration
date beyond December 31, 2028, or otherwise outside the parameters
established by this Policy, will require City Council approval.
2. The City may cooperate with commercial real estate brokers who are
authorized to negotiate leases on behalf of prospective tenants.
SECTION F: GENERAL PROVISIONS
This Leasing Policy may be altered by the City at any time, in its sole discretion, and
shall not create any right or reliance interest for any person.
Minimum Standards
For
Commercial Aeronautical Services
At
SANTA MONICA MUNICIPAL AIRPORT
Table of Contents
SECTION 1 GENERAL INFORMATION ............................................................................................... 1
SECTION 2 APPLICATION PROCEDURES ........................................................................................ 5
SECTION 3 GENERAL REQUIREMENTS ........................................................................................... 8
SECTION 4 FIXED BASE OPERATOR ............................................................................................... 13
SECTION 5 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
CHARTER AND AIR TAXI.............................................................................................. 19
SECTION 6 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: FLIGHT TRAINING
................................................................................................................................................. 21
SECTION 7 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
MAINTENANCE AND REPAIR STATIONS ............................................................. 23
SECTION 8 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: SELF‐SERVICE
FUEL PUMPS ...................................................................................................................... 25
SECTION 9 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
MANAGEMENT SERVICES ........................................................................................... 27
SECTION 10 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
SALES OPERATOR ........................................................................................................... 30
SECTION 11 SPECIALIZED AERONAUTICAL SERVICE OPERATOR: OTHER
AERONAUTICAL SERVICES ......................................................................................... 31
SECTION 12 SPECIAL RULES FOR A SASO CONDUCTING MULTIPLE AERONAUTICAL
SERVICES ............................................................................................................................ 32
SECTION 13 RECOGNITION AND REGULATION OF SELF‐SERVICE AND SELF‐
FUELING RIGHTS ............................................................................................................. 34
APPENDIX A: DEFINITIONS
APPENDIX B: INSURANCE REQUIREMENTS AND STANDARDS
APPENDIX B-1: MINIMUM INSURANCE REQUIREMENTS MATRIX
APPENDIX C: FLY NEIGHBORLY PROGRAM NOTIFICATIONS
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SECTION 1
GENERAL INFORMATION
PURPOSE
These Minimum Standards supplement the Leasing and Licensing Policy (the “Airport
Leasing Policy”) in place at the Santa Monica Airport (the “Airport”) by setting minimum
standards that must be met by any person or entity that uses or seeks to use the Airport
as a base for any Commercial Aeronautical Activity (an “Operator”). Each Operator
must have a written agreement with the City of Santa Monica (the "City").
The adoption and enforcement of these Minimum Standards is intended to establish
reasonable threshold entry requirements that will ensure that each Operator is
reasonably fit, willing and able to perform the services it seeks to provide at the Airport;
to promote good service and fair competition at the Airport; to prevent unqualified
applicants from operating at the Airport; to prevent irresponsible, unsafe, or inadequate
services; and to make the Airport as financially self-sustaining s possible. The
establishment of these Minimum Standards does not imply any right on the part of any
Operator to provide any services at the Airport.
It is the City’s policy to extend the opportunity to provide aeronautical services to any
person or entity meeting the City's Minimum Standards for such services at the Airport,
subject to availability of suitable space at the Airport (as determined by the City) to
accommodate such activities, and subject to the City’s rights under the Settlement
Agreement/Consent Decree Between The Federal Aviation Administration And The City
Of Santa Monica, approved by the court in City of Santa Monica v. United States of
America, et al., Case No. 13-CV-8046-JFW (C.D. Cal. Jan. 31, 2017) (the “Consent
Decree”). The City’s rights under the Consent Decree include, but are not limited to, its
rights to shorten the runway at the Airport, to exercise its proprietary exclusive right to
provide any or all of the aeronautical services that are the subject of these Minimum
Standards, and to close the Airport on or after January 1, 2029.
These Minimum Standards are subordinate to the Consent Decree. To the extent that
these Minimum Standards may conflict with the provisions of the Consent Decree, the
Consent Decree shall govern.
These Minimum Standards are also subordinate to the City of Santa Monica’s Charter
and Municipal Code, including but not limited to Municipal Code Chapter 10.04, and the
Airport Leasing Policy. To the extent that these Minimum Standards may conflict with
the provisions of the City’s Charter or Municipal Code or the Airport Leasing Policy,
those City instruments shall govern. As a result, among other things, these Minimum
Standards do not alter the Municipal Code requirement that no Operator may use the
Airport as a base for any commercial activity without an operations permit issued by the
City Manager after consideration by the Airport Commission (SMMC 10.04.06.020, .030)
or the Airport Leasing Policy requirement that all leases be approved by the City
Manager, and that certain leases be approved by the City Council.
To the extent (if any) that these Minimum Standards may conflict with the Santa Monica
Airport Operations Handbook, these Minimum Standards control.
Capitalized terms are defined in Appendix “A” to these Minimum Standards.
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APPLICABILITY
All Operators shall, as a condition of conducting Commercial Aeronautical Activities at
the Airport, comply with all applicable requirements concerning such activities as set
forth in these Minimum Standards and any subsequent amendments to these Minimum
Standards. These Minimum Standards shall be deemed to be a part of each Operator’s
written agreement with the City (in whatever form, whether lease, license, permit or
other) except to the extent any particular provisions of these Minimum Standards are
waived or modified, in writing, by an authorized representative of the City. The mere
omission of any particular standard from an Operator’s written agreement with the City
shall not constitute a waiver or modification of such standard in the absence of clear and
convincing evidence that the City intended to waive or modify such standard. The
requirements set forth in these Minimum Standards are minimums, and all Operators are
encouraged to exceed these minimums in conducting their activities.
These Minimum Standards apply to every Operator as of the date of adoption of these
Minimum Standards, and amendments to these Minimum Standards will apply to every
Operator as of the date of their amendment, provided, however, that:
(a) If an Operator has an existing written agreement with the City at the time
these Minimum Standards are adopted or amended, and if compliance
with these Minimum Standards as adopted or amended would create a
conflict with the written agreement, the written agreement shall prevail
until such time as it is amended, updated, renegotiated, renewed, or, with
the City’s approval, assigned, or a new written agreement is negotiated,
at which time Operator will fully comply with these Minimum Standards as
adopted or amended;
(b) If an Operator has an existing written agreement with the City at the time
these Minimum Standards are adopted and that agreement provides for
application of Minimum Standards following their adoption, the Operator
shall have six months from the date of adoption of these Minimum
Standards to comply with these Minimum Standards, with the exception
that any new subleases shall be immediately prohibited and any existing
sub-tenancies at the time of adoption of these Minimum Standards shall
be immediately subject to an orderly phase-out at the discretion of the
City; and
( c) Any Operator engaging in activities covered by these Minimum Standards
without a written agreement with the City, shall have six months from the
date of adoption to comply with these Minimum Standards.
These Minimum Standards shall not be deemed to modify any existing written
agreement with the City under which an Operator is required to exceed these Minimum
Standards nor prohibit the City from entering into and enforcing a written agreement or
amendment thereto that requires an Operator to exceed these Minimum Standards.
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EFFECTIVE DATE
These Minimum Standards shall become effective on _____________, 2018 (the
"Effective Date"). Each and every Operator conducting any Commercial Aeronautical
Activity at the Airport on or after the Effective Date must hold either (a) a current and
valid Lease with the City which specifies that the Operator's Commercial Aeronautical
Activities are a permitted use; (b) a Non-Exclusive License from the City authorizing the
Operator to engage in such Commercial Aeronautical Activities; or (c) if an approved
subcontractor for an Operator, a Commercial Operations Permit authorizing the
subcontractor to engage in or facilitate the Operator’s Commercial Aeronautical Activities
as a subcontractor of the Operator. Any such Lease, Non- Exclusive License, or
Commercial Operations Permit shall be in a form prescribed by the City that specifies
which types of Commercial Aeronautical Activities the Operator (or subcontractor) is
authorized to provide; requires the payment of fees to the City; imposes insurance,
indemnification, and environmental obligations; and requires a security deposit or other
form of contract security.
COMPLIANCE
The Airport Director shall periodically conduct a review of each Operator’s compliance
with the terms of its Lease or Non-Exclusive License and these Minimum Standards. If
the Airport Director, in his or her discretion, determines that there has been substantial
non-compliance, the Airport Director shall notify the Operator of the non-compliance and
take steps, which may include declaring a default of the Operator’s Lease or Non-
Exclusive License, to ensure that the Operator comes into compliance with the terms of
its Lease or Non-Exclusive License and these Minimum Standards.
RIGHT TO AMEND STANDARDS
The City reserves the right to amend these Minimum Standards as the City determines
may be necessary or desirable to meet the needs of the Airport, to improve the quality of
services, to enhance competition or as otherwise deemed to be reasonable by the City.
The City further reserves the right to amend these Minimum Standards to pursue the
City’s rights under the Consent Decree, including the closure of the Airport on or after
January 1, 2029, as described in the Consent Decree.
WAIVERS
The Airport Director may, in his or her discretion, waive any requirement imposed by
these Minimum Standards for the benefit of any governmental entity providing non-profit
services to the aviation industry, performing emergency medical or rescue services to
the public by means of aircraft or performing fire prevention or firefighting operations.
Except as otherwise limited by these Minimum Standards, the Airport Director may also
waive any of the Minimum Standards for non-governmental Operators if the Airport
Director, in his or her discretion, finds clear circumstances demonstrating such a waiver
to be in the best interest of the City. Waivers must be approved by the City Manager
(and City Council if City Council approval is required under the Airport Leasing Policy or
under specific provisions of these Minimum Standards) after consideration by the Airport
Commission. The Airport Director shall maintain a log of all such waivers indicating for
each waiver: the clear circumstances demonstrating the basis for the waiver, the date on
which it was presented for consideration by the Airport Commission, and the date on
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which it was or was not approved by the City Manager (and City Council if City Council
approval was required under the Airport Leasing Policy or under specific provisions of
these Minimum Standards). When any such waiver is being proposed for an Operator,
the Airport Director shall present to the Airport Commission for consideration at one of its
public meetings a public document that attaches the log of prior waivers and identifies
the basis for the proposed waiver.
CATEGORIES OF AERONAUTICAL SERVICE OPERATORS
The following categories of Operators may provide commercial aeronautical services at
the Airport:
1. Fixed Base Operator ("FBO")
2. Specialized Aeronautical Services Operator ("SASO")
a. Aircraft Charter and Air Taxi
b. Flight Training
c. Aircraft Maintenance and Repair Stations
d. Self-Service Fuel Pumps
e. Aircraft Management
f. Air Transportation Arranger
g. Aircraft Sales Operator
h. Other Aeronautical Services
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SECTION 2
APPLICATION PROCEDURES
1. An application to perform commercial aeronautical services at the Airport must
be made in accordance with these Minimum Standards. The application must be
signed by an authorized person and include the name, address, email address
and telephone number of the applicant and the following information:
a. For all applicants - the name, address and telephone number of each
person with a controlling interest in the applicant.
b. For a corporation - the name, address, email address and telephone
number of the corporation’s officers and directors.
c. For a partnership or joint venture - the name, address and telephone
number of each partner or member of the venture.
d. Whether any officer, director, partner or person with a controlling interest
in the applicant is also an officer, director, partner or person holding a
controlling interest in any other commercial aeronautical service Operator
at the Airport.
2. The application, together with all required supporting documentation, shall be
submitted to:
City of Santa Monica, Santa Monica Airport –
Attn: Airport Director
3223 Donald Douglas Loop South
Santa Monica, CA 90405.
3. An applicant shall furnish the following supporting documents as evidence of its
organizational and financial capability to provide the proposed aeronautical
services:
a. Business Plan - a written proposal detailing the nature of the proposed
aeronautical service to be provided, the applicant's space and facility
requirements, and the proposed location on the Airport.
b. Financial Statement - a current financial statement (for a corporation, sole
proprietorship or for all principals of a partnership or joint venture)
prepared in accordance with generally accepted accounting principles by
a certified public accountant.
c. Credit Report - a current credit report (for a corporation or for all principals
of a partnership or joint venture) covering all business activities in which
the applicant has participated within the past ten years. To satisfy this
requirement, an applicant shall furnish to the Airport with its application a
fee that the Airport shall use to perform the required credit report check.
d. Personnel - a list, with resumes, of key personnel to be assigned to the
Airport along with a description of their duties and responsibilities.
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e. Licenses and permits - copies of all licenses, certifications and permits
possessed by the applicant or its key employees to be based at the
Airport that are required to perform the proposed services.
f. Evidence of insurance that meets the applicable requirements as set forth
in Section 3 of these Minimum Standards.
g. Commercial Operations Permit Application.
h. Such other information as the Airport Director may require.
4. The Airport Director shall deny any application to provide aeronautical services at
the Airport if, in his or her discretion, the Airport Director determines that:
a. the applicant does not meet any applicable provisions of these Minimum
Standards;
b. the applicant has supplied the City, or any other person, with false or
misleading information or has failed to make full disclosure in its
application or in its supporting documents;
c. there is no appropriate, adequate or available space on the Airport to
accommodate the applicant at the time of application;
d. the proposed activity would conflict with existing aeronautical uses;
e. the proposed activity would require the City to spend funds or to supply
materials or manpower that the City would, in its discretion, prefer not to
spend or supply;
f. the proposed activity would require existing Operators without their
consent to reduce the amount of Airport property they use to provide
aeronautical services, result in congestion anywhere within the Airport or
interfere with the orderly activities of existing Operators;
g. the proposed service activities would be detrimental to the Airport;
h. the applicant has violated any of these Minimum Standards or any other
regulations of the City, the standards or regulations of any other airport,
or any other statutes, regulations, ordinances, laws or orders applicable
to the Airport or any other airport;
i. the applicant is currently in default, or has been in default in the past, in
the performance of any lease or other agreement with the City or at any
other airport;
j. the applicant's financial statement or credit report contains information
that creates doubt as to the applicant’s abilities to provide the proposed
services;
k. the applicant does not have or cannot demonstrate access to the
operating capital necessary to conduct the proposed operation;
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l. the applicant is unable to obtain sufficient insurance, financial sureties or
guarantors to protect the interests of the City or other appropriate
governmental entities;
m. the applicant has been convicted of any felony or misdemeanor involving
moral turpitude; except that the Airport Director, in his or her discretion,
may disregard such conviction based on consideration of the following
factors: mitigating circumstances that may exist, the nature and gravity of
the offense, the time elapsed, the nature of the aeronautical services to
which the application applies and the relatedness of the conviction to
those services, and any other factors that are related to the application
and consistent with business necessity;
n. the applicant's proposal is not in the best interest of the health, safety,
welfare or convenience of the traveling public or Airport Users;
o. the applicant is unable to qualify for unescorted access to Airport
Operating Areas, if required to provide proposed services;
p. approval of the proposed activity would be inconsistent with the Consent
Decree, the City’s Charter or Municipal Code, or the Airport Leasing
Policy.
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SECTION 3
GENERAL REQUIREMENTS
These Minimum Standards establish certain requirements to be met by every Operator
providing aeronautical services at the Airport. Such Operators must, in addition to
complying with all applicable Minimum Standards, comply with all other applicable laws,
regulations, ordinances, rules, building codes, or other provisions, including contracts,
relating to their operations at the Airport.
In addition to the Minimum Standards applicable to each specific category of commercial
service operation set forth below, every Operator providing aeronautical services at the
Airport must meet the following general requirements.
1. Property/Facilities. Unless exempted from this requirement by the Airport Director
in his or her discretion, each Operator must lease the property or facilities
required for the services it renders directly from the City.
2. Hangars and Other Buildings. If required by these Minimum Standards, the
Operator shall lease hangar space for aircraft storage and shall lease sufficient
building space to support its activities at the Airport.
3. Aircraft Parking Apron. If required by these Minimum Standards, the Operator
shall lease sufficient paved aircraft parking apron space within its leasehold
premises to meet the requirements of its aeronautical activity and shall maintain
any paved taxiways necessary for access to the Airport’s taxiway system.
4. Equipment.
a. The Operator must demonstrate that it owns, leases or otherwise has
sufficient access to all equipment required to provide the applicable
aeronautical services promptly on demand without causing any flight
delays or other operational impacts on aircraft at the Airport. All
equipment must be maintained in good operating condition and good
appearance and must be in compliance with all applicable safety
standards and regulations. All heavy equipment except aircraft must be
clearly designated with the name and logo of the Operator prominently
displayed.
b. Any Operator that is involved with towing aircraft off of its leased
premises and onto other airport property shall own or contract for
appropriate equipment to be used and for appropriate lighting to be used
during tow operations (including strobe lights).
c. All vehicles driven on Airport property must have any permits or required
registrations as required by federal, state or local law. Such vehicles also
must be operated by persons with appropriate licenses or permits and
trained under the Airport’s driver safety training program, should the
Airport require such training.
d. Any Vehicle used for Commercial purposes in the AOA must bear
identification designating the Commercial Aeronautical Operator to whom
the vehicle is assigned. The display of identification shall be in letters in
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sharp contrast to the background and shall be of such size, shape, and
color as to be readily legible during daylight hours from a distance of 50
feet.
5. Personnel and Training.
a. All personnel shall display Santa Monica Airport ID badges at all times on
their person, as required by Airport Rules. Non-Administrative personnel
in the AOA shall wear clothing that displays the identification of the
Operator in letters in sharp contrast to the background which shall be of
such size, shape, and color as to be readily legible during daylight hours
from a distance of 20 feet. Administrative personnel need not wear
uniforms.
b. An adequate number of qualified and, where applicable, licensed
employees shall be on duty at all times of operation to provide services
consistent with these Standards.
c. At least one qualified supervisor shall be on duty when any aeronautical
services are being performed by any Operator. A supervisor may be “on
duty” for purposes of this subsection if the supervisor is available by
phone, but not at the Airport, provided that in such a case an Operator
must provide the Airport Director with a list of phone numbers at which
the Airport can reach supervisors during regularly scheduled shifts.
d. Each Operator shall establish a written job description for each type of
employee to ensure that all employees are thoroughly trained and
qualified to perform the aviation tasks to which they are assigned. The
level of detail required for each job description shall be commensurate
with the technical complexity and safety risks associated with the
employee’s work. At a minimum, each job description shall include a
statement of responsibilities, as well as required skills, degrees, and
certificates. For more technically specialized work or work involving
heavy equipment or significant safety concerns, the description shall also
include what training, experience, and safety precautions are required to
perform the required tasks. Upon request, the Operator shall submit a
copy of its written job descriptions to the Airport Director or designee.
e. All personnel who will operate a vehicle on the AOA must successfully
complete the Airport’s initial training course on driving on the AOA and
any refresher training that may be required by the City.
f. Each Operator shall provide to the Airport Operations/Public Safety
Officer Unit a list of company officials and 24-hour contact information.
This list shall include:
i. the Operator’s local representative with administrative, operational
and fiscal authority over the aircraft/facility involved;
ii. the Operator’s corporate representative with administrative,
operational and fiscal authority over the aircraft/facility involved;
and
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iii. the Operator’s point of contact for emergency/security incidents.
6. Insurance Requirements.
a. All Operators shall comply with the insurance Requirements and
Standards set forth in Appendix “B” to these Minimum Standards, which
may be revised by the City. These include the requirement that all
Operators shall procure prior to commencement of service, and shall
thereafter maintain continuously in effect throughout the term of their
activities at the Airport, at the Operator's sole expense, insurance of the
types and in at least such minimum amounts as are set forth in Appendix
“B-1” to these Minimum Standards, which may be revised by the City.
b. The insurance requirements imposed by this Section may not be waived
by the Airport Director. .
7. Airport Security.
a. All Operators shall comply with all applicable security requirements
adopted for the Airport by the City (including but not limited to any Airport
Security Plan issued by the City), the FAA, or the Transportation Security
Administration, and shall comply with the directives of any law
enforcement officer or other airport personnel implementing these
requirements. The City reserves the right in its discretion at any time to
impose additional security requirements, applicable to all similarly-
situated Operators.
b. Operator shall have a documented security plan consistent with its
Activity or Activities and adequate for the type of operation and services
being provided. The security plan shall be made available to the Airport
Director upon request and shall address at a minimum procedures for the
following:
i. Securing Commercial Aeronautical Operator’s Leasehold to
prevent unauthorized access to the Leasehold and the AOA of the
Airport.
ii. Monitoring and controlling access to the Airside Area of the Airport
through Commercial Operator’s Leasehold.
iii. Providing escort to vendors, customers or other visitors operating
vehicles on the AOA.
iv. Informing Commercial Aeronautical Operator’s employees,
vendors, customers and other visitors of security requirements
and procedures.
c. The Airport Security requirements imposed by this Section may not be
waived by the Airport Director.
8. Subcontracting. A SASO may, but only with written permission from the Airport
Director, subcontract any of the services it is authorized to provide on an item by
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item basis for no more than 180 days, subject to renewal with the permission of
the Airport Director.
9. No Subleasing. Subleasing shall be prohibited. Existing sub-tenancies at the time
of adoption of these Minimum Standards shall be subject to an orderly phase-out
at the discretion of the City.
10. Commercial T-Hangars. Commercial T-hangar rental shall be prohibited. Only
the City may lease and manage T-hangars for storage of general aviation
aircraft.
11. Nondiscrimination. Operator shall not discriminate against any person or class of
persons by reason of race, creed, color, national origin, sex, age, sexual
orientation, gender identity, or physical handicap in providing any products,
services, or facilities or in the use of any of its facilities that are available to the
public, or in any manner prohibited by applicable regulatory measures including
without limitation Part 21 of the Rules and Regulations of the office of the
Secretary of Transportation effectuating Title VI of the Civil Rights Act of 1964, as
amended or reenacted. This non-discrimination requirement may not be waived
by the Airport Manager.
12. Legal Compliance.
a. Americans with Disabilities Act Compliance. Operator shall comply with
the Americans with Disabilities Act, as amended, to the extent required by
law.
b. Environmental Compliance. Operator shall comply with all applicable
federal, state, and local environmental laws and regulations.
c. Noise Restrictions Compliance. Operator shall comply with all applicable
federal, state, and local noise restriction laws and regulations.
d. Airport Leasing Policy, City Charter and Municipal Code. Operator must
comply with all applicable sections of the Municipal Code and the policies
of the City of Santa Monica, including but not limited to, the following:
i. The City’s Airport Leasing Policy;
ii. The City’s Charter and Municipal Code, including but not
limited to: (a) Article XXII of the City of Santa Monica Charter (the
“Oaks Initiative”); and (b) Chapter 10.04 of the Municipal Code.
e. The legal compliance requirements imposed by this Section may not be
waived by the Airport Director.
13. Combination of Space Requirements. In his or her discretion, to reduce the
overall amount of space required, the Airport Director may adjust or combine the
minimum space requirements set forth for each type of aeronautical service if
more than one type of service will be provided by a SASO from the same
premises.
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14. Required Fees and Payments. The fees and payments to be made to the City by
each Operator will be set forth in the Operator's Lease or Non- Exclusive License
and shall be reasonable and not unjustly discriminatory.
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SECTION 4
FIXED BASE OPERATOR
This section sets forth the minimum standards for a Fixed Base Operator at the Airport.
STATEMENT OF CONCEPT
An FBO provides a wide range of aeronautical services to the public. An FBO must
provide all of the following products and services at its premises at the Airport:
1. Storage of aviation fuel and other petroleum products at City’s fuel storage
facilities.
2. Aircraft and engine maintenance and repair services directed towards the
general aviation market.
3. Tie-down services.
4. Shuttle service for passengers of chartered, private and executive aircraft.
5. Arrange car rental, limo services or taxi-cab services for customers.
6. Arrange catering services for customers.
7. Marshaling and parking of aircraft.
8. Maintenance of the Airport’s Registration Log and other statistical data
concerning the FBO’s activities on the Airport.
9. Automotive maintenance for ground support equipment at the Airport.
10. Aviation maintenance and repair service with a licensed airframe and power plant
mechanic at the Airport.
11. Gate service for aircraft such as, but not limited to, passenger ramp service
baggage handling, catering, and interior cleaning of aircraft.
12. Towing service for disabled aircraft. For larger aircraft (over 30,000 lbs.) the
FBO may arrange with other qualified operators to provide this service.
13. Into-plane Fueling.
a. Aviation fuels (including both jet fuel and either AvGas or unleaded
AvGas once unleaded AvGas is commercially available and approved for
use) and lubricating oils shall be stored and dispensed by an FBO in
accordance with all local, state and federal laws, regulations, rules and
other requirements, as same may be amended, regarding the sale and
storage of such fuels and oils, including without limitation any rules,
regulations or minimum standards that are established by the City.
b. Prior to commencement of the operations of dispensing and selling fuels,
an FBO shall submit to the City, for review and comment, the FBO’s Spill
Prevention Control and Countermeasure Plan and Pollution Incident and
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Prevention Plan and any permit requirements necessary by local, county
and State agencies.
14. Other Services. An FBO may provide other specialized aeronautical services on
its leasehold subject to the approval of the City, through the Airport Director,
including the sale or rental of all types of consumer products normally related to
the ownership or operation of aircraft; and any other services normally performed
by similar FBOs at other airports in the United States. These requests will be
reviewed and approved on a case-by-case basis.
15. Subcontracting. An FBO shall not subcontract any fueling services or other
services that it is authorized or required to provide without the prior written
approval of the Airport Director. Subcontracting of services shall not relieve FBO
of any of its obligations or liabilities under these Minimum Standards or its Lease
or operating agreement with the City.
16. Prohibited Activities. Each FBO is expressly prohibited from engaging in any of
the following activities:
a. Provision of terminal facilities for passenger operations, other than those
covered by Federal Aviation Regulations 14 CFR Parts 91 and 135.
b. Sale of non-aviation products, except for paraphernalia associated with
the Operator’s business (i.e., t-shirts, hats, etc.) and food and beverage
amenities (i.e. vending machine snacks, sodas, etc., but not alcoholic
beverages).
c. Air shows or meets.
d. Film shoots, or displays or other public gatherings, without the express
written approval of the Airport Director.
e. Any service prohibited by law or not related to aviation.
f. Advertising of any kind unrelated to services FBO is permitted to provide
at the Airport.
g. Storage of Hazardous Materials, liquid industrial waste or any other
regulated waste that does not fully comply with all applicable
environmental laws.
h. Constructing or operating a fuel farm without the express written approval
of the Airport Director.
i. Heavy maintenance on an aircraft on a parking apron or any other area
not designated or leased for aircraft maintenance without the express
written approval of the Airport Director. This does not apply to routine line
maintenance of aircraft.
j. Parking, storing, or allowing the parking or storage of any vehicles on the
Operator’s premises that are not used in the daily operation of the general
aviation business permitted to be conducted on the premises, unless
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such vehicles are owned and operated by the Operator’s customers or
employees.
MINIMUM STANDARDS
1. Experience. An Operator proposing to operate as an FBO shall have a minimum
of 5 years’ experience as an FBO (including the fueling of aircraft). The Airport
Director may not exercise his or her discretion to waive this requirement unless
the Airport Director is satisfied, after reviewing documentation from an applicant
the Airport Director deems to be sufficient, that the proposed FBO Operator’s
management personnel have sufficient knowledge and experience to safely and
efficiently conduct FBO operations at the Airport.
2. Land. Each FBO must lease enough land to provide adequate space for
buildings, paved private auto parking, paved aircraft parking, paved pedestrian
walkways, fuel storage facilities, and all storage, servicing utilities and support
facilities as may be mutually agreed upon in writing by the City and FBO. The
minimum area required will not be less than 144,000 square feet.
3. Hangars and Other Buildings. Each FBO must lease facilities to provide at least
6,000 square feet of lounge (for crew and passengers), offices, flight planning
facilities, pilot waiting areas, and public restrooms.
4. Aircraft Parking. Each FBO must provide paved aircraft parking of a minimum of
30,000 square feet that can accommodate the largest aircraft to be handled or
serviced by the FBO.
5. Automobile Parking. Each FBO must lease a minimum of 20 paved private
automobile parking spaces excluding employee parking.
6. Fuel Storage Facilities. Depending on the location and nature of the proposed
FBO business, with the advance approval of the Airport Director in writing, which
approval may be issued by the Airport Director only after authorization by the City
Council, the FBO may be permitted to establish and operate its own fuel farm. If
a request by the FBO to establish and operate its own fuel farm is approved by
the Airport Director, the following requirements will apply:
a. The FBO shall lease sufficient land for installation of above-ground fuel
storage tanks to be constructed and operated on the FBO’s leased
premises in compliance with all applicable environmental requirements.
b. Total storage capacity shall consist of at least one (1) 10,000 gallon
storage tanks for jet fuel and one (1) 2,500 gallon storage tank for
aviation gasoline to assure adequate supplies of fuel at all times.
c. The fuel storage system must include adequate fuel spill prevention
features and containment capabilities, together with an approved fuel spill
containment and countermeasures control plan, and shall be improved
and upgraded as necessary to meet all current EPA, State, and City of
Santa Monica requirements for spill prevention, containment and
mitigation as they may be revised.
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d. The FBO shall be required to undertake at its own expense any
environmental testing of its fuel facilities which the City may reasonably
request, on or off the Airport, and to take any remedial actions determined
to be necessary or appropriate as a result of such testing.
e. The right is reserved to the City to disapprove installation of a new FBO
fuel farm if the City determines, in its discretion, that the proposed FBO
fuel farm would have an adverse effect on safety or otherwise not be in
the interest of a safe and efficient airport operation.
7. Mobile Dispensing Equipment.
a. Each FBO shall provide at least three (3) metered filter-equipped mobile
dispensing trucks for dispensing jet fuel, AvGas, and unleaded AvGas
(once commercially available and approved for use), with separate
dispensing pumps and meters required for each type of fuel.
b. At least two (2) of the mobile dispensing trucks must be used for jet fuel
with each having a minimum capacity of at least 3,000 gallons.
c. The remaining mobile dispensing truck shall provide Unleaded AvGas
with a capacity of at least 750 gallons. Until such time as unleaded AvGas
is commercially available and approved for use, standard AvGas may be
used.
d. All dispensers must have bottom-refilling capabilities and turbine fuel
dispensers must have single point refueling capabilities.
e. All dispensers shall meet all applicable safety requirements, with reliable
metering devices subject to independent inspection.
f. All equipment shall be maintained and operated in accordance with
Federal, State, City and industry requirements, including ATA 103, NFPA
407, OSHA guidelines, and Municipal Code 10.04.06.120.
8. Aircraft Service Equipment. Each FBO shall procure and maintain tools, jacks,
tugs, towing equipment, tire repairing equipment, ground power units, portable
compressed air tanks, oxygen cart and supplies, fire extinguishers, air stairs,
chocks, ropes, tie-down supplies, crew and passenger courtesy transportation
vehicles, and any other equipment appropriate and necessary for the servicing
of all aircraft types normally expected to use the FBO facilities.
9. Hours of Operation. Each FBO shall provide aircraft fueling and line services
during the hours of 7 a.m. to 9 p.m. Monday thru Friday and from 8 a.m. to 9 p.m.
on Saturdays and Sundays.
10. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards:
a. Full-Time Manager: All activities of the FBO shall be conducted under the
guidance and supervision of a full-time FBO Manager who must have
demonstrated experience in FBO supervision and operations and must be
approved in advance by the Airport Director, which approval the Airport
Page | 17
Director retains discretion to deny. The FBO Manager must be vested
with full power and authority to direct and conduct the FBO operation.
The FBO Manager shall be assigned to the Airport and shall be available
during normal business hours.
b. Line Service: At least two (2) fully trained and qualified fuel service
personnel shall be on duty at all times while the facility is open for
business. And adequate staff shall be on duty to ensure that aircraft are
able to be marshalled onto FBO’s leased area expeditiously without
interfering with Airport operation in the AOA. One must be a responsible
supervisor trained in accordance with 14 CFR §§ 139.321(b)(6) and
(e)(1).
c. Maintenance: At least one (1) FAA-certificated aircraft mechanic shall
promptly be available upon request. The FBO can meet this requirement
with mechanics employed by the FBO, or by contracting with an on-call
Specialized Aeronautical Service Operator authorized to conduct Aircraft
Maintenance at the Airport, provided that the Airport Director approves
such contract.
d. All personnel shall be suitably uniformed.
e. There shall be at least one person on duty during the hours of 7 a.m. to 9
p.m. Monday thru Friday and from 8 a.m. to 9 p.m. on Saturdays and
Sundays to act as supervisor, customer service representative, ramp
attendant, and dispatcher for General Aviation activity, unless otherwise
agreed in writing by the City. If an FBO deplanes passengers outside of
the hours provided in this subsection, then the FBO shall staff sufficient
personnel to perform necessary functions for those passengers and for
safe operation of the aircraft.
f. All fuel service personnel shall have successfully completed an approved
line technician safety course. A National Air Transportation Association
(NATA) course or equivalent is acceptable.
g. Supervisors and all other personnel dispensing fuel must have received
initial and required recurrent training in accordance with 14 CFR §
139.321. Training records for all personnel providing fueling services
must be maintained on file at the Airport and be available for inspection
by the City.
11. Insurance Requirements. Each FBO shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with the City.
12. Airport Security. Each FBO shall comply with all security requirements specified
by Section 3 or otherwise applicable as a matter of law.
13. Required Fees and Payments.
Lease: The FBO shall enter into a lease agreement providing for the payment of
rent for leased space and facilities.
Page | 18
Fuel Flowage: In addition to the rent to be paid under its lease with the City, the
FBO shall pay the City any fuel flowage fees or other fees that are specified in its
lease.
14. Fly Neighborly Program. The FBO shall maintain on its premises copies of, and
shall provide to each pilot using the FBO, a Pilot’s Guide for the type of aircraft
being flown by that pilot (fixed wing, jet, or helicopter), in the form attached as
Appendix C or such similar form as may be provided by the Airport Director.
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SECTION 5
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT CHARTER AND AIR TAXI
STATEMENT OF CONCEPT
An Aircraft Charter or Air Taxi Operator is a person, firm or corporation engaged in the
business of providing commercial air transportation (persons or property) to the general
public for hire under FAR Part 135 and using the Airport as a base for engaging in this
business.
MINIMUM STANDARDS
1. Facilities.
a. If providing facilities for customer use at the Airport through an FBO
operating at the Airport, the Operator shall provide the Airport Director
with documentation confirming the FBO’s agreement to provide such
facilities and establishing that the FBO has complied with all the terms of
its Iease with the City and all applicable provisions of these Minimum
Standards, and, upon a determination by the Airport Director that these
requirements have been satisfied, shall enter into a Non-Exclusive
License with the City for provision of services.
b. Otherwise, the Operator shall lease from the City an area of sufficient
size, shape, and location as mutually agreed upon to provide at least
1,000 square feet of floor space for office, restrooms, and customer
lounge for customer use. All office/lounge space shall be properly heated
and lighted. The Operator shall provide sufficient automobile parking
space to accommodate employees and customers parking with no on-
street parking. Paved walkways with all points of access conforming to
the criteria specified in the Americans with Disabilities Act (ADA) as
required by the act will be provided by the Operator. Adequate hard
surfaced aircraft ramp must be provided within the leased area, sufficient
to accommodate the Operator’s activities, operations, and adequate tie-
down facilities. If the Operator utilizes existing facilities, which may not
meet the minimum sizes outlined in this section, the minimum square
footage requirements may be determined by the availability of facilities
and through written agreement with the City.
2. Aircraft. The Operator shall provide for charter one or more aircraft, which may
be single- or multi-engine, or helicopters. All aircraft must be either owned by or
under written lease to Operator. All aircraft must meet the requirements of the
FAA and the FAR Part 135 certificate held by the Operator.
3. FAA Approvals. The Operator shall have and provide copies to the City of all
appropriate certifications, approvals and FAA issued operating certificates. Any
time certifications or approvals are modified, the updated documentation
reflecting the changes shall be provided to the City within three calendar days.
Only air charter and air taxi activities authorized by the FAA and appropriate City
approvals may be conducted at the Airport under this section, and all such
activities must be conducted in accordance with all applicable FAA regulations,
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including any such regulations limiting the permissible weight of aircraft loads
based on factors such as runway length, weather, and aircraft operating
specifications.
4. Reports. For each flight providing commercial air transportation to persons, the
Operator shall provide the Airport Director, upon request made by the Airport
Director within 180 days after the flight, with a written report stating the type of
aircraft, number of passenger seats, and number of passengers actually carried.
5. Employees. If certified to engage in on-demand common carriage for persons or
property, the Operator shall employ the number of employees required by 14
CFR Part 135.
6. Mitigation Measures. As described in the Municipal Code, § 10.04.06.030(d),
applications for air carrier service at the Airport “shall identify and assess the
effects of the service on community aircraft noise exposure, automobile traffic,
and other significant environmental impacts and propose appropriate mitigation
measures. Environmental assessment shall be in accordance with State and City
laws and procedures.” As used in the Code, “air carrier” service includes
commuter service, air charter and air taxi operations, freight, cargo, express, and
mail service, indirect air carriers and other commercial flight operations
certificated by the Federal Aviation Administration.
7. Hours of Operation. If leasing premises to provide customer services pursuant to
Section 5.1(b) above, the Operator shall have its premises open and services
available to customers at least two (2) hours prior to and one (1) hour after each
flight offered by the Operator.
8. Personnel and Training. The Operator shall have in its employ suitably
uniformed and trained personnel in such numbers as are required to meet the
minimum standards set forth in this category, but never less than two FAA
currently certificated commercial pilots appropriately rated to conduct the flight
activity offered by Operator. The Operator shall have available sufficient qualified
personnel for checking in passengers, handling of luggage, ticketing and for
furnishing or arranging for suitable ground transportation.
9. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 and Appendix B
of these Minimum Standards and its Lease with or Non-Exclusive License from
the City.
10. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
11. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
12. Fly Neighborly Program. The Operator shall provide to each pilot flying for the
Operator a Pilot’s Guide for the type of aircraft being flown by that pilot (fixed
wing, jet, or helicopter), in the form attached as Appendix C or such similar form
as may be provided by the Airport Director.
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SECTION 6
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
FLIGHT TRAINING
STATEMENT OF CONCEPT
A Flight Training Operator may provide instruction to pilots in dual and solo flight
training, in fixed wing aircraft, and any related ground school instruction as is necessary
for preparation to taking an FAA written examination and flight check ride for various
category or categories of pilot’s licenses and ratings.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease from the City an area of sufficient size,
shape, and location to provide sufficient area to accommodate all of the
Operator’s activities and operations as described below. The Operator shall
provide at a minimum:
a. At least 1,000 square feet of floor space for an office, shop, restrooms,
customer lounge, classroom, and briefing room space to support flight-
training activities.
b. For aircraft using a hangar, sufficient area for parking the Operator’s
aircraft.
c. For aircraft not using a hangar, tie-down spaces of sufficient area for
parking the Operator’s aircraft.
d. Sufficient automobile parking space to accommodate employees and
customers parking with no on-street parking.
e. Paved walkways with all points of access conforming to the criteria
specified in the Americans with Disabilities Act (ADA) as required by the
act will be provided by the Operator.
f. Copies of all applicable federal, state and local licenses to operate a flight
training facility, including but not limited to any approvals required under
14 CFR Part 61 or 14 CFR Part 141.
2. Equipment. The Operator shall have available for use in flight training, either
owned or under written lease to the Operator, not less than two (2) properly
certificated aircraft, at least one (1) of which must be equipped for and capable of
use in instrument flight instruction, unless the Operator is only providing sport
pilot training.
3. Personnel. The Operator shall have on duty, on a full-time basis, at least one (1)
flight instructor who is currently certificated by the FAA to provide the type of
flight training offered; and shall have available for call, on a part-time basis, at
least one (1) flight instructor who is currently certified by the FAA to provide the
type of flight training offered. The Operator shall provide a currently certified
ground school instructor as needed; this requirement may be satisfied by a
certificated flight instructor with appropriate experience in ground school
teaching. The Operator shall have its premises open and services available in
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day and night hours as necessary to meet demand for training, and shall have an
employee in the facility at all times that flight or ground training is being
conducted.
4. Maintenance of Aircraft and Space for Maintenance. If the Operator is
conducting Aircraft Maintenance on Aircraft owned or leased or operated by (and
under the full and exclusive control of) the Operator, then the Operator must
lease at least 1,500 square feet of hangar space for such Aircraft Maintenance,
including employee work areas, shop areas, and storage.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
8. Fly Neighborly Program. The Operator shall maintain on its premises copies of,
and shall provide to each person being trained, a Pilot’s Guide for the type of
aircraft on which the person is being trained (fixed wing, jet, or helicopter), in the
form attached as Appendix C or such similar form as may be provided by the
Airport Director.
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SECTION 7
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT MAINTENANCE AND REPAIR STATIONS
STATEMENT OF CONCEPT
An Aircraft Repair Station Operator provides maintenance, repair, rebuilding, alteration
or inspection of aircraft or any of their component parts. Two types of Aircraft Repair
Station Operators are permitted at the Airport: (1) Aircraft Repair Stations and (2) Minor
and Specialized Maintenance and Repair Operators.
An Aircraft Repair Station must be certificated by the FAA under FAR Part 145 to
perform aircraft maintenance and shall provide only those maintenance and inspection
services permitted by its FAA certification. An Aircraft Repair Station Operator may also
sell aircraft parts and accessories on a non-exclusive basis.
A Minor and Specialized Maintenance and Repair Operator may provide either or both of
the following types of maintenance and repair services:
a. A Minor Maintenance and Repair Operator may provide aircraft airframe and
engine inspection, maintenance and repair on general aviation aircraft that is not
required to be performed by a Repair Station certificated under 14 CFR Part 145.
Services may include minor aircraft airframe and engine inspection, maintenance
and repair, and sale of incidental parts and accessories.
b. A Specialized Minor Aircraft Maintenance and Repair Operator may provide
maintenance and repair of aircraft radios, propellers, instruments, and
accessories for general aviation aircraft. This category shall include the sale of
new and/or used aircraft radios, propellers, instruments, and accessories on a
non-exclusive basis.
MINIMUM STANDARDS
1. Hangars and Shops. The Operator shall lease a hangar or shop facilities of at
least 5,000 square feet to conduct its business.
2. Aircraft Apron. If necessary for its operations, the Operator shall lease at least
4,000 square feet of paved aircraft parking and storage area to support its
activities, unless the City agrees in writing to a lesser leased area.
3. Aircraft Service Equipment.
a. Aircraft Repair Station Operators shall at all times maintain an adequate
supply of all necessary parts, equipment and accessories as needed for
its business operations.
b. Minor and Specialized Maintenance and Repair Operators shall provide
sufficient equipment, supplies and parts to provide minor repairs,
inspections and preventative Maintenance as defined in FAA regulations
at 14 CFR Part 43, including machine tools, jacks, lifts and testing
equipment.
Page | 24
c. If the Operator is involved with moving aircraft, the Operator shall have,
lease or contract with an FBO at least one aircraft tug of sufficient power
or braking weight to handle any aircraft that the Operator is permitted to
service under the Operator’s FAA certificate.
d. The Operator shall own, lease or otherwise have available all of the tools
and equipment required under the Operator’s FAA certificate.’
4. Hours of Operation.
a. The Repair Station shall be open and have services available at least
eight (8) hours a day, five (5) days a week.
b. The Operator shall provide for services during off-hours through an “on-
call” system.
5. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards:
a. The Operator shall have in its employ, and on duty during its hours of
operation under Section 7.4.a above, trained personnel in such numbers
as are required to meet contract requirements and FAA regulations, in a
safe and efficient manner, but never less than one (1) person who is an
employee of the Operator and is currently certified by the FAA with
ratings appropriate to the work being performed, and who holds an
airframe, power plant or an aircraft inspector rating. The requirements of
this subsection regarding inspector ratings shall not apply to radio shop
repair stations, if any.
b. During its hours of operation under Section 7.4.a above, the Operator
shall maintain a responsible person in charge to supervise its operations
on the Airport who has authority to represent and act for and on behalf of
the Operator.
c. All employees shall be suitably uniformed.
6. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
7. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
8. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 8
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
SELF-SERVICE FUEL PUMPS
STATEMENT OF CONCEPT
A Commercial Self-Service Fuel Operator provides and operates a commercial self-
service fueling facility from which pilots may fuel their aircraft. A commercial self-service
fueling facility may or may not be attended. Commercial self-service fueling is distinct
from self-fueling, in which an aircraft owner or operator performs services on its Owned
Aircraft with its Own Employees and Own Equipment.
MINIMUM STANDARDS
1. Land. The Operator shall lease, at a minimum, 8,000 square feet to provide
sufficient land for a retail self-service aviation fueling pump and corresponding
underground fuel storage tank (or a retail self-service aviation fueling pump and
the installation of a new above-ground fuel storage tank), supporting reporting
equipment and credit card authorization, and to provide fueling and dispensing
services to customers.
2. Services. The Operator shall operate a commercial self-service fueling facility
and shall provide retail aviation fueling and dispensing services to Airport users,
including the retail distribution of either 100 low lead AvGas or unleaded AvGas
(once unleaded AvGas is commercially available and approved for use). The
City, in its discretion, may allow subcontracting for these services after reviewing
a request for approval in writing.
3. Equipment, Operations, and Spill Control.
a. Equipment. The Operator must demonstrate that it owns, leases or
otherwise has sufficient access to all equipment required to provide
storage and dispensing operations at the Airport. All equipment shall be
maintained and operated in accordance with Federal, State, City and
industry requirements, including ATA 103, NFPA 407, OSHA guidelines,
and Municipal Code 10.04.06.120.
b. Operating procedures. The Operator shall develop and maintain
Standard Operating Procedures (SOP) for fueling and shall ensure
compliance with all applicable federal, state and local requirements or
standards, including those set forth in Advisory Circular 150/5230-4B -
Aircraft Fuel Storage, Handling, Training, and Dispensing on Airports,
ATA 103, NFPA 407, OSHA guidelines, Municipal Code 10.04.06.120,
and ASTM best management practices. The SOP shall include the
following:
i. a training plan,
ii. fuel quality assurance procedures,
iii. a schedule for inventory, inspections, and maintenance
procedures;
Page | 26
iv. record keeping procedures, and
v. emergency response procedures for fuel spills and fires,
including prevention measures;
vi. information regarding the control of access and security for fuel
and oil dispensing areas.
The SOP shall be submitted to the City not later than ten (10) business
days before the Operator commences operation at the Airport.
c. Spill Prevention and Containment. Prior to transporting or dispensing
aviation fuel or oil onto the Airport, the Operator shall provide the City with
a Spill Prevention Contingency and Control Plan (SPCC) that meets
regulatory requirements for fuel and oil storage facilities. An updated copy
of such SPCC Plan shall be filed with the City at least ten (10) business
days prior to actual implementation. Such plan shall describe, in detail,
those methods that shall be used by the Operator to clean up any
potentially hazardous fuel spills. The plan should include Equipment to be
used, emergency contact personnel and their telephone numbers, and all
other details as to how the Operator would contain such a spill. This plan
should also describe, in detail, what methods the Operator intends to use
to prevent any such spill from occurring.
4. Hours of Operation. The facilities shall be open and have services available
during the hours of 7 a.m. to 9 p.m. Monday thru Friday and from 8 a.m. to 9 p.m.
on Saturdays and Sundays.
5. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
in its employ, and on duty during business hours, trained personnel in such
numbers as are required to meet FAA regulations and any applicable terms
specified in the Operator’s Lease with or Non-Exclusive License from the City, in
a safe and efficient manner. All employees shall be suitably uniformed.
6. Insurance Requirements. The Operator shall provide evidence of insurance
coverage specified in Section 3.
7. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
8. Permits. The Operator shall have, and shall make available to the City on
request, evidence of all federal, state and local licenses, certificates and permits
that are required.
9. Fuel Revenues and Flowage Fees. The Operator shall pay to the City on a
monthly basis two types of fees: percentage revenue and a fuel flowage fee.
These fees may be based on fuel sale revenues and amounts, and may be
specified in the Operator’s Lease with or Non-Exclusive License from the City.
The Operator also may be required to pay other required fees and payments as
specified in the Operator's Lease with or Non-Exclusive License from the City.
Page | 27
SECTION 9
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT MANAGEMENT SERVICES
STATEMENT OF CONCEPT
An Aircraft Management Services Operator is a person, firm or corporation engaged in
the business of providing aircraft management including, but not limited to, flight
dispatch, flight crews, or aircraft maintenance coordination to the general public, under a
long-term contract. Management contracts must be in writing and must identify each
managed aircraft by registration number, type and model, and must be for a term of at
least six months. Contracts must be bona fide, exclusive and comprehensive, covering
all aspects of aircraft operation including, without limitation, fees and charges, insurance,
inspection, maintenance and repair during the term of the contract. Management
contracts may be “wet” or “dry,” and with or without crew.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease adequate space and facilities at the Airport to
store park or hangar managed aircraft, to store equipment, to operate its
business, and to accommodate its employee parking requirements. Leased
space must include sufficient work space for any aircraft upon which
maintenance or repairs are being performed by the Operator.
2. Equipment. The Operator must have the use of sufficient and appropriate
equipment to serve the types of aircraft being managed. The Operator must
have computer hardware and accounting software adequate to provide
comprehensive records of all revenues and expenses of aircraft management as
well as required aircraft maintenance.
3. Hours of Operation. The Operator shall have services available as required by its
customers.
4. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
trained and suitably uniformed personnel sufficient to provide services desired by
contract customers.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. Each The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 10
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIR TRANSPORTATION ARRANGER
STATEMENT OF CONCEPT
An Air Transportation Arranger Operator is a person, firm or corporation, whether or not
certificated by the FAA, using the Airport as a base to engage in the business of
arranging commercial air transportation (persons or property) to the general public for
hire, which commercial air transportation is provided by one or more persons, firms or
corporations engaged in the business of providing commercial air transportation
(persons or property) to the general public for hire under FAR Part 135 or any other
section of the FAR (the “Contracted Carrier”).
MINIMUM STANDARDS
1. Facilities or License.
a. If providing facilities for customer use at the Airport through either an FBO
or a Contracted Carrier operating at the Airport pursuant to Section 5 of
these Minimum Standards, the Operator shall provide the Airport Director
with documentation confirming the FBO’s or Contracted Carrier’s
agreement to provide such facilities and establishing that the FBO or
Contracted Carrier has complied with all the terms of its Iease with the
Airport and all applicable provisions of these Minimum Standards, and,
upon a determination by the Airport Director that these requirements have
been satisfied, shall enter into a Non-Exclusive License with the City for
provision of services.
b. Otherwise, the Operator shall lease from the City an area of sufficient
size, shape, and location as mutually agreed upon to provide at least
1,000 square feet of floor space for office, restrooms, and customer
lounge for customer use, in accordance with the requirements set forth in
Section 5.1.b of these Minimum Standards.
2. Contracted Carrier Compliance. The Operator shall provide the City with
documentation establishing that each Contracted Carrier operating at the Airport
pursuant to Section 5 of these Minimum Standards satisfies the requirements set
forth in Sections 5.2 through 5.11 of these Minimum Standards and that any
other Contracted Carrier has all required FAA certifications and complies with all
applicable FAA regulations.
3. Reports. For each flight providing commercial air transportation to persons, the
Operator shall provide the Airport Director, upon request made within 180 days of
the flight, with a written report identifying the Contracted Carrier that provided the
flight and, if that Contracted Carrier is not operating at the Airport pursuant to
Section 5 of these Minimum Standards, stating the type of aircraft, number of
passenger seats, and number of passengers actually carried.
4. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 and Appendix B
Page | 29
of these Minimum Standards and its Lease with or Non-Exclusive License from
the City.
5. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
6. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
7. Fly Neighborly Program. For any flight provided by a Contracted Carrier that is
not operating at the Airport pursuant to Section 5 of these Minimum Standards,
the Operator shall provide to the pilot of that flight a Pilot’s Guide for the type of
aircraft being flown by that pilot (fixed wing, jet, or helicopter), in the form
attached as Appendix C or such similar form as may be provided by the Airport
Director.
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SECTION 11
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT SALES OPERATOR
STATEMENT OF CONCEPT
An Aircraft Sales Operator is an Operator engaged in the sale of more than three new or
used Aircraft during a 12-month period. This excludes individuals selling personally
owned Aircraft, unless the individual purchased the Aircraft for the primary purpose of
resale.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease adequate space and facilities at the Airport to
store, park or hangar Aircraft to be sold, to store equipment, to operate its
business, and to accommodate its employee parking requirements. Leased
space must include sufficient work space for any aircraft upon which
maintenance or repairs are being performed by the Operator.
2. Equipment, License and Certifications. The Operator shall have sufficient and
appropriate equipment to serve the types of aircraft being stored and sold as
appropriate for its business. If the Operator offers flight demonstration for Aircraft
offered for sale, then the Operator shall also be properly certificated by the FAA,
hold appropriate ratings and medical certifications for providing flight
demonstration, and employ personnel authorized to fly such Aircraft for such
demonstration purposes.
3. Hours of Operation. The Operators shall have services available as required by
its customers.
4. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
trained personnel sufficient to provide services desired by customers.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 12
SPECIALIZED AERONAUTICAL SERVICE OPERATOR:
OTHER AERONAUTICAL SERVICES
STATEMENT OF CONCEPT
There may be other types of aeronautical services provided or to be provided at the
Airport that are not covered by the Minimum Standards set forth above and they may not
warrant the establishment of specific Minimum Standards at this time. Any existing
provider of such services must meet the general requirements of Section 3 of these
Minimum Standards.
1. Existing services not covered by specific category minimum standards.
a. Specialized Aeronautical Service Operators not covered by the specific
minimum standards in Sections 4 through 11 must meet all the
requirements of this section and Sections 3 and 14, including the
requirement that they have a Non-Exclusive License to provide services
at the Airport.
b. The City may require that the Operator lease space on the Airport.
c. Operators covered by this provision may be required to pay other
required fees and payments as specified in the Operator’s Lease with or
Non-Exclusive License from the City.
2. Application for new specialized aeronautical service operations. If and when an
applicant proposes to conduct a specialized aeronautical service that is not
currently conducted at the airport and is not covered by any of Sections 4
through 11 of these Standards, the City may adopt applicable Minimum
Standards for such service, taking into consideration the desires of the applicant,
the needs of the City and the need for such service at the Airport. At a minimum,
all aeronautical service providers at the Airport must comply with Section 3,
General Requirements.
Page | 32
SECTION 13
SPECIAL RULES FOR A SASO CONDUCTING
MULTIPLE AERONAUTICAL SERVICES
STATEMENT OF CONCEPT
This section would apply to any Specialized Aeronautical Services Operator that
engages in any two (2) or more of the specialized aeronautical services for which
Minimum Standards have been developed. The sale of aviation fuels is not included in
this section because only FBOs are permitted to engage in the sale of aviation fuels.
MINIMUM STANDARDS
1. Land. If required by these Minimum Standards, the Operator shall lease, from the
City an area that is equal to the total area required by the sum of the minimum
land areas required under the individual specialized services the Operator is
providing.
2. Hangars and Other Buildings. If required by these Minimum Standards, this
Operator shall lease hangar facilities providing a total square footage that is
equal to the total area required by the sum of the minimum hangar size required
under the individual specialized services the Operator is providing. The hangar
must have a door that meets the largest width and height requirements of the
individualized services the Operator is providing.
3. Aircraft Apron. If required by these Minimum Standards, the Operator shall lease
paved aircraft parking apron that provides a total square footage that is equal to
the total area required by the sum of the minimum apron areas required under
the individual specialized services the Operator is providing.
4. Hours of Operation. The Operator shall maintain the longest hours of operation
required elsewhere in these Minimum Standards for any of the aeronautical
services it provides.
5. Personnel. In addition to the general personnel and training requirements in
Section 3 of these Minimum Standards, the Operator shall have in its employ and
on duty during the appropriate business hours, suitably uniformed, trained
personnel in such numbers as are required to meet these Minimum Standards for
the aeronautical services to be provided. Multiple responsibilities may be
assigned to meet the personnel requirements for each specialized aeronautical
service being performed.
6. Equipment. The Operator shall provide all of the facilities, equipment and
services required to meet the Minimum Standards for each of the aeronautical
services it provides.
7. Insurance. The Operator shall obtain, as a minimum, that insurance coverage
which is equal to the highest single coverage requirement of all the aeronautical
services being performed by the Operator.
8. Required Fees and Payments. The Operator shall pay all fees applicable to each
and every service that it provides at the Airport.
Page | 33
9. Applicability of Specific Provisions. The provision of multiple types of services by
the Operator shall not exempt the Operator from any of the requirements
otherwise applicable to each of the services provided.
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SECTION 14
RECOGNITION AND REGULATION
OF SELF-SERVICE AND SELF-FUELING RIGHTS
RIGHT TO SELF-SERVICE AND SELF-FUELING
An aircraft owner may perform services, including Self-Fueling, on the owner’s Own
Aircraft utilizing the aircraft owner’s Own Employees and Own Equipment.
In the interests of safety and fairness, a Person desiring to Self-Fuel must hold a current
Non-Commercial Annual Operational Permit from the Santa Monica Fire Department
and be granted Self-Fueling rights by the City in a Lease, Non-Exclusive License, or
Non-Commercial Self-Fueling Permit. Any Person not party to a Lease or Non-Exclusive
License granted by the City may only have permission to Self-Fuel such Person’s
Owned Aircraft if such Person (a) holds a valid and current Non-Commercial Self-
Fueling Permit from the City, and (b) is in and continues to be in compliance with all City,
state and federal requirements applicable to aircraft fuel handling practices.
If an aircraft owner does not exercise the right to Self-Fuel, that owner’s aircraft may be
fueled or otherwise serviced at the Airport only by those Operators authorized to provide
such services at the Airport under a Lease or Non-Exclusive License approved by the
City.
NON-COMMERCIAL SELF-FUELING PERMIT
1. General
A Person desiring to Self-Fuel that Person’s Owned Aircraft, and not holding Self-
Fueling rights under a Lease or Non-Exclusive License, shall have a reasonable
opportunity to qualify for and receive a Non-Commercial Self-Fueling Permit. Each
Person conducting non-commercial Self-Fueling at the Airport shall comply with the
following minimum standards. Any Person desiring to Self-Fuel its Owned Aircraft may
only do so using its Own Employees and its Own Equipment. Third-party employees
and equipment can never be used for Self-Fueling.
Self-service fueling by an aircraft owner or operator at an FBO’s self-service pump is not
Self-Fueling and does not require a Self-Fueling Permit.
2. Permit/Approval
a. No Person shall engage in Self-Fueling activities unless a valid Non-
Commercial Self-Fueling Permit authorizing such activity has been
obtained from the City.
b. The Permit shall not reduce or limit Permittee’s obligations with respect to
these Self-Fueling minimum standards, which shall be incorporated in the
Permit by reference.
c. An applicant for a Permit shall provide evidence that any aircraft to be
fueled by the applicant is an Owned Aircraft. At any time after a Permit is
issued, the Permittee, upon request by the Airport Director or delegee,
shall provide evidence that all aircraft being Self-Fueled are Owned
Aircraft.
Page | 35
d. The Airport Director will make binding determinations about whether
specific aircraft qualify as Owned Aircraft for purposes of Self-Fueling.
e. A Person seeking to Self-Fuel on the basis of a Long Term Lease for any
aircraft must obtain insurance to cover all of its interest and activities with
respect to the leased aircraft or be a named insured under the policy of
the lessor and must attach true and correct copies of the lease and a
complying certificate of insurance to such Person’s application for a Non-
Commercial Self-Fueling Permit, as updated by such Person before there
are any changes in the aircraft such Person seeks to Self-Fuel.
f. A Person seeking to Self-Fuel aircraft on the basis of a Long Term
Management Contract for any aircraft must obtain insurance to cover all
of its interests and activities with respect to the aircraft or be named as an
insured under the policy of the aircraft owner and must attach true and
correct copies of the management contract and a complying certificate of
insurance to such Person’s application for a Non-Commercial Self-
Fueling Permit, as updated by such Person before there are any changes
in the aircraft such Person seeks to Self-Fuel.
g. A Person seeking to Self-Fuel using facilities or equipment that are under
a Long Term Lease or other written agreement must obtain insurance to
cover all of its interests and activities with respect to the subject of the
agreement or be a named insured under the policy of the equipment
owner and must attach true and correct copies of the agreement and a
complying certificate of insurance to such Person’s application for a Non-
Commercial Self-Fueling Permit as updated by that Person before there
are any changes in the facilities or equipment to be used for Self-Fueling
by such Person.
3. Fuel Storage and Delivery
a. Permittee shall arrange and demonstrate that satisfactory arrangements
have been made for the storage and delivery of fuel in accordance with
this Section 14.
b. Fuel Storage Facilities. A Permittee may be authorized to establish its
own fuel farm only with the advance written approval of the Airport
Director, which approval may be issued by the Airport Director only after
authorization by the City Council,. A Permittee authorized by the City to
install its own fuel tank may lease land and construct or install an above-
ground fuel storage facility at a location approved by the Airport Director
in writing. If a request by the Permittee to use its own fuel farm is
approved by the Airport Director, after obtaining authorization from the
City Council, the following requirements will apply:
i. The Permittee shall lease sufficient land for installation of above-
ground fuel storage tanks to be constructed and operated on the
Permittee’s leased premises in compliance with all applicable
environmental requirements.
Page | 36
ii. All fuel storage must be above-ground. In no event shall the total
storage capacity be less than 10,000 gallons for Jet Fuel or 2,500
gallons for Avgas.
iii. The fuel storage system must include adequate fuel spill
prevention features and containment capabilities, together with an
approved fuel spill containment and countermeasures control
plan, and shall be improved and upgraded as necessary to meet
all current EPA requirements for spill prevention, containment and
mitigation as they may be revised.
iv. The Permittee shall be required to undertake at its own expense
any environmental testing of its fuel facilities which the City may
reasonably request, on or off the Airport, and to take any remedial
actions determined to be necessary or appropriate as a result of
such testing. The right is reserved to the Airport Director to
disapprove installation of a new fuel farm if the facility would have
an adverse effect on safety or otherwise in the judgment of the
Airport Director not be in the interest of a safe and efficient airport
operation.
v. In no event shall fuel delivery trucks be used for fuel storage on
the Airport. Vehicles used to deliver fuel to the Airport will transfer
fuel to storage tanks or, if approved, directly to the Permittee’s fuel
dispensing trucks, and depart the Airport.
c. Permittee shall be liable and indemnify the City for all leaks, spills, or
other damage that may result through the handling and dispensing of fuel.
d. Fuel delivered shall be clean, bright, pure, and free of microscopic
organisms, water, or other contaminants. Ensuring the quality of the fuel
is the responsibility of Permittee.
4. Fueling Equipment
a. Permittee shall utilize a single mobile dispensing truck that has the
following minimum capacity: (1) for Avgas or jet fuel, 750 gallons; (2) for
MoGas, 80 gallons. Avgas or MoGas dispensing trucks shall have a
maximum capacity of 1,200 gallons and jet fuel dispensing trucks shall
have a maximum capacity of 3,000 gallons. All Refueling Vehicles shall
be capable of bottom loading, and turbine fuel dispensers must have
single point refueling capability.
b. Each Refueling Vehicle shall be equipped and maintained to comply at all
times with all applicable safety and fire prevention requirements or
standards, as may be amended, including without limitation, those
prescribed by:
i. National Fire Protection Association (NFPA) 407, OSHA
guidelines, the California Fire Code, and Municipal Code
10.04.06.120;
Page | 37
ii. 14 CFR Part 139, Airport Certification, § 139.321
“Handling/Storing of Hazardous Substances and Materials”; and
iii. applicable FAA Advisory Circulars (AC) including AC 150/5210-
20, Ground Vehicle Operations on Airports”; and AC 150/5210-5D,
"Painting, Marking and Lighting of Vehicles Used On An Airport".
5. Spill Prevention and Containment. Prior to transporting Fuel onto the Airport, the
Permittee shall provide the City with a Spill Prevention Contingency and Control
Plan (SPCC) that meets regulatory requirements for above ground Fuel storage
facilities. An updated copy of such SPCC Plan shall be filed with the City at least
ten (10) business days prior to actual implementation. Such plan shall describe,
in detail, those methods that shall be used by the Permittee to clean up any
potentially hazardous Fuel spills. The plan should include Equipment to be used,
emergency contact personnel and their telephone numbers, and all other details
as to how the Permittee would contain such a spill. This plan should also
describe, in detail, what methods the Permittee intends to use to prevent any
such spill from occurring.
6. Operating procedures. In accordance with all applicable Regulatory Measures
and appropriate industry practices, the Permittee shall develop and maintain
Standard Operating Procedures (SOP) for fueling and shall ensure compliance
with standards set forth in NFPA 407, the California Fire Code, and Municipal
Code 10.04.06.120. The SOP shall include a training plan, fuel quality
assurance procedures, record keeping, and emergency response procedures for
fuel spills and fires. The SOP shall also address the following: (1) bonding and
fire protection, (2) public protection, (3) control of access to fuel dispensing
vehicle storage areas, and (4) marking and labeling of fuel dispensing vehicles.
The SOP shall be submitted to the City not later than ten (10) business days
before the Permittee commences Self-Fueling at the Airport.
7. Licenses, Certifications, and Permits. Permittee shall have, and shall make
available to the City on request, evidence of all federal, state and local licenses,
certificates and permits that are required to conduct Self-Fueling.
8. Reporting
a. Permittee shall report all Fuel delivered to the approved Permittee’s fuel
storage facility, if any, and into Permittee’s Aircraft during each calendar
month and submit a summary report along with appropriate fees and
charges due the City on or before the 10th day of the subsequent month.
b. Permittee shall during the term of the Permit and for three (3) years
thereafter maintain records identifying the total number of aviation Fuel
gallons purchased and delivered. Records (and meters) shall be made
available for audit to the City or representatives of the City. In the case of
a discrepancy, Permittee shall promptly pay, in cash, all additional rates,
fees, and charges due the City, plus annual interest on the unpaid
balance at the lesser of 18% or the maximum rate allowable by law from
the date originally due.
Page | 38
9. Personnel
a. Only the Permittee’s Own Employees may conduct Self-Fueling
operations on the Permittee’s aircraft. All Employees of the Permittee
conducting Self-Fueling must be properly trained in Aircraft refueling, in
compliance with 14 CFR § 139.321.
b. There must be a minimum of two (2) trained individuals present during
Self-Fueling activities.
10. Limitations on Self-Fueling Rights.
a. A Permittee may not sell or dispense fuels to based or transient aircraft
that are not Owned Aircraft of the Permittee. Any such sale or dispensing
shall be grounds for immediate revocation of the Permit. Revocation
upon first violation will be for a period of one (1) year. Revocation upon a
second violation shall be permanent.
b. Once unleaded Avgas is commercially available and approved for use,
self-fueling using leaded Avgas or MoGas will no longer be permitted.
11. Insurance. Except as otherwise provided for in these Minimum Standards,
Permittee shall maintain, at a minimum, the coverages and policy limits set forth
in Appendix B – Insurance Requirements.
12. Required Fees and Payments. Fuel flowage fees and any other payments to be
made to the City by each Permittee will be set forth in the Permittee's Non-
Commercial Self-Fueling Permit and shall be reasonable and not unjustly
discriminatory.
APPENDIX A
DEFINITIONS
The following terms shall have the following meanings:
AERONAUTICAL ACTIVITY – Any activity that involves, makes possible, or is required
for the operation of aircraft or that contributes to or is required for the safety of such
operations. Activities within this definition, commonly conducted on airports, include, but
are not limited to, the following: general and corporate aviation, air taxi and charter
operations, scheduled and nonscheduled air carrier operations, pilot training, aircraft
rental and sightseeing, aerial photography, crop dusting, aerial advertising and
surveying, aircraft sales and services, aircraft storage, sale of aviation petroleum
products, repair and maintenance of aircraft, sale of aircraft parts, parachute or ultralight
activities, and any other activities that, because of their direct relationship to the
operation of aircraft, can appropriately be regarded as aeronautical activities.
AIRPORT – Santa Monica Airport (SMO).
AIRPORT DIRECTOR – the Airport Director of the Santa Monica Airport or the duly
authorized representative of the Airport Director.
AIRPORT USER – a person who operates an aircraft at the Airport.
AIR OPERATIONS AREA or AOA – that portion of the Airport used or intended to be
used for landing, take off or surface maneuvering of aircraft including the hangar and
cargo areas and aircraft parking aprons.
AIRPORT LEASING POLICY -- Santa Monica City Council Airport Leasing and
Licensing Policy (“Airport Leasing Policy”).
APRON or RAMP – those areas of the Airport within the AOA designated for the
loading, unloading, servicing, or parking of aircraft.
CITY – the City of Santa Monica, California. The City may delegate its powers to the
Airport Director or such other City staff member as the City may choose.
COMMERCIAL – conducted with the intent or purpose of generating or securing
earnings, income, compensation or profit, whether or not such objectives are
accomplished.
CONSENT DECREE – the Consent Decree between the City and the United States in
the U.S. District Court, City of Santa Monica v. United States, Dkt. No. 2:13-cv-08046
(C.D. Cal. 2017), dated January 31, 2017.
FAA – Federal Aviation Administration, or any successor agency.
FIXED BASE OPERATOR (FBO) – an operator that furnishes a full range of
aeronautical activities and services to the public, including fueling and line services to
General Aviation aircraft.
FUELING OPERATIONS – the receipt, storage, handling, movement, delivery and
dispensing of fuel for aircraft at the Airport, including the installation, use and
maintenance of fueling equipment, and the operations and supervision of all personnel
engaged in fueling activities.
GENERAL AVIATION – all aviation operating under FAR Part 91 (with the exception of
government aircraft operations) and FAR Part 135 operations to the extent permitted in
these Minimum Standards.
INDIVIDUAL – An Operator’s agent, employee, supplier, contractor, tenant, invitee or
other party that has been granted access to the Operator’s premises.
LEASE – an agreement with the City for the exclusive use of designated airport land
and/or facilities.
LONG TERM LEASE – a written lease for one or more aircraft, with adequate
consideration, for a term of at least six months and terminable within six months only for
cause which provides that the primary care, custody and control of the aircraft is in the
Person applying to conduct Self-Fueling Operations and contains substantially all terms
and conditions standard in the industry for that type of lease.
LONG TERM MANAGEMENT CONTRACT – a written management contract for
specified aircraft, with adequate consideration, for a term of at least six months and
terminable within six months only for cause which provides that the primary care,
custody and control of the aircraft is in the Person applying to conduct Self-Fueling
Operations and contains substantially all terms and conditions standard in the industry
for that type of contract. The management contract must provide that the Person
applying to conduct Self-Fueling Operations is responsible for all maintenance, all pilot
service, and all scheduling of the aircraft that are subject to the managements contract.
MUNICIPAL CODE – the City of Santa Monica Municipal Code.
NON-COMMERCIAL SELF-FUELING PERMIT – a written document issued by the City
authorizing Self-Fueling at the Airport.
NON-EXCLUSIVE LICENSE – an agreement with the City granting permission for the
conduct of specified commercial aeronautical services on the Airport, but not granting an
exclusive right to provide those services or the exclusive use of any Airport property or
facilities.
OPERATOR – a person or persons, firm, company, joint venture, partnership or
corporation using the Airport as a base for any Commercial Aeronautical Activity.
OWNED AIRCRAFT – for FAA Part 91 or Part 135 operators, aircraft listed on that
operator’s then-current Part 91 or Part 135 Certificate and for all other operators: aircraft
used exclusively by that Person and titled and registered with the FAA in that Person’s
own name; aircraft used by that Person as lessee under a Long Term Lease, or aircraft
used by that Person under a Long Term Management Contract.
OWN EMPLOYEES – employees of the Person applying to conduct Self-Fueling
Operations for whom all state and federal employment taxes are paid by that Person.
OWN EQUIPMENT – facilities or equipment that is used exclusively by and titled in the
name of the Person applying to conduct Self-Fueling Operations or is used by that
Person subject to a Long Term Lease or written purchase, financing or use agreement
for such facilities or equipment, with adequate consideration, for a term of at least six
months and terminable within six months only for cause which provides that the primary
care, custody and control of the facilities or equipment is in the Person applying to
conduct Self-Fueling Operations and contains substantially all terms and conditions
standard in the industry for that type of agreement.
PERMITTEE – a Person who has been issued and holds a valid and current Non-
Commercial Self-Fueling Permit.
PERSON – an Individual, firm, company, joint venture, partnership or corporation.
REPAIR STATION – a facility utilized for the repair of aircraft approved and certificated
by the FAA under 14 CFR Part 145. Activities may include repair and maintenance of
airframes, power plants, propellers, radios, instruments and accessories.
SELF-FUELING – a Person’s conduct of Fueling Operations for that Person’s Own
Aircraft, using that Person’s Own Equipment and conducted by that Person or the
Person’s Own Employees. Self-fueling may be permitted by a Lease or Non-Exclusive
License authorizing commercial services or by a Non-Commercial Self-Fueling Permit.
SPECIALIZED AERONAUTICAL SERVICES OPERATOR (SASO) – an Operator that
is authorized to engage in one or more of the following specialized aeronautical support
services:
a. Aircraft Charter and Air Taxi
b. Flight Training
c. Aircraft Maintenance and Repair Stations
d. Self-Service Fuel Pumps
e. Aircraft Management
f. Air Transportation Arranger
g. Aircraft Sales Operator
h. Other Aeronautical Services
APPENDIX B
INSURANCE REQUIREMENTS AND STANDARDS
The City has established the following minimum insurance requirements and standards
for Operators providing commercial aeronautical services at the Santa Monica Municipal
Airport:
A. The Operator shall procure and maintain at its own expense for the duration of the
Operator’s activities and/or use of leased premises at the Airport insurance as set
out in the Minimum Insurance Requirements Matrix (Appendix B-1) against claims
for injuries to persons or damages to property that may arise from or in connection
with activities and/or the use of leased premises at the Airport by the Operator, its
agents, representatives, employees or subcontractors.
B. If the Operator maintains broader coverage or higher limits than the minimums
required in Appendix B-1, the City of Santa Monica requires and shall be entitled
to any broader coverage and higher limits maintained by the Operator. Any
available insurance proceeds in excess of the specified minimum limits of
insurance and coverage shall be available to the City of Santa Monica.
C. The insurance policies are to contain, or be endorsed to contain, the following
provisions:
i. Additional Insured Status: The City of Santa Monica, its officers, officials,
employees and volunteers are to be covered as additional insureds on the
CGL policy with respect to liability arising out of the use, occupancy,
operations or maintenance of leased premises, including work or
operations performed on behalf of the Operator.
ii. Primary Coverage: For any claims related to Operator’s activities and/or
use of leased premises at the Airport, the Operator’s insurance shall be
primary coverage at least as broad as Insurance Services Offices Form CG
20 01 04 13 as respects the City of Santa Monica, its officers, officials,
employees and volunteers. Any insurance or self-insurance maintained by
the City of Santa Monica, its officers, officials, employees or volunteers
shall be in excess of the Operator’s insurance and shall not contribute with
it.
iii. Notice of Cancellation: Each insurance policy required herein shall state
that coverage shall not be cancelled except after notice has been given to
the City of Santa Monica.
iv. Waiver of Subrogation: Operator hereby grants to the City of Santa
Monica a waiver of any right of subrogation which any insurer of said
Operator may acquire against the City of Santa Monica by virtue o f
payment of any loss. Operator agrees to obtain any endorsement that may
be necessary to affect this waiver of subrogation, but this provision applies
regardless of whether or not the City of Santa Monica has received a waiver
of subrogation endorsement from the insurer.
v. Claims Made Policies: If the pollution liability policy provides “claims
made” coverage: the Retroactive Date must be shown and must be before
the commencement of the Operator’s lease; the insurance must be
maintained and evidence of insurance must be provided for at least 3 years
after the expiration of the Operator’s lease; and if the policy is cancelled or
not renewed, and not replaced with another “claims made” policy form with
a Retroactive Date prior to the effective date of the lease, the Operator
must purchase “extended reporting” coverage for a minimum of 3 years
after lease expiration.
vi. Indemnification and Hold Harmless. Operator shall defend, indemnify,
save, protect, and hold harmless the City of Santa Monica, the Santa
Monica Airport, the Santa Monica Airport Commission, and the Santa
Monica City Council, individually and collectively, and their representatives,
officers, officials, employees, agents, and volunteers from any and all
claims, demands, damages, fines, obligations, suits, judgments, penalties,
causes of action, losses, liabilities, administrative proceedings, arbitration,
or costs at any time received, incurred, or accrued by the City of Santa
Monica, the Santa Monica Airport, the Santa Monica Airport Commission,
and the Santa Monica City Council, individually and collectively, and their
representatives, officers, officials, employees, agents, and volunteers as a
result of, or arising out of Operator's activities, actions, or inactions. In the
event a party indemnified hereunder is in part responsible for the loss, the
indemnitor shall not be relieved of the obligation to indemnify; however, in
such a case, liability shall be shared in accordance with California
principles of comparative fault.
Operator shall accept total responsibility, defend, indemnify, save, protect,
and hold harmless the City of Santa Monica, the Santa Monica Airport, the
Santa Monica Airport Commission, and the Santa Monica City Council,
individually and collectively, and their representatives, officers, officials,
employees, agents, and volunteers in the event of an environmental
contaminating accident or incident caused by Operator, its employees, its
vendors or any other personnel used by the Operator to maintain
Operator's improvements, vehicles, equipment, or aircraft.
Nothing herein shall constitute a waiver of any protection available to the
City and the City Council, individually and collectively, and its
representatives, officers, officials, employees, agents and volunteers under
the State of California’s governmental immunity act or any similar doctrine
or statutory provision.
D. All insurance shall be placed with insurers authorized to conduct business in
California with a current A.M. Best rating of no less than A:VII, unless otherwise
acceptable to the City of Santa Monica.
E. Operator shall furnish the City of Santa Monica with original certificates and
amendatory endorsements (or copies of the applicable policy language effecting
coverage provided by this clause). All certificates and endorsements are to be
received and approved by the City of Santa Monica before the lease commences.
However, failure to obtain required documents prior to the work beginning shall not
waive the Operator’s obligation to provide them. The City of Santa Monica
reserves the right to require complete, certified copies of all required insurance
policies, including the endorsements required herein, at any time.
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.
APPENDIX C
FLY NEIGHBORLY PROGRAM NOTIFICATIONS
¹
Santa Monica Airport
VFR Pilot’s Guide Address: Santa Monica Municipal Airport
3223 Donald Douglas Loop South
Santa Monica, CA 90405
Phone: 310.458.8591
Noise: 310.458.8692
Noise Email: noise@smgov.net
Fax: 310.572.4495
Email: airport@smgov.net
Web: www.santamonicaairport.org
SMO Fly Neighborly, Fly Quietly
FIXED-WING PROPELLER AIRCRAFT
Contact Us
Photography courtesy of Chad Slattery.
Golf Course
Noise
Managment
Office
Airport
Administration
Building
Air Traffic
Control Tower
21
3
Runway
Runway
SMO
AIRPORT DIAGRAM
SMO VOR 110.8
Transient
Parking
FBO
Self-Serve Fuel
www.santamonicaairport.org | 310.458.8591
Santa Monica Airport (SMO)
Fly Neighborly Program
Welcome to the neighborhood and the Santa Monica
Municipal Airport, one of the busiest single–runway general
aviation airports in the nation. We hope you will enjoy your
time with us. This brochure introduces you to the Santa
Monica Airport’s Fly Neighborly Program and will help you
operate your aircraft in the least impactful manner possible
while providing a safe environment.
The Airport is in the heart of a neighborhood surrounded
by over 130,000 residents. The City of Santa Monica is
proactively committed to its extensive noise mitigation
program, which includes a maximum allowable noise level,
limited aircraft operations hours, and requested VFR noise
mitigation fl ight paths and procedures. This brochure is
designed to assist you with compliance of these procedures;
helping you be a good neighbor.
The City and Airport staff recognize that pilots truly are the
key to a successful noise mitigation program. We greatly
appreciate your help and cooperation in making the Airport
a good neighbor.
DISCLAIMER: The procedures described in this brochure are not intended to
preempt the prerogatives or responsibilities of the pilot-in-command, confl ict with
safe aircraft operations, or interfere with ATC instructions or any domain that is the
exclusive authority of the FAA.
Not to Scale
Arrival
Departure
Pattern Flight
Santa
Monica
Pier
No right turns
prior to shoreline
Venic
e
B
l
v
d
No left turns
prior to
Lincoln Blvd
Not For Navigational Use
Marina del Rey
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c
o
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n
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Golf C
o
u
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s
e
225°
c
o
u
r
s
e
Mandatory Restrictions
The following procedures and limitations are enforced per the
City’s Aircraft Noise Ordinance. Violations may result in the
imposition of fi nes and/or exclusion from Santa Monica Airport.
Maximum Noise Level: 95.0 dBA Single Event Noise
Exposure Level (SENEL) as measured 2,200’ from
either ends of the runway.
Intersection departures are prohibited.
Formation takeoffs and landings are prohibited.
Touch and go, stop and go and low approaches are
prohibited weekends, holidays, and weekdays one half
hour after sunset until 7am the following day.
Prior Permission Required from the Airport Director
for dual wheel aircraft in excess of 60,000 lbs. MCLW
Call (310) 458-8591.
Mandatory Night Departure Curfew
No takeoffs or engine starts, including Auxiliary Power Units
(APU) between 11pm and 7am Monday through Friday or
until 8am on weekends. Exceptions are allowed for bona fi de
medical or public safety emergencies only. Contact Airport
Administration.
Voluntary Night Arrival Curfew
11pm and 7am Monday through Friday or until 8am on weekends.
Pilots are requested to avoid operations during this time period
due to the negative noise impact on the community.
Note: Compliance with the Airport Ordinance is mandatory
unless deviations are made necessary by weather, ATC
instructions or clearances, infl ight emergency or other safety
considerations.
Fixed-Wing Propeller Aircraft Procedures
Frequencies
CTAF 120.1 MHz
ATIS 119.15 MHz or (310) 450-4620
Tower 120.1 MHz (0700 to 2100 local)
Ground Control 121.9 MHz (0700 to 2100 local)
Unicom 122.95 MHz (after hours)
VOT 113.9MHz
SMO VORTAC 110.8 MHz
Traffi c Pattern
Left Traffi c Runway 21
Right Traffi c Runway 03
Pattern Altitude 1,370 feet MSL Single-Engine
1,870 feet MSL Multi-Engine
Instrument Approach Procedure
VOR Runway 21
RNAV (GPS) Runways 03 & 21
Airfi eld Information
Field Elevation 170 feet MSL
Runway 21 170 feet MSL
Runway 03 126 feet MSL
Runway Length/Width 3,500 feet X 150 feet (ASPH)
Runway Slope 1.2% down SW
Runway Lighting MIRLs, PAPI R03, REIL & PAPI R21
Maximum Weight 60,000 lbs. Maximum Certifi ed
Landing Weight (dual wheel)
Fixed Based Operator
Atlantic Aviation
2828 Donald Douglas Loop North, Santa Monica, CA 90405
Phone: 310-396-6770 Frequency: 122.95 MHz
Fuel – JetA, 100LL
Aeroplex
Self-serve Fuel Station
Fuel: 100LL
Located Southwest of the fi eld
VFR Departures
Westerly Flow: Runway 21
Standard traffi c pattern is left. Please over-fl y the Penmar Golf
Course west of SMO. This procedure requires an initial 10° left
turn over the VOR and then a right turn to overfl y the length of
the golf course. Please do not initiate the left 10° turn prior to
the VOR (See map).
Special Flight Rules Area: Runway 21
Right climbing 270° turn at shoreline to head southeast along
SMO 132° radial at 3,500 feet MSL (see map.)
Mini Route
Remain outside class B airspace until receiving clearance from
LAX tower. SMO tower will coordinate transitions through the
Mini Route. Crossing altitude 2500’
Easterly Flow: Runway 03
Standard traffi c pattern is right. Turn crosswind over 405 FWY.
Special Flight Rules Area: Runway 03
Left climbing 270° turn to fl y southeast along the SMO 132°
radial at 3,500 feet MSL. No crosswind turns prior to the
405 FWY.
VFR Arrivals
Runways 03/21
Maintain pattern altitude or above as long as practical.
Special Flight Rules Area Arrivals
Contact SMO Tower for north crossing midfi eld to enter right
traffi c (see map.)
Noise Mitigation Policies
Fly Neighborly, Fly Quietly
(SFRA) RUNWAY 21
Santa
Monica
Pier
No right turns
prior to shoreline
Venic
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B
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Marina del Rey
Arrival
Departure
21
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Golf C
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SMO VOR 110.8
Air to Air Freq. 128.55
225° c
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Fixed Wing VFR Operations Only Santa Monica Airport Information
Procedures for Special Flight Rules Area
Santa Monica Airport
Pilot’s Guide
HELICOPTERS
Address: Santa Monica Municipal Airport
3223 Donald Douglas Loop South
Santa Monica, CA 90405
Phone: 310.458.8591
Noise: 310.458.8692
Fax: 310.572.4495
Email: airport@smgov.net
Web: www.santamonicaairport.org
Frequencies
CTAF 120.1 MHz
ATIS 119.15 MHz or (310) 450-4620
Tower 120.1 MHz (0700 to 2100 local)
Ground Control 121.9 MHz (0700 to 2100 local)
Unicom 122.95 MHz (after hours)
VOT 113.9MHz
SMO VORTAC 110.8 MHz
Tr a f fi c Pattern
Left Traffi c Runway 21
Right Traffi c Runway 03
Pattern Altitude 1,370 feet MSL Single-Engine
1,870 feet MSL Multi-Engine
Instrument Approach Procedure
VOR or GPS-A Runway 21
Airfi eld Information
Field Elevation 170 feet MSL
Runway 21 170 feet MSL
Runway 03 126 feet MSL
Runway Length/Width 3,500 Feet X 150 Feet (ASPH)
Runway Slope 1.2% down SW
Runway Lighting MIRLs, PAPI R03, REIL & PAPI R21
Maximum Weight 60,000 lbs. Maximum Certifi ed
Landing Weight (dual wheel)
Photography courtesy of Chad Slattery.SMO Fly Neighborly, Fly Quietly www.santamonicaairport.org | 310.458.8591
BUSINESS
PARK
Golf Course
Noise
Managment
Office
Airport
Administration
Building
Air Traffic
Control Tower
21
3
Runway
Runway SMO VOR 110.8
Helipad
Parking Restricted
2 hours only
Atlantic Aviation
122.95MHz
Helicopter
Landing Location
NOISE SENSITIVE
HELICOPTER
LANDING LOCATIONS
East Overflow
Ramp
FBO
SMO Fly Neighborly ProgramContact Us
Fly Neighborly Program
Welcome to the neighborhood and the Santa Monica
Municipal Airport, one of the busiest single–runway general
aviation airports in the nation. We hope you will enjoy your
time with us. This brochure introduces you to the Santa
Monica Airport’s Fly Neighborly Program and will help you
operate your aircraft in the least impactful manner possible
while providing a safe environment.
The Airport is in the heart of a neighborhood surrounded
by over 130,000 residents. The City of Santa Monica is
proactively committed to its extensive noise mitigation
program, which includes a maximum allowable noise level,
limited aircraft operations hours, and requested VFR noise
mitigation fl ight paths and procedures. This brochure is
designed to assist you with compliance of these procedures;
helping you be a good neighbor.
The City and Airport staff recognize that pilots truly are the
key to a successful noise mitigation program. We greatly
appreciate your help and cooperation in making the Airport
a good neighbor.
DISCLAIMER: The procedures described in this brochure are not intended to
preempt the prerogatives or responsibilities of the pilot-in-command, confl ict with
safe aircraft operations, or interfere with ATC instructions or any domain that is the
exclusive authority of the FAA.
Not to Scale
Mandatory Restrictions
The following procedures and limitations are enforced per the
City’s Aircraft Noise Ordinance. Violations may result in the
imposition of fi nes and/or exclusion from Santa Monica Airport.
Maximum Noise Level: 95.0 dBA Single Event Noise
Exposure Level (SENEL) as measured 2,200’ from
either ends of the runway.
Formation takeoffs and landings are prohibited.
Formation fl ying within Class D airspace is highly
discouraged unless necessary for an emergency.
Helicopter fl ight training is prohibited.
Mandatory Night Departure Curfew
No takeoffs or engine starts including Auxiliary Power Units (APU)
between 11pm and 7am Monday through Friday or until 8am on
weekends. Exceptions are allowed for bona fi de medical or public
safety emergencies only. Contact Airport Administration.
Voluntary Night Arrival Curfew
11pm and 7am Monday through Friday or until 8am on weekends.
Pilots are requested to avoid operations during this time period
due to the negative noise impact on the community.
Note: Compliance with the Airport Ordinance is mandatory unless deviations
are made necessary by weather, ATC instructions or clearances, infl ight
emergency or other safety considerations.
Helicopter Procedures
These helicopter procedures are derived from a Letter of
Agreement between the City of Santa Monica and the FAA.
Helicopter Departures RWY 21
Depart via runway and offset left at the VOR to over-fl y the
length of the Penmar Golf Course. Please make all turns at
shoreline (see map).
Helicopter Departures RWY 03
Depart via runway and proceed straight out to 405 FWY before
executing left or right crosswind
VFR Helicopter Arrivals
Enter midfi eld 90 degrees to the runway at or above 900
feet MSL and execute descending turn to runway. Whenever
possible, do not commence descent until established over the
Airport or Business Park located north of the runway.
Public Use Helipad Parking (Restricted to 2 hours)
The Helipad is located on the south side of runway 03/21.
When landing on the helipad, avoid fl ying over the Airport
Observation Deck at the Airport Administration Building and
stationary or taxiing aircraft to minimize rotor wash. Remain
clear of the runway at all times unless approved by the ATC.
Contact Atlantic Aviation for overnight or long term parking.
(310) 396 6770
Noise Mitigation Policies
Fly Neighborly, Fly Quietly
Fixed Based Operators Providing Transient Services
Atlantic Aviation
2828 Donald Douglas Loop North, Santa Monica, CA 90405
Phone: 310-396-6770 Frequency: 122.95 MHz
Fuel – JetA, 100LL
Aeroplex
Self-serve Fuel Station
Fuel: 100LL
Located Southwest side of the fi eld
IMAGE CUT OFF
Arrival
Departure Runway 21
Departure Runway 3
Map Key
21
3
BUSINESS
PARK
For Noise Mitigation purposes,
cross the Airport boundary
at or above 900’ MSL
No Right Turns Prior to Shoreline
Santa
Monica
Pier
Li
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B
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L
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B
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Venic
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B
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SMO VOR
110.8
Marina del Rey
Golf C
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Helicopter Operations (Not for Navigational Use)
JET AIRCRAFT
Santa Monica Airport
Pilot’s Guide
Address: Santa Monica Municipal Airport
3223 Donald Douglas Loop South
Santa Monica, CA 90405
Phone: 310.458.8591
Noise: 310.458.8692
Noise Email: noise@smgov.net
Fax: 310.572.4495
Email: airport@smgov.net
Web: www.santamonicaairport.org
SMO Fly Neighborly, Fly Quietly www.santamonicaairport.org | 310.458.8591
Golf Course
Noise
Managment
Office
Airport
Administration
Building
Air Traffic
Control Tower
21
3
Runway
Runway SMO VOR 110.8
FBO
JET AIRCRAFT
AIRPORT DIAGRAM
ATTENTION: Turbine aircraft prohibited from parking
in the transient parking area in the vicinity of the
Airport Administration Building.
Contact the Airport Office for further information.
Atlantic Aviation
122.95MHz
Santa Monica Airport (SMO)
Fly Neighborly Program
Welcome to the neighborhood and the Santa Monica
Municipal Airport, one of the busiest single–runway general
aviation airports in the nation. We hope you will enjoy your
time with us. This brochure introduces you to the Santa
Monica Airport’s Fly Neighborly Program and will help you
operate your aircraft in the least impactful manner possible
while providing a safe environment.
The Airport is in the heart of a neighborhood surrounded
by over 130,000 residents. The City of Santa Monica is
proactively committed to its extensive noise mitigation
program, which includes a maximum allowable noise level,
limited aircraft operations hours, and requested VFR noise
mitigation fl ight paths and procedures. This brochure is
designed to assist you with compliance of these procedures;
helping you be a good neighbor.
The City and Airport staff recognize that pilots truly are the
key to a successful noise mitigation program. We greatly
appreciate your help and cooperation in making the Airport
a good neighbor.
DISCLAIMER: The procedures described in this brochure are not intended to
preempt the prerogatives or responsibilities of the pilot-in-command, confl ict with
safe aircraft operations, or interfere with ATC instructions or any domain that is the
exclusive authority of the FAA.
Photography courtesy of Cessna Aircraft Company.
Not to Scale
Contact Us
The following aircraft have been shown to be unable to
meet the maximum noise level of 95.0 dBA SENEL and are
permanently excluded from operating at Santa Monica Airport
after one violation and subject to misdemeanor prosecution:
Piaggio Aero P.180 Avanti (I&II), Aero Delfi no l-29, BAC Jet
Provost, North American B-17, B-25, Casa Saeta, De Havilland
Vampire, Venom, Sea Vixen, Douglas DC-9, A-4 Skyhawk,
English Electric Lightening, Folland, Gnat, Fouga CM 170
Magister, Gates Learjet 23, 24B, 24BA, 25, 25B, 25D, 25F, 28;
Gloster Meteor, Grumman F9F Panther/Couger, Gulfstream II,
IIB, III; Hansa HFB 320, Hawker Hunter, Jet Commander 1121,
IAI Westwind 1123, HS125-1A, 3A; Lockheed T-33/Canadian
Silver Star, Lockheed F-1-4 Starfi ghter, Lockheed 1329 Jetstar,
VC-121A Constellation; Morane-Saulnier Paris II, Mikoyan
Gurevich MIG 15, MIG 17, MIG 19, MIG 21; North American
F86/Canadair CL-13 Abre, North American Rockwell Sabreliner
39,40A, 60, 60A, 70, 75, 80. This list may be updated. Please
contact the Noise Management Offi ce for current aircraft list.
IFR Engine Start Procedures
Contact Ground Control on 121.9 MHz for IFR clearances.
Contact Ground Control one minute prior to actual engine
start. Do not start engines prior to advising ATC.
Auxiliary Power Unit (APU) Limitations
Limit APU usage to thirty (30) minutes.
Reverse Thrust Use
Use minimum reverse thrust necessary for safety.
Turbine Aircraft Parking Restrictions
Turbine aircraft prohibited from parking in the transient parking
area in the vicinity of the Airport Administration Building.
Contact the Airport Offi ce for further information.
Jet Aircraft Procedures
Mandatory Restrictions
The following procedures and limitations are enforced per the
City’s Aircraft Noise Ordinance. Violations may result in the
imposition of fi nes and/or exclusion from Santa Monica Airport.
Maximum Noise Level: 95.0 dBA Single Event Noise
Exposure Level (SENEL) as measured 2,200’ from either
ends of the runway.
Intersection departures are prohibited.
Formation takeoffs and landings are prohibited.
Prior Permission Required from the Airport Director
for dual wheel aircraft in excess of 60,000 lbs. MCLW
Call (310) 458-8591.
Mandatory Night Departure Curfew
No takeoffs or engine starts including Auxiliary Power Units (APU)
between 11pm and 7am Monday through Friday or until 8am on
weekends. Exceptions are allowed for bona fi de medical or public
safety emergencies only. Contact Airport Administration.
Voluntary Night Arrival Curfew
11pm and 7am Monday through Friday or until 8am on weekends.
Pilots are requested to avoid operations during this time period
due to the negative noise impact on the community.
Note: Compliance with the Airport Ordinance is mandatory unless deviations
are made necessary by weather, ATC instructions or clearances, infl ight
emergency or other safety considerations.
Santa Monica Airport Information
Frequencies
ATIS 119.15 MHz or (310) 450-4620
Tower 120.1 MHz (0700 to 2100 local)
Ground Control 121.9 MHz (0700 to 2100 local)
Unicom 122.95 MHz (after hours)
VOT 113.9MHz
SMO VORTAC 110.8 MHz
Traffi c Pattern
Left Traffi c Runway 21
Right Traffi c Runway 03
Pattern Altitude 1,370 feet MSL Single-Engine
1,870 feet MSL Multi-Engine
Instrument Approach Procedure
VOR or GPS-A Runway 21
RNAV (GPS) Runway 03 & 21
Airfi eld Information
Field Elevation 170 feet MSL
Runway 21 170 feet MSL
Runway 03 126 feet MSL
Runway Length/Width 3,500 feet X 150 feet (ASPH)
Runway Slope 1.2% down SW
Runway Lighting MIRLs, PAPI R03, REIL & PAPI R21
Maximum Weight 60,000 lbs. Maximum Certifi ed
Landing Weight (dual wheel)
Fixed Based Operators Providing Transient Services
Atlantic Aviation
2828 Donald Douglas Loop North, Santa Monica, CA 90405
Phone: 310-396-6770 Frequency: 122.95 MHz
Fuel – JetA, 100LL
Aeroplex
Self-serve Fuel Station
Fuel - 100LL
Located Southwest of the fi eld
Noise Monitor LocationsNoise Mitigation Policies
Warning—Listed Aircraft
Fly Neighborly, Fly Quietly Ph
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City Council
Report
City Council Meeting: August 8, 2017
Agenda Item: 3.M
1 of 7
To: Mayor and City Council
From: Rick Cole, City Manager, City Manager's Office, Administration
Subject: Santa Monica Airport Leasing and Licensing Policy
Recommended Action
Staff recommends that the City Council:
1. Approve the attached Santa Monica Airport Leasing and Licensing Policy for the
leasehold and license management of properties at the Santa Monica Airport
(Airport or SMO).
2. Authorize the City Manager to negotiate and execute leases at the Santa Monica
Airport in accordance with this Policy.
Executive Summary
On March 22, 2016, the City Council adopted an Airport Leasing and Licensing Policy
(Attachment A). Over the past year and a half, the Policy provided staff critical
guidance for pursuing the Council’s Strategic Goal of regaining local land use control
over the property presently occupied by the Santa Monica Airport . Moreover, the
existing Leasing Policy has been a financial success. As a direct consequence of the
Council’s decision to adopt the Airport Leasing Policy, the Airport is posi tioned to repay
the millions owed the City, repair and maintain facilities, and achieve long -term financial
self-sufficiency until it closes in 2028. Specifically, the Council’s decision to terminate
master tenants and charge market rates have produced a significantly increased
revenue stream.
Staff is recommending changes in the Leasing Policy that reflect changed
circumstances due to the Consent Decree with the Federal Government:
Terms:
Term for Aeronautical Service Providers. As stipulated by the Consent Decree
aeronautical service providers must be offered three-year lease terms.
2 of 7
Term for Non-Aviation Tenants. Lease terms may be month -to-month or longer.
However, no lease shall have a term that goes beyond December 31, 2028.
Lease Approvals & Delegation of Authority
The existing Policy grants the City Manager the authority to negotiate and
execute leases with terms ending no later than June 30, 2018. The proposed
policy would extend the same authority to the City Manager for leases
terminating on or before December 31, 2022.
The Airport Commission has voted to support these changes.
Background
Airport lands are divided into two categories: aviation and non-aviation. The Santa
Monica Airport has 187 acres designated and used for aviation activities and 40 acres
designated and used for non-aviation purposes. As of July 1, 2017, there are 383
tenants at the Airport. This includes a combination of offices, hangars, storage, land
leases, and tie-down tenant. There are approximately 60 vacant leasable spaces.
Lease and license revenues account for approximately 70% of total annual Airport
revenues. The revenue derived from Airport leasing supports the City’s goals of
achieving a financially self-sufficient airport, eliminating subsidies from the General
Fund, and repaying the principal and interest of past General Fund subsidies. In the
past, the Airport's operation, maintenance, and capital expenditures were subsidized by
the General Fund. As of June 30, 2017, the Airport has a debt obligation to the General
Fund of over $10M. Since FY 2013-14, the Airport Fund has no longer required an
operating subsidy from the General Fund.
3 of 7
On March 22, 2016, the City Council adopted an Airport Leasing and Licensing Policy
(Attachment A). Over the last 16 months, the Policy provided staff critical guidance
used to position the Airport into a much stronger financial condition.
On January 28, 2017, the City of Santa Monica and the U.S. Department of Justice, on
behalf of the Federal Aviation Administration, signed a settlement agreement regarding
the airport. On February 1st, U.S. Judge Walters approved the settlement agreement
thereby converting it into a Consent Decree (Attachment B). The Consent Decree
imposes two obligations that are relevant to leasing policy. First, the Consent Decree
requires the City to offer aeronautical service providers, such as Atlantic Aviation and
Kim Davidson Aviation, three-year lease terms based on market rates. Aeronautical
service providers offer a range of services, including flight schools, fueling,
maintenance, etc. The Consent Decree also obligates the City to adhere to FAA grant
assurance 22. FAA grant assurance 22 requires airport sponsor/owners to lease to
aviation users based on reasonable commercial terms.
Discussion
The City currently has a total of 383 tenants at the Santa Monica Airport that lease
hangars, tie-downs, office space, studio space, and storage. The Consent Decree
represents new circumstances at the Airport and therefore the Leasing and Licensing
Policy should evolve to reflect existing conditions. The proposed changes are
consistent with the Consent Decree:
Terms
For Aeronautical Service Providers: As stipulated by the Consent Decree
aeronautical service providers must be offered three-year lease terms.
For Non-Aviation Tenants: Lease terms may be month -to-month or longer;
however, no lease shall have a term that goes beyond December 31, 2028.
Lease Approvals & Delegation of Authority
4 of 7
The existing Policy grants the City Manager the authority to negotiate and
execute leases with terms ending no later than June 30, 2018. The proposed
policy would extend the same authority to the City Manager for leases
terminating on or before December 31, 2022.
Leasing Policy Review: July 2015 – July 2017
The existing Leasing Policy has been a financial success. As a direct consequence of
the Council’s decision to adopt the Airport Leasing Policy, the Airport is positioned to
repay the estimated $10M+ it owes the City, repair and maintain facilities, and achieve
long-term financial self-sufficiency until it closes in 2028. Specifically, the Council
decisions to terminate master tenants and charge market rates are the reasons for the
success.
In FY 2015/16, prior to the Leasing Policy, the Airport generated approximately $5.9M in
annual rent revenue. For FY 2017-18, staff estimates the Airport will produce $12.2M in
rental revenue by eliminating master tenants Gunnell Properties, American Flyers,
Krueger Aviation, partial elimination of Atlantic Aviation as a master tenant, and raising
rents to reflect market rates.
Continued Phasing Out of Master Tenants is Likely to Result in Increases in
Leasing Revenues
There are three leftover master tenants subleasing a mix of facilities at Santa Monica
Airport. A master tenant is considered a landlord of subtenants, meaning that a master
tenant is able to evict a subtenant, collect rent, set terms, etc. The three master tenants
at Santa Monica Airport combined have approximately 1 47 subtenants. Below is a
breakdown of the master tenants and their sub-tenants:
MASTER TENANTS AND THEIR SUBTENANTS: JULY 2017
MASTER TENANTS Hangars Tie-Down Office/Studio Total
Atlantic Aviation 22 0 3 25
Santa Monica Air Center 12 47 27 86
5 of 7
Santa Monica Art Studios 0 0 36 36
TOTAL 34 47 66 147
As directed by Council in March 2016, staff continues to eliminate all master tenancies
in a fair and reasonable manner for an orderly transition and to ensure the City has the
property management capacity required to assume the responsibilities. Of the three
remaining master tenants only Atlantic Aviation is an aviation master tenant. Staff
intends to phase out the remaining master tenants during FY 2017-18. An orderly
transition provides the City the time needed to build the management capacity required
to assume the added responsibilities.
Staff believes leasing revenues at the Airport will increase, albeit at a much slower pace
than over the last two years, during FY 17-18 due to several on-going lease
negotiations. For instance, assuming Atlantic Aviation and the City agree to terms on a
three-year lease for its facility per the Consent Decree, staff anticipates the City will
realize greater revenue from the premises occupied by Atlantic Aviation for two reasons.
First, Atlantic Aviation’s rent is likely to be adjusted upward to reflect market rates and
second the City will be transitioning Atlantic’s sub-tenants into direct tenants of the City.
In addition to lease negotiations with Atlantic Aviation, the City is or soon will be in lease
negotiations with Santa Monica College and Santa Monica Air Center. Santa Monica
Art Studios will also be renegotiated and the new terms may lead to an increase in
future revenues.
Operating and Capital Expenditures Are Projected to Increase
As forecast in March 2016, staff report, having the City take over as a direct landlord
has increased real estate brokerage fees, property management fees, and capital
expenditures. In response to the increase in property management responsibilities and
real estate brokerage duties, the City hired Aeroplex Property Management and
Commercial Management Group following the competitive bidding process. In FY
2017-18, staff has budgeted $500,000 to cover property management fees and real
estate brokerage fees.
6 of 7
Expenditures for capital improvements, repairs, maintenance and replacement now, and
will into the foreseeable future, consume significant capital due to the poor condition of
the facilities formerly managed by the above master tenants. In order to determine the
magnitude of the problem, staff intends to perform a comprehensive facilities condition
assessment (FCA) in FY 17-18. The runway shortening project will also require
significant funding. With proper management, vigilant oversight, and prudent fiscal
restraint, staff is confident the Airport will be able to maintain aviation facilities up to
standard, repay its debt, and maintain a safe airport, until it closes in 2028.
Alternatives
Staff identifies three possible alternatives:
1. The City Council may consider not adopting the proposed Leasing Policy. If the
new amended policy is not adopted, the City Manager would be prohibited from
offering leases beyond June 30, 2018.
2. The City Council may consider amending the Leasing Policy as it deems
appropriate.
3. The City Council may consider returning the Leasing Policy to the Airport
Commission, if necessary, and as appropriate, for additional input ..
Actions of the Airport Commission
At its August 1, 2017 special meeting, the Airport Commission voted to recommend that
City Council adopt the Airport Leasing Policy as presented to the Airport Commission.
Financial Impacts and Budget
There are no immediate financial impacts or budget authorization required as a result of
adopting the Santa Monica Airport Leasing and Licensing Policy. However, staff will
return to Council during FY 17-18 mid-year budget cycle if specific budget changes are
required.
7 of 7
Prepared By: Nelson Hernandez, Senior Advisor for Airport Affairs
Approved
Forwarded to Council
Attachments:
A. Airport Leasing and Licensing Policy
B. Consent Decree
C. Written Comments
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 1 of 51
Responses to Comments
Following publication of draft Minimum Standards for Commercial Aeronautical
Services at Santa Monica Municipal Airport (the “Minimum Standards”), the City of
Santa Monica received comments suggesting changes to the Minimum Standards
from the individuals and entities listed in Table 1. The City thanks all of the
commenters for their interest in and comments on the Minimum Standards. The
City has reviewed and carefully considered all of the comments received. This
document organizes the comments received by the section of the Minimum
Standards to which they refer, and provides the City’s responses. Where the City has
proposed a change in response to a comment, the change is reflected in the
attached redlined copy of the Minimum Standards (the “attached redline”).
Table 1 Minimum Standards Comment Index
Letter
No. Commenter Date
1 National Business Aviation Administration (“NBAA”), Aircraft Owners and Pilots
Association (“AOPA”), and the Santa Monica Airport Association (“SMAA”) (referred to
collectively below as “NBAA”).
02/09/18
2 Santa Monica Flyers 01/25/18
3 David M. Shaby II 01/22/18
4 Kami Pahlavan, Kapa International 01/31/18
5 Steve Schwartz, Aerista 01/25/18
6 Members of the Public During Community Meetings 02/10/18
7 Lael Rubin 02/19/18
8 Andrew Wilder 02/20/18
9 Peter Donald 02/20/18
10 Ellen Hannan 02/23/18
11 Ken (D Davis) 02/23/18
12 Julie Adelson 02/23/18
13 Alan Levenson 02/23/18
14 Chris Waller 02/24/18
15 Mindy Taylor-Ross 02/26/18
16 Ben Wang 03/01/18
17 Lisa Sandbank 03/02/18
18 Robert W. Pann 03/02/18
19 Lara Osment 03/02/18
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 2 of 51
Letter
No. Commenter Date
20 Lorri Benson 03/02/18
21 Tom Lynch 03/02/18
22 Ammar Lughod 03/02/18
23 Joseph Hardin 03/02/18
24 Stephen Manes 03/02/18
25 David Abramis and Iris Souza 03/02/18
26 Peter Altschuler 03/02/18
27 Michael Grecco 03/03/18
28 Tina Grossman 03/03/18
29 Steve Naftali 03/03/18
30 Sylvia Rath 03/04/18
31 John Ventura 03/03/18
32 Joe Schmitz 03/05/18
Comment 1. Purpose of Minimum Standards (Minimum
Standards, § 1, Purpose)
The City received the following comment:
Page 1 – 3rd paragraph, 2nd sentence “These Minimum Standards are designed to
promote good service and fair competition at the Airport and to discourage
unqualified applicants.” Suggestion: Eliminate the word “discourage” and replace
with “prevent.”
City’s Response to Comment 1:
As shown in the attached redline, the City has made the requested change and
further modified this sentence to make clear that a purpose of the Minimum
Standards is to prevent unqualified applicants from operating at the Airport.
Comment 2. Interaction with Leasing Policy (Minimum
Standards, § 1, Purpose)
The City received the following comment:
The draft asserts that it is subordinate to, and that commercial tenants must comply
with, the City’s Airport Leasing and Licensing Policy. But as NBAA, among others,
previously has noted (i.e., in the March 17, 2016 letter from NBAA Chief Operating
Officer Steve Brown), many of its provisions are directly at odds with the airport’s
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 3 of 51
ongoing obligations to the FAA, such as the policy’s provision that aeronautical uses of
SMO must be compatible with adjacent land uses (a 180° inversion of FAA
requirements). Simply put, the policy is not reasonable nor relevant, but rather is
unjustly discriminatory.
City’s Response to Comment 2:
The commenter references a letter commenting on a 2016 version of the Santa
Monica City Council Airport Leasing and Licensing Policy, which has since been
updated. See https://www.smgov.net/uploadedFiles/Departments/Airport/
AIRPORT%20LEASING%20AND%20LICENSING%20POLICY.pdf (Last revised: Aug.
2017). Both the Airport Leasing Policy and the Minimum Standards, are subordinate
to the Consent Decree reached between the City and the FAA, as reflected in the
Minimum Standards, Section 1 (Purpose) and the Airport Leasing and Licensing
Policy. For example, the Airport Leasing Policy includes within authorized uses those
“uses required by the Consent Decree.” To the extent the commenter has comments
on the Airport Leasing Policy, those concerns can be raised separately. The City
disagrees that any aspects of the Minimum Standards or the Airport Leasing Policy
are unreasonable, irrelevant, or unjustly discriminatory.
Comment 3. Airport Operations Handbook (Minimum
Standards, § 1, Purpose)
The City received the following comment:
Please also note that the Santa Monica Airport Operations Handbook was last updated
in 2008 (and is no longer available from the City website), but so far as we are aware
includes the most current statement of the airport’s requirements for commercial
aeronautical services. The draft does not make clear if it is intended to replace those
sections of the handbook, and how/if the handbook will be updated to reflect the
adoption of minimum standards and other changed circumstances at SMO.
City’s Response to Comment 3:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment by specifying that the Santa Monica Airport
Operations Handbook is intended to be subordinate to these Minimum Standards,
and to the extent that any conflict between the two documents arises, the Minimum
Standards control.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 4 of 51
Comment 4. Space at the Airport (Minimum Standards,
§ 1, Purpose)
The City received the following comment:
Page 1 - 4th paragraph, 1st sentence. “It is the City’s policy to extend the opportunity to
provide aeronautical services to any person or entity meeting the City's Minimum
Standards for such services at the Airport, subject to availability of suitable space at
the Airport (as determined by the City) to accommodate such activities, and subject to
the City’s rights under the Consent Decree.” Suggestion: This wording contradicts
Section 4(d) and 4(g) on page 5.
City’s Response to Comment 4:
The City declines to revise the referenced sentence. The City disagrees that this
sentence regarding the purpose of the Minimum Standards presents any conflict
with Sections 4.d and 4.g, which provide reasons why the Airport Director may
determine that it is appropriate to deny an application to provide aeronautical
services, namely, where the proposed activity would conflict with existing
aeronautical uses or could be detrimental to the Airport.
Comment 5. Right to Amend Standards (Minimum
Standards, § 1)
The City received the following comment:
Page 2 – “Right to Amend Standards”. Question: Can we impose the minimum
standards upon current tenants if the City provides current tenants with reasonable
notice (6 months)?
City’s Response to Comment 5:
As shown in the attached redline, the City has added language to the Minimum
Standards (Section 1, Applicability) to address the issue raised by this comment and
clarify how the Minimum Standards apply to current tenants, new tenants, and
entities currently engaging in activities covered by the Minimum Standards without
a lease, license, permit, or agreement. The City has also added language to address
the application of any subsequent amendments of the Minimum Standards.
Comment 6. City’s Discretion (Minimum Standards, § 1,
Waivers)
The City received the following comment:
Multiple times throughout the current draft, the Airport Director and/or City (or a
"designee") has the ability to waive any or all of some of the requirements at their sole
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 5 of 51
discretion and determination. That could lead to inconsistent--and therefore unfair--
application of these standards. Moreover, if these are intended to be "minimum"
standards then they need to be enforceable, and consistently enforced. Please remove
these waivers in order to ensure that all tenants, operators, and businesses will be
consistently and fairly held to the same standards.
The same commenter further stated:
As mentioned above, if the Airport Director can waive any requirement then the
minimum standards are meaningless. Safety, accountability, security, and insurance
standards should not be waivable.
However, I recognize the potential need to be able to waive, temporarily, some minor
requirements (such as the example of a specialized mechanic needing access to the
airport to service a specific aircraft), but the way this section is currently written is far
too malleable. It must have some kind of limiting mechanism.
As a potential solution, I propose a 72-hour time limit on any waivers. The last
sentence in this section could be changed to read:
"The Airport Director may also waive any of the Minimum Standards for up to 72
hours for any non-governmental Operators if the Airport Director deems such a waiver
to be in the best interest of the City."
The City also received the following comment:
The draft also provides that the Airport Director may deny an application to provide
commercial aeronautical services at SMO if “the proposed activity would require the
City to spend funds or to supply materials or manpower that the City would prefer not
to spend or supply,” and also may waive any of the minimum standards “if the Airport
Director, in his or her sole discretion, deems such a waiver to be in the best interest of
the City.” Provisions such as these inappropriately give SMO and the City unfettered
discretion to ignore the minimum standards and the interests of aviation, and to
violate the airport’s ongoing obligations to the FAA.
The City also received the following comment:
Page 2 – “Waivers” Last sentence. Suggestion: Can we include language that,
excluding emergency waivers, that the City has to provide the information to the
Airport Commission of the waiver and the need of such waiver.
City’s Response to Comment 6:
It is appropriate for the City to retain the ability to waive the requirements of the
Minimum Standards when warranted. Although the Minimum Standards apply to all
Operators, the City recognizes that it may be appropriate to modify requirements of
the Minimum Standards based on fact-specific circumstances that the City may not
be able to foresee at the time of drafting these Minimum Standards. The inclusion
of a waiver provision does not mean that the Minimum Standards are
unenforceable, but instead that the Airport Director or City Manager (as applicable)
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 6 of 51
may allow for flexibility in the application of these Standards where warranted by
applicable facts and circumstances.
The Airport and the City do not have, as NBAA alleges, “unfettered discretion to
ignore the Minimum Standards and the interests of aviation, and to violate the
airport’s ongoing obligations to the FAA.” As the Minimum Standards explicitly
state, the City is subject to the existing Consent Decree, in addition to the Leasing
Policy, the City’s Charter and its Municipal Code, and other applicable federal, state
and local laws. Within the boundaries provided by that Consent Decree and those
laws, the City may properly act within its role as proprietor of the Airport and make a
determination to waive the requirements of the Minimum Standards in appropriate
circumstances.
As shown in the attached redline, the City has added additional language requiring
that long-term waivers for the duration of a lease must be approved by the City
Manager. The City declines to limit waivers to 72-hours only, because some
extended waivers may be warranted.
With respect to the request that information regarding waivers, other than
emergency waivers, be provided to the Airport Commission, the City notes that the
approval of leases and permits at the Airport is reviewed by the Airport Commission,
and the terms are explained to the Commission before it considers those
documents. The documents related to that review are publicly available before their
approval. As shown in the attached redline, the City has added additional language
to ensure that any proposal for a waiver is specifically noted in any public document
submitted to the Airport Commission or City Manager. As a result, the public will be
on notice regarding any proposed waiver, and may comment on it at the
appropriate public meeting as lease and permit approvals come before the Airport
Commission.
Comment 7. Credit Reports (Minimum Standards § 2.3.c)
The City received the following comment:
On page 4, section 2, Item 3.c. requires the applicant to provide a current credit report
covering all business activities within the past ten years. This is vague & ambiguous. If
it means a business credit report from Dun & Bradstreet, that is something the
granting party, in this case the airport should request and receive not the applicant. If
it means something else such as providing reference then it should be defined and
explained. Please clarify what you mean by credit report and what kind of credit report
you are requesting.
City’s Response to Comment 7:
As shown in the attached redline, the City has addressed the concern raised by this
comment by adding to § 2.3.c language specifying that the requirement to provide a
credit report may be satisfied by an applicant submitting a fee as part of its
application so that the City may run its required credit report check.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 7 of 51
Comment 8. Grounds for Application Denial (Minimum
Standards § 2.4.e)
The City received the following comment:
The language..."the City would prefer not to spend or supply" could give too much
wiggle room to the City and could be viewed as arbitrary. How would the City make
this determination? Perhaps something along the lines of ... "in its discretion" …
City’s Response to Comment 8:
The language concerning what the City would “prefer not to spend or supply” is
intended to capture an instance in which an applicant may propose a type of
covered operation that, to be safely or successfully administered at the Airport,
would require the City to expend funds. In some circumstances, a proposal may
overlap with the City’s interests at the Airport and the City may be willing to
contribute resources, but for other proposals the City may not be interested in
expending resources. The City agrees that it would be helpful to clarify this
language, and, as shown in the attached redline, has added the phrase “in its
discretion.”
Comment 9. Grounds for Application Denial (Minimum
Standards § 2.4.g)
The City received the following comment:
Page 5 – Section 4(g) this sentence is vague specifically the part that states “could be
detrimental to the Airport.”
City’s Response to Comment 9:
The noted language in Section 2.4.g describes a determination left to the discretion
of the Airport Director regarding what types of activities would be detrimental to the
Airport. Because this determination must be based on the particular application at
hand, the language in Section 2.4.g is intended to provide the Airport Director with
sufficient flexibility to make such a determination in his or her best judgment. The
City declines to revise this section of the Minimum Standards.
Comment 10. Grounds for Application Denial (Minimum
Standards § 2.4.g)
The City received the following comment:
The proposed service activities could be detrimental..." Again, how would the City
make this determination? What are the guidelines?
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 8 of 51
City’s Response to Comment 10:
The language noted in the comment is intended to provide for appropriate
implementation in fact-specific circumstances. The Airport Director, in his or her
experience and discretion, may deny an application based on his or her assessment
that such activities could be detrimental to the Airport.
Comment 11. Grounds for Application Denial (Minimum
Standards § 2.4.m)
The City received the following comment:
Page 5 – Section 4(m). Question: Can we legally deny an application when a person
was convicted of any felony?
The City also received the following comment:
The applicant has been convicted of any felony. Do you want a time period or the type
of felony or related to a crime of violence or moral turpitude?
City’s Response to Comment 11:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments by providing that an application may be denied
where the applicant has been convicted of any felony or misdemeanor involving
moral turpitude, and specifying that the Airport Director retains discretion to
disregard a conviction based on consideration of specific circumstances, including in
particular the time elapsed from the conviction. As modified, this provision is
consistent with California Labor Code Section 432.7, California Government Code
Section 12952, and Santa Monica City Council Resolution 10898 (July 28, 2015), all of
which address consideration of criminal convictions for purposes of contracting,
leasing, and/or employment.
Comment 12. Appeals (Minimum Standards § 2.4)
The City received the following comment:
Under Section 2.4, the document states, "The Airport Director may deny any
application to provide aeronautical services at the Airport if, in his or her sole
discretion, the Airport Director determines that..." Is there an opportunity for the public
or the applicant to appeal a decision made by the Airport Director?
City’s Response to Comment 12:
The Minimum Standards do not contain language regarding appeals of decisions
made by the Airport Director. Santa Monica Municipal Code Section 10.04.06.030,
however, specifies that, after presentation to the Airport Director, applications for
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 9 of 51
commercial operations permits are considered by the Airport Commission before
issuance of a permit by the City Manager, and that decisions by the City Manager to
either grant or deny an operations permit are final, subject to judicial review.
Comment 13. Denials of Applications (Minimum
Standards § 2.4)
The City received the following comment:
Under Section 2.4, consider adding the following additional subsection: "the applicant
is in violation or will be in violation of applicable environmental rules and
regulations."
City’s Response to Comment 13:
As shown in the attached redline, in response to Comment 55, in the interest of
highlighting the importance of environmental compliance, the City has added a new
Section 3.14 that specifically references compliance with environmental laws and
regulations as a general requirement. With this new Section 3.14 in place, it is clear
that existing language in Section 2.4 allows the Airport Director to deny an
application if applicable environmental rules or regulations have been violated.
Section 2.4.h provides that the Airport Director may deny an application because the
applicant has violated “any of these Minimum Standards” or “any other statutes,
regulations, ordinances, laws or orders applicable to the Airport or any other
airport.” Under this section, if an applicant had violated an environmental rule or
regulation applicable to their operations in Santa Monica, that violation and/or the
resulting violation of new Section 3.14 would be an appropriate grounds for denial.
Given this, the City declines to add the proposed language to Section 2.4 because
the City believes the addition of new Section 3.14 and the existing language in
Section 2.4 sufficiently address the concern raised by this comment.
Comment 14. Nondiscrimination (Minimum Standards
§ 3)
The City received the following comment:
Add a requirement to include a robust non-discrimination policy for all operators,
tenants, users, and leaseholders.
Long Beach Airport includes this in their standards. 2.8.1 (page 7) The Long Beach
language is a good start, but "sexual orientation" and "gender identity" need to be
added to the list:
2.8.1 Operator shall not discriminate against any person or class of persons by reason
of race, creed, color, national origin, sex, age, [sexual orientation, gender identity,] or
physical handicap in providing any products, services, or facilities or in the use of any
of its facilities that are available to the public, or in any manner prohibited by
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 10 of 51
applicable regulatory measures including without limitation Part 21 of the Rules and
Regulations of the office of the Secretary of Transportation effectuating Title VI of the
Civil Rights Act of 1964, as amended or reenacted.
City’s Response to Comment 14:
As shown in the attached redline, the City has addressed the concern raised by this
comment by adding new Section 3.12 (Nondiscrimination).
Comment 15. Americans with Disabilities Act (Minimum
Standards § 3)
The City received the following comment:
Add a requirement that all entities must comply with the Americans with Disabilities
Act.
City’s Response to Comment 15:
As shown in the attached redline, the City has addressed the concern raised by this
comment by adding new Section 3.13 (Americans with Disabilities Act Compliance).
Comment 16. Equipment (Minimum Standards § 3.4.a)
The City received the following comment:
Page 7, Section 3, Paragraph 4a: This paragraph states that all equipment must be
clearly designated with the name and logo of the operator. That language is unduly
broad. Does that mean that the Operator’s logo has to be prominently displayed on
every screwdriver and wrench? There is already a requirement that aircraft tugs and
vehicles display the operator’s name and logo. I think that that is sufficient.
The City also received the following comment:
Section 3.4 - we have no equipment (other than computers and phones)
City’s Response to Comment 16:
As shown in the attached redline, the City has addressed the concern raised by these
comments by modifying this section to make clear that the requirement of an
Operator name and logo on equipment need not extend to “every screwdriver and
wrench,” or to computers and phones or administrative supplies, but rather is limited
to heavy equipment.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 11 of 51
Comment 17. Equipment Towing (Minimum Standards
§ 3.4.b)
The City received the following comment:
Page 7, Section 3, Paragraph 4b: The way that this is worded is too onerous on the
Operator. It should apply to only towing that is being conducted off of the leased
premises and onto general airport property. Towing an aircraft a few feet within the
leasehold premises should not be subject to these requirements.
City’s Response to Comment 17:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment.
Comment 18. Vehicle Permits and Registrations
(Minimum Standards § 3.4.c)
The City received the following comment:
The commenter wrote that this section’s language stating “must have permits and any
required registrations” should be changed to “must have permits or any required
registrations,” since “street legal” vehicles will not be permitted.” The commenter also
wrote that this Section should state that persons operating such vehicles should be
trained under the Airport’s driver safety training program, “should the Airport require
such a training.”
The City also received the following comment:
On page 7, section 3, Item 4.c. requires that all vehicle driven on the airport property
to have “Permit and any required registration”. What permit are you referring to in
addition to the registration? What about golf carts which are not street legal but
allowed and encouraged in the airport property? They are a vehicle which needs
neither a permit nor a registration. Suggestion would be to change the requirement to
have “permit or registration if applicable or required by state or federal law”.
City’s Response to Comment 18:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 12 of 51
Comment 19. Personnel Uniforms (Minimum Standards
§ 3.5a)
The City received the following comment:
Page 8, Section 3, Paragraph 5a: Requiring employees to display an aircraft ID badge
at all times is unduly restrictive. There is already a requirement that they be in
uniform. All this will do is create an environment where aircraft ID badges will be lost,
which could cause a big problem with security and unauthorized airport entry.
The City also received the following comment:
"Requiring all non-management personnel to wear uniforms is unnecessarily
restrictive. CFIs and Office Staff should not be required to wear uniforms. Statement
should be qualified to say that "non-administrative/teaching operations staff working
on the field or apron".
City’s Response to Comment 19:
As shown in the attached redline, the City has modified this section to address the
concerns noted in these comments. In general, the Minimum Standards require all
Operators and their employees to carry their Airport ID badge on their person at all
times, which is a necessary, appropriate, and not overly-burdensome security
measure. As modified, the Minimum Standards do not require administrative
personnel to wear a uniform, but all non-administrative personnel in the AOA must
wear clothing, hats, etc. with a display of identification of the Operator in letters of
sufficient size and contrast to be easily legible. This requirement is appropriate to
ensure that personnel conducting operations in the AOA can readily be identified to
the Operator for whom they are performing those operations.
Comment 20. Personnel “On Duty” (Minimum Standards
§ 3.5b)
The City received the following comment:
An adequate number of qualified...What is adequate or perhaps another descriptor.
The City also received the following comment:
"On duty" should be qualified as "on location or via telephone". It would be
unreasonable to expect staff to be on duty, at the airport, ""at all times".
City’s Response to Comment 20:
Section 3 provides generally that the number of personnel on duty must be
“adequate.” More specific information regarding the number of personnel required
is set forth in more specific provisions applicable to particular types of Operators.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 13 of 51
As shown in the attached redline, the City has modified this section in response to
these comments to specify that personnel must be on duty at all times “of
operation,” rather than at all times. The City believes it is reasonable to expect staff
to be on duty at all times of operation. The aeronautical uses conducted at the
Airport involve significant safety requirements, and it is reasonable that personnel
from an Operator be required to be on site during operations.
Comment 21. Supervisor “On Duty” (Minimum Standards
§ 3.5.c)
The City received the following comment:
"On duty" should be qualified as "on location or via telephone". It would be
unreasonable to expect a supervisor be on duty, at the airport, when "any aeronautical
services are being performed by the Operator".
City’s Response to Comment 21:
With respect to supervisors, the City agrees that it may be overly burdensome to
require a supervisor on site at all times during operations. However, it is important
for safety and notification purposes that a supervisor be available to be contacted by
the Airport and by the Operator’s personnel. As shown in the attached redline, the
City has revised this section to reflect that a supervisor may be offsite but available
by phone, if the Operator provides the Airport with phone numbers for supervisors
and a schedule of supervisor availability.
Comment 22. Written Training Programs (Minimum
Standards 3.5.d)
The City received the following comment:
"This requirement is unreasonably burdensome. It would be extremely time consuming
to draft a written training program for all tasks/responsibilities of all CFIs, all office
staff, all operations staff and all management staff. It might be reasonable to expect a
simplified version of this — say a list of responsibilities and expectations/standards —
of applicants.
The City also received the following comment:
On page 8, section 3, Item 5.d. requires that each operator to establish a written
training program to ensure all employees are thoroughly trained and “qualified” to
perform the aviation task they are assigned to. This is vague, ambiguous and most
importantly burdensome. While it is understood some aviation task may be safety
sensitive or highly specialized and need special training, indeed not all aviation task
needs special training. What if an employee is tasked to clean the aircraft or its
windshield only? What kind of written training program shall be put together?
Generalizing such requirement and to apply it to all task for all employees is indeed
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 14 of 51
unnecessary and burdensome. My suggestion would be to limit such requirement to
highly specialized or safety sensitive aviation tasks.
The City also received the following comment:
Section 3.5d - training program is n/a because only personnel are salespeople
City’s Response to Comment 22:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments and to provide more detail regarding
appropriate job requirements, skills, and safety precautions to be documented for
various job types.
Comment 23. Insurance Requirements (Minimum
Standards § 3.6)
The City received the following comment:
Cut this paragraph entirely. The insurance minimum standards should never be
allowed to be waived.
The City also received the following comment:
Section 3.6 - our business activities render the following insurance requirement moot
and I would ask for a waiver of these 3 insurance requirements:
- hangar keepers: out policy does carry hangar keepers at $100k aircraft/occurrence.
But we rarely, if ever, touch airplanes, and those we do touch have hull values that
would never incur a claim against hangar keepers greater than $100k. So the
$250k/$500k requirement is overkill
- business interruption: all of our business is conducted via phone and computer. If I
lost access to the airport office for any length of time, it would have zero impact on my
ability to conduct business. So purchasing this type of insurance is overkill.
- property insurance: in the same vain, our only property is a computer and some
furniture. It's not worth enough to insure.
City’s Response to Comment 23:
The City believes that in certain circumstances that it may not be able to foresee, it
may be appropriate to waive, reduce or modify certain insurance requirements
depending on the facts presented, and thus the ability to grant such a waiver should
remain in the Minimum Standards. However, the City recognizes the first
commenter’s concern that waiver may lead to operations at the Airport that lack any
insurance, which would be inappropriate. As shown in the attached redline,
therefore, the City has added language stating that in no circumstance may an
Operator be permitted to operate at the Airport with no insurance and modified the
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 15 of 51
language to make more clear that insurance requirements must be met prior to
commencing service and throughout the term of activities at the Airport.
In response to the second commenter, the City has added a new Section 11 to the
Minimum Standards relating to Aircraft Sales Operators, and will be adding an
Aircraft Sales Operator category to the Minimum Insurance Requirements Matrix set
out in Appendix B-1 to address insurance requirements more tailored for such
Operators.
Comment 24. Security Plans (Minimum Standards § 3.7.b)
The City received the following comment:
Section 7b - I doubt we need a security plan, given the nature of our business. But, if
so, I'd ask for the City to provide an example that would be appropriate for our type of
business.
City’s Response to Comment 24:
The City declines to modify the language of Section 3.7.b because the City believes
that all Operators at the Airport must maintain a security plan. However, that
security plan should be tailored to the nature of the Operator’s operations, the
facilities on site, the value of equipment on the Operator’s premises, and the security
risks associated with such equipment. Operators may present the security plans
they believe most appropriate for their operations to the City for review.
Comment 25. Subcontracting (Minimum Standards § 3.8)
The City received the following comment:
Why the 180 days?
City’s Response to Comment 25:
Subcontracting is only permitted with approval of the Airport Director. The 180-day
limitation on subcontracting (subject to renewal with the Airport Director’s
permission) is included in the Minimum Standards to strike a balance between
commercially reasonable needs that may arise for Operators to subcontract, and the
City’s interest in ensuring that subcontracting arrangements at the Airport do not
undermine the purposes of these Minimum Standards by continuing indefinitely.
Comment 26. Subleasing (Minimum Standards § 3.9)
The City received the following comment:
Change this section to: "Subleasing shall be prohibited."
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 16 of 51
The City also received the following comment:
Page 9 – Section 9. Let’s change that to “No subleasing”. Currently we don’t have any
subleases for commercial operators at the airport.
City’s Response to Comment 26:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments. In particular, the City has modified the title of
this section to be “No Subleasing,” and has updated the text of the provision as well.
Comment 27. FBO Subcontracting (Minimum Standards
§ 4.15)
The City received the following comment:
Just as sub-leasing is no longer allowed, subcontracting should not be allowed either.
Change entire paragraph to:
"An FBO may not subcontract any fueling services or other services that it is
authorized or required to provide."
City’s Response to Comment 27:
The City declines to make the requested change because it believes that the section
as currently drafted appropriately provides the Airport Director with discretion,
should particular circumstances warrant, to allow FBOs to subcontract fueling and
other services.
Comment 28. FBO Prohibited Activities – Non-Aviation
Products (Minimum Standards § 4.16.b)
The City received the following comment:
Page 12, Section 4, Paragraph 16b: This paragraph could be construed to prohibit the
sale of caps and T-shirts that bear the Operator’s name and logo. This paragraph
should be changed to read: “Sale of non-aviation related products”.
The City also received the following comment:
Section 4, FBO Minimum Standards, Item 16b, Page 12, prohibits the sale of all non-
aviation products; it sweeps too broadly and would prohibit sale of amenities and
accessories such as food and beverage products (i.e. vending machine snacks, sodas,
etc.; shirts and hats with the operator’s logo, etc.).
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 17 of 51
City’s Response to Comment 28:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments.
Comment 29. FBO Prohibited Activities: Airshows
(Minimum Standards § 4.16.c)
The City received the following comment:
Air Shows should be separated out and expressly prohibited, with no waiver option
City’s Response to Comment 29:
As shown in the attached redline, the City has modified this section to make clear
that air shows and meets are a prohibited activity by an FBO, with no ability for the
Airport Director to approve them. Film shoots, displays, and other public gatherings
have been split out into a separate section to make clear that these are generally
prohibited, but may be permitted with express written approval from the Airport
Director.
Comment 30. FBO Prohibited Activities: Meets, Displays,
or Other Public Gatherings (Minimum Standards § 4.16.c)
The City received the following comment:
Meets, displays, or other public gatherings should have express insurance
requirements/coverage
City’s Response to Comment 30:
See City response to Comment 29 above. With respect to insurance, the City
believes that the insurance requirements already in place for FBO operators are
sufficient to cover these types of activities. To the extent a particular activity of this
type is determined to require additional insurance, the Airport Director may require
it as a condition of approving the activity.
Comment 31. FBO Prohibited Activities – Hazardous
Materials (Minimum Standards § 4.16.f)
The City received the following comment:
Page 12, Section 4, Paragraph 16f: Again, the way that this is written is unduly
restrictive. It should read: “Storage of Hazardous Materials other than fuel and oil,
liquid industrial waste or any other regulated waste that does not fully comply with all
applicable environmental laws”.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 18 of 51
City’s Response to Comment 31:
The City declines to make the requested modification. This section does not
prohibit the storage of hazardous materials (including fuel and oil), liquid industrial
waste or other regulated waste necessary for operations at the Airport so long as
such storage complies with all applicable environmental laws. If such storage of
materials is prohibited under environmental laws, or does not comply with them,
then it is prohibited by these Minimum Standards. Certain Operators may store fuel
and oil at the Airport subject to the terms set forth in these Minimum Standards, and
in such instances must comply with environmental laws as well.
Comment 32. FBO Prohibited Activities: Fuel Farms
(Minimum Standards § 4.16.g)
The City received the following comment:
Construction of a fuel farm should require City Council approval (not just Airport
Director or City Manager approval). Specifying "of the City" is unclear.
City’s Response to Comment 32:
As shown in the attached redline, the City has modified this section to make clear
that the required approval is that of the Airport Director. The City believes that this
is an operational decision that should be made at the operational level by the
Airport Director. See also City responses to Comments 58 and 64.
Comment 33. FBO Prohibited Activities – Parking
(Minimum Standards § 4.16.i)
The City received the following comment:
Section 4, FBO Minimum Standards, Item 16i, Page 12, is too restrictive as written. We
suggest the following language “Parking, storing or allowing the parking or storage of
any vehicles on the Premises that are not used in the daily operation of the general
aviation business permitted to be conducted on the premises, unless said vehicles are
owned or operated by Operator’s customers and/or employees.”
The City also received the following comment:
Page 12, Section 4, Paragraph 16i: The way that this paragraph is written could be
interpreted to mean that employees may not park their personal vehicles on the
premises. Thus, it is too restrictive. A suggested change is as follows:
Parking, storing or allowing the parking or storage of any vehicles on the Premises
that are not used in the daily operation of the general aviation business permitted to
be conducted on the premises, unless said vehicles are owned or operated by
Operator’s customers and/or employees.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 19 of 51
City’s Response to Comment 33:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments and allow for customer and employee parking
on an Operator’s premises.
Comment 34. FBO Required Experience (Minimum
Standards § 4, Min. Std. 1)
The City received the following comment:
Page 12, Minimum Standards, paragraph 1: The experience requirement of five years
as listed is too onerous and restrictive. That would effectively prevent the opening of
any new FBO on the field. I can envision a situation where a supervisor with 20 years
on the job running an aircraft refueling business is hired by a newly formed FBO, to
run the fueling operation. A suggested change is as follows:
1. Experience. An Operator proposing to operate as an FBO shall have a minimum of
five years experience as an FBO, including the fueling of aircraft unless the Airport
Manager is satisfied that proposed FBO has the knowledge and experience through its
key personnel as is required to maintain safety and efficiency in conducting of the FBO
business.
City’s Response to Comment 34:
As shown in the attached redline, the City has modified this section to address the
concerns raised by this comment and provide the Airport Director flexibility, under
appropriate circumstances, to allow an Operator to operate as an FBO without a
minimum of five years’ experience.
Comment 35. FBO Required Space (Minimum Standards
§ 4, Min. Stds. 2, 3, and 4)
The City received the following comment:
Page 13, Minimum Standards, paragraphs 2, 3, 4 and 5: The minimum area of 144,000
ft.², the 6000 ft.² of lounge, offices, pilot waiting areas, etc. and the paved aircraft
parking of 30,000 ft.² along with the 20 customer parking spaces is excessive and
unduly restrictive. Would the old American Flyers FBO have qualified?
City’s Response to Comment 35:
The City declines to modify the space requirements set forth in these sections
because it believes they are not excessive or unduly restrictive, and reflect the
amount of space appropriate for FBOs to provide specified services. The City notes
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 20 of 51
that American Flyers was a self-service fuel pump Operator, not an FBO.
Comment 36. FBO Environmental Testing (Minimum
Standards § 4, Min. Std. 6.d)
The City received the following comment:
Page 13, Minimum Standards, paragraph 6d: I cannot think of a situation where in
FBO should be required to perform environmental testing off of the airport grounds.
Why is that included in there?
City’s Response to Comment 36:
The City declines to modify the environmental testing requirements set forth in this
section because it believes that, in particular circumstances, FBOs should be required
to perform environmental testing off of airport grounds. For example, should the
City or an Operator become aware that hazardous or potentially hazardous materials
are being or have been released at an Operator’s site, and migrated from that site to
locations off of the airport grounds, it would be appropriate and likely required by
law that the Operator perform environmental testing to assess the release and its
impact both on and off Airport grounds.
Comment 37. FBO Mobile Dispensing Equipment
(Minimum Standards § 4, Min. Stds. 7.a and 7.b)
The City received the following comment regarding section 7.a:
Page 13, Minimum Standards, paragraph 7a: Why should an FBO be required to
maintain 3 mobile dispensing trucks? Shouldn’t that be left up to the Operator to
determine what its needs are? If one of the trucks is to be dedicated to unleaded
avgas, then that truck may be sitting idle or years until unleaded avgas is
commercially available.
The same commenter stated the following regarding section 7.b:
Page 14, Minimum Standards, paragraph 7b: Why should an FBO be required to
maintain 2 mobile dispensing trucks for jet fuel? Shouldn’t that be left up to the
Operator to determine what its needs are?
City’s Response to Comment 37:
The City declines to modify the requirements for specified numbers of trucks with
specified capacity because it believes these requirements are appropriate. The City
notes that other general aviation airports set minimum numbers for trucks and fuel
capacity in their Minimum Standards.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 21 of 51
As shown in the attached redline, the City has modified this section to specify that
the requirements concerning unleaded AvGas only apply once unleaded AvGas is
commercially available and approved for use.
Comment 38. FBO Mobile Dispensing Equipment
(Minimum Standards § 4, Min. Std. 7.c)
The City received the following comment:
Unleaded AvGas must be made available once commercially available and approved
for use. The wording currently is unclear because of the "and/or" used. I propose
changing it to:
"The remaining mobile dispensing truck shall provide Unleaded AvGas with a capacity
of at least 750 gallons. Until such time as unleaded AvGas is commercially available
and approved for use, standard AvGas may be used."
City’s Response to Comment 38:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment.
Comment 39. FBO Hours of Operation (Minimum
Standards § 4, Min. Std. 9)
The City received the following comment:
Hours of Operation. FBOs should not be required to sell fuel for extended hours. I
propose changing this paragraph to:
Hours of Operation. Each FBO shall provide aircraft fueling and line services during the
hours of 7 a.m. to 7 p.m. Monday through Friday and from 8 a.m. through 7 p.m. on
Saturdays and Sundays. Any fueling outside of normal business hours must have at
least the minimum number of qualified, certified employees present to perform the
fueling, as well as an additional person inside the premises in case of emergency
City’s Response to Comment 39:
The City declines to make the requested modification to this section, and notes that
the current hours that an FBO is required to sell fuel match the operational hours of
the Airport, which are the operational hours set forth in this section.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 22 of 51
Comment 40. FBO Personnel and Training: Full Time
Manager (Minimum Standards § 4, Min. Std. 10.a)
The City received the following comment:
The FBO Manager...approval may be denied for any reason. Is this too much discretion
to be viewed as arbitrary?
City’s Response to Comment 40:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment and make clear that it provides the Airport Director
with discretion, when warranted, to disapprove an FBO Manager.
Comment 41. FBO Deplaning Passengers (Minimum
Standards, Minimum Standard § 4, Min. Std. 10.e)
The City received the following comment:
Page 15 – Section 10(e). Add that they will be required to have a person outside the
set hours to deplane passengers and provide the services required under this section.
City’s Response to Comment 41:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment and specify that if FBOs deplane passengers outside
of the hours provided in this subsection, appropriate personnel must be on site to
fulfill necessary functions.
Comment 42. FBO Safety Course, NATA (Minimum
Standards § 4, Min. Std. 10.f)
The City received the following comment:
Section 4, FBO Minimum Standards, Item 10f, Page 15, references NATA; the
proper full name for the organization is the ”National Air Transportation
Association.”
City’s Response to Comment 42:
As shown in the attached redline, the City has modified this section to reflect the
proper name of the organization.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 23 of 51
Comment 43. Air Charter and Taxi Parking (Minimum
Standards, § 5, Min. Std. 1)
The City received the following comment:
Page 16 – Section 1. Should we more specific on the minimum number of automobile
parking spaces we will require SASO Aircraft Charter and Air Taxi operators?
City’s Response to Comment 43:
The City declines to require a specific number of parking spaces because it believes
that the necessary number of spaces may vary, and that it is better to maintain
flexibility to require each air charter and taxi SASO to lease a parking area
appropriate to accommodate the number of passengers it anticipates serving based
on the number and capacity of aircraft it operates.
Comment 44. Aircraft Charter and Air Taxi, Twin Engine
Aircraft (Minimum Standards, § 5, Min. Std. 2)
The City received the following comment:
The section of the draft which establishes requirements for charter and air taxi services
requires them to provide twin-engine aircraft. There is no basis for such a requirement,
which would in effect be a total ban on solely single-engine air taxi/charter services
from being based at SMO, despite the fact that their use constitutes an aeronautical
activity which must be provided access to the airport on reasonable terms.
City’s Response to Comment 44:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment.
Comment 45. Air Charter and Taxi Premises (Minimum
Standards, § 5.3)
The City received the following comment:
The Operator shall have its premises open... Even if there are no flights?
City’s Response to Comment 45:
The City believes that the minimum hours of operation are appropriate and need
not be modified. The City notes that the minimum hours of operation are consistent
with those required at other general aviation airports.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 24 of 51
Comment 46. Air Charter and Taxi Employees, Related
Aircraft Management Services (Minimum Standards, § 5.4)
The City received several comments concerning charter operations at the Airport,
including comments addressing charters facilitated through web-based services.
The City received the following comment:
Page 16 – Section 4. Can we require the minimum number of employees that they
need to have on site? They suggested we identify staffing in addition to pilots. This is
the section that crowdsourcing apps, scheduled operators and others wanting to use
the airport have to comply by. We are seeing that these types of operators reach out
to the FBO to conduct their operation. By requiring certain staffing other than pilots
will ensure that they have adequate staffing to handle their operations.
Can we stipulate that if an operator begins service at the Airport without the City’s
knowledge and the City finds out that the City has the right to restrict them from
operating at the airport in the future. Some form of a penalty.
Can we incorporate the language to the COP attached for air carrier in this section?
The City also received the following comment:
Page 24 – SASO Aircraft Management Services. Can we require the minimum number
of employees that they need to have on site? They suggested we identify staffing in
addition to pilots. This is the section that crowdsourcing apps, scheduled operators
and others wanting to use the airport have to comply by. We are seeing that these
types of operators reach out to the FBO to conduct their operation. By requiring certain
staffing other than pilots will ensure that they have adequate staffing to handle their
operations.
Can we incorporate the language to the COP attached for air carrier in this section?
Can we stipulate that if an operator begins service at the Airport without the City’s
knowledge and the City finds out that the City has the right to restrict them from
operating at the airport in the future. Some form of a penalty.
The City also received the following comment:
What is going on at the Santa Monica airport? Why would we be leasing any airport
land to any commercial aircraft companies when we are supposed to be winding down
the air traffic for the next 10 long years? We're not supposed to be pandering to the
one-percenters that are running and ruining our country now. We do not want or need
helicopter taxis polluting and disturbing the peace 24/7. We do not need or want a
commercial jet port for another minute. What is going on with the Santa Monica City
government and SMO? Why are you not doing everything humanly possible to curb
commercial aviation at SMO?
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 25 of 51
The City also received the following comment:
I am contacting you in regards to leasing SMO to new aviation businesses, including
Uber-style "Airlines" and traditional Charter Companies. I would like to voice my
opposition for any new lease agreements to aviation companies at SMO, and to urge
you to pass all future proposals consistent with the election results of 2014 which
rejected Measure “D” and passed Measure “LC”.
The City also received the following comment:
I’m an airport neighbor and will be affected by the content of the airport’s new
minimum standards.
You are aware that charter and fly-share companies are increasing in numbers and
decreasing in price point.
The City also received the following comment:
Expansion of Services – We are concerned about SMO’s expansion of all services. It
seems like the airport is gearing up to be busier then ever, even thought your own
citizens voted to take control and close the airport in a more timely manner than
2028. We are concerned about additional charter flights (both plane and Helicopter).
Minimum Standards must apply to all operators at SMO, and the prop planes must not
fly exclusively over Venice. What are your immediate plans, i.e. more flight schools,
Air Taxi Services such as Elevate (UberAir, Blade), Helicopter flights, more Shuttles,
etc.?
Security/Insurance Requirements –There should be stringent rules in place for
passengers and pilots in the sensitive areas around the Santa Monica Airport. Security
measures should be similar to what TSA does at large airports. Student pilots who are
training to fly at SMO should have background checks to prevent a similar situation to
the 911 terrorists’ that trained at U.S. airports. What kind of security will be in effect
for all travelers using SMO?
All businesses and pilots should be required to have minimum insurance protections
that would cover the true costs of catastrophic accidents in the surround areas. Relying
on the insurance standards that protect aeronautical interests, instead of those
potential victims and property on the ground is unconscionable.
We insist minimum insurance requirements at SMO be raised. How will you raise your
minimum standards for insurance protection?
The same commenter also stated:
General Aviation Airport – If this is a “General Aviation Airport”, what is the rational
for commercial charters, taxis, and fractional ownership aircraft that have a schedule?
For example, having a scheduled shuttle from SMO to Las Vegas would require a fixed
schedule, which is not allowed in a “general aviation airport”. We insist that you
adhere to the non-scheduled aircraft regulation that applies to SMO.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 26 of 51
The City also received the following comment:
My main concern is with ticket brokers such as Blackbird and Blade and, I gather, other
charter companies, who are adopting the same business model of selling tickets under
one FAA regulation and flying passengers under another. By holding these brokers to
some sort of airport user requirement that provides a level of liability and standard of
best practices required of all other airport users, we can have some control over this
new way of doing business that will protect the community and the integrity of the
other actors in aviation operations. Like Commissioner Rubin, whose comments I have
seen, the Minimum Standards as drafted do not seem to address this issue and, like
her, I may be missing something but I’m as concerned as she that some language be in
the Standards that addresses these air carriers without planes. Otherwise, I think that
Commissioner Ruben’s critiques are perfectly reasonable and spoke well of her
experience as a public-sector attorney and her value to the Commission. This effort to
codify best practices for airport users and operators is a valuable step in making SMO
a good neighbor in its remaining eleven years of life.
The City also received the following comment:
We living near the Santa Monica Airport are waiting for it to close for good! We are
anxiously waiting for a beautiful new sustainable park to be built. In the meantime, we
would like some peace and quiet and strict regulations and standards followed with
regards to future aviation use of the airport. We do not want taxi/uber jets, we do not
want dangerous flight schools, we do not want an increase in helicopter traffic, we do
not want fuel sold at the airport, we do not want any more loud and smelly jets using
the airport. We have seen in the past how many aviation businesses skirt the laws,
using loop holes to abuse the neighborhood. Do these businesses have adequate
insurance? Are their jets licensed and by whom? Are the pilots up to date on safety
measures? We want to know who owns these jets and who to contact if there are any
issues? We ask you to clamp down on the aviation businesses and set standards and
ENFORCE these standards. We support all airport standards that secure our safety
and well being as neighbors living near this dangerous and polluting airport.
City’s Response to Comment 46:
The City will only allow charter operations and flight-sharing activities to occur at the
Airport if they comply with all applicable federal, state and local requirements and if
the City is obligated by federal law and the Consent Decree governing the closure of
the Airport to allow these operations to occur at the Airport. As shown in the
attached redline, the City has modified the minimum standards applicable to Aircraft
Charter and Air Taxi Operators to include new sections 5.3, 5.4, 5.5, and 5.6 that
require compliance with applicable federal and City requirements and reports that
will assist the Airport Director in ensuring compliance with these requirements. The
City has also added new Section 10 to specify minimum standards applicable to Air
Transportation Arrangers. The standards in new Section 10 are intended to apply to
entities involved in arranging commercial air transportation from and to the Airport,
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 27 of 51
in the event it is determined that their business operations take them outside the
scope of the Aircraft Charter minimum standards set forth in Section 5.
Comment 47. Flight Training Facility Space (Minimum
Standards § 6, Min. Std. 1.a)
The City received the following comment:
"(with adequate mockups, pictures, slides, filmstrips, and other visual aids)" is
unnecessarily prescriptive. Part 61 Flight Schools and their Flight Instructors have an
enormous amount of teaching tools at their disposal, most of which are available on
the internet. The list of visual aids listed in this paragraph is not only limited but out-
dated (i.e. "filmstrips" are likely not used in any flight school anymore). It is
unnecessary to list visual aids that are required. It may be helpful to list "I.E." in front
of this list and update the list.
City’s Response to Comment 47:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment by removing the language regarding mockups,
pictures, slides, filmstrips, and other visual aids.
Comment 48. Flight Training Telephone Facilities
(Minimum Standards § 6.1.g)
The City received the following comment:
In the age of the proliferation of cell phones it is unreasonable and unnecessary to
require a flight school (or any service provider for that matter), to provide "telephone
facilities for customer use.”
The City also received the following comment:
Telephone facilities for customer use. In this age of ubiquitous cell phones, is this a
necessary requirement?
City’s Response to Comment 48:
As shown in the attached redline, the City has modified this section to address the
concern raised by these comments by removing the requirement for telephone
facilities.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 28 of 51
Comment 49. Flight Training Equipment (Minimum
Standards § 6, Min. Std. 2)
The City received the following comment:
"a sufficient number of aircraft" should be deleted. Most flight schools these days, with
the surge of student pilots due to the massive pilot shortage in the airline/corporate
industry, are completely deficient in the number of aircraft they have available for
flight training. It is unreasonable to require a flight school to "have available for use ...
a sufficient number of aircraft". It is reasonable to require that a flight school have "at
least (2)" so that clause should be left in the paragraph.
The same commenter further stated:
"It is unreasonable to require a flight school to have aircraft "equipped for and capable
of use in instrument flight instruction". None of the Light Sport Aircraft are IFR
equipped. We operated our flight school for five years before having any IFR equipped
aircraft. It was not until Justice Aviation closed that we acquired IFR equipped aircraft.
Should the industry and the needs of our students change, we will require the ability to
strip our fleet of all aircraft except LSAs.
City’s Response to Comment 49:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments by clarifying (a) that two aircraft shall be
sufficient for a flight school; and (b) where an Operator is providing only sport pilot
training, IFR equipped aircraft are not required. With this exception, the City
believes that the requirement of one aircraft equipped for use and capable of use in
instrument flight instruction is reasonable.
Comment 50. Flight Training Ground Instructors
(Minimum Standards § 6, Min. Std. 3)
The City received the following comment:
"It is unnecessary to require a flight school to have a "certified ground instructor" on
staff. Fully certificated Flight Instructors are more than capable of teaching ground
school. Part 61 schools do not require "Ground Instructors" in order to operate
effectively or successfully.
City’s Response to Comment 50:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment and specify that certified flight instructors otherwise
required on staff by these Minimum Standards, who also have experience in ground
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 29 of 51
instruction, may teach ground school, instead of requiring a separate certified
ground instructor to be employed by the flight school.
Comment 51. Aircraft Maintenance and Repair Stations
Equipment (Minimum Standards § 7, Min. Std. 3a)
The City received the following comment:
Page 20, Section 7, Paragraph 3a: Requiring an Operator to maintain a minimum of
$100,000 in parts and equipment is very arbitrary, and may not be suitable for every
Operator. It is better to say that the Operator must maintain an adequate supply of all
necessary parts, Whitman and accessory as needed for its business.
The City also received the following comment:
Section 7, SASO Aircraft Maintenance and Repair Stations, Item 3a, requires
an Operator to maintain a minimum of $100,000 in parts and equipment; this
appears to be an arbitrary figure, and may not be suitable for every Operator. We
suggest instead: “Operator shall have access to an adequate supply of all
necessary parts and accessories as needed for its business.”
City’s Response to Comment 51:
As shown in the attached redline, the City has modified this section to address the
concerns raised by these comments and delete the $100,000 minimum.
Comment 52. Aircraft Maintenance and Repair Stations
Hours of Operation (Minimum Standards § 7, Min. Std. 4.a)
The City received the following comment:
Add the word “staffed”. “The repair station shall be open, staffed, and have services
available at least…”
City’s Response to Comment 52:
The City declines to make the requested change, and notes that section 7.5.a
provides the staffing requirements for this type of Operator. As shown in the
attached redline, the City has modified section 7.5.a to clarify that its staffing
requirements apply during the hours of operation specified in section 7.4.a.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 30 of 51
Comment 53. Aircraft Maintenance and Repair Stations
Personnel (Minimum Standards § 7, Min. Std. 5a)
The City received the following comment:
Page 21, Section 7, Paragraph 5a: The requirement for an Operator to have an A&P
or AI on staff during operating hours does not take into consideration the possibility
that an Operator may be a radio shop repair station. A different license other than an
A&P or AI is required. Why not delete “and who holds an airframe, power plant or an
aircraft inspector rating” from the end of that paragraph.
The City also received the following comment:
Section 7, Paragraph 5a, Page 21, the requirement for an Operator to have an
A&P or AI on staff during operating hours, does not take into consideration the
possibility that an Operator may be a radio shop repair station. A different license
other than an A&P or AI is required. We suggest deleting “and who holds an
airframe, power plant or an aircraft inspector rating” from the end of that
paragraph.
City’s Response to Comment 53:
As shown in the attached redline, the City has modified this section to address the
concern raised by these comments and exempt radio shop repair stations from the
inspector rating requirements.
Comment 54. Self-Service Fuel Pumps, Aviation Oil
(Minimum Standards § 8, Min. Std. 2)
The City received the following comment:
Section 8, SASO Self-Service Fuel Pumps Minimum Standards, Item 2,
Page 22, suggests that self-serve pumps must offer aviation oil, which is not an
item provided as part of self-serve. We suggest removing that reference.
City’s Response to Comment 54:
As shown in the attached redline, the City has modified this section to address the
concern raised by this comment and remove the reference to aviation oil.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 31 of 51
Comment 55. Additional Environmental Requirements
(Minimum Standards § 8.3)
The City received the following comment:
General Comment: In Section 8.3, the Draft Minimum Standards include a requirement
for a Spill Prevention, Containment, and Countermeasure (SPCC) Plan for self-service
fuel pumps. However, this requirement may apply to other aeronautical service
categories, and there are additional environmental requirements that may apply to
each of the various service categories. The following environmental protection and
emergency response regulations should be considered for inclusion into the Draft
Minimum Standards.
a. SPCC Plan and associated requirements for any facility that stores either a total of
1,320 gallons of petroleum, oil, and lubricants (POL) in aboveground containers of 55-
gallons or more or a total of 42,000 gallons of POL in underground storage containers.
Tenants must comply with the requirements of Title 40 of the Code of Federal
Regulations (CFR) Section 112 (40 CFR 112) and any local requirements of the Santa
Monica Fire Department, which is the local California Unified Program Agency
(CUPA). This requirement would most likely be applicable to Fixed Base Operations
(FBOs) and fueling operations.
b. Preparation and submittal of a Hazardous Materials Business Plan (HMBP) under
California Health and Safety Code (HSC) Sections 25500 — 25519. Any facility that
stores hazardous materials as defined in 29 CFR 1910.1200 in quantities greater than
or equal to 55 gallons (liquids), 500 pounds (solids), or 200 cubic feet (compressed gas)
is required to submit an HMBP. This requirement may be applicable to any category of
aeronautical service operators.
c. Any tenant of the Airport that plans on generating hazardous waste, including
California-only hazardous waste, must obtain a Generator ID Number from the United
States Environmental Protection Agency. This requirement would most likely be
applicable to FBOs, aircraft maintenance and repair shops, and fueling operations.
d. Tenants should identify any equipment requiring a Permit to Operate from the
South Coast Air Quality Management District (SCAQMD), and the potential tenant
should be required to submit a permit application to SCAQMD for each piece of
identified equipment prior to being issued a lease. Equipment that may require a
permit includes, but is not limited to, aboveground storage tanks, emergency
generators, and certain fuel dispensing equipment. This requirement would most likely
be applicable to FBOs and fueling operations, but certain operations within other
service categories, such as painting, can require a permit.
e. Tenants should provide relevant information to the Airport regarding storm water
pollution prevention, so Airport Staff can incorporate the new information into the
Airport's Storm water Pollution Prevention Plan (SWPPP). Relevant information may
include a facility map, hazardous materials inventory, and a designated contact for
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 32 of 51
environmental issues. This is applicable to any category of aeronautical service
operators
City’s Response to Comment 55:
The City shares the commenter’s concern for compliance with environmental
requirements. Existing language in Section 3 requires Operators to comply with all
applicable laws and regulations, which the City believes would include
environmental requirements. In the interest of highlighting the importance of
environmental compliance, the attached redline includes a new Section 3.14 that
specifically references compliance with environmental laws and regulations. The City
does not believe it is appropriate to attempt to detail more specific requirements for
each and every type of Operator, where regulatory obligations may change over
time and where each Operator’s regulatory obligations may differ according to
conditions on site and the nature of the Operations.
Comment 56. Other Aeronautical Services (Minimum
Standards § 10.1a)
The City received the following comment:
[This section] states “Specialized Aeronautical Service operators not covered by the
specific minimum standards in section 4 through 9 must meet all the requirement of
this section and section 2 and 11”. If they are not providing multiple aeronautical
services, why should they meet the requirement of section 11? For example we provide
aircraft sales only and will fall under section 10 but we do not provide multiple service.
Yet as written now, we must meet requirement of section 11. The suggestion would be
to say they must meet section 11 if they provide multiple services.
It also requires that specialized aeronautical service operators not covered by the
specific category in sections 4-9 among other requirements, must pay the city for the
privilege of providing service at the airport. Again this is vague and ambiguous and
needs to be clarified. Aircraft sales is not in any category and falls under section 10
and as it is written now they would have to pay such privilege fee irrelevant of whether
they are a tenant and lease a space in the airport or not. Why should a company who
is engaged in sales of aircraft and is leasing space should pay the city for privilege of
providing services at the airport but not a company who provides service or repair to
the aircraft or an FBO or a charter service or for that matter any other operation
covered under section 4-9 who also is a tenant and leases a space? The suggestion
would be to remove this language completely and put such requirement to pay the
airport the privilege fee as part of or as condition of processing or granting their
commercial operation permit or to define when and under what circumstance an
operator should pay such fee. If you choose the latter, the amount and fee structure
should be defined and should not be arbitrarily.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 33 of 51
City’s Response to Comment 56:
As shown in the attached redline, the City has modified this section to address the
concerns raised in these comments by: (a) clarifying that Operators falling under
Section 10 (now 12) (Other Aeronautical Services) of the Minimum Standards are
subject to Section 3 (General Requirements) and Section 12 (now 14) (Self-Fueling),
unless the Operator provides multiple aeronautical services, in which case Section 11
(now 13) (Multiple Aeronautical Services) applies; and (b) removing the pay for
privilege clause and adding a provision specifying that Operators falling under this
section may be required to pay fees and payments as specified in their lease or
license with the City. The City notes that it has added to the Minimum Standards a
new Section 10 governing Air Transportation Arrangers and a new Section 11
governing aircraft sales operators.
Comment 57. Multiple Aeronautical Services, Sale of
Lubricants (Minimum Standards § 11, Statement of
Concept)
The City received the following comment:
Page 26, Section 11, Statement of Concept: The words “and lubricants” should be
deleted from this section because businesses such as Kim Davidson Aviation and Bill’s
Air Center can legally sell oil as part of an oil change. Oil is a lubricant and the not
only FBO’s are permitted to sell lubricants.
The City also received the following comment:
Section 11, Statement of Concept, Page 26, the words “and lubricants” should
be deleted from this section because aviation business that provide maintenance
services can legally sell lubricants (i.e. oil) and as part of an oil change or directly
to the consumer.
City’s Response to Comment 57:
As shown in the attached redline, the City has modified this section to address the
concerns raised in these comments by removing the term “and lubricants” from the
Statement of Concept.
Comment 58. Self-Service and Self-Fueling Rights, Fuel
Storage and Delivery (Minimum Standards § 12.3.b)
The City received the following comment:
As with Section 4 for FBOs, construction or establishment of a fuel farm should require
City Council approval (not just Airport Director or City Manager approval).
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 34 of 51
City’s Response to Comment 58:
The City declines to modify this section as requested. The City believes that this is
an operational decision that should be made at the operational level by the Airport
Director. See also City responses to Comments 32 and 64.
Comment 59. Self-Service and Self-Fueling Rights, Fuel
Storage and Delivery (Minimum Standards § 12.3.b.ii)
The City received the following comment:
Page 29, Section 12, Paragraph 3b(ii): Why have a minimum fuel tank amount?
Shouldn’t that be up to the self-fueler dependent on what its needs are?
City’s Response to Comment 59:
The City declines to modify this section as requested. The City notes that the
required fuel tank size is based on aircraft usage and effective tank size for such
usage derived from current FBO experience.
Comment 60. Self-Service and Self-Fueling Rights,
Fueling Equipment (Minimum Standards § 12.4a)
The City received the following comment:
Page 30, Section 12, Paragraph 4a: Why is the city dictating the size of a fuel
dispensing truck for a self-fueler? Should that not be up to the needs of the self-fueler?
City’s Response to Comment 60:
The City declines to modify this section as requested. The City notes that the
required fuel truck size is based on safety, and is consistent with requirements at
other general aviation airports.
Comment 61. Self-Service and Self-Fueling Rights,
Personnel (Minimum Standards § 12.9)
The City received the following comment:
Page 32, Section 12, Paragraph 9b: Why must there be a minimum of two individuals
present during self refueling operations? Again, should that not be up to the self-
fueler?
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 35 of 51
City’s Response to Comment 61:
The City declines to modify this section as requested. The City notes that the
requirement for two individuals to be present during self-refueling operations is
based on safety, and is consistent with self-fueling requirements at other general
aviation airports.
Comment 62. Self-Service and Self-Fueling Rights,
General (Minimum Standards § 12)
The City received the following comment:
Note: With regard to self-fuelers, they tend to be smaller operations than the FBO’s.
Establishing requirements for them that are similar to that of an FBO is unnecessary
and overly burdensome. Other than protecting the business of an FBO, many of the
self-fueler requirements are completely unnecessary and should be left up to the self-
fueler (eg. size of storage tanks, number of fuel trucks, etc.) After all, the self-fueler is
still required to pay a fuel flowage fee to the City.
City’s Response to Comment 62:
The City declines to modify this section as requested. The City does not believe that
the self-fueling provisions of the Minimum Standards are overly burdensome,
superfluous, or protectionist of FBOs. Rather, these Minimum Standards for self-
fuelers are intended to provide reasonable requirements for such entities that
ensure safety at the Airport.
Comment 63. Treatment of Dealer/Broker Operators
Generally
The City received the following comment:
As an aircraft dealer/broker, Aerista's business is substantially different than the other
aeronautical service providers on airport property, so we either belong under the
"other" category or need a separate category defined for us. By different, I mean that
we rarely carry inventory on-site (the vast majority of our clients and their aircraft are
based/domiciled at airports throughout the U.S.), so any standard dealing with the
handling of aircraft is largely moot in our case. To that extent, the following general
requirements do not seem applicable to our business.
City’s Response to Comment 63:
The City notes that, depending on the nature of its operations, an aircraft
dealer/broker would be subject to the new Section 11 (Aircraft Sales Operator) or
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 36 of 51
Section 10 (now 12) (Other Aeronautical Services), unless the aircraft dealer/broker is
providing multiple services, in which case Section 11 (now 12) would apply. The City
further notes that to the extent a particular dealer/broker believes that a waiver from
application of some of these Minimum Standards is appropriate, it may request a
waiver from the Airport Director.
Comment 64. Definition of “City” (Minimum Standards
Appendix A)
The City received the following comment:
The definition of "City" should not include delegation of powers to the Airport Director.
(If a delegation option must be included, it should instead be to the City Manager.)
City’s Response to Comment 64:
The City believes that it is appropriate for the definition of “City” to include
delegation of powers to the Airport Director. Per Santa Monica Municipal Code
10.04.02, the Airport Director has all rights, power and authority of the City to issue
orders and enforce orders, laws and regulations pertaining to the use of the Airport.
In certain circumstances, where the authority of the City Manager is required, it is
called out in specific provisions of the Minimum Standards.
Comment 65. Definition of “General Aviation” (Minimum
Standards Appendix A)
The City received the following comment regarding the definition of “General
Aviation”:
The draft defines “general aviation” solely as operations under 14 C.F.R. Part 91, even
though many operations at SMO in fact are conducted under 14 C.F.R. Part 135. As a
result, the draft suggests that commercial aeronautical services at SMO may only be
provided to Part 91 operators, among other terms that are facially non-compliant with
the airport’s ongoing obligations to the FAA. We assume that this is an unintentional
oversight, and can easily be corrected. This error further emphasizes why careful and
thorough review of the draft is required.
City’s Response to Comment 65:
As shown in the attached redline, the City has modified Appendix A to address the
concern raised by this comment by referencing Part 135 operations in the definition
of general aviation.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 37 of 51
Comment 66. Definition of “Individual” (Minimum
Standards Appendix A)
The City received the following comment:
Under INDIVIDUAL, omit the term "servant".
City’s Response to Comment 66:
As shown in the attached redline, the City has modified Appendix A to address this
comment by removing this term.
Comment 67. Insurance Requirements and Standards
(Minimum Standards Appendix B)
The City received the following comment:
The Long Beach standards have good language for liability waivers and
indemnification. See section 2.16 on page 11 (and especially 2.16.2). This language
should probably be at the front of the minimum standards [OR ADDED TO APPENDIX
B, INSURANCE REQUIREMENTS?], so it applies to ALL operators/leaseholders/etc.
2.16 Indemnification and Hold Harmless
2.16.1 Operator shall defend, indemnify, save, protect, and hold harmless the City of
Long Beach, the Long Beach Airport, and the Long Beach City Council, individually and
collectively, and their representatives, officers, officials, employees, agents, and
volunteers from any and all claims, demands, damages, fines, obligations, suits,
judgments, penalties, causes of action, losses, liabilities, administrative proceedings,
arbitration, or costs at any time received, incurred, or accrued by the City of Long
Beach, the Long Beach Airport, and the Long Beach City Council, individually and
collectively, and their representatives, officers, officials, employees, agents, and
volunteers as a result of, or arising out of Operator's activities, actions, or inactions. In
the event a party indemnified hereunder is in part responsible for the loss, the
indemnitor shall not be relieved of the obligation to indemnify; however, in such a
case, liability shall be shared in accordance with California principles of comparative
fault.
2.16.2 Operator shall accept total responsibility, defend, indemnify, save, protect, and
hold harmless the City of Long Beach, the Long Beach Airport, and the Long Beach
City Council, individually and collectively, and their representatives, officers, officials,
employees, agents, and volunteers in the event of an environmental contaminating
accident or incident caused by Operator, its employees, its vendors or any other
personnel used by the Operator to maintain Operator's improvements, vehicles,
equipment, or aircraft.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 38 of 51
City’s Response to Comment 67:
As shown in the attached redline, the City has modified Appendix B to address the
concerns raised in this comment (new section C.vi.).
Comment 68. Minimum Insurance Requirements
(Minimum Standards Appendix B-1)
The City received the following comment:
As we discussed in the meeting, these minimum insurance requirements are far too
low. I carry more personal insurance coverage simply to operator my car and to
protect my home from even a simple "slip and fall" accident. This airport is within 300
feet of multi-million dollar homes -- and many of these homes are inside what should
be a Runway Protection Zone (even with the shortened runway). A small piston aircraft
crashing into a single home could easily cause more damage than would be covered
by the currently proposed minimums -- and of course a larger aircraft could cause
much greater damage. Medical costs, legal fees, etc., can easily and quickly reach into
the many millions of dollars. The Pollution Liability Insurance requirements also seem
very low, considering the damage that fuel and other lubricants can cause. The
cleanup costs can easily extend into the many millions of dollars as well. As such, I
recommend increasing the following limits by at least 5 times what is currently listed
in these categories: General Liability minimums, Hanger Keepers Liability (increasing
3x may be sufficient here?), Aircraft & Passenger Liability, Pollution Liability Insurance.
The City also received the following comment:
Standards to Mitigate Operational and Financial Risks
Commercial service providers are required to maintain Liability Insurance and
Pollution Insurance to minimize financial exposure to liabilities and environmental
damage. Funded by service provider.
Insurance minimums must be significantly increased to cover a major catastrophic
accident. Insurance should include coverage for potential deaths and injuries, property
and aircraft destruction, and environmental contamination resulting from accidents
and ongoing operations. No subleasing or subcontracting of services.
From 2000 to 2017, the NTSB and FAA reported 35 deaths in 17 years related to SMO
Local and Itinerant operations. That’s an average of more than 2 fatalities per year. It
is extremely likely that there will be continued deaths, injuries, and destruction of
property through 2029.
Environmental Pollution Insurance –
https://www.insurancejournal.com/magazines/magfeatures/2001/07/23/18589.htm
SMO list of accidents from local and itinerant operations –
http://casmat.org/2015/03/updated-list-of-smoaccidents.html
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 39 of 51
City’s Response to Comment 68:
Revised Appendix B-1 contains updated minimum insurance requirements
applicable to the various types of operators covered by the Minimum Standards
The City believes these proposed insurance requirements are reasonable and
declines to modify them further. The City notes that these insurance requirements
were set after consultation with the City’s Risk Manager and an insurance broker and
reflect requirements customary and reasonable in the industry and imposed by
similar general aviation airports. Moreover, the insurance requirements remain
subject to modification by the City’s Risk Manager if new or changing risks emerge.
The City further notes that under the Consent Decree, for so long as the Airport
continues to operate as a general aviation airport, the City must allow aeronautical
service providers access on fair and reasonable conditions without unjust economic
discrimination, and that the FAA has found that to comply with this standard,
required insurance must be both attainable and reasonable.
Comment 69. Pollution Liability (Minimum Standards
Appendix B-1)
The City received the following comment:
Appendix B-1. Increase the limits on pollution liability insurance.
City’s Response to Comment 69:
See City’s response to Comment 68. In addition, the City notes that fuel tanks and
fueling facilities at the Airport are subject to regular inspections as well as
requirements for maintaining stringent leak prevention measures.
Comment 70. Pollution Liability Insurance (Minimum
Standards Appendix B-1: Minimum Insurance
Requirements)
The City received the following comment:
In Appendix B-1: Minimum Insurance Requirements Matrix, Aircraft & Repair and
Maintenance Services are not required to provide pollution liability insurance.
Depending on the scale and extent of operations, repair shops can use and store
significant quantities of hazardous materials and waste. A liability of one million
dollars would be excessive, but Airport Staff should be aware that the use and storage
of these hazardous materials may result in accidental release or other environmental
contamination.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 40 of 51
City’s Response to Comment 70:
See City’s response to Comment 68. In addition, the City notes that repair shops
storing hazardous waste are subject to regular inspections and have available
mechanisms for disposal of such wastes.
Comment 71. “Archaic or Peculiar” Requirements
The City received the following comment regarding general requirements in the
Minimum Standards:
Throughout the draft, many of the proposed requirements are archaic and/or peculiar.
A notable example is the requirement that flight training schools and aircraft
charter/air taxi providers provide “telephone facilities for customer use,” which
presumably dates to a time before mobile phones were ubiquitous. We suggest
removing the telephone requirement, and other obsolete language.
The same commenter further stated:
The draft appears to have been based on a template that is obsolete (a further
example being a reference to filmstrips), internally inconsistent, and not tailored to a
general aviation airport, and thus it is vital that close scrutiny be given to all of its
requirements for commercial activities – not just those identified above – before it is
finalized.
City’s Response to Comment 71:
As shown in the attached redline, the City has addressed the comments’ concerns
regarding “archaic and/or peculiar” requirements by updating or removing such
requirements. See, e.g., City’s responses to Comments 47 and 48 above..
Comment 72. Uniforms Generally
The City received the following comment:
Similarly, the draft would require certain – but not all – businesses (i.e., repair station
and self-service fuel vendors) to put all of their employees in uniform, irrespective of
their actual responsibilities (or any obvious necessity). We suggest the minimum
standards at a minimum more clearly define the uniform requirements, with the
particular focus on eliminating the need for back office employees to be in uniform.
City’s Response to Comment 72:
As shown in the attached redline, the City has revised uniform requirements in
response to comments it has received. As modified, the Minimum Standards do not
require administrative personnel to wear a uniform, but all non-administrative
personnel in the AOA, must wear clothing that displays the identification of the
Operator in letters of sufficient size and contrast to be easily legible. This
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 41 of 51
requirement is appropriate to ensure that personnel conducting operations in the
AOA can readily be identified to the Operator for whom they are performing those
operations. See also City response to Comment 19.
Comment 73. Security Generally
The City received the following comment:
There should be one gate with a guard for access to the airport. ID must be required
at the gate. Now anyone can take off and there is no accountability. Also if they are
landing due to a medical emergency (stomach ache) they pilot needs to radio for
medical help to be available.
City’s Response to Comment 73:
Airport security measures undertaken by the City itself are not the subject of these
Minimum Standards, which set requirements for individual operators providing
commercial aeronautical services at the Airport. The City notes that the Minimum
Standards require each Operator to comply with applicable security requirements
and to implement a documented security plan. See Minimum Standards, Section
3.7. The City also notes that individual decisions concerning medical help are
beyond the scope of these Minimum Standards, and may be governed by other
protocols for pilots or emergency medical personnel.
Comment 74. Hours of Operation
The City received the following comment:
I am a resident of Ocean Park in Santa Monica and I am very disappointed in the
hours of operation in the draft. The hours should be limited to 10am - 5pm M-Sat
with no flights on Sunday. Santa Monica controls the hours. Why are we still being
forced to endure the noise, pollution and threat to our lives and homes longer than
necessary for another 11 years?! I see nothing in this draft about the affect these
operations have on the residents. I think you should add if you get 1 noise complaint
that jet service must end. Also, you should not be able to waive any insurance, fee
requirements.
City’s Response to Comment 74:
Neither the Airport’s operating hours nor its noise restrictions are changed by these
Minimum Standards, which are intended only to set requirements for individual
operators providing commercial aeronautical services at the Airport. The City shares
the concern expressed by this comment and others regarding compliance with
existing noise restrictions. The City notes that Section 2.4(h) permits the denial of an
application if the applicant has violated any statutes, regulations, ordinances, laws or
orders applicable to the Airport, which would include the Airport’s noise restrictions.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 42 of 51
The City further notes that Section 3 imposes the general requirement that
operators comply with all applicable laws, regulations, ordinances, and rule relating
to their Airport operations, which would include the Airport’s noise restrictions.
Nevertheless, as shown in the attached redline, in response to this comment and
others reflecting community concerns with the existing noise restrictions, in the
interest of highlighting the importance of compliance with these restrictions, the
City has added a new Section 3.15 that specifically references compliance with
applicable noise restrictions laws and regulations as a general requirement for all
Operators providing aeronautical services at the Airport.
With respect to waivers, see City responses to Comments 6 and 23.
Comment 75. Ticket Brokers and Charter Operations
The City received the following comment:
1. What are the reasons you think flights are so radically down? IFR? DAAP
requirements not met? Insurers? Smart owners and operators?
2. Was the on site weather reporting system upgraded last December?
3. Do the following fly under part 135 or part 91K? Netjets, Flight Options, Wheels
Up (Gama Air), Blade, Blackbird Air, Surf Air, JetSuiteX
4. Balanced Fuel Length charts (runway length, load, wind, temp., slope, wet/dry etc.)
for: Embraer 300, Pilatus P-12, King Air 250, Citation C560, Falcon 50EX
5. Who has made inquires to lease that would fall under Charter, Air Taxi, SASO,
Aircraft Management or Combination?
City’s Response to Comment 75:
The City notes that the questions posed in this comment are outside the scope of
the Minimum Standards and can be addressed elsewhere.
Comment 76. Fly Neighborly Program
The City received the following comment:
Fly Neighborly Program – SMO’s “Fly Neighborly Program” impacts Venice negatively
”. This program strongly recommends departing planes turn south, sending air traffic
over Venice, and away from residents of Santa Monica. What are your plans to address
this burden on neighboring communities, and protect your neighbors from Santa
Monica Airport’s negative impacts?
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 43 of 51
In conversation with the FAA (western division), we were told that the “Fly Neighborly”
policy was arbitrary. Flight training pilots are capable of taking off in either direction,
either north or south, the FAA just wants a consistent takeoff pattern for student pilots.
The prior Airport Director, Bob Trimborn told us that in the past prop-planes
alternated take offs between Santa Monica and Venice. It was due to Santa Monica
resident’s complaints that the city of Santa Monica decided to fly almost exclusively
over Venice. The FAA is concerned only with selecting one consistent director for turns
upon takeoff. For other visual flight planes, the FAA does not require any consistent
takeoff director, only Santa Monica does. There has been a great outcry about the
health and safety concerns of neighboring citizens.
City’s Response to Comment 76:
The City notes that the issues raised in this comment concerning flight direction for
departing planes are outside the scope of these Minimum Standards and can be
addressed elsewhere.
Comment 77. Flight School Traffic Pattern
The City received the following comment:
Flight School Traffic Pattern – We are concerned about the possible increased number
of flight schools (see above). There are currently five. What is the motivation for more
flight schools when your own citizens want fewer round-robin flights by inexperienced
trainer pilots? What is the expected flight school path, and how will you limit the
impacts to the surrounding community?
City’s Response to Comment 77:
The City notes that the issues raised in this comment concerning flight school paths
are outside the scope of these Minimum Standards and can be addressed elsewhere.
The City also notes that these Minimum Standards are intended to establish
reasonable entry requirements for entities interested in providing flight school
services at the Airport, and that the City would evaluate any applications to do so in
a manner consistent with the Minimum Standards, City regulations and policies, and
applicable federal rules governing operations of the Airport.
Comment 78. SMO Fuel Sales
The City received the following comment:
SMO Fuel Sales – We feel that providing fuel sales encourages the use of SMO, and
we’re against that.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 44 of 51
City’s Response to Comment 78:
The City notes that general aviation airports, including Santa Monica Airport while it
remains in operation under the Consent Decree, must permit fuel sales consistent
with any applicable federal regulatory requirements.
Comment 79. 3,500’ Runway
The City received the following comment:
3,500’ Runway – The 3,500’ runway is only marginally safe for 3% of the aircraft that
previously used SMO for charter flights (per the Coffman Report). Only 3% meet
charter standards at 30% load. Minimum Standards need to protect the community
beyond the safe load for SMO’s new shorter runway. How are you going to make
certain departing planes adhere to the FAA guidelines to protect the community from
aircraft using the airport beyond the safe load of the aircraft for SMO’s short runway?
We understand your explanation, but we are still concerned with large jets flying in
and out of this airport, which makes added pollution, traffic, and noise for the
community.
City’s Response to Comment 79:
The City notes that the issues raised by this comment regarding runway length and
FAA guidelines for aircraft use of the shortened 3,500 foot runway are outside the
scope of the Minimum Standards and can be addressed elsewhere. With respect to
compliance with noise restrictions, see City response to comment 74.
Comment 80. Request for Weight Auditing Provisions
The City received several comments requesting that the City impose a “weight
auditing provision” requiring operators to disclose the weights of incoming or
departing flights.
The City received the following comment:
Standards for the Disclosure and Transparency of Operational Data
Commercial service providers supporting any aeronautical operations are required to
provide monthly operational data in electronic format. Data to be made public and
included in the SM open data portal. Funded by service provider.
Disclosure and reporting of: passenger numbers; fuel quantity distributed; aircraft
origins and destinations; aircraft makes and models; aircraft weights; purpose of
operation (recreation, training, medical, travel).
Supports the City’s Open Data initiatives and provides public visibility and
accountability for SMO’s operations.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 45 of 51
Press Release -- https://www.smgov.net/Content.aspx?id=52569
SM Open Data Portal – https://data.smgov.net
The City also received the following comment:
I urge you to pass a Minimum Standards with weight auditing provisions, and not to
lease our land until the Minimum Standards have been approved.
The City also received the following comment:
Please Pass a Minimum Standards with weight auditing provisions, and not to lease
our land until the Minimum Standards have been approved.
We live at the end of the runway and have already had one plane crash into the side
of our house.
Our kids go to school within 5 min walk of the airport.
JUST DO THE RIGHT THING. People come first. Its so easy when you do the right thing.
The City also received the following comment:
A provision in the minimum standards should require companies to share name-
redacted flight logs for audit of passenger, baggage and fuel weights as a condition to
leasing property at the airport, and properties must not be leased until the standards
have been approved.
The same commenter further stated:
On 3,500 foot runways these business jet loads are restricted by weight and weather
conditions by the FAA, for the safety of pilots, passengers and populations.
We want this restriction regulated and enforced by the Minimum Standards.
The City also received the following comment:
In your discussions and voting on issues regarding leasing our land at Santa Monica
Airport to aviation businesses, please pass a Minimum Standards with weight auditing
provisions, and please do not lease our land until the Minimum Standards have been
approved. We want the remaining years before we can close the airport operations for
good to be safe years.
The City also received the following comment:
As a resident affected by the air traffic at Santa Monica airport, I am petitioning for the
City Council and The Airport Manager to please pass a Minimum Standards with
weight auditing provision, and do not lease our land until the Minimum Standards
have been approved. I believe these items to be a health and safety issue.
The City also received the following comment:
We ask our city council and staff to pass a Minimum Standards with weight auditing
provisions, and not to lease our land until the Minimum Standards have been
approved. Please note we’re trying to keep our community and children safe from
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 46 of 51
pollution jet fuel, and possibly accidents from these planes. We asked for less runway
to stop such jets and commercial operations. Yet it still has jets and the dangers are all
still there. I am longtime concerned resident of sunset park, homeowner, parent, voter
and tax payer. Please listen to your community and residents.
The City also received the following comment:
Please pass a Minimum Standards with weight auditing provisions, and kindly refrain
from leasing the land until the Minimum Standards have been approved.
The City also received the following comment:
Our request is simple: Pass "minimum standards" with weight auditing provisions,
and do not lease our land until those minimum standards have been approved.
That's it. If you want our votes in the next election, and if you want us to tell our
friends to vote for you, and if you give a darn about the citizens of Santa Monica, do
these simple things. We have spent too many years supporting the needs of the few
(i.e., SMO aircraft owners and users) without regard for the many (i.e., the rest of us).
The City also received the following comment:
The new, shorter runway is having an audibly noticeable effect. Yet the situation
requires ongoing oversight.
Safety must remain a primary concern. To minimize the potential for danger, all
aircraft must adhere to FAA guidelines governing the weight of passengers, baggage,
and fuel. Those mandates ensure that planes retain sufficient power and
maneuverability to takeoff and land without risking the lives of people onboard and
on the ground.
As you consider what rules for the new runway should be in place and consistently
enforced, I urge you to incorporate the Federal requirements.
The City also received the following comment:
I have lived at Pier and 17th Street for 25 years. When we bought our house, there
were not jets allowed and since that time the jet noise and pollution have become
unbearable. I have 3 children that live there, and their safety and health are of the
utmost importance to me and my family.
I would like to ask that you work with the City Council to pass a Minimum Standards
with weight auditing provisions, and not to lease our land to jet companies until the
Minimum Standards have been approved.
The City also received the following comment:
With respect to our small local airport, please approve Minimum Standards with
weight auditing provisions. Please do not sign leases or permit airport use, even on
temporary basis, until the Minimum Standards are adopted. Greater conditions and
restrictions are needed; Minimum Standards are the starting line of acceptable.
Anything less is unacceptable.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 47 of 51
The City also received the following comment:
As a Santa Monica Resident down the flight path of Santa Monica Airport, I
respectfully request that you avoid leasing to aircraft operations or renewing the leases
of existing operations at SMO, until the Minimum Standards for lease have been
approved. Further, I respectfully request that those minimum standards include
provisions that allow audit of passenger, baggage and fuel weights. These weights are
critical in determining needed runway length for take-off and landing as specified by
manufacturers and FAA regulations at our airport.
The City also received the following comment:
Regarding jet use on our short runway: Please pass Minimum Standards with weight
auditing provisions, and not to lease our land until the Minimum Standards have been
approved.
The City also received the following comment:
I would also like to voice my support to pass a Minimum Standards with weight
auditing provisions, and not to lease our land until the Minimum Standards have been
approved.
These Minimum Standards should include a provision that allows audit of passenger,
baggage and fuel weights.
City’s Response to Comment 80:
The City shares the commenters’ commitment to the safe operation of the Airport.
The City notes that aircraft manufacturers, in conjunction with the FAA, set
restrictions on permissible aircraft loads. As shown in the attached redline: (a)
Section 5.3 has been added to require Aircraft Charter Operators to comply with all
applicable FAA regulations, including any such regulations limiting the permissible
weight of aircraft loads based on factors such as runway length, weather, and aircraft
operating specifications; and (b) Section 5.4 has been added to require reports
identifying the type of aircraft, number of passenger seats, and number of
passengers carried on each flight, all information relevant to determinations by the
Airport Director that Air Charter operators are not exceeding the scope of their FAA
certifications. With respect to additional “weight auditing provisions,” that would
require Aircraft Charter Operators not only to comply with FAA regulations, but also
to provide the City with specific weight information and other information regarding
the purpose of particular flights, or the names of passengers on particular flights, the
City notes that such information likely will be viewed as bearing only a limited
relationship to the City’s operation of the Airport and is not typically required at
other general aviation airports.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 48 of 51
Comment 81. Standards to Minimize Environmental
Impacts
The City received the following comment:
Standards to Minimize Environmental Impacts
Commercial service providers are required to implement the highest level of
operations and equipment available in the industry to minimize environmental
impacts. Funded by service provider.
FBOs required to use electric tugs and sustainable ground power units. Aircraft are
required to be towed to the end of the runway. Training aircraft are required to be
solar, when solar is commercially available. Non-leaded fuel required when
commercially available, and leaded fuel must not be provided. No commercial self-
service fueling (which defeats the purpose of having minimum standards).
Supports the City’s commitment to sustainability and reduces the negative
environmental impacts of SMO.
Electric Tugs –https://youtu.be/itrtVlYOUQQ
Sustainable GPUs –https://youtu.be/DX-ejWuGzsA
City’s Response to Comment 81:
The City notes that it has incorporated by reference in these Minimum Standards
applicable federal, state, and local requirements concerning environmental interests
and insurance measures to protect against potential harm. See, e.g., City response
to comment 55. The City further notes that, under the terms of the Consent Decree,
for so long as the Airport continues to operate as a general aviation airport, the City
must allow aeronautical service providers access on fair and reasonable conditions
without unjust economic discrimination. . The City declines to revise the Minimum
Standard to include the requested changes.
Comment 82. Security Issues
The City received the following comment:
Standards to Increase Safety and Security
Commercial service providers are required to maintain TSA level security. Must comply
with local and FAA regulations. Operate only in SMO areas authorized for
aeronautical use. Funded by service provider.
Commercial service providers are required to maintain TSA level security. Must comply
with local and FAA regulations. Operate only in SMO areas authorized for
aeronautical use. Funded by service provider.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 49 of 51
On July 14, 2015 City Council directed staff to review SMO security issues. SMO
security is minimal and inconsistent at best.
September 11th terrorists trained at flight schools in Florida, Arizona, and Minnesota.
Big Holes in Aviation Security, No screening of private flights, passengers –
http://www.nbcnews.com/id/3540829/ns/us_newssecurity/t/big-holes-seen-aviation-
security
SMO has been used repeatedly to transport drugs – http://smdp.com/flight-out-of-
smo-ends-in-drugbust/79503
City’s Response to Comment 82:
Airport security measures undertaken by the City itself are not the subject of these
Minimum Standards, which set requirements for individual operators providing
commercial aeronautical services at the Airport. The City notes that the Minimum
Standards require each Operator to comply with applicable security requirements
and to implement a documented security plan. See Minimum Standards, Section
3.7. See also City response to Comment 73.
Comment 83. General (Waivers and Other Topics)
The City received from one commenter detailed comments on several aspects of the
Minimum Standards, and the City has reviewed these comments carefully. The City
has included below this commenter’s overall summary in the cover letter
accompanying his comments:
A (considerably) revised version of this document will help the City to manage Airport
operations and protect itself from unqualified, unsafe, or counterproductive
operators/operations.
This draft should be clarified, simplified, include residents as stakeholders. It should
elevate and limit the many discretionary approval and disapproval options by the
Airport Director. As it stands, some approval options infringe on City Council policy
choices, City Manager authority, and/or exclude the City Attorney from knowing about
and providing legal advice that informs consequential City-wide choices.
Minimum standard “waivers” should be recorded, compiled, and be publicly available.
Transparency should be preserved. Widespread waivers facilitate claims of favoritism
and open avenues for FAA Part 16 litigation.
Lastly, it seems that many of the “minimum” requirements really should be minimum
and thus not be waived – because of inherent prudent limits on aviation tenants, their
importance, and - because when minimum requirements are routinely waived, it
demonstrates a predicate basis for capricious and/or favoritism.
I think that the City can protect itself and residents more effectively with some
changes. I’ve added 50+ comments to this draft.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 50 of 51
• Don’t require the FBO (and some SASOs) to operate until 11PM (even after the tower
closes); aviation lease holders may choose to stay open but should not be required to
do so.
• For the City to require the full range of aviation support services to be immediately
available until 11PM as a lease condition:
o Demonstrates contempt for surrounding residents’ health and wellbeing that is
now harmed by evening aircraft noise during and after voluntary evening curfew
hours. Recent gold-standard research demonstrates the severe damage that noise,
particularly at night, causes to cardiac health. Reference available on request.
• One overarching principle should be to reduce SMO’s negative consequences for
Santa Monica and its residents by “baking in” as many of the aviation “negative
externalities” into FBO and SASO operations.
o Present third-party aircraft liability insurance is inadequate to pay for loss of
house or life should an aircraft (many are LLCs) destroy a house or kill/injure
nearby residents.
o This document seems to ratify low insurance coverages and allows the Airport
Director to further waive “minimum” requirements.
• The City can and should require the FBO and appropriate SASOs to communicate
City Noise Code enforcement, and advise operators of 3,500’ runway constraints and
the FAA safety requirements that must be observed – some as a matter of operational
planning.
Last, please see my comments in Sections 5 and 9 that are intended to proactively
address On-Demand operations.
City’s Response to Comment 83:
The City notes that several of these comments concerning waivers, insurance
requirements, charter operations, on-demand operations, and security have been
addressed in City responses to other comments above. See City responses to
comments 6, 23, 46, 67, 68-70, 73, and 82. With respect to compliance with
environmental and noise restriction laws and regulations, see City responses to
comments 13, 55, and 74.
Comment 84. Bond Requirement for Leases
The City received the following comment:
Is there a bond or security deposit built into leases at SMO? If no, I recommend
incorporating a bond or security deposit into any new lease at the airport. This deposit
could cover any costs associated with waste disposal or environmental cleanup that
may be required after a tenant leaves or the airport closes.
City of Santa Monica
Responses to Comments – Airport Minimum Standards Pg. 51 of 51
City’s Response to Comment 84:
The City notes that security deposit requirements are outside the scope of the
Minimum Standards and can be addressed elsewhere.
Minimum Standards
For
Commercial Aeronautical Services
At
SANTA MONICA MUNICIPAL AIRPORT
Table of Contents
SECTION 1 GENERAL INFORMATION ............................................................................................ 11
SECTION 2 APPLICATION PROCEDURES ..................................................................................... 44
SECTION 3 GENERAL REQUIREMENTS ........................................................................................ 77
SECTION 4 FIXED BASE OPERATOR .......................................................................................... 1211
SECTION 5 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
CHARTER AND AIR TAXI......................................................................................... 1817
SECTION 6 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: FLIGHT TRAINING
............................................................................................................................................ 2019
SECTION 7 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
MAINTENANCE AND REPAIR STATIONS ........................................................ 2221
SECTION 8 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: SELF‐SERVICE
FUEL PUMPS ................................................................................................................. 2423
SECTION 9 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
MANAGEMENT SERVICES ...................................................................................... 2725
SECTION 10 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
SALES OPERATOR ...................................................................................................... 3027
SECTION 11 SPECIALIZED AERONAUTICAL SERVICE OPERATOR: OTHER
AERONAUTICAL SERVICES .................................................................................... 3128
SECTION 12 SPECIAL RULES FOR A SASO CONDUCTING MULTIPLE AERONAUTICAL
SERVICES ....................................................................................................................... 3229
SECTION 13 RECOGNITION AND REGULATION OF SELF‐SERVICE AND SELF‐
FUELING RIGHTS ........................................................................................................ 3431
APPENDIX A DEFINITIONS ............................................................................................................ 3636
APPENDIX B INSURANCE REQUIREMENTS AND STANDARDS Error! Bookmark not
defined.42
APPENDIX B‐1 MINIMUM INSURANCE REQUIREMENTS MATRIX .. Error! Bookmark
not defined.42
Page 1 of 48
SECTION 1
GENERAL INFORMATION
PURPOSE
These regulations prescribe the Minimum Standards that must be met by any person or
entity that provides or seeks to provide commercial aeronautical services (an "Operator")
at the Santa Monica Airport (the "Airport"). Each Operator must have a written
agreement with the City of Santa Monica (the "City").
The purpose of these Minimum Standards is to establish reasonable threshold entry
requirements for any person or entity wishing to provide commercial aeronautical
services to the public; to prevent irresponsible, unsafe or inadequate services; to prevent
unfair competition; and to make the Airport as financially self-sustaining as possible. The
establishment of these Minimum Standards does not imply any right to provide any
services at the Airport.
The adoption and enforcement of these Minimum Standards is intended to ensure that
each Operator is reasonably fit, willing and able to perform the services it seeks to
provide at the Airport. These Minimum Standards are designed to promote good service
and fair competition at the Airport and to discourageprevent unqualified applicants from
operating at the Airport.
It is the City’s policy to extend the opportunity to provide aeronautical services to any
person or entity meeting the City's Minimum Standards for such services at the Airport,
subject to availability of suitable space at the Airport (as determined by the City) to
accommodate such activities, and subject to the City’s rights under the Consent Decree.
The City’s rights include, but are not limited to, its rights to shorten the runway at the
Airport, to exercise its proprietary exclusive right to provide any or all of the aeronautical
services that are the subject of these Minimum Standards, and to close the Airport on or
after January 1, 2029.
These Minimum Standards are subordinate to the Consent Decree. To the extent that
these Minimum Standards may conflict with the provisions of the Consent Decree, the
Consent Decree shall govern.
These Minimum Standards are also subordinate to the City of Santa Monica’s Charter
and Municipal Code, including but not limited to Municipal Code Chapter 10.04, and the
City’s Airport Leasing Policy. To the extent that these Minimum Standards may conflict
with the provisions of the City’s Charter, or Municipal Code or the Airport Leasing Policy,
those City instruments shall govern.
To the extent (if any) that these Minimum Standards may conflict with the Santa Monica
Airport Operations Handbook, these Minimum Standards control.
Capitalized terms are defined in Appendix “A” to these Minimum Standards.
APPLICABILITY
All Operators shall, as a condition of conducting Commercial Aeronautical Activities at
the Airport, comply with all applicable requirements concerning such activities as set
forth in these Minimum Standards and any amendments thereto. The requirements set
forth herein are the Minimum Standards which are applicable to Operators at the Airport
Page 2 of 48
and all persons are encouraged to exceed such Minimum Standards in conducting their
activities. These Minimum Standards shall be deemed to be a part of each Operator’s
Lease, license, permit or Agreementagreement with or from the City unless any such
provisions are waived or modified, in writing, by an authorized representative of the City.
The mere omission of any particular standard from an Operator’s written Lease, license,
permit or Agreementagreement with the City, shall not constitute a waiver or
modification of such standard in the absence of clear and convincing evidence that the
City intended to waive or modify such standard.
These Minimum Standards apply to any person or entity that provides aeronautical
services to any third party at the Airport.
These Minimum Standards shall not affect any lease, license, permit or agreement with
an Operator or amendment to any such an agreement that was properly executed prior
to the date of adoption of these Minimum Standards, except: (a) as provided for in such
agreement, in which case, these Minimum Standards shall apply to the extent permitted
by such agreement, subject to the Operator having six months from the date of adoption
to comply with these Minimum Standards; and (b) that any new subleases shall be
prohibited and any existing sub-tenancies at the time of adoption of these Minimum
Standards shall be subject to an orderly phase-out at the discretion of the City.
These Minimum Standards shall not be deemed to modify any existing Lease, license,
permit or agreement under which an Operator is required to exceed these Minimum
Standards nor prohibit the City from entering into and enforcing a Lease, license, permit
or agreement or amendment thereto that requires an Operator to exceed these Minimum
Standards.
Any entity currently engaging in activities covered by these Minimum Standards without
a Lease, license, permit or agreement shall have six months from the date of adoption to
comply with these Minimum Standards.
If these Minimum Standards are amended after an Operator enters into a Lease, license,
permit or agreement with the City, the entity shall not be required to comply with the
amended Minimum Standards, except as provided for in such Lease, license, permit or
agreement, until (a) such time as the entity’s existing Lease, license, permit or
agreement is amended or renewed, (b) the City approves an assignment to another
entity, or (c) the entity enters into a new Lease, license, permit or agreement with the
City.
EFFECTIVE DATE
These Minimum Standards shall become effective on January 1,_____________, 2018
(the "Effective Date"). Each and every Operator conducting any commercial aeronautical
activity at the Airport on or after the Effective Date must hold either (a) a current and
valid Lease with the City which specifies that the Operator's commercial aeronautical
activities are a permitted use; (b) a Non-Exclusive License from the City authorizing the
Operator to engage in such commercial aeronautical activity; or (c) if an approved
subcontractor for an Operator, a Commercial Operations Permit. Any such Lease, Non-
Exclusive License, or Commercial Operations Permit shall be in a form prescribed by the
City that specifies which types of aeronautical services the Operator (or subcontractor) is
authorized to provide; requires the payment of fees to the City; imposes insurance,
Page 3 of 48
indemnification, environmental obligations; and requires a security deposit or other form
of contract security.
RIGHT TO AMEND STANDARDS
The City reserves the right to amend these Minimum Standards as the City determines
may be necessary or desirable to meet the needs of the Airport, to improve the quality of
services, to enhance competition or as otherwise deemed to be reasonable by the City.
The City further reserves the right to amend these Minimum Standards to pursue the
City’s rights under the Consent Decree, including the closure of the Airport on or after
January 1, 2029, as described in the Consent Decree.
WAIVERS
The Airport Director may, in his or her sole discretion, waive any requirement imposed
by these Minimum Standards for the benefit of any governmental entity providing non-
profit services to the aviation industry, performing emergency medical or rescue services
to the public by means of aircraft or performing fire prevention or firefighting operations.
The Airport Director may also waive any of the Minimum Standards for non-
governmental Operators if the Airport Director, in his or her sole discretion, deems such
a waiver to be in the best interest of the City. Waivers that extend for the duration of any
new lease must be approved by the City Manager. If a waiver is being proposed for an
Operator, then the Airport Director shall note in any public document submitted to the
Airport Commission or City Manager that such waiver has been proposed.
CATEGORIES OF AERONAUTICAL SERVICE OPERATORS
The following categories of Operators may provide commercial aeronautical services at
the Airport:
1. Fixed Base Operator ("FBO")
2. Specialized Aeronautical Services Operator ("SASO")
a. Aircraft Charter and Air Taxi
b. Flight Training
c. Aircraft Maintenance and Repair Stations
d. Aircraft Management
e. Self-Service Fuel Pumps
e. Aircraft Management
f. Air Transportation Arranger
g. Aircraft Sales Operator
h. Other Aeronautical Services
Page 4 of 48
SECTION 2
APPLICATION PROCEDURES
1. An application to perform commercial aeronautical services at the Airport must
be made in accordance with these Minimum Standards. The application must be
signed by an authorized person and include the name, address, email address
and telephone number of the applicant and the following information:
a. For all applicants - the name, address and telephone number of each
person with a controlling interest in the applicant.
b. For a corporation - the name, address, email address and telephone
number of the corporation’s officers and directors.
c. For a partnership or joint venture - the name, address and telephone
number of each partner or member of the venture.
d. Whether any officer, director, partner or person with a controlling interest
in the applicant is also an officer, director, partner or person holding a
controlling interest in any other commercial aeronautical service Operator
at the Airport.
2. The application, together with all required supporting documentation, shall be
submitted to:
City of Santa Monica, Santa Monica Airport –
Attn: Airport Director
3223 Donald Douglas Loop South
Santa Monica, CA 90405.
3. An applicant shall furnish the following supporting documents as evidence of its
organizational and financial capability to provide the proposed aeronautical
services:
a. Business Plan - a written proposal detailing the nature of the proposed
aeronautical service to be provided, the applicant's space and facility
requirements, and the proposed location on the Airport.
b. Financial Statement - a current financial statement (for a corporation, sole
proprietorship or for all principals of a partnership or joint venture)
prepared in accordance with generally accepted accounting principles by
a certified public accountant.
c. Credit Report - a current credit report (for a corporation or for all principals
of a partnership or joint venture) covering all business activities in which
the applicant has participated within the past ten years. To satisfy this
requirement, an applicant shall furnish to the Airport with its application a
fee that the Airport shall use to perform the required credit report check.
d. Personnel - a list, with resumes, of key personnel to be assigned to the
Airport along with a description of their duties and responsibilities.
Page 5 of 48
e. Licenses and permits - copies of all licenses, certifications and permits
possessed by the applicant or its key employees to be based at the
Airport that are required to perform the proposed services.
f. Evidence of insurance that meets the applicable requirements as set forth
in Section 3 of these Minimum Standards.
g. Commercial Operations Permit Application.
h. Such other information as the Airport Director may require.
4. The Airport Director may deny any application to provide aeronautical services at
the Airport if, in his or her sole discretion, the Airport Director determines that:
a. the applicant does not meet any applicable provisions of these Minimum
Standards;
b. the applicant has supplied the City, or any other person, with false or
misleading information or has failed to make full disclosure in its
application or in its supporting documents;
c. there is no appropriate, adequate or available space on the Airport to
accommodate the applicant at the time of application;
d. the proposed activity would conflict with existing aeronautical uses;
e. the proposed activity would require the City to spend funds or to supply
materials or manpower that the City would, in its discretion, prefer not to
spend or supply;
f. the proposed activity would require existing Operators without their
consent to reduce the amount of Airport property they use to provide
aeronautical services, result in congestion anywhere within the Airport or
interfere with the orderly activities of existing Operators;
g. the proposed service activities could be detrimental to the Airport;
h. the applicant has violated any of these Minimum Standards or any other
regulations of the City, the standards or regulations of any other airport,
or any other statutes, regulations, ordinances, laws or orders applicable
to the Airport or any other airport;
i. the applicant is currently in default, or has been in default in the past, in
the performance of any lease or other agreement with the City or at any
other airport;
j. the applicant's financial statement or credit report contains information
that creates doubt as to the applicant’s abilities to provide the proposed
services;
k. the applicant does not have or cannot demonstrate access to the
operating capital necessary to conduct the proposed operation;
Page 6 of 48
l. the applicant is unable to obtain sufficient insurance, financial sureties or
guarantors to protect the interests of the City or other appropriate
governmental entities;
m. the applicant has been convicted of any felony;
m. the applicant has been convicted of any felony or misdemeanor involving
moral turpitude; except that the Airport Director, in his or her discretion,
may disregard such conviction based on consideration of the following
factors: mitigating circumstances that may exist, the nature and gravity of
the offense, the time elapsed, the nature of the aeronautical services to
which the application applies and the relatedness of the conviction to
those services, and any other factors that are related to the application
and consistent with business necessity;
n. the applicant's proposal is not in the best interest of the health, safety,
welfare or convenience of the traveling public or Airport Users;
o. the applicant is unable to qualify for unescorted access to Airport
Operating Areas, if required to provide proposed services;
p. approval of the proposed activity would be inconsistent with the Consent
Decree;
q. the applicant’s proposal is inconsistent with the City’s Airport Leasing
Policy; or
r. the applicant’s proposal is inconsistent with the City’s Charter or
Municipal Code.
Page 7 of 48
SECTION 3
GENERAL REQUIREMENTS
These Minimum Standards establish certain requirements to be met by every Operator
providing aeronautical services at the Airport. Such Operators must, in addition to
complying with all applicable Minimum Standards, comply with all other applicable laws,
regulations, ordinances, rules, building codes, or other provisions, including contracts,
relating to their operations at the Airport.
In addition to the Minimum Standards applicable to each specific category of commercial
service operation set forth below, every Operator providing aeronautical services at the
Airport must meet the following general requirements.
1. Property/Facilities. Unless exempted from this requirement by the Airport Director
in his or her sole discretion, each Operator must lease the property or facilities
required for the services it renders directly from the City.
2. Hangars and Other Buildings. If required by these Minimum Standards, the
Operator shall lease hangar for aircraft storage and shall lease sufficient
buildings to support its activities at the Airport.
3. Aircraft Parking Apron. If required by these Minimum Standards, the Operator
shall lease sufficient paved aircraft parking apron within its leasehold premises to
meet the requirements of its aeronautical activity and shall maintain any paved
taxiways necessary for access to the Airport’s taxiway system.
4. Equipment.
a. The Operator must demonstrate that it owns, leases or otherwise has
sufficient access to all equipment required to provide the applicable
aeronautical services promptly on demand without causing any flight
delays or other operational impacts on aircraft at the Airport. All
equipment must be maintained in good operating condition and good
appearance and must be in compliance with all applicable safety
standards and regulations. All heavy equipment except aircraft must be
clearly designated with the name and logo of the Operator prominently
displayed.
b. Any Operator that is involved with towing aircraft off of its leased
premises and onto other airport property shall own or contract for
appropriate equipment to be used and for appropriate lighting to be used
during tow operations (including strobe lights).
c. All vehicles driven on Airport property must have any permits and anyor
required registrations, and as required by federal, state or local law.
Such vehicles also must be operated by persons with appropriate
licenses or permits and trained under the Airport’s driver safety training
program, should the Airport require such training.
Page 8 of 48
d. Any Vehicle used for Commercial purposes in the AOA must bear
identification designating the Commercial Aeronautical Operator to whom
the vehicle is assigned. The display of identification shall be in letters in
sharp contrast to the background and shall be of such size, shape, and
color as to be readily legible during daylight hours from a distance of 50
feet.
5. Personnel and Training.
a. All non-management personnel in the AOA shall be suitably
uniformed, with the name of the Operator prominently displayed. All
personnel in the AOA personnel shall display Santa Monica Airport ID
badges at all times on their person, as required by Airport Rules. Non-
Administrative personnel in the AOA shall wear clothing that displays the
identification of the Operator in letters in sharp contrast to the background
which shall be of such size, shape, and color as to be readily legible
during daylight hours from a distance of 20 feet. Administrative personnel
need not wear uniforms.
b. An adequate number of qualified and, where applicable, licensed
employees shall be on duty at all times of operation to provide services
consistent with these Standards.
c. At least one qualified supervisor shall be on duty when any aeronautical
services are being performed by any Operator. A supervisor may be “on
duty” for purposes of this subsection if the supervisor is available by
phone, but not at the Airport, provided that in such a case an Operator
must provide the Airport Director with a list of phone numbers at which
the Airport can reach supervisors during regularly scheduled shifts.
d. Each Operator shall establish a written training programjob description
for each type of employee to ensure that all employees are thoroughly
trained and qualified to perform the aviation tasks to which they are
assigned. The training program shall contain detailed instruction in
proper operating procedures for each job classification. Upon
request, the Operator shall submit a copy of its written training
program The level of detail required for each job description shall be
commensurate with the technical complexity and safety risks associated
with the employee’s work. At a minimum, each job description shall
include a statement of responsibilities, as well as required skills, degrees,
and certificates. For more technically specialized work or work involving
heavy equipment or significant safety concerns, the description shall also
include what training, experience, and safety precautions are required to
perform the required tasks. Upon request, the Operator shall submit a
copy of its written job descriptions to the Airport Director or designee.
e. All personnel who will operate a vehicle on the AOA must successfully
complete the Airport’s initial training course on driving on the AOA and
any refresher training that may be required by the City.
Page 9 of 48
f. Each Operator shall provide to the Airport Operations/Public Safety
Officer Unit a list of company officials and 24-hour contact information.
This list shall include:
i. the Operator’s local representative with administrative, operational
and fiscal authority over the aircraft/facility involved;
ii. the Operator’s corporate representative with administrative,
operational and fiscal authority over the aircraft/facility involved;
and
iii. the Operator’s point of contact for emergency/security incidents.
6. Insurance Requirements.
a. PriorAll Operators shall comply with the insurance Requirements and
Standards set forth in Appendix “B” to these Minimum Standards, which
may be revised by the City. These include the requirement that all
Operators shall procure prior to commencement of service, all
Operatorsand shall procure andthereafter maintain continuously in
effect throughout the term of their activities uponat the Airport, at the
Operator's sole expense, insurance of the types and in at least such
minimum amounts as are set forth in Appendix “B-1” to these Minimum
Standards, which may be revised by the City.
b. In his or her sole discretion, the Airport Director may waive, reduce or
otherwise modify any of the insurance requirements set forth in these
Minimum Standards including, but not limited to, reducing required policy
limits, waiving certain coverage requirements or authorizing larger self-
insured retentions, provided, however, that in no circumstance may an
Operator be permitted to operate at the Airport without insurance.
7. Airport Security.
a. All Operators shall comply with all applicable security requirements
adopted for the Airport by the City (including but not limited to any Airport
Security Plan issued by the City), the FAA, or the Transportation Security
Administration, and shall comply with the directives of any law
enforcement officer or other airport personnel implementing these
requirements. The City reserves the right in its sole discretion at any time
to impose additional security requirements, applicable to all similarly-
situated Operators.
b. Operator shall have a documented security plan consistent with its
Activity or Activities and adequate for the type of operation and services
being provided. The security plan shall be made available to the Airport
Director upon request and shall address at a minimum procedures for the
following:
i. Securing Commercial Aeronautical Operator’s Leasehold to
prevent unauthorized access to the Leasehold and the AOA of the
Airport.
Page 10 of 48
ii. Monitoring and controlling access to the Airside Area of the Airport
through Commercial Operator’s Leasehold.
iii. Providing escort to vendors, customers or other visitors operating
vehicles on the AOA.
iv. Informing Commercial Aeronautical Operator’s employees,
vendors, customers and other visitors of security requirements
and procedures.
8. Subcontracting. A SASO may, but only with written permission from the Airport
Director may, subcontract any of the services it is authorized to provide on an
item by item basis for no more than 180 days, subject to renewal with the
permission of the Airport Director.
9. No Subleasing. New sub-leasingSubleasing shall be prohibited. Existing sub-
tenancies at the time of adoption of these Minimum Standards shall be subject to
an orderly phase-out at the sole discretion of the City.
10. Commercial T-Hangars. Commercial T-hangar rental shall be prohibited. Only
the City may lease and manage T-hangars for storage of general aviation
aircraft.
11. Compliance with Airport Leasing Policy, City Charter and Municipal Code. All
Operators must comply with all applicable sections of the Municipal Code and the
policies of the City of Santa Monica, including but not limited to, the following:
a. The City’s Airport Leasing Policy;
b. The City’s Charter and Municipal Code, including but not
limited to:
i. Article XXII of the City of Santa Monica Charter (the
“Oaks Initiative”) (located at
http://www.qcode.us/codes/santamonica/view.php?topic=the_char
ter_of_the_city_of_santa_monica-xxii&frames=on); and
ii. Chapter 10.04 of the Municipal Code.
1112. Nondiscrimination. Operator shall not discriminate against any person or class of
persons by reason of race, creed, color, national origin, sex, age, sexual
orientation, gender identity, or physical handicap in providing any products,
services, or facilities or in the use of any of its facilities that are available to the
public, or in any manner prohibited by applicable regulatory measures including
without limitation Part 21 of the Rules and Regulations of the office of the
Secretary of Transportation effectuating Title VI of the Civil Rights Act of 1964, as
amended or reenacted.
13. Americans with Disabilities Act Compliance. Operator shall comply with the
Americans with Disabilities Act, as amended, to the extent required by law.
14. Environmental Compliance. Operator shall comply with all applicable federal,
state, and local environmental laws and regulations.
Page 11 of 48
15. Noise Restrictions Compliance. Operator shall comply with all applicable federal,
state, and local noise restriction laws and regulations.
16. Combination of Space Requirements. In his or her sole discretion, to reduce the
overall amount of space required, the Airport Director may adjust or combine the
minimum space requirements set forth for each type of aeronautical service if
more than one type of service will be provided by a SASO from the same
premises.
1217. Required Fees and Payments. The fees and payments to be made to the City by
each Operator will be set forth in the Operator's Lease or Non- Exclusive License
and shall be reasonable and not unjustly discriminatory.
Page 12 of 48
SECTION 4
FIXED BASE OPERATOR
This section sets forth the minimum standards for a Fixed Base Operator at the Airport.
STATEMENT OF CONCEPT
An FBO provides a wide range of aeronautical services to the public. An FBO must
provide all of the following products and services at its premises at the Airport:
1. Storage of aviation fuel and other petroleum products at City’s fuel storage
facilities.
2. Aircraft and engine maintenance and repair services directed towards the
general aviation market.
3. Tie-down services.
4. Shuttle service for passengers of chartered, private and executive aircraft.
5. Arrange car rental, limo services or taxi-cab services for customers.
6. Arrange catering services for customers.
7. Marshaling and parking of aircraft.
8. Maintenance of the Airport’s Registration Log and other statistical data
concerning the FBO’s activities on the Airport.
9. Automotive maintenance for ground support equipment at the Airport.
10. Aviation maintenance and repair service with a licensed airframe and power plant
mechanic at the Airport.
11. Gate service for aircraft such as, but not limited to, passenger ramp service
baggage handling, catering, and interior cleaning of aircraft.
12. Towing service for disabled aircraft. For larger aircraft (over 30,000 lbs.) the
FBO may arrange with other qualified operators to provide this service.
13. Into-plane Fueling.
a. Aviation fuels (including both jet fuel, AvGas and unleaded AvGas once
commercially available and approved for use) and lubricating oils shall be
stored and dispensed by an FBO in accordance with all local, state and
federal laws, regulations, rules and other requirements, as same may be
amended, regarding the sale and storage of such fuels and oils, including
without limitation any rules, regulations or minimum standards that are
established by the City.
Page 13 of 48
b. Prior to commencement of the operations of dispensing and selling fuels,
an FBO shall submit to the City, for review and comment, the FBO’s Spill
Prevention Control and Countermeasure Plan and Pollution Incident and
Prevention Plan and any permit requirements necessary by local, county
and State agencies.
14. Other Services. An FBO may provide other specialized aeronautical services on
its leasehold subject to the approval of the City, through the Airport Director,
including the sale or rental of all types of consumer products normally related to
the ownership or operation of aircraft; and any other services normally performed
by similar FBOs at other airports in the United States. These requests will be
reviewed and approved on a case-by-case basis.
15. Subcontracting. An FBO shall not subcontract any fueling services or other
services that it is authorized or required to provide without the prior written
approval of the Airport Director. Subcontracting of services shall not relieve FBO
of any of its obligations or liabilities under these Minimum Standards or its Lease
or Operating Agreementoperating agreement with the City.
16. Prohibited Activities. Each FBO is expressly prohibited from engaging in any of
the following activities:
a. Provision of terminal facilities for passenger operations, other than those
covered by Federal Aviation Regulations 14 CFR Parts 91 and 135.
b. Sale of non-aviation products.
b. Sale of non-aviation products, except for paraphernalia associated with
the Operator’s business (i.e., t-shirts, hats, etc.) and food and beverage
amenities (i.e. vending machine snacks, sodas, etc., but not alcoholic
beverages).
c. Air shows, or meets, .
d. Film shoots, or displays or other public gatherings, without the express
written approval of the Airport Director or designee.
de. Any service prohibited by law or not related to aviation.
ef. Advertising of any kind unrelated to services FBO is permitted to provide
at the Airport.
fg. Storage of Hazardous Materials, liquid industrial waste or any other
regulated waste that does not fully comply with all applicable
environmental laws.
gh. Constructing or operating a fuel farm without the express written approval
of the CityAirport Director.
hi. Heavy maintenance on an aircraft on a parking apron or any other area
not designated or leased for aircraft maintenance without the express
written approval of the Airport Director. This does not apply to routine line
maintenance of aircraft.
Page 14 of 48
ij. Parking, storing, or allowing the parking or storage of any vehicles on the
PremisesOperator’s premises that are not used in the daily operation of
the general aviation business permitted to be conducted on the
Premisespremises, unless such vehicles are owned and operated by the
Operator’s customers or employees.
MINIMUM STANDARDS
1. Experience. An Operator proposing to operate as an FBO shall have a minimum
of 10 years’ experience as an FBO, including the fueling of aircraft. 5 years’
experience as an FBO (including the fueling of aircraft). The Airport Director may
not exercise his or her discretion to waive this requirement unless the Airport
Director is satisfied, after reviewing documentation from an applicant the Airport
Director deems to be sufficient, that the proposed FBO Operator’s management
personnel have sufficient knowledge and experience to safely and efficiently
conduct FBO operations at the Airport.
2. Land. Each FBO must lease enough land to provide adequate space for
buildings, paved private auto parking, paved aircraft parking, paved pedestrian
walkways, fuel storage facilities, and all storage, servicing utilities and support
facilities as may be mutually agreed upon in writing by the City and FBO. The
minimum area required will not be less than 144,000 square feet.
3. Hangars and Other Buildings. Each FBO must lease facilities to provide at least
86,000 square feet of lounge (for crew and passengers), offices, flight planning
facilities, pilot waiting areas, and public restrooms.
4. Aircraft Parking. Each FBO must provide paved aircraft parking of a minimum of
30,000 square feet that can accommodate the largest aircraft to be handled or
serviced by the FBO.
5. Automobile Parking. Each FBO must lease a minimum of 20 paved private
automobile parking spaces excluding employee parking.
6. Fuel Storage Facilities. Depending on the location and nature of the proposed
FBO business, the with the advance approval of the Airport Director in writing,
the FBO may be permitted to establish and operate its own fuel farm with the
advance approval of the City in writing.. If a request by the FBO to
useestablish and operate its own fuel farm is approved by the CityAirport
Director, the following requirements will apply:
a. The FBO shall lease sufficient land for installation of above-ground fuel
storage tanks to be constructed and operated on the FBO’s leased
premises in compliance with all applicable environmental requirements.
b. Total storage capacity shall consist of at least one (1) 10,000 gallon
storage tanks for jet fuel and one (1) 2,500 gallon storage tank for
aviation gasoline to assure adequate supplies of fuel at all times.
c. The fuel storage system must include adequate fuel spill prevention
features and containment capabilities, together with an approved fuel spill
containment and countermeasures control plan, and shall be improved
Page 15 of 48
and upgraded as necessary to meet all current EPA, State, and City of
Santa Monica requirements for spill prevention, containment and
mitigation as they may be revised.
d. The FBO shall be required to undertake at its own expense any
environmental testing of its fuel facilities which the City may reasonably
request, on or off the Airport, and to take any remedial actions determined
to be necessary or appropriate as a result of such testing. The right is
reserved to the City to disapprove installation of a new FBO fuel
farm if the facility would have an adverse effect on safety or
otherwise in the judgment of the City not be in the interest of a safe
and efficient airport operation.
e. The right is reserved to the City to disapprove installation of a new FBO
fuel farm if the City determines, in its discretion, that the proposed FBO
fuel farm would have an adverse effect on safety or otherwise not be in
the interest of a safe and efficient airport operation.
7. Mobile Dispensing Equipment.
a. Each FBO shall provide at least three (3) metered filter-equipped mobile
dispensing trucks for dispensing jet fuel, AvGas, and unleaded AvGas
(once commercially available and approved for use), with separate
dispensing pumps and meters required for each type of fuel.
b. At least two (2) of the mobile dispensing trucks must be used for jet fuel
with each having a minimum capacity of at least 3,000 gallons.
c. The remaining mobile dispensing truck shall be for AvGas
and/orprovide Unleaded AvGas with a capacity of at least 750 gallons.
Until such time as unleaded AvGas is commercially available and
approved for use, standard AvGas may be used.
d. All dispensers must have bottom-refilling capabilities and turbine fuel
dispensers must have single point refueling capabilities.
e. All dispensers shall meet all applicable safety requirements, with reliable
metering devices subject to independent inspection.
f. All equipment shall be maintained and operated in accordance with
Federal, State, City and industry requirements, including ATA 103, NFPA
407, OSHA guidelines, and Municipal Code 10.04.06.120.
8. Aircraft Service Equipment. Each FBO shall procure and maintain tools, jacks,
tugs, towing equipment, tire repairing equipment, ground power units, portable
compressed air tanks, oxygen cart and supplies, fire extinguishers, air stairs,
chocks, ropes, tie-down supplies, crew and passenger courtesy transportation
vehicles, and any other equipment appropriate and necessary for the servicing
of all aircraft types normally expected to use the FBO facilities.
Page 16 of 48
9. Hours of Operation. Each FBO shall provide aircraft fueling and line services
during the hours of 7 a.m. to 11 p.m. Monday thru Friday and from 8 a.m. thru 11
p.m. on Saturdays and Sundays.
10. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards:
a. Full-Time Manager: All activities of the FBO shall be conducted under the
guidance and supervision of a full-time FBO Manager. Such person who
must have demonstrated experience in FBO supervision and operations
and themust be approved in advance by the Airport Director, which
approval the Airport Director retains discretion to deny. The FBO
Manager must be vested with full power and authority to direct and
conduct the FBO operation. The FBO Manager must be approved in
advance by the City, which approval may be denied for any reason.
Such The FBO Manager shall be assigned to the Airport and shall be
available during normal business hours.
b. Line Service: At least two (2) fully trained and qualified fuel service
personnel shall be on duty at all times while the facility is open for
business. And adequate staff shall be on duty to ensure that aircraft are
able to be marshalled onto FBO’s leased area expeditiously without
interfering with Airport operation in the AOA. One must be a responsible
supervisor trained in accordance with 14 CFR §§ 139.321(b)(6) and
(e)(1).
c. Maintenance: At least one (1) FAA-certificated aircraft mechanic shall
promptly be available upon request. The FBO can meet this requirement
with mechanics employed by the FBO, or by contracting with an on-call
Specialized Aeronautical Service Operator authorized to conduct Aircraft
Maintenance at the Airport, provided that the Airport Director approves
such contract.
d. All fuel and line service personnel shall be suitably uniformed with the
name of the FBO prominently displayed.
e. There shall be at least one person on duty during the hours of 7 a.m. to
11 p.m. Monday thru Friday and from 8 a.m. thru 11 p.m. on Saturdays
and Sundays to act as supervisor, customer service representative, ramp
attendant, and dispatcher for General Aviation activity, unless otherwise
agreed in writing by the City. If an FBO deplanes passengers outside of
the hours provided in this subsection, then the FBO shall staff sufficient
personnel to perform necessary functions for those passengers and for
safe operation of the aircraft.
f. All fuel service personnel shall have successfully completed an approved
line technician safety course. A National AviationAir Transportation
Association (NATA) course or equivalent is acceptable.
g. Supervisors and all other personnel dispensing fuel must have received
initial and required recurrent training in accordance with 14 CFR §
139.321. Training records for all personnel providing fueling services
Page 17 of 48
must be maintained on file at the Airport and be available for inspection
by the City.
11. Insurance Requirements. Each FBO shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with the City.
12. Airport Security. Each FBO shall comply with all security requirements specified
by Section 3 or otherwise applicable as a matter of law.
13. Required Fees and Payments.
Lease: The FBO shall enter into a lease agreement providing for the payment of
rent for leased space and facilities.
Fuel Flowage: In addition to the rent to be paid under its lease with the City, the
FBO shall pay the City any fuel flowage fees or other fees that are specified in its
lease.
Page 18 of 48
SECTION 5
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT CHARTER AND AIR TAXI
STATEMENT OF CONCEPT
An Aircraft Charter or Air Taxi Operator is a person, firm or corporation engaged in the
business of providing commercial air transportation (persons or property) to the general
public for hire under FAR Part 135.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease from the City an area of sufficient size,
shape, and location as mutually agreed upon to provide at least 1,000 square
feet of floor space for office, restrooms, and customer lounge, and telephone
facilities for customer use. All office/lounge space shall be properly heated and
lighted. The Operator shall provide sufficient automobile parking space to
accommodate employees and customers parking with no on-street parking.
Paved walkways with all points of access conforming to the criteria specified in
the Americans with Disabilities Act (ADA) as required by the act will be provided
by the Operator. Adequate hard surfaced aircraft ramp must be provided within
the leased area, sufficient to accommodate the Operator’s activities, operations,
and adequate tie-down facilities. If the Operator utilizes existing facilities, which
may not meet the minimum sizes outlined in this section, the minimum square
footage requirements may be determined by the availability of facilities and
through written agreement with the City.
2. Aircraft. The Operator shall provide for charter one or more multisingle-engine
aircraft, and may provide one or more singlemulti-engine aircraft. All aircraft
must be equipped for and capable of use under instrument conditions, and either
owned by or under written lease to Operator. All aircraft must meet the
requirements of the FAA and the FAR Part 135 certificate held by the Operator.
3. 3. FAA Approvals. The Operator shall have and provide copies to the City
of all appropriate certifications, approvals and FAA issued operating certificates.
Any time certifications or approvals are modified, the updated documentation
reflecting the changes shall be provided to the City within three calendar days.
Only air charter and air taxi activities authorized by the FAA and appropriate City
approvals may be conducted at the Airport under this section, and all such
activities must be conducted in accordance with all applicable FAA regulations,
including any such regulations limiting the permissible weight of aircraft loads
based on factors such as runway length, weather, and aircraft operating
specifications.
4. Reports. For each flight providing commercial air transportation to persons, the
Operator shall provide the Airport Director upon request with a written report
stating the type of aircraft, number of passenger seats, and number of
passengers actually carried.
Page 19 of 48
5. Employees. If certified to engage in on-demand common carriage for persons or
property, the Operator shall employ the number of employees required by 14
CFR Part 135.
6. Mitigation Measures. As described in the Municipal Code, § 10.04.06.030(d),
applications for air carrier service at the Airport “shall identify and assess the
effects of the service on community aircraft noise exposure, automobile traffic,
and other significant environmental impacts and propose appropriate mitigation
measures. Environmental assessment shall be in accordance with State and City
laws and procedures.” As used in the Code, “air carrier” service includes
commuter service, air charter and air taxi operations, freight, cargo, express, and
mail service, indirect air carriers and other commercial flight operations
certificated by the Federal Aviation Administration .
7. Hours of Operation. The Operator shall have its premises open and services
available eight (8) hours daily, five (5) days per week, and shall provide on-call
service at all other hours.
4. 8. Personnel and Training. The Operator shall have in its employ suitably
uniformed and trained personnel in such numbers as are required to meet the
minimum standards set forth in this category, but never less than two FAA
currently certificated commercial pilots appropriately rated to conduct the flight
activity offered by Operator. The Operator shall have available sufficient qualified
personnel for checking in passengers, handling of luggage, ticketing and for
furnishing or arranging for suitable ground transportation.
59. Insurance Requirements. Each Air CharterThe Operator shall provide evidence
of insurance coverage in the types and with the limits specified by Section 3 and
Appendix B of these Minimum Standards and its Lease with or Non-Exclusive
License from the City.
610. Airport Security. Each Air CharterThe Operator shall comply with all security
requirements specified by Section 3 or otherwise applicable as a matter of law.
711. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
Page 20 of 48
SECTION 6
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
FLIGHT TRAINING
STATEMENT OF CONCEPT
A Flight Training Operator may provide instruction to pilots in dual and solo flight
training, in fixed wing aircraft, and any related ground school instruction as is necessary
for preparation to taking an FAA written examination and flight check ride for various
category or categories of pilot’s licenses and ratings.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease from the City an area of sufficient size,
shape, and location to provide sufficient area to accommodate all of the
Operator’s activities and operations as described below. The Operator shall
provide at a minimum:
a. At least 1,000 square feet of floor space for an office, shop, restrooms,
customer lounge, classroom, and briefing room space (with adequate
mockups, pictures, slides, filmstrips, and other visual aids) to
support flight-training activities.
b. For aircraft using a hangar, sufficient area for parking the Operator’s
aircraft.
c. For aircraft not using a hangar, tie-down spaces of sufficient area for
parking the Operator’s aircraft.
d. Sufficient automobile parking space to accommodate employees and
customers parking with no on-street parking.
e. Paved walkways with all points of access conforming to the criteria
specified in the Americans with Disabilities Act (ADA) as required by the
act will be provided by the Operator.
f. Copies of all applicable federal, state and local licenses to operate a flight
training facility, including but not limited to any approvals required under
14 CFR Part 61 or 14 CFR Part 141.
g. Telephone facilities for customer use.
2. Equipment. The Operator shall have available for use in flight training, either
owned or under written lease to the Operator, a sufficient number of aircraft
properly certificated to handle the proposed scope of its student operation,
but not less than two (2) properly certificated aircraft, at least one (1) of which
must be equipped for and capable of use in instrument flight instruction. , unless
the Operator is only providing sport pilot training.
Page 21 of 48
3. Personnel. The Operator shall have on duty, on a full time basis, at least one (1)
flight instructor who is currently certificated by the FAA to provide the type of
flight training offered; and shall have available for call, on a part-time basis, at
least one (1) flight instructor who is currently certified by the FAA to provide the
type of flight training offered; and. The Operator shall provide a currently
certified ground school instructor available as needed; this requirement may be
satisfied by a certificated flight instructor with appropriate experience in ground
school teaching. The Operator shall have its premises open and services
available in day and night hours as necessary to meet demand for training, and
shall have an employee in the facility at all times that flight or ground training is
being conducted.
4. Maintenance of Aircraft and Space for Maintenance. If the Flight Training
Operator is conducting Aircraft Maintenance on Aircraft owned or leased or
operated by (and under the full and exclusive control of) the Operator, then the
Operator must lease at least 1,500 square feet of hangar space for such Aircraft
Maintenance, including employee work areas, shop areas, and storage.
5. Insurance Requirements. Each Flight TrainingThe Operator shall provide
evidence of insurance coverage in the types and with the limits specified by
Section 3 of these Minimum Standards and its Lease with or Non-Exclusive
License from the City.
6. Airport Security. Each Flight TrainingThe Operator shall comply with all
security requirements specified by Section 3 or otherwise applicable as a matter
of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
Page 22 of 48
SECTION 7
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT MAINTENANCE AND REPAIR STATIONS
STATEMENT OF CONCEPT
An Aircraft Repair Station Operator provides maintenance, repair, rebuilding, alteration
or inspection of aircraft or any of their component parts. Two types of Aircraft Repair
Station Operators are permitted at the Airport: (1) Aircraft Repair Stations and (2) Minor
and Specialized Maintenance and Repair Operators.
An Aircraft Repair Station must be certificated by the FAA under FAR Part 145 to
perform aircraft maintenance and shall provide only those maintenance and inspection
services permitted by its FAA certification. An Aircraft Repair Station Operator may also
sell aircraft parts and accessories on a non-exclusive basis.
A Minor and Specialized Maintenance and Repair Operator may provide either or both of
the following types of maintenance and repair services:
a. A Minor Maintenance and Repair Operator may provide aircraft airframe and
engine inspection, maintenance and repair on general aviation aircraft that is not
required to be performed by a Repair Station certificated under 14 CFR Part 145.
Services may include minor aircraft airframe and engine inspection, maintenance
and repair, and sale of incidental parts and accessories.
b. A Specialized Minor Aircraft Maintenance and Repair Operator may provide
maintenance and repair of aircraft radios, propellers, instruments, and
accessories for general aviation aircraft. This category shall include the sale of
new and/or used aircraft radios, propellers, instruments, and accessories on a
non-exclusive basis.
MINIMUM STANDARDS
1.
1. Hangars and Shops. The Operator shall lease a hangar or shop facilities of at
least 5,000 square feet to conduct its business.
2. Aircraft Apron. If necessary for its operations, the Operator shall lease at least
50,00044,000 square feet of paved aircraft parking and storage area to support
its activities, unless the City agrees in writing to a lesser leased area.
3. Aircraft Service Equipment.
a. Aircraft Repair Station Operators shall at all times maintain an adequate
supply of all necessary parts, equipment and accessories with a
minimum value of $100,000as needed for its business operations.
b. Minor and Specialized Maintenance and Repair Operators shall provide
sufficient equipment, supplies and parts to provide minor repairs,
Page 23 of 48
inspections and preventative Maintenance as defined in FAA regulations
at 14 CFR Part 43, including machine tools, jacks, lifts and testing
equipment.
c. If the Operator is involved with moving aircraft, the Operator shall have,
lease or contract with an FBO at least one aircraft tug of sufficient power
or braking weight to handle any aircraft that the Operator is permitted to
service under the Operator’s FAA certificate.
d. The Operator shall own, lease or otherwise have available all of the tools
and equipment required under the Operator’s FAA certificate.’
4. Hours of Operation.
a. The Repair Station shall be open and have services available at least
eight (8) hours a day, five (5) days a week.
b. The Operator shall provide for services during off-hours through an “on-
call” system.
5. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards:
a. The Operator shall have in its employ, and on duty during the
appropriate businessits hours of operation under Section 7.4.a above,
trained personnel in such numbers as are required to meet contract
requirements and FAA regulations, in a safe and efficient manner, but
never less than one (1) person who is an employee of the Operator and is
currently certified by the FAA with ratings appropriate to the work being
performed, and who holds an airframe, power plant or an aircraft
inspector rating. The requirements of this subsection regarding inspector
ratings shall not apply to radio shop repair stations, if any.
b. During businessits hours of operation under Section 7.4.a above, the
Operator shall maintain a responsible person in charge to supervise its
operations on the Airport who has authority to represent and act for and
on behalf of the Operator.
c. All employees will be in uniform with the name of the Operator
prominently displayedshall be suitably uniformed.
6. Insurance Requirements. Each Specialized Aeronautical ServiceThe
Operator shall provide evidence of insurance coverage in the types and with the
limits specified by Section 3 of these Minimum Standards and its Lease with or
Non-Exclusive License from the City.
7. Airport Security. Each Specialized Aeronautical ServiceThe Operator shall
comply with all security requirements specified by Section 3 or otherwise
applicable as a matter of law.
8. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
Page 24 of 48
SECTION 8
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
SELF-SERVICE FUEL PUMPS
STATEMENT OF CONCEPT
A Commercial Self-Service Fuel Operator provides and operates a commercial self-
service fueling enables a pilot to facility from which pilots may fuel antheir aircraft from
a commercial fuel pump installed for that purpose by an Operator or the airport
sponsor. Commercial. A commercial self-service fuel pumpsfueling facility may or
may not be attended. Commercial self-service fueling is distinct from self-fueling, in
which an aircraft owner or operator performs services on its Owned Aircraft with its Own
Employees and Own Equipment.
MINIMUM STANDARDS
1. Land. The Operator shall lease, at a minimum, 8,000 square feet to provide
sufficient land for a retail self-service aviation fueling pump and corresponding
underground fuel storage tank, supporting reporting equipment and credit card
authorization, and to provide fueling and dispensing services to customers.
2. Services. The Operator shall operate a commercial self-service fueling facility
and shall provide retail aviation fueling and dispensing services to Airport users,
including the retail distribution of 100 low lead AvGas, aviation oil, and unleaded
AvGas (once commercially available and approved for use). The City, in its sole
discretion, may allow subcontracting for these services after reviewing a request
for approval in writing.
3. Equipment, Operations, and Spill Control.
a. Equipment. The Operator must demonstrate that it owns, leases or
otherwise has sufficient access to all equipment required to provide
storage and dispensing operations at the Airport. All equipment shall be
maintained and operated in accordance with Federal, State, City and
industry requirements, including ATA 103, NFPA 407, OSHA guidelines,
and Municipal Code 10.04.06.120.
b. Operating procedures. The Operator shall develop and maintain
Standard Operating Procedures (SOP) for fueling and shall ensure
compliance with all applicable federal, state and local requirements or
standards, including those set forth in Advisory Circular 150/5230-4B -
Aircraft Fuel Storage, Handling, Training, and Dispensing on Airports,
ATA 103, NFPA 407, OSHA guidelines, Municipal Code 10.04.06.120,
and ASTM best management practices. The SOP shall include the
following:
i. a training plan,
Page 25 of 48
ii. fuel quality assurance procedures,
iii. a schedule for inventory, inspections, and maintenance
procedures;
iv. record keeping procedures, and
v. emergency response procedures for fuel spills and fires,
including prevention measures;
vi. information regarding the control of access and security for
fuel and oil dispensing areas.
The SOP shall be submitted to the City not later than ten (10) business
days before the Operator commences operation at the Airport.
c. Spill Prevention and Containment. Prior to transporting or dispensing
aviation fuel or oil onto the Airport, the Operator shall provide the City with
a Spill Prevention Contingency and Control Plan (SPCC) that meets
regulatory requirements for fuel and oil storage facilities. An updated copy
of such SPCC Plan shall be filed with the City at least ten (10) business
days prior to actual implementation. Such plan shall describe, in detail,
those methods that shall be used by the Operator to clean up any
potentially hazardous fuel spills. The plan should include Equipment to be
used, emergency contact personnel and their telephone numbers, and all
other details as to how the Operator would contain such a spill. This plan
should also describe, in detail, what methods the Operator intends to use
to prevent any such spill from occurring.
4. Hours of Operation. The facilities shall be open and have services available
during the hours of 7 a.m. to 11 p.m. Monday thru Friday and from 8 a.m. thru 11
p.m. on Saturdays and Sundays.
5. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
in its employ, and on duty during business hours, trained personnel in such
numbers as are required to meet FAA regulations and any applicable terms
specified in the Operator’s Lease with or Non-Exclusive License from the City, in
a safe and efficient manner. All employees will be in uniform with the name
of the Operator prominently displayed at all times while present at the
facilityAll employees shall be suitably uniformed.
6. Insurance Requirements. The Operator shall provide evidence of insurance
coverage specified in Section 3.
7. Airport Security. EachThe Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
8. Permits. PermitteeThe Operator shall have, and shall make available to the City
on request, evidence of all federal, state and local licenses, certificates and
permits that are required.
Page 26 of 48
9. Fuel Revenues and Flowage Fees. The Operator shall pay to the City on a
monthly basis two types of fees: percentage revenue and a fuel flowage fee.
These fees may be based on fuel sale revenues and amounts, and may be
specified in the Operator’s Lease with or Non-Exclusive License from the City.
The Operator also may be required to pay other required fees and payments as
specified in the Operator's Lease with or Non-Exclusive License from the City.
Page 27 of 48
SECTION 9
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT MANAGEMENT SERVICES
STATEMENT OF CONCEPT
An Aircraft Management Services Operator is a person, firm or corporation engaged in
the business of providing aircraft management including, but not limited to, flight
dispatch, flight crews, or aircraft maintenance coordination to the general public, under a
long-term contract. Management contracts must be in writing and must identify each
managed aircraft by registration number, type and model, and must be for a term of at
least six months. Contracts must be bona fide, exclusive and comprehensive, covering
all aspects of aircraft operation including, without limitation, fees and charges, insurance,
inspection, maintenance and repair during the term of the contract. Management
contracts may be “wet” or “dry,” and with or without crew.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease adequate space and facilities at the Airport to
store park or hangar managed aircraft, to store equipment, to operate its
business, and to accommodate its employee parking requirements. Leased
space must include sufficient work space for any aircraft upon which
maintenance or repairs are being performed by the Operator.
2. Equipment. The Operator must have the use of sufficient and appropriate
equipment to serve the types of aircraft being managed. The Operator must
have computer hardware and accounting software adequate to provide
comprehensive records of all revenues and expenses of aircraft management as
well as required aircraft maintenance.
3. Hours of Operation. OperatorsThe Operator shall have services available as
required by theirits customers.
4. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, Operatorsthe Operator
shall have trained and suitably uniformed personnel sufficient to provide services
desired by contract customers.
5. Insurance Requirements. EachThe Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. Each The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
Page 28 of 48
Page 29 of 48
SECTION 10
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIR TRANSPORTATION ARRANGER
STATEMENT OF CONCEPT
An Air Transportation Arranger Operator is a person, firm or corporation, whether or not
certificated by the FAA, engaged in the business of arranging commercial air
transportation (persons or property) to the general public for hire, which commercial air
transportation is provided by one or more FAA certificated operators (“the Contracted
Operators”) pursuant to agreement with the Air Transportation Arranger Operator.
MINIMUM STANDARDS
1. Facilities or License. If providing facilities for customer use through an FBO or
Air Charter or Air Taxi Operator operating at the Airport, the Operator shall
provide the Airport Director with documentation confirming the FBO’s or Air
Charter or Air Taxi Operator’s agreement to provide such facilities and
establishing that the FBO or Air Charter or Air Taxi Operator has complied with
all the terms of its Iease with the Airport and all applicable provisions of these
Minimum Standards, and, upon a determination by the Airport Director that these
requirements have been satisfied, shall enter into a Non-Exclusive License with
the City for provision of services. Otherwise, the Operator shall lease from the
City an area of sufficient size, shape, and location as mutually agreed upon to
provide at least 1,000 square feet of floor space for office, restrooms, and
customer lounge for customer use, in accordance with the requirements set forth
in Section 5.1 of these Minimum Standards.
2. Contracted Operator Compliance. The Operator shall provide the City with
documentation establishing that each Contracted Operator operating at the
Airport satisfies the requirements set forth in Sections 5.2 through 5.11 of these
Minimum Standards and that any other Contracted Operators have all required
FAA certifications and comply with all applicable FAA regulations.
3. Reports. For each flight providing commercial air transportation to persons, the
Operator shall provide the Airport Director, upon request, with a written report
stating the type of aircraft, number of passenger seats, and number of
passengers actually carried.
4. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 and Appendix B
of these Minimum Standards and its Lease with or Non-Exclusive License from
the City.
5. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
6. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 11
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT SALES OPERATOR
STATEMENT OF CONCEPT
An Aircraft Sales Operator is an Operator engaged in the sale of more than three new or
used Aircraft during a 12-month period. This excludes individuals selling personally
owned Aircraft, unless the individual purchased the Aircraft for the primary purpose of
resale.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease adequate space and facilities at the Airport to
store, park or hangar Aircraft to be sold, to store equipment, to operate its
business, and to accommodate its employee parking requirements. Leased
space must include sufficient work space for any aircraft upon which
maintenance or repairs are being performed by the Operator.
2. Equipment, License and Certifications. The Operator shall have sufficient and
appropriate equipment to serve the types of aircraft being stored and sold as
appropriate for its business. If the Operator offers flight demonstration for Aircraft
offered for sale, then the Operator shall also be properly certificated by the FAA,
hold appropriate ratings and medical certifications for providing flight
demonstration, and employ personnel authorized to fly such Aircraft for such
demonstration purposes.
3. Hours of Operation. The Operators shall have services available as required by
its customers.
4. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
trained personnel sufficient to provide services desired by customers.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 12
SPECIALIZED AERONAUTICAL SERVICE OPERATOR:
OTHER AERONAUTICAL SERVICES
STATEMENT OF CONCEPT
There may be other types of aeronautical services provided or to be provided at the
Airport that are not covered by the Minimum Standards set forth above and they may not
warrant the establishment of specific Minimum Standards at this time. Any existing
provider of such services must meet the general requirements of Section 3 of these
Minimum Standards.
1. Existing services not covered by specific category minimum standards.
a. Specialized Aeronautical Service Operators not covered by the specific
minimum standards in Sections 4 through 911 must meet all the
requirements of this section and Sections 3 and 1114, including the
requirement that they have a Non-Exclusive License to provide services
at the Airport and must pay the City for the privilege of providing
services at the Airport..
b. The City may require that the Operator lease space on the Airport.
c. Operators covered by this provision may be required to pay other
required fees and payments as specified in the Operator’s Lease with or
Non-Exclusive License from the City.
2. Application for new specialized aeronautical service operations. If and when an
applicant proposes to conduct a specialized aeronautical service that is not
currently conducted at the airport and is not covered by any of Sections 4
through 911 of these Standards, the City may adopt applicable Minimum
Standards for such service, taking into consideration the desires of the applicant,
the needs of the City and the need for such service at the Airport. At a minimum,
all aeronautical service providers at the Airport must comply with Section 3,
General Requirements.
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SECTION 13
SPECIAL RULES FOR A SASO CONDUCTING
MULTIPLE AERONAUTICAL SERVICES
STATEMENT OF CONCEPT
This section would apply to any Specialized Aeronautical Services Operator that
engages in any two (2) or more of the specialized aeronautical services for which
Minimum Standards have been developed. The sale of aviation fuels and lubricants is
not included in this section because only FBOs are permitted to engage in the sale of
aviation fuels and lubricants.
MINIMUM STANDARDS
1. Land. If required by these Minimum Standards, thisthe Operator shall lease, from
the City an area that is equal to the total area required by the sum of the
minimum land areas required under the individual specialized services the
Operator is providing.
2. Hangars and Other Buildings. If required by these Minimum Standards, this
Operator shall lease hangar facilities providing a total square footage that is
equal to the total area required by the sum of the minimum hangar size required
under the individual specialized services the Operator is providing. The hangar
must have a door that meets the largest width and height requirements of the
individualized services the Operator is providing.
3. Aircraft Apron. If required by these Minimum Standards, the Operator shall lease
paved aircraft parking apron that provides a total square footage that is equal to
the total area required by the sum of the minimum apron areas required under
the individual specialized services the Operator is providing.
4. Hours of Operation. The Operator shall maintain the longest hours of operation
required elsewhere in these Minimum Standards for any of the aeronautical
services it provides.
5. Personnel. In addition to the general personnel and training requirements in
Section 3 of these Minimum Standards, the Operator shall have in its employ and
on duty during the appropriate business hours, suitably uniformed, trained
personnel in such numbers as are required to meet these Minimum Standards for
the aeronautical services to be provided. Multiple responsibilities may be
assigned to meet the personnel requirements for each specialized aeronautical
service being performed.
6. Equipment. The Operator shall provide all of the facilities, equipment and
services required to meet the Minimum Standards for each of the aeronautical
services it provides.
7. Insurance. The Operator shall obtain, as a minimum, that insurance coverage
which is equal to the highest single coverage requirement of all the aeronautical
services being performed by the Operator.
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8. Required Fees and Payments. A Specialized Aeronautical Service Operator
engaged in more than one category of aeronautical activityThe Operator
shall pay all fees applicable to each and every service that it provides at the
Airport.
9. Applicability of Specific Provisions. The provision of multiple types of services by
a SASOthe Operator shall not exempt the SASOOperator from any of the
requirements otherwise applicable to each of the services provided.
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SECTION 14
RECOGNITION AND REGULATION
OF SELF-SERVICE AND SELF-FUELING RIGHTS
RIGHT TO SELF-SERVICE AND SELF-FUELING
An aircraft owner may perform services, including Self-Fueling, on the owner’s Own
Aircraft utilizing the aircraft owner’s Own Employees and Own Equipment.
In the interests of safety and fairness, a Person desiring to Self-Fuel must hold a current
Non-Commercial Annual Operational Permit t from the Santa Monica Fire Department
and be granted Self-Fueling rights by the City in a Lease, Non-Exclusive License, or
Non-Commercial Self-Fueling Permit. Any Person not party to a Lease or Non-Exclusive
License granted by the City may only have permission to Self-Fuel such Person’s
Owned Aircraft if such Person (a) holds a valid and current Non-Commercial Self-
Fueling Permit from the City, and (b) is in and continues to be in compliance with all City,
state and federal requirements applicable to aircraft fuel handling practices.
If an aircraft owner does not exercise the right to Self-Fuel, that owner’s aircraft may be
fueled or otherwise serviced at the Airport only by those Operators authorized to provide
such services at the Airport under a Lease or Non-Exclusive License approved by the
City.
NON-COMMERCIAL SELF-FUELING PERMIT
1. General
A Person desiring to Self-Fuel that Person’s Owned Aircraft, and not holding Self-
Fueling rights under a Lease or Non-Exclusive License, shall have a reasonable
opportunity to qualify for and receive a Non-Commercial Self-Fueling Permit. Each
Person conducting non-commercial Self-Fueling at the Airport shall comply with the
following minimum standards. Any Person desiring to Self-Fuel its Owned Aircraft may
only do so using its Own Employees and its Own Equipment. Third-party employees
and equipment can never be used for Self-Fueling.
Self-service fueling by an aircraft owner or operator at an FBO’s self-service pump is not
Self-Fueling and does not require a Self-Fueling Permit.
2. Permit/Approval
a. No Person shall engage in Self-Fueling activities unless a valid Non-
Commercial Self-Fueling Permit authorizing such activity has been
obtained from the City.
b. The Permit shall not reduce or limit Permittee’s obligations with respect to
these Self-Fueling minimum standards, which shall be incorporated in the
Permit by reference.
c. An applicant for a Permit shall provide evidence that any aircraft to be
fueled by the applicant is an Owned Aircraft. At any time after a Permit is
issued, the Permittee, upon request by the CityAirport Director or
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delegee, shall provide evidence that all aircraft being Self-Fueled are
Owned Aircraft.
d. The CityAirport Director will make binding determinations about whether
specific aircraft qualify as Owned Aircraft for purposes of Self-Fueling.
e. A Person seeking to Self-Fuel on the basis of a Long Term Lease for any
aircraft must obtain insurance to cover all of its interest and activities with
respect to the leased aircraft or be a named insured under the policy of
the lessor and must attach true and correct copies of the lease and a
complying certificate of insurance to such Person’s application for a Non-
Commercial Self-Fueling Permit, as updated by such Person before there
are any changes in the aircraft such Person seeks to Self-Fuel.
f. A Person seeking to Self-Fuel aircraft on the basis of a Long Term
Management Contract for any aircraft must obtain insurance to cover all
of its interests and activities with respect to the aircraft or be named as an
insured under the policy of the aircraft owner and must attach true and
correct copies of the management contract and a complying certificate of
insurance to such Person’s application for a Non-Commercial Self-
Fueling Permit, as updated by such Person before there are any changes
in the aircraft such Person seeks to Self-Fuel.
g. A Person seeking to Self-Fuel using facilities or equipment that are under
a Long Term Lease or other written agreement must obtain insurance to
cover all of its interests and activities with respect to the subject of the
agreement or be a named insured under the policy of the equipment
owner and must attach true and correct copies of the agreement and a
complying certificate of insurance to such Person’s application for a Non-
Commercial Self-Fueling Permit as updated by that Person before there
are any changes in the facilities or equipment to be used for Self-Fueling
by such Person.
3. Fuel Storage and Delivery
a. Permittee shall arrange and demonstrate that satisfactory arrangements
have been made for the storage and delivery of fuel in accordance with
this Section 1214.
b. Fuel Storage Facilities. A Permittee may be authorized to establish its
own fuel farm only with the advance written approval of the Airport
Director. A Permittee authorized by the City to install its own fuel tank
may lease land and construct or install an above-ground fuel storage
facility at a location approved by the Airport Director in writing. If a
request by the Permittee to use its own fuel farm is approved by the
Airport Director, the following requirements will apply:
i. The Permittee shall lease sufficient land for installation of above-
ground fuel storage tanks to be constructed and operated on the
Permittee’s leased premises in compliance with all applicable
environmental requirements.
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ii. All fuel storage must be above-ground. In no event shall the total
storage capacity be less than 10,000 gallons for Jet Fuel or 2,500
gallons for Avgas.
iii. The fuel storage system must include adequate fuel spill
prevention features and containment capabilities, together with an
approved fuel spill containment and countermeasures control
plan, and shall be improved and upgraded as necessary to meet
all current EPA requirements for spill prevention, containment and
mitigation as they may be revised.
iv. The Permittee shall be required to undertake at its own expense
any environmental testing of its fuel facilities which the City may
reasonably request, on or off the Airport, and to take any remedial
actions determined to be necessary or appropriate as a result of
such testing. The right is reserved to the Airport Director to
disapprove installation of a new fuel farm if the facility would have
an adverse effect on safety or otherwise in the judgment of the
Airport Director not be in the interest of a safe and efficient airport
operation.
v. In no event shall fuel delivery trucks be used for fuel storage on
the Airport. Vehicles used to deliver fuel to the Airport will transfer
fuel to storage tanks or, if approved, directly to the Permittee’s fuel
dispensing trucks, and depart the Airport.
c. Permittee shall be liable and indemnify the City for all leaks, spills, or
other damage that may result through the handling and dispensing of fuel.
d. Fuel delivered shall be clean, bright, pure, and free of microscopic
organisms, water, or other contaminants. Ensuring the quality of the fuel
is the responsibility of Permittee.
4. Fueling Equipment
a. Permittee shall utilize a single mobile dispensing truck for each type of
Fuel to be dispensed with a minimum capacity of 750 gallons. Avgas
dispensing trucks shall have a maximum capacity of 1,200 gallons and jet
fuel dispensing trucks shall have a maximum capacity of 3,000 gallons.
All Refueling Vehicles shall be capable of bottom loading, and turbine fuel
dispensers must have single point refueling capability.
b. Each Refueling Vehicle shall be equipped and maintained to comply at all
times with all applicable safety and fire prevention requirements or
standards, as may be amended, including without limitation, those
prescribed by:
i. National Fire Protection Association (NFPA) 407, OSHA
guidelines, the California Fire Code, and Municipal Code
10.04.06.120;
ii. 14 CFR Part 139, Airport Certification, § 139.321
“Handling/Storing of Hazardous Substances and Materials”; and
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iii. applicable FAA Advisory Circulars (AC) including AC 150/5210-
20, Ground Vehicle Operations on Airports”; and AC 150/5210-5D,
"Painting, Marking and Lighting of Vehicles Used On An Airport".
5. Spill Prevention and Containment. Prior to transporting Fuel onto the Airport, the
Permittee shall provide the City with a Spill Prevention Contingency and Control
Plan (SPCC) that meets regulatory requirements for above ground Fuel storage
facilities. An updated copy of such SPCC Plan shall be filed with the City at least
ten (10) business days prior to actual implementation. Such plan shall describe,
in detail, those methods that shall be used by the Permittee to clean up any
potentially hazardous Fuel spills. The plan should include Equipment to be used,
emergency contact personnel and their telephone numbers, and all other details
as to how the Permittee would contain such a spill. This plan should also
describe, in detail, what methods the Permittee intends to use to prevent any
such spill from occurring.
6. Operating procedures. In accordance with all applicable Regulatory Measures
and appropriate industry practices, the Permittee shall develop and maintain
Standard Operating Procedures (SOP) for fueling and shall ensure compliance
with standards set forth in NFPA 407, the California Fire Code, and Municipal
Code 10.04.06.120. The SOP shall include a training plan, fuel quality
assurance procedures, record keeping, and emergency response procedures for
fuel spills and fires. The SOP shall also address the following: (1) bonding and
fire protection, (2) public protection, (3) control of access to fuel dispensing
vehicle storage areas, and (4) marking and labeling of fuel dispensing vehicles.
The SOP shall be submitted to the City not later than ten (10) business days
before the Permittee commences Self-Fueling at the Airport.
7. Licenses, Certifications, and Permits. Permittee shall have, and shall make
available to the City on request, evidence of all federal, state and local licenses,
certificates and permits that are required to conduct Self-Fueling.
8. Reporting
a. Permittee shall report all Fuel delivered to the approved Permittee’s fuel
storage facility, if any, and into Permittee’s Aircraft during each calendar
month and submit a summary report along with appropriate fees and
charges due the City on or before the 10th day of the subsequent month.
b. Permittee shall during the term of the Permit and for three (3) years
thereafter maintain records identifying the total number of aviation Fuel
gallons purchased and delivered. Records (and meters) shall be made
available for audit to the City or representatives of the City. In the case of
a discrepancy, Permittee shall promptly pay, in cash, all additional rates,
fees, and charges due the City, plus annual interest on the unpaid
balance at the lesser of 18% or the maximum rate allowable by law from
the date originally due.
9. Personnel
a. Only the Permittee’s Own Employees may conduct Self-Fueling
operations on the Permittee’s aircraft. All Employees of the Permittee
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conducting Self-Fueling must be properly trained in Aircraft refueling, in
compliance with 14 CFR § 139.321.
b. There must be a minimum of two (2) trained individuals present during
Self-Fueling activities.
10. Limitations on Self-Fueling Rights. A Permittee may not sell or dispense fuels to
based or transient aircraft that are not Owned Aircraft of the Permittee. Any such
sale or dispensing shall be grounds for immediate revocation of the Permit.
Revocation upon first violation will be for a period of one (1) year. Revocation
upon a second violation shall be permanent.
11. Insurance. Except as otherwise provided for in these Minimum Standards,
Permittee shall maintain, at a minimum, the coverages and policy limits set forth
in Appendix B – Insurance Requirements.
12. Required Fees and Payments. Fuel flowage fees and any other payments to be
made to the City by each Permittee will be set forth in the Permittee's Non-
Commercial Self-Fueling Permit and shall be reasonable and not unjustly
discriminatory.
APPENDIX “A”
DEFINITIONS
The following terms shall have the following meanings:
AERONAUTICAL ACTIVITY – Any activity that involves, makes possible, or is required
for the operation of aircraft or that contributes to or is required for the safety of such
operations. Activities within this definition, commonly conducted on airports, include, but
are not limited to, the following: general and corporate aviation, air taxi and charter
operations, scheduled and nonscheduled air carrier operations, pilot training, aircraft
rental and sightseeing, aerial photography, crop dusting, aerial advertising and
surveying, aircraft sales and services, aircraft storage, sale of aviation petroleum
products, repair and maintenance of aircraft, sale of aircraft parts, parachute or ultralight
activities, and any other activities that, because of their direct relationship to the
operation of aircraft, can appropriately be regarded as aeronautical activities.
AIRPORT – Santa Monica Airport (SMO).
AIRPORT DIRECTOR – the Airport Director of the Santa Monica Airport or the duly
authorized representative of the Airport Director.
AIRPORT USER – a person who operates an aircraft at the Airport.
AIR OPERATIONS AREA or AOA – that portion of the Airport used or intended to be
used for landing, take off or surface maneuvering of aircraft including the hangar and
cargo areas and aircraft parking aprons.
AIRPORT LEASING POLICY -- Santa Monica City Council Airport Leasing and
Licensing Policy (“Airport Leasing Policy”).
APRON or RAMP – those areas of the Airport within the AOA designated for the
loading, unloading, servicing, or parking of aircraft.
CITY – the City of Santa Monica, California. The City may delegate its powers to the
Airport Director or such other City staff member as the City may choose.
COMMERCIAL – conducted with the intent or purpose of generating or securing
earnings, income, compensation or profit, whether or not such objectives are
accomplished.
CONSENT DECREE – the Consent Decree between the City and the United States in
the U.S. District Court, City of Santa Monica v. United States, Dkt. No. 2:13-cv-08046
(C.D. Cal. 2017), dated January 31, 2017.
FAA – Federal Aviation Administration, or any successor agency.
FIXED BASE OPERATOR (FBO) – an operator that furnishes a full range of
aeronautical activities and services to the public, including fueling and line services to
General Aviation aircraft.
FUELING OPERATIONS – the receipt, storage, handling, movement, delivery and
dispensing of fuel for aircraft at the Airport, including the installation, use and
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maintenance of fueling equipment, and the operations and supervision of all personnel
engaged in fueling activities.
GENERAL AVIATION – all aviation operating under FAR Part 91 (with the exception of
government aircraft operations) and FAR Part 135 operations to the extent permitted in
these Minimum Standards.
INDIVIDUAL – An Operator’s agent, servant, employee, supplier, contractor, tenant,
invitee or other party that has been granted access to the Operator’s premises.
LEASE – an agreement with the City for the exclusive use of designated airport land
and/or facilities.
LONG TERM LEASE – a written lease for one or more aircraft, with adequate
consideration, for a term of at least six months and terminable within six months only for
cause which provides that the primary care, custody and control of the aircraft is in the
Person applying to conduct Self-Fueling Operations and contains substantially all terms
and conditions standard in the industry for that type of lease.
LONG TERM MANAGEMENT CONTRACT – a written management contract for
specified aircraft, with adequate consideration, for a term of at least six months and
terminable within six months only for cause which provides that the primary care,
custody and control of the aircraft is in the Person applying to conduct Self-Fueling
Operations and contains substantially all terms and conditions standard in the industry
for that type of contract. The management contract must provide that the Person
applying to conduct Self-Fueling Operations is responsible for all maintenance, all pilot
service, and all scheduling of the aircraft that are subject to the managements contract.
MUNICIPAL CODE – the City of Santa Monica Municipal Code.
NON-COMMERCIAL SELF-FUELING PERMIT – a written document issued by the City
authorizing Self-Fueling at the Airport.
NON-EXCLUSIVE LICENSE – an agreement with the City granting permission for the
conduct of specified commercial aeronautical services on the Airport, but not granting an
exclusive right to provide those services or the exclusive use of any Airport property or
facilities.
OPERATOR – a person or persons, firm, company, joint venture, partnership or
corporation providing any commercial aeronautical service at the Airport.
OWNED AIRCRAFT – for FAA Part 121 or Part 135 operators, aircraft listed on that
operator’s then-current Part 121 or Part 135 Certificate and for all other operators:
aircraft used exclusively by that Person and titled and registered with the FAA in that
Person’s own name; aircraft used by that Person as lessee under a Long Term Lease,
or aircraft used by that Person under a Long Term Management Contract.
OWN EMPLOYEES – employees of the Person applying to conduct Self-Fueling
Operations for whom all state and federal employment taxes are paid by that Person.
OWN EQUIPMENT – facilities or equipment that is used exclusively by and titled in the
name of the Person applying to conduct Self-Fueling Operations or is used by that
Person subject to a Long Term Lease or written purchase, financing or use agreement
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for such facilities or equipment, with adequate consideration, for a term of at least six
months and terminable within six months only for cause which provides that the primary
care, custody and control of the facilities or equipment is in the Person applying to
conduct Self-Fueling Operations and contains substantially all terms and conditions
standard in the industry for that type of agreement.
PERMITTEE – a Person who has been issued and holds a valid and current Non-
Commercial Self-Fueling Permit.
PERSON – an individualIndividual, firm, company, joint venture, partnership or
corporation.
REPAIR STATION – a facility utilized for the repair of aircraft approved and certificated
by the FAA under 14 CFR Part 145. Activities may include repair and maintenance of
airframes, power plants, propellers, radios, instruments and accessories.
SELF-FUELING – a Person’s conduct of Fueling Operations for that Person’s Own
Aircraft, using that Person’s Own Equipment and conducted by that Person or the
Person’s Own Employees. Self-fueling may be permitted by a Lease or Non-Exclusive
License authorizing commercial services or by a Non-Commercial Self-Fueling Permit.
SPECIALIZED AERONAUTICAL SERVICES OPERATOR (SASO) – an Operator that
is authorized to engage in one or more of the following specialized aeronautical support
services:
a. Aircraft Charter/ and Air Taxi
b. Flight Training
c. Aircraft Maintenance and Repair StationStations
d. Aircraft Management
e. Self-Service Fuel Pumps
e. Aircraft Management
f. Air Transportation Arranger
g. Aircraft Sales Operator
h. Other Aeronautical Services
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Page 37 of 48
APPENDIX B
INSURANCE REQUIREMENTS AND STANDARDS
The City has established the following minimum insurance requirements and standards
for Operators of commercial aeronautical services at the Santa Monica Municipal Airport:
A. The Operator shall procure and maintain at its own expense for the duration of the
Operator’s activities and/or use of leased premises at the Airport insurance as set
out in the Minimum Insurance Requirements Matrix (Appendix B-1) against claims
for injuries to persons or damages to property that may arise from or in connection
with activities and/or the use of leased premises at the Airport by the Operator, its
agents, representatives, employees or subcontractors.
B. If the Operator maintains broader coverage or higher limits than the minimums
required in Appendix B-1, the City of Santa Monica requires and shall be entitled
to any broader coverage and higher limits maintained by the Operator. Any
available insurance proceeds in excess of the specified minimum limits of
insurance and coverage shall be available to the City of Santa Monica.
C. The insurance policies are to contain, or be endorsed to contain, the following
provisions:
i. Additional Insured Status: The City of Santa Monica, its officers, officials,
employees and volunteers are to be covered as additional insureds on the
CGL policy with respect to liability arising out of the use, occupancy,
operations or maintenance of leased premises, including work or
operations performed on behalf of the Operator.
ii. Primary Coverage: For any claims related to Operator’s activities and/or
use of leased premises at the Airport, the Operator’s insurance shall be
primary coverage at least as broad as Insurance Services Offices Form CG
20 01 04 13 as respects the City of Santa Monica, its officers, officials,
employees and volunteers. Any insurance or self-insurance maintained by
the City of Santa Monica, its officers, officials, employees or volunteers
shall be in excess of the Operator’s insurance and shall not contribute with
it.
iii. Notice of Cancellation: Each insurance policy required herein shall state
that coverage shall not be cancelled except after notice has been given to
the City of Santa Monica.
iv. Waiver of Subrogation: Operator hereby grants to the City of Santa
Monica a waiver of any right of subrogation which any insurer of said
Operator may acquire against the City of Santa Monica by virtue o f
payment of any loss. Operator agrees to obtain any endorsement that may
be necessary to affect this waiver of subrogation, but this provision applies
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regardless of whether or not the City of Santa Monica has received a waiver
of subrogation endorsement from the insurer.
v. Claims Made Policies: If the pollution liability policy provides “claims
made” coverage: the Retroactive Date must be shown and must be before
the commencement of the Operator’s lease; the insurance must be
maintained and evidence of insurance must be provided for at least 3 years
after the expiration of the Operator’s lease; and if the policy is cancelled or
not renewed, and not replaced with another “claims made” policy form with
a Retroactive Date prior to the effective date of the lease, the Operator
must purchase “extended reporting” coverage for a minimum of 3 years
after lease expiration.
vi. Indemnification and Hold Harmless. Operator shall defend, indemnify,
save, protect, and hold harmless the City of Santa Monica, the Santa
Monica Airport, the Santa Monica Airport Commission, and the Santa
Monica City Council, individually and collectively, and their representatives,
officers, officials, employees, agents, and volunteers from any and all
claims, demands, damages, fines, obligations, suits, judgments, penalties,
causes of action, losses, liabilities, administrative proceedings, arbitration,
or costs at any time received, incurred, or accrued by the City of Santa
Monica, the Santa Monica Airport, the Santa Monica Airport Commission,
and the Santa Monica City Council, individually and collectively, and their
representatives, officers, officials, employees, agents, and volunteers as a
result of, or arising out of Operator's activities, actions, or inactions. In the
event a party indemnified hereunder is in part responsible for the loss, the
indemnitor shall not be relieved of the obligation to indemnify; however, in
such a case, liability shall be shared in accordance with California
principles of comparative fault.
Operator shall accept total responsibility, defend, indemnify, save, protect,
and hold harmless the City of Santa Monica, the Santa Monica Airport, the
Santa Monica Airport Commission, and the Santa Monica City Council,
individually and collectively, and their representatives, officers, officials,
employees, agents, and volunteers in the event of an environmental
contaminating accident or incident caused by Operator, its employees, its
vendors or any other personnel used by the Operator to maintain
Operator's improvements, vehicles, equipment, or aircraft.
Nothing herein shall constitute a waiver of any protection available to the
City and the City Council, individually and collectively, and its
representatives, officers, officials, employees, agents and volunteers under
the State of California’s governmental immunity act or any similar doctrine
or statutory provision.
D. All insurance shall be placed with insurers authorized to conduct business in
California with a current A.M. Best rating of no less than A:VII, unless otherwise
acceptable to the City of Santa Monica.
Page 39 of 48
E. Operator shall furnish the City of Santa Monica with original certificates and
amendatory endorsements (or copies of the applicable policy language effecting
coverage provided by this clause). All certificates and endorsements are to be
received and approved by the City of Santa Monica before the Operator’s activities
and/or use of leased premises at the Airportlease commences. However, failure
to obtain required documents prior to the work beginning shall not waive the
Operator’s obligation to provide them. The City of Santa Monica reserves the right
to require complete, certified copies of all required insurance policies, including the
endorsements required herein, at any time.
AP
P
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Notes
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&
completed operations, bodily injury, personal injury and pr operty damage including owned
an
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A
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1
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jury, personal injury, property damage, and products & complete d operations.
•
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(
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shall include bodily injury & pr operty damage for all vehicles (owned, non‐owned, or hired vehicles).
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damage for all non‐owned aircra ft under the care, custody & control of the Operator. ²
•
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damage for all non‐owned aircra ft under the care, custody & control of the Operator. ²
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damage for all non‐owned aircra ft under the care, custody & control of the Operator. ²
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(
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property damage for owned, leased, or operated aircraft.
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5
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include bodily injury and pro perty damage for owned, leased, or operated aircraft.
•
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roperty damage for owned, leased, or operated aircraft.
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njury and property damage for non‐owned aircraft. ᶾ
•
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shall include bodily injury and property damage for non‐owned aircraft. ᶾ
•
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ry and property damage for non‐owned aircraft. ᶾ
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$
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City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 1 of 29
Responses to Comments
Second Comment Period
Following initial publication of draft Minimum Standards for Commercial Aeronautical Services at
Santa Monica Municipal Airport (the “Minimum Standards”), the City of Santa Monica received a
series of public comments. Revisions to the draft Minimum Standards were made, and an initial
set of responses was prepared, to address these initial comments. The revised draft Minimum
Standards, a redline showing the changes from the original draft Minimum Standards, and the
responses to the initial comments were all presented to the Airport Commission at its June 5,
2018 meeting. The result of that meeting was an agreement to solicit a second set of
comments on the revised draft Minimum Standards. Notice was circulated that comments
needed to be submitted by June 21, 2018. During the second comment period, the City
received comments from the individuals and entities set forth in Table 1 below. The City thanks
all of the commenters for their interest in and comments on the revised draft Minimum
Standards. The City has reviewed and carefully considered all of the comments received. This
document organizes the comments received by the topics to which they relate and provides the
City’s responses. Where the City has made a further revision to the draft Minimum Standards in
response to a comment, the change is reflected in the attached redlined copy of the revised
draft Minimum Standards (the “attached redline”).
Table 1 Minimum Standards Comment Index
Date Commenter
June 4, 2018 Ben Wang
June 5, 2018 Alex Gertsen (on behalf of NBAA)
June 7, 2018 Bryan LNU
June 7, 2018 Paul Netty
June 7, 2018 David Reilly
June 7, 2018 Alex Wilcox (on behalf of JetSuitesX)
June 12, 2018 Gavin Scott & Nicola Scott
June 13, 2018 Adam Cohen
June 13, 2018 William Fordes
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 2 of 29
Date Commenter
June 13, 2018 Frank Hatch
June 13, 2018 Elin Katz
June 13, 2018 Randall Klarin
June 13, 2018 Micah Linton
June 13, 2018 Ellen Mark
June 13, 2018 Karen Melick
June 13, 2018 Tobin Mills
June 13, 2018 Steven Naftali
June 13, 2018 Amy Pohlig
June 13, 2018 Sherri Sawaya & Peter Sawaya
June 13, 2018 Louis Ssutu, Deanna Ssutu & Laura Ssutu
June 13, 2018 Eileen Tunick
June 14, 2018 Michael Greco
June 14, 2018 Mark & Tina Grossman
June 14, 2018 Julia Liebeskind
June 14, 2018 Anne Linstatter
June 14, 2018 John Machtinger
June 14, 2018 Tony Nitti
June 14, 2018 Sharon Ryan
June 14, 2018 Patrick Seeholzer
June 14, 2018 Robin Swicord
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 3 of 29
Date Commenter
June 15, 2018 Poonam Bhatla
June 15, 2018 Erin Ferro
June 15, 2018 Robert Newmark
June 15, 2018 Jessica Tracy
June 16, 2018 Howard Wolfe & Margie Wolfe
June 17, 2018 John Ventura
June 18, 2018 C. Bendat
June 18, 2018 D. Ken Davis
June 20, 2018 M. Goldman
June 20, 2018 Christine Hardin
June 20, 2018 Joseph Hardin
June 20, 2018 Maureen Jerrett
June 20, 2018 Alan Levenson
June 20, 2018 Andrew Wilder
June 21, 2018 Peter Donald
June 21, 2018 Alex Gertsen (on behalf of NBAA)
June 21, 2018 Betsy Katz
June 21, 2018 Michael Katz
June 21, 2018 Cathy Larson
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 4 of 29
Topic 1: Interaction with Leasing Policy
(Minimum Standards § 1)
The City received the following comments regarding the interaction between the Minimum
Standards and the Airport Leasing Policy:
(a) I noticed significant errors in the Minimum Standards documents. For example,
the City didn’t edit the latest version of the Leasing Policy. So, the Airport
Commission and the public are not looking at the right information. I think it’s
important that the we get this right, with zero mistakes. These Minimum
Standards are far too important to have such issues.
(b) The new leasing policy at SMO should maintain the provisions of the Consent
Decree and extend the authority of the City Manager to ONLY authorize leases
that terminate on or before December 31, 2022 at which time all aviation leases
should revert to month to month leases until the airport is closed or when the City
needs the space to facilitate the transition of the airport into a park.
(c) NBAA also re-emphasizes that certain elements of the Minimum Standards,
unchanged from the initial draft, continue to be problematic. Notably, the City’s
leasing policy for SMO – cross-referenced and deferred to in Sections 1-3 – is
inconsistent with its ongoing obligations to the FAA. In response to comments,
Airport staff has noted that the policy has been revised since it was originally
adopted in 2016, such as to include a reference to the consent decree issued last
year by the U.S. District Court for the Central District of California. But the policy
remains fundamentally flawed – such as in its provision that aeronautical uses of
SMO must be compatible with adjacent land uses, a 180° inversion of federal
requirements.
City Response:
In addition to the attached redline of the Minimum Standards, the City has attached to this
document a redline of the current Airport Leasing Policy showing proposed changes. As set
forth in the redlined Airport Leasing Policy, the City has added language making clear that the
Airport Leasing Policy (like the Minimum Standards) is subordinate to the Consent Decree, and
that leasing decisions must be consistent with the Consent Decree. Pursuant to the terms of
the Consent Decree, which mandates operation of the Airport through December 31, 2028, the
City must continue to offer leases of no less than three years to aeronautical service providers.
In addition, for non-aeronautical service providers, the City needs discretion to enter into leases
up to five years to effectively manage Airport property and ensure the Airport a stream of
revenue during the time the Airport remains in operation. Accordingly, the City declines to make
the recommended change to limit the City Manger’s authority to enter into leases longer than
month-to-month only if they terminate before December 31, 2022.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 5 of 29
Topic 2: Application to Renewed Leases
(Minimum Standards § 1)
The City received the following comment regarding the application of the Minimum Standards to
renewals of existing leases:
(a) Applicability (Page 2) - Regarding the Minimum Standards applicability to leases, it is
unclear if future renewals of existing leases will require the entity to comply with the
minimum standards.
In the last paragraph of the "Applicability" section (just before the "Effective Date"
section, I suggest changing to the following:
"If these Minimum Standards are adopted or amended after an Operator enters
into a Lease..."
For reference, the language the Santa Barbara Airport Minimum Standards uses is much
clearer:
"If an Operator has an existing agreement with the City at the time the Minimum
Standards are adopted or amended, and if compliance with the Minimum
Standards would create a conflict with the agreement, the agreement shall
prevail until such time that it is amended, updated, renegotiated, or a new
agreement is negotiated, at which time Operator will fully comply with the
Minimum Standards." [Section 3-1, Page 9]
City’s Response:
As shown in the attached redline, the Applicability section of the Minimum Standards has been
modified to address the concerns expressed in this comment.
Topic 3: Waivers and Transparency (Minimum Standards § 1)
The City received a number of comments addressing the authority of the Airport Director to
waive application of Minimum Standards and the need for transparency regarding both these
waiver decisions and other leasing, licensing, and tenancy decisions. These comments
included the following:
(a) The new rules should not give the Airport Manager the power to help, via waivers or any
other discretionary acts, air taxi companies eager to increase the number of flights over
Santa Monica, and the rules should include a list of aircraft that aren't suitable for use at
SMO. The rules should insist on transparency so that whatever decisions are made
about aviation businesses come up before the whole council first, so local residents can
have a say.
(b) However, in the interim before the closing, there is a chance to make the lives of the
people of SM worse, by allowing the Airport Commissioner to use his or her discretion in
granting waivers to pilots/aircraft from the Minimum Standards. This should not be
permitted, and must not be allowed without strict oversight of the decision making
process. This is a SLAP IN THE FACE to the VAST majority of voters who demanded
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 6 of 29
that the Airport be closed immediately upon termination of the term of lease with the
FAA/Federal Gov’t. This flies in the face of the will of the people, ignores the fact that
those people who came out to campaign for and vote for the closure will certainly take
note of the decision, and they vote.
(c) We all know that given half a chance the Ubers of this world will start to use Santa
Monica Airport to fill local skies a with constant, noisy air taxis, making our lives as much
of a misery as they were when the jets were at full throttle. What I didn’t realise till I went
to last week’s Airport Commissioners meeting was that the Airport Manager is pushing
for new rules which will give him ‐ or whoever is in his job during the next ten years ‐ the
“discretion” to grant “waivers” that will make it much more likely this will happen in a way
we’re unlikely to even know about. . . . The new rules should not give the Airport
Manager the power to help air taxi companies eager to increase the number of flights
over Santa Monica, . . .. The rules should insist on transparency so that whatever
decisions are made that could help the air taxi enthusiasts lever their way in come up
before the whole council first, so local people can have a say.
(d) The rules and actions involving the airport commissioner’s right to grant waivers need to
be available for transparency and public comment.
(e) I am writing to say I support the Minimum Standards effort to keep air taxis from using
SMO. You, of all people, know how we have fought for *years* to prevent noise (and)
pollution in the areas both East and West of the Santa Monica Airport. Jets were the
worst but there already has been an increase in helicopters and possibly small planes
that are barely tolerable. Please do not use your discretionary ability to grant “waivers”
for air taxis or similar aircraft unless it is an emergency!
(f) The Airport Director waiver authority seems overly broad
(g) The rules should insist that whatever decisions are made come up before the whole
council first, so the people can have a say.
(h) demand transparency from all involved parties so that we citizens can give our input on
decisions about aviation businesses [and] avoid giving the Airport Manager the power to
waive or circumvent existing regulations for certain air taxi companies or any other users
of the airport. Allowing the Airport Manager to give special dispensations would set up a
playing field for pressures and/or enticements on the Airport Manager.
(i) Public and transparent process of awarding leases, tenancies, and licenses to operate --
The airport is the property of the people of Santa Monica and they must be informed
about any decision regarding the allocation of, and payment for, rights to operate there.
. . . We hope that the airport will now be managed in a completely transparent way for
the benefit of the owners ‐ the citizens of Santa Monica. It is not the purpose of the
airport to serve commercial interests. It is a public good and must serve the public good.
(j) No change to current airport rules unless approved by SM City Council. No waivers that
could increase the number of air taxis. No "flexibility" in airport operations through
manager changes… . . SM City Council must review any "discretionary" changes
proposed by airport manager.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 7 of 29
(k) As property owner and resident . . . we are hugely impacted by every take off. We have
lived in our home here since 1988 and in Santa Monica since 1982. The first few years
in our house there were no jets and we never had any objection to small aircraft. The
increase of jets and helicopters has definitely negatively impacted our quality of life. I do
not agree that an airport manager should be able to waive any requirements that impact
the noise, safety or peacefulness of this city and our neighborhood in partIcular. I also
am very concerned about the airport allowing Uber type services to operate here and
that aircraft can take off after the tower is closed.
(l) We would like to see the airport be a good neighbor. We do not want any Air Taxi's or
Jet companies coming into SMO. We want transparency in ALL functions of the Airport.
We do not want the director or anyone to have total power on decisions made at the
airport. The community and neighbors deserve to have a voice in the airport functions.
AGAIN we would like the airport to engage the locals in what takes place there. The
security concerns, the audits, the businesses who come in, the sub rentals, the runway,
the noise and pollution.
(m) The Airport Director or City Manager at SMO should Not have the right to help, via
waivers or any other discretionary acts, air taxi companies or any company eager to
increase the number of flights over Santa Monica, and the rules should include a list of
aircraft that are not suitable for use at SMO.
(n) There are many instances of the Director’s specific ability to grant waivers throughout
the document, as noted in detail by Cathy Larson. But the Waivers clause on Page 3 of
the redlined version pretty much covers everything, i.e., the Airport Director can waive
any of the Minimum Standards for government and non-government operations. It
makes the document appear to have not been thought through well enough to give
guidance to subsequent Directors or City Managers. That is, where there could be a lack
of situational clarity, we’ve just patched in “discretion” to get this document out.
Obviously, not every contingency can be anticipated but there should be some sort of
required due process before one or two people can make a far-reaching decision in the
form of a waiver. Granted, it’s time consuming but unless there’s a public safety
emergency (earthquake or power outage, etc.), more people (possibly the Airport
Commission) should be involved in the process.
(o) There are a plethora of instances where “discretion” is given to the airport director to
waive the minimum standards without a formal transparent review that should include
reasons for the requested waiver and information substantiated why it would be in the
best interest of the city to grant the waiver. The purpose of creating the minimum
standard is just that—the minimum—not some moving target. See items: pg. 3 Waivers,
pg. 7‐3.1, pg. 9‐3.6.b and 3.8, pg. 10‐3.16, pg. 12‐4.14, 4.15, 4.16.d, 4.16.h. There
should be very clear and concise language regarding a transparent process for a “rare”
exception to a minimum standard including an opportunity for public review, comment,
and either City Manager or City Council approval for the requested waiver.
(p) Airport Director waiver authority is vastly overbroad – unprecedented compared to
virtually all other California (or US) airports.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 8 of 29
o Such waiver authority invalidates the premise and purpose of “minimum
standards”,
o Opens the City to valid prima facie clams of favoritism,
o Infringes on the duties and rights of the City Manager,
o Permits the Airport Director (e.g. approving fuel farms) to make decisions that
clearly impact the City Council’s prerogatives and obligations.
Recommendations:
1. Greatly curtail waiver scope and eliminate most waivers in most domains.
Any waiver that might impact more City departments than just the Airport
should require City Manager approval. Waivers that involve infrastructure
(e.g. new fuel farms) or increased airport impacts upon residents (e.g.
establishment of and/or waivers for air charter or tax, or aircraft
management & transportation) should require City Council approval.
2. While I disagree with using the Airport Commission for waiver processes
– any waivers that are presented to the Airport Commission should have
complete descriptions, staff rationales, be readily available to the public
for a reasonable time prior to Commission review – and if approved, they
should be readily available in a transparent public database.
(q) Although this draft is an improvement, the Airport Director and the City still have far too
much latitude to waive requirements of the minimum standards. That could lead to
inconsistent--and therefore unfair--application of these standards. Moreover, if these are
truly intended to be "minimum" standards then they should not be waivable -- waivers
defeat the purpose of this document. Please remove all waivers in order to ensure
that all tenants, operators, and businesses will be consistently and fairly held to the
same standards.
I was curious to see if other airports had waivers in their Minimum Standards, so I looked
a few up. Critically, I did not find any other airport Minimum Standards with
pervasive waiver language similar to what is being proposed for Santa Monica.
* * *
Further thoughts on transparency and accountability: If waivers must be a part of this
document (which of course I disagree), then at the very least they should not be able to
be "rubber stamped" by the Airport Director, with no public process, public comment,
deliberation, or approval process. Simply informing the Airport Commission or City
Manager that such a waiver has been "proposed" is not sufficient. Additionally, any
current/approved waivers must be publicly available and easy to find - not "buried" and
scattered in Airport Commission meeting agenda packets.
(r) The minimum standards should include no waiver authority of any standard to the Airport
Manager or whoever fills that position. The new rules should insist on transparency of
all decisions by the airport commission and the city council.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 9 of 29
(s) We do not support giving you, the airport manager, or any future manager, discretionary
powers that might help charter and air taxi companies increase the number of flights in
and out of SMO. We must insist on transparency: all decisions concerning air taxi and
charter companies must be brought before the full city council so we who live here are
heard.
(t) Please keep things transparent regarding the airport governance, so that Santa Monica
residents always know what is happening, rather than having to find out after things
have already been decided. The Santa Monica airport is a public holding, and we should
always have public transparency, and public input.
City’s Response:
The City remains of the view that It is appropriate for the City to retain the ability to waive the
requirements of the Minimum Standards when warranted, but agrees with various commenters
that: (a) any such waiver should be the exception, justified only by clear circumstances
rendering the waiver in the City’s best interest; (b) certain fundamental requirements should not
be subject to waiver; and (c) waivers should be granted through a transparent process that
renders them easily visible to the public. With these principles in mind, the draft Minimum
Standards have been revised as shown in the attached redline as follows:
(1) Section 1, General Information, Purpose now states explicitly that the Minimum
Standards do not alter the Municipal Code and Airport Leasing Policy
requirements that the City Manager (an in some instances the City Council) must
approve both Airport commercial operation permits and Airport leases;
(2) Section 1, General Information, Waivers, has been modified to require that, for a
waiver of any of the waivable Minimum Standards for any non-governmental
operator, the Airport Director must find clear circumstances demonstrating the
waiver to be in the City’s best interests and must obtain approval from the City
Manager (or the City Council if that level of approval is required) after
consideration by the Airport Commission. The Airport Director is also required to
keep a publicly-available log of all waivers that describes the basis for each
waiver, the date it was presented for consideration by the Airport Commission,
and the date on which it was or was not approved by the City Manager or City
Council.
(3) Section 2.4 (Application Procedures) has been modified to specify that the
Airport Director “shall” deny any application if the Airport Director determines that
the applicant does not meet any applicable provisions of the Minimum Standards;
and
(4) Sections 3.6, 3.7, 3.11, and 3.12 (General Requirements) have been modified to
state that insurance, airport security, nondiscrimination, and legal compliance
requirements cannot be waived.
Although the Minimum Standards apply to all Operators, the City recognizes that it may be
appropriate to modify certain requirements of the Minimum Standards (for example, equipment,
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 10 of 29
personnel, and square-footage requirements) based on fact-specific circumstances that the City
may not be able to foresee at the time of drafting these Minimum Standards. The inclusion of a
waiver provision does not mean that the Minimum Standards are unenforceable, but instead
that the City may allow for flexibility in the application of the Minimum Standards where
warranted by applicable facts and circumstances.
Topic 4: Application Procedures (Minimum Standards § 2)
The City received the following comment regarding Section 2 – Application Procedures of the
Minimum Standards:
(a) The Airport Director should deny any application that does not meet the minimum
standards. Therefore, the operative word in the introduction of this section should be
"shall," not "may." This is a critical distinction! Please change the introductory sentence
of this section to read:
"The Airport Director shall deny any application to provide aeronautical services
at the Airport, if, in his or her discretion, the Airport Director determines that:"
City’s Response:
As shown in the attached redline, Section 2.4 of the Minimum Standards has been revised as
requested in this comment.
Topic 5: Supervisor “On Duty” (Minimum Standards § 3.5.c)
The City received the following comment regarding permitting a supervisor to be on duty via
telephone:
(a) Pg. 8‐3.5.c Supervisor considered “on duty” if available by phone is not adequate
if there is an emergency.
City’s Response:
This provision was modified in response to a comment in the original round of comments that
stated as follows: "On duty" should be qualified as "on location or via telephone". It would be
unreasonable to expect a supervisor be on duty, at the airport, when "any aeronautical services
are being performed by the Operator". With respect to supervisors, the City maintains the view
stated in its response to the original comments, as follows.
The City agrees that it may be overly burdensome to require a supervisor on site at all times
during operations. However, it is important for safety and notification purposes that a supervisor
be available to be contacted by the Airport and by the Operator’s personnel. The balancing
struck by the Minimum Standards is that a supervisor may be offsite but available by phone, but
only if the Operator provides the Airport with phone numbers for supervisors and a schedule of
supervisor availability so that they can be reached immediately in the case of an emergency.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 11 of 29
Topic 6: Insurance Requirements (Minimum Standards § 3.6)
The City received a number of comments regarding the insurance requirements, including the
following:
(a) The third party liability insurance is inadequate.
(b) All 3rd Party insurance coverage should be more than $3 million for private aircraft
operators and should be more than $25 million for commercial aircraft operators. This
would protect the city from paying out large amounts of money for an aircraft accident.
(c) Some of the insurance rates are appropriate but if a turbine aircraft carries $10m worth
of public liability insurance, why does the company that booked the flight (Air
Transportation Manager) have none? It seems logical that the booking agent bears
some responsibility for damages, as it is an integral part of this business model, i.e.,
without them, the Part 135 air carrier would have none of this sell-by-the-seat business.
The idea is to have the Air Transportation Managers, to do business at SMO, bear some
insurance cost for all types of aircraft it books. And if it’s not true for transient aircraft, it
should be. They should be carrying the same insurance as SMO-based aircraft.
(d) Appendix B‐1. Having several tiers of minimum liability insurance at only $1 million is
laughable when aircraft are flying in close proximity to homes whose individual values by
far exceed that amount not to mention the potential harm to the occupants they contain.
In addition, there should be a clause stating the minimum will be reviewed periodically
and adjusted for inflation, changes in land and equipment values.
(e) Aircraft insurance requirements are too low. They should not be waived.
o Other California airports have substantially higher insurance requirements.
o LLC ownership structures should require 1 / 5 / 10 million-dollar insurance coverage
(the same as present air charter, air taxi, and aircraft management services).
o FBO and other SASOs’ Hangar Keeper’s liability should be higher.
o Waiving insurance requirements and permitting low property damage liability limits
insufficient for residents’ damages from aircraft accidents puts the City at undue risk.
Recommendations:
1. Greatly increase minimum insurance requirements for aircraft with LLC
structures.
2. Increase other minimum insurance requirements like other airports with similar
aircraft and adjacent multimillion-dollar homes, such as the Van Nuys or the
Ventura County Airports.
3. To fail to protect residents to the maximum extent legally possible opens the
City to unnecessary and justified liability claims. Further, it exposes residents to
unwarranted harm when they can and should be protected by their own local
government.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 12 of 29
(f) To the extent that Appendix B – “Minimum Insurance Requirements Matrix” – sets forth
the details of the insurance requirements implemented by Section 3(6) of the Minimum
Standards, we would like to ask the City to make available and transparent the
methodology of how these numbers were derived, as well as clarify if they were
compared to requirements at other similar LA-area airports, and if so to please share
that analysis also.
(g) As we have discussed multiple times, these minimum insurance requirements are far too
low. I carry more personal insurance coverage simply to operator my car and to protect
my home from even a simple "slip and fall" accident.
This airport is within 300 feet of and surrounded by hundreds of multi-million dollar
homes -- and many of these homes are inside what should be a Runway Protection
Zone (even with the shortened runway).
A small piston aircraft crashing into a single home could easily cause more damage than
would be covered by the currently proposed minimums -- and of course a larger aircraft
could cause much greater damage. Medical costs, legal fees, etc., can easily and
quickly reach into the many millions of dollars.
The Pollution Liability Insurance requirements also seem very low, considering the
damage that fuel and other lubricants can cause. Moreover, isn't the airport land sitting
above an aquifer, and the City has a goal of becoming 100% self-sufficient for water?
The cleanup costs can easily extend into the many millions of dollars as well. Other
airports have $5,000,000 pollution liability insurance requirements, so why would we
only require $1,000,000?
* * *
Staff's claim that higher insurance coverage is not reasonable or attainable is false, as
demonstrated by the minimum requirements at other airports. Therefore, please raise
the minimums as follows:
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 13 of 29
(a) Commercial General Liability. CGL limits have been raised from $1 million per
occurrence to $2 million per occurrence for the following categories: Aircraft
Charters/Air Taxis Flight Training, Aircraft Maintenance & Repair, Aircraft
Management Services, and Aircraft Sales. This increased requirement appears
consistent with airports of comparable size. Please note that CGL limits for Air
Transportation arrangers remain at $1 million per occurrence; this appears
adequate to address the risks presented by this service category.
(b) Pollution Liability. Pollution liability limits have been raised from $1 million per
occurrence to $2 million per occurrence given the City’s decision to shift
responsibility for tank maintenance and testing to Operators. This increased
requirement appears consistent with the risks posed and with requirements
imposed at other airports.
In addition to these changes, Appendix B-1 has been revised to make clear that the minimum
insurance requirements will be evaluated annually and modified as appropriate to reflect
changes in insurance industry standards (i.e., limits and coverage) and/or to address new or
changing risks. And, as noted under Topic 3 above, Section 3.6 has been modified to specify
that the minimum insurance requirements may not be waived by the Airport Director.
The City believes these modified insurance requirements are consistent with requirements
customary and reasonable in the industry and imposed by similar general aviation airports, and
thus reflect an appropriate balance between setting standards high enough to protect the City
and its residents from risks posed by operations while not so high that they unreasonably limit
the ability of operators to obtain the insurance needed to engage in profitable operations at the
Airport. In this regard, the City notes that under the Consent Decree, for so long as the Airport
continues to operate as a general aviation airport, the City must allow aeronautical service
providers access on fair and reasonable conditions without unjust economic discrimination, and
that the FAA has found that to comply with this standard, required insurance must be both
attainable and reasonable.
With respect to certain specific comments: (a) The City believes Hangar Keepers insurance
should remain as set out in the earlier draft. The limits as shown represent a middle ground
based on the City’s assessment of risks, broker advice regarding the reasonable availability of
insurance, and information regarding comparable airports. (b) FBOs are not required to
maintain Aircraft Liability Insurance but are required to maintain $5 million in Airport Liability
Insurance, which appears better addressed to the risks posed by FBO operations. To the
extent a particular FBO were to engage in aircraft operations, the City would remain free to
impose additional insurance obligations on that FBO.
Topic 7: Security Issues (Minimum Standards § 3.7)
The City received the following comments arguing that additional security requirements should
be put in place:
(a) Terrorism and Crime. The airport, airplanes, airplane parts, electronics and fuel can be
converted to evil purposes. The airport opens Santa Monica to the worst people in the
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 14 of 29
world. We need to search people, baggage, and packages. We need X-ray, bomb
detection dogs and machines, video/sound recording with permanent offsite storage and
separate offsite backup, advanced scanners/sensors, more security personal, and
ground sensors and cameras all around the airport. We need to hold all passengers, and
their employees, contractors, agents, and pilots, while a background check is done for
passports, finger prints, outstanding criminal warrants and holds for on all Federal
agencies and all 50 state and territory databases: as well as a security interview. If this
raises airport fee, it is worth it.
City’s Response:
Airport security measures undertaken by the City itself are not the subject of these Minimum
Standards, which set requirements for individual operators providing commercial aeronautical
services at the Airport. The City notes that the Minimum Standards require each Operator to
comply with applicable security requirements and to implement a documented security plan.
See Minimum Standards, Section 3.7. As noted under Topic 3 above, Section 3.7 has been
revised to specify that these security requirements may not be waived by the Airport Director.
Topic 8: Subcontracting (Minimum Standards §§ 3.8 & 4.15)
The City received the following comment regarding subcontracting, both in general (Section 3.8)
and by FBOs specifically (Section 4.15):
(a) SECTION 3 – GENERAL REQUIREMENTS
* * *
8 (Subcontracting, Page 9). Just as sub-leasing is no longer allowed, subcontracting of
services should not be allowed either.
* * *
SECTION 4 (FIXED BASE OPERATOR)
Statement of Concept 15. (Page 12). Just as sub-leasing is no longer allowed,
subcontracting of fuel services should not be allowed either. Please change the entire
paragraph to:
"An FBO may not subcontract any fueling services or other services that it is
authorized or required to provide."
City’s Response:
Subcontracting is only permitted with approval of the Airport Director and with a 180-day
limitation on subcontracting (subject to renewal with the Airport Director’s permission). The City
maintains its view that this limited authorization for subcontracting is needed to strike a balance
between commercially reasonable needs that may arise for Operators to subcontract, and the
City’s interest in ensuring that subcontracting arrangements at the Airport do not undermine the
purposes of these Minimum Standards by continuing indefinitely.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 15 of 29
Topic 9: Noise Restrictions (Minimum Standards § 3.12.c)
The City received a number of comments regarding enforcement of noise restrictions. These
included:
(a) The new rules should let all aviation companies know loud and clear that there are strict
noise ordinance rules and they’re strictly enforced. . . . And finally the new rules should
include information about tightening up noise code enforcement.
(b) And finally the new rules should include about tightening up noise code enforcement –
because we all know what hell the planes produce when they're allowed to make as
much racket as they want.
(c) Planes should fly over the Penmar Golf Course instead of over our neighborhood, and
the absolute enforcement of noise restrictions needs to be paramount.
(d) [T]here are two elementary schools in the immediate vicinity and the research into the
adverse impact exposure to aircraft noise has on cognitive development is well known. .
. . Any change in operations at Santa Monica airport aimed at diminishing the negative
impact from flights over Venice is a needed welcome. Airplanes are not my area of
domain nor am I competent in facts regarding policies and procedures at Santa Monica
airport. However, a few suggestions that seem logical and within reason would be to
ensure flights are directed over the ocean instead of turning and climbing directly
overhead heavily populated areas. Likewise, there is a substantial difference in the
altitudes of planes, some are barely discernable whereas others are clear enough to
read the numbers listed on the side. Establishing a consistent and mandatory elevation
of 1000 ft. above home, businesses, and schools seems to be a general requirement of
flying and might reduce noise significantly.
(e) They should let anyone who wants to set up shop here know loud and clear that there
are strict noise ordinance rules and they’re strictly enforced. . . . The new rules should
include tightening up noise code enforcement – because we all know what hell the
planes produce when they're allowed to make as much racket as they want.
(f) Reduce, though strict enforcement of rules, the noise created by the airport traffic.
(Come live in Sunset Park for a while and you will understand the seriousness of this
problem.)
(g) Limiting non‐prop aircraft traffic -- First, the number and type of operators needs to be
strictly controlled. In terms of limiting noise pollution and maintaining/ improving air
quality, we residents demand strict limits on jets and helicopters using the airport. We
are particularly concerned about increased noise and emissions going forwards as
commercial aviation interests seek to bypass the runway limits by moving to STOL jet
raft and helicopters. The number of takeoff and landing slots for non‐prop aircraft must
be strictly limited.
(h) Strictly enforce noise ordinances. (This is not done now.)
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 16 of 29
(i) We, my wife and I, are concerned about noise, pollution and safety. We hope that rules
are strictly enforced, including not using SMO after the closing time. Also we do not look
forward to having a low flying UBER craft going over our property.
(k) Pg. 10‐3.15 If business violates noise policy, there lease should a defined warning, fine,
lease termination.
(l) Another addition to the Minimum Standards is paragraph 3.15 (in the “General
Requirements” section) which states that operators at SMO must “comply with all
applicable federal, state, and local noise restriction laws and regulations.” While this may
be intended to reference the current noise policy at SMO, as written, the revised draft
can be read to suggest that new requirements can be imposed on operators at SMO,
absent the detailed study and affirmative FAA approval required by the Airport Noise and
Capacity Act of 1990 (“ANCA”). As you know, that is not the case. The pre-1990 aircraft
noise restrictions in the City’s Airport Code (§ 10.04.04.060) are “grandfathered.” For
any new restrictions, municipalities must comply with ANCA.
City’s Response:
As noted by one of the commenters, the pre-1990 noise restrictions currently set forth in Santa
Monica Municipal Code Subchapter 10.04.040 are grandfathered in and cannot be changed
without compliance with ANCA. Moreover, as the City noted in its response to the initial set of
public comments, neither the Airport’s operating hours nor its noise restrictions are changed by
these Minimum Standards, which are intended only to set requirements for individual operators
providing commercial aeronautical services at the Airport. The City, however, shares the
concern expressed by a number of commenters regarding compliance with existing noise
requirements. Thus, as shown in the attached redline, the Minimum Standards retain a
requirement that all Operators comply with “all applicable federal, state, and local noise
restriction laws and regulations.” Section 3.12.c. This specifically requires compliance with the
noise restrictions set out in the Santa Monica Municipal Code. Moreover, as noted above and
as shown in the attached redline, Section 3.12.e has been added to make clear that the Airport
Director may not waive compliance with these noise restrictions, subject only to any exceptions
to enforcement permitted by the grandfathered noise restrictions themselves. If these
exceptions were eliminated, the City might not be able to enforce any of its grandfathered noise
restrictions.
Topic 10: Hours of Operation
(Minimum Standards §§ 4.9, 4.10.e, 8.4)
The City received a number of comments addressing hours of operation. These included:
(a) The new rules mustn’t, as they do now, encourage operators keep flying until 11pm at
night – even after the airport tower has closed down at 8pm.
(b) I fully understand that any standard having to do with safety and safe operations is
paramount. But i do want to point out that the city won, the airport will be closing in a
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 17 of 29
number of years. And now i fear that many people in the community are hoping to take
advantage of this opportunity with the Minimum Standards to be punitive against the
aviation businesses at the airport. That’s just unfair. Requiring business to stay open
(11pm) serves no purpose but to make it hard on the business in hopes that they will
suffer. New uniforms for businesses is an expense. Please weigh carefully what are
manipulative moves and what is best to protect the public and maintain safety. There is
a lot of emotion wrapped up in the airport but hobbling business proprietors is not in the
best interest of the public.
(c) New rules need to be observant of a curfew that adheres to the tower’s hours.
(d) Requiring the FBO and other specialized aeronautical services operators to stay open
until 11pm could have negative consequences
(e) I was shocked to learn that the city council and airport commissioners have thought it
just fine to let planes operate until 11pm when the control tower closes at 8pm. My dad
used to fly commercial planes for a living; that’s why I know this detail most city residents
don’t know about is a disaster waiting to happen.
(f) do everything possible to discourage pilots from flying late into the night.
(g) Maintaining strict limits on hours of operation -- The airport's operators must be required
to abide by strict limits on hours of operation to avoid noise disturbance during evenings,
nighttime and early morning when residents are at home and entitled to quiet enjoyment
of their residences.
(h) No take‐offs or landings after Airport Tower has closed down at 9 pm.
(i) As property owner and resident . . . we are hugely impacted by every take off. We have
lived in our home here since 1988 and in Santa Monica since 1982. The first few years
in our house there were no jets and we never had any objection to small aircraft. The
increase of jets and helicopters has definitely negatively impacted our quality of life. I do
not agree that an airport manager should be able to waive any requirements that impact
the noise, safety or peacefulness of this city and our neighborhood in partIcular. I also
am very concerned about the airport allowing Uber type services to operate here and
that aircraft can take off after the tower is closed.
(j) We, my wife and I, are concerned about noise, pollution and safety. We hope that rules
are strictly enforced, including not using SMO after the closing time. Also we do not look
forward to having a low flying UBER craft going over our property.
(k) No airport business should be required to stay opened until 11pm and none should be
permitted to stay open after 11pm. FYI, most of the community surrounding the airport
prefer that no planes land or take off after 10pm or before 8am and for safety reasons,
an air traffic person be on duty during the limited hours of operation at the Santa Monica
Airport.
(l) FBO Business Hours -- It seems logical that this sort of passenger/aircraft service
business should not be required to stay open past 9:00pm, when the tower closes. The
language in 4.9 on page 16 of the redlined document says, “Hours of Operation. Each
FBO shall provide aircraft fueling and line services during the hours of 7 a.m. to 11 p.m.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 18 of 29
Monday thru Friday and from 8 a.m. thru 11 p.m. on Saturdays and Sundays”. (underline
added) It should read,” Each FBO may provide aircraft fueling….” This language would
make it the FBO’s choice, whether to stay open or not.
(m) I question the requirement of business hours 7am‐11pm weekdays, 8am‐11pm
weekends. Is this encouraging more traffic during what should be considered “quiet”
hours for an airport imbedded in a neighborhood?
(n) Extended, required evening FBO/SASO hours harm residents – and they are not FAA-
imposed.
o The City should not require aviation operations when the tower is closed (after 9 pm).
o The scientific consensus is now overwhelming: Frequent aircraft noise exposure
(especially after dark) seriously harms human cardiovascular functions.
▪ Causing increased morbidity and death.
o Guaranteeing the full range of aviation support activities late at night makes SMO
attractive for more on-demand, non-scheduled, Uber-like commercial flights.
Recommendation: Change the FBO and other SASO City-required operating hours to
end at or before 9 pm. This permits aviation services to be based on customer-driven,
economic demands. It comports with FAA requirements while it respects residents’
health and their property rights.
(o) FBOs should not be required to sell fuel for extended hours. I propose changing the
minimum times to match when the Tower is open/operational. If an FBO wants to close
up shop at 9pm when the Tower closes, we should let them.
* * *
As with Section 4 for FBOs, self-service fueling facilities should not be required to stay
open as long. I propose changing the minimum times to match when the Tower is
open/operational. If a self-service facility wants to close up shop at 9pm when the Tower
closes, we should let them.
(p) We insist flights be highly discouraged after 8PM.
City’s Response:
The Airport’s operating hours, which are set forth in Santa Monica Municipal Code
§10.04.04.080, are not changed by these Minimum Standards, which are intended only to set
requirements for individual operators providing commercial aeronautical services at the Airport.
The City, however, shares the concern expressed by commenters that the Minimum Standards
should not require Operators to provide services during later evening hours, which might be
viewed as encouraging operations during these hours. In accordance with these comments, as
shown in the attached redline, Sections 4.9, 4.10.e,, and 8.4 have been modified to require the
provision of services only until 9:00 pm, to coincide with the closing of the airport tower.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 19 of 29
Topic 11: Fuel Farms (Minimum Standards §§ 4.6, 14.3.b)
The City received the following comment regarding approval of construction of a new fuel farm:
(a) [With respect to FBOs] I strongly disagree with Staff's position that construction of a fuel
farm is an "operational decision" (see response to Comment 32, page 18). Rather, a fuel
farm is significant infrastructure.
Construction of a new fuel farm should require City Council approval, not just
Airport Director or City Manager approval.
* * *
As with Section 4 for FBOs, a fuel farm is significant infrastructure, not an operational
decision. Construction or establishment of a fuel farm should require City Council
approval, not just Airport Director or City Manager approval.
City’s Response:
As shown in the attached redline, the City has modified Sections 4.6 and 14.3.b of the draft
Minimum Standards to make clear that authorization from the City Council is required for the
construction of any fuel farm.
Topic 12: SMO Sales and Use of AvGas
(Minimum Standards §§ 4.13, 14.4)
The City received a comment addressing sales and use of Avgas:
(a) Likewise, it is my understanding that the majority of aircraft utilizing Santa Monica Airport
rely on avgas which also has a long history of cognitive and neurological harm. Any
change in operations at Santa Monica airport aimed at diminishing the negative impact
from flights over Venice is a needed welcome. . . . Regarding the use of avgas, I have
to admit I’m baffled as to how this is still legal but is it a requirement?
City’s Response:
The City notes that general aviation airports, including Santa Monica Airport while it remains in operation
under the Consent Decree, must permit fuel sales consistent with applicable federal regulatory
requirements.
Topic 13: Aircraft Charter and Air Taxi Minimum Standards
(Minimum Standards § 5)
The City received the following comments addressing various parts of this section of the
Minimum Standards (one of which requested more clarity in the language not only in this
Section 5, but also in Sections 9 and 10, with respect to requirements for “on demand” flights):
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 20 of 29
(a) 1 ‐ Operators should be allowed to use FBOs on the field and not be required to lease
space. This is standard practice at thousands of airports across the country. Any attempt
by the City to restrict interstate commerce by failing to lease adequate space is back
door regulation and categorically illegal. No undefined, arbitrary "written agreement" with
the city may be required under law to operate a charter from any US Airport. If leased
space is required, the city should make a good faith effort to find and provide, as does
every other airport in the country.
2 ‐ As written this section seems to imply an operator with only multi engine airplanes
would have to acquire a single engine airplane to operate at SMO. What basis? Please
re‐write or clarify. Further, what basis does the City have for requiring IFR equipped
aircraft? Equipage and aircraft standards are a federal matter for the FAA. Remove this
please.
4 ‐ What is the statute of limitations on this section 4?
5 ‐ This is totally redundant. The city has already called for compliance with Part 135.
Please remove.
6 ‐ Please provide a clear threshold level of activity whereby this would be required. The
airport master plan already contemplates a certain level of operations, and complies with
applicable environmental law.
7 ‐ This section is totally arbitrary. If an operator chooses to offer just 1 flight a day, why
shall they be forced to be open for 8 hours?
(b) Inadequate language requirements for “on demand” flights. More clarity in language
added to Section 5 Aircraft Charter and Air Taxi, Section 9 Aircraft Management
Services and Section 10 Air Transportation Arranger to address this growing market.
(c) Similarly, additional language has been added to Section 5 (“Aircraft Charter and Air
Taxi”), including that such entities must provide an assessment of the environmental
impact of their operations to SMO. As the Minimum Standards acknowledge, such
entities are “air carriers” under federal law – and federal law preempts local regulation of
their operations. These and similar restrictions – in particular, the requirement that such
operators must utilize certain types of aircraft – are inappropriate, unenforceable, and
should be deleted.
▪ Additionally, Section 5 does not differentiate between operators that are based
at SMO, versus those that use the airport on a transient basis. NBAA suggests
that a clear distinction between requirements for based and transient operators
be made and that any requirement that transient operators have an agreement
with the City be removed.
City’s Response:
As shown in the attached redline, the City has modified this section to address a number of the
concerns raised by these comments. In particular:
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 21 of 29
(1) The definition of Operator has been modified to make clear that it is intended to be
consistent with Santa Monica Municipal Code § 10.04.06.020 which defines individuals
and entities who must obtain commercial operations permits as those who “use the
Airport as a base for any commercial activity.” Accordingly, the revised draft Minimum
Standards now define an Operator as “a person or persons, firm, company, joint venture,
partnership or corporation using the Airport as a base for any Commercial Aeronautical
Activity.” Similarly, the “Statement of Concept” in Section 5 has been modified to make
clear that it applies to Aircraft Charter or Air Taxi Operators that are “using the Airport as
a base” for their air transportation activities. Whether any particular individual or entity is
using the Airport as a base for air transportation activities, including when those air
transportation activities are “on demand” flights, is a matter for determination on a case-
by-case basis.
(2) The Facilities requirements in Section 5.1 have been modified to make clear that if an
Aircraft Charter or Air Taxi Operator wishes to provide its services through an
arrangement for use of facilities operated by an FBO, it may do so, subject to entering
into a non-exclusive license with the City and demonstration that the FBO is in
compliance with its lease and the Minimum Standards.
(3) The Aircraft requirements in Section 5.2 have been modified to make clear that an
Aircraft Charter or Air Taxi Operator may provide for charter either single- or multi-
engine aircraft.
(4) The Reports requirements in Section 5.4 have been modified to specify that requests by
the Airport Director must be made within 180 days after the flight for which information is
requested.
(5) The City declines to make any change to the Mitigation Measures requirements in
Section 5.6, which are consistent with Santa Monica Municipal Code § 10.04.06.030(d).
(5) The Hours of Operations requirements in Section 5.7 have been modified to specify that
leased facilities must be open and services available to customers at least two hours
prior to and one hour after each flight offered by the Operator.
Topic 14: Aircraft Maintenance and Repair Stations
(Minimum Standards § 7)
The City received the following comment regarding the square footage requirement for Aircraft
Maintenance and Repair Stations:
(a) The original square footage required was 50,000. The new draft changes it to 4,000 --
but the redline looks like it should have been 44,000. Which is correct? 4,000 square
feet sounds very low, and obviously a dramatic reduction from 50,000.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 22 of 29
City’s Response:
As set forth in Sections 7.1 and 7.2 of the revised draft Minimum Standards, after modification
based on the original set of public comments, the minimum space requirements are: 5,000
square feet of hangar or shop facilities and 4,000 square feet of pave aircraft parking and
storage area.
Topic 15: Air Transportation Arrangers
(Minimum Standards § 10)
The City received the following comments addressing various parts of this section of the
Minimum Standards:
(a) Inadequate language requirements for “on demand” flights. More clarity in language
added to Section 5 Aircraft Charter and Air Taxi, Section 9 Aircraft Management
Services and Section 10 Air Transportation Arranger to address this growing market.
(b) The revised draft contains entirely new sections, including standards for “Air
Transportation Arrangers” (Section 10). It is not at all clear that the standards proposed
in this section are practical and/or compliant with SMO’s federal obligations. The
application of the entire section is both ambiguous and, to the extent intended to apply to
entities which do not maintain a physical presence at SMO, legally problematic – for
example, the requirement that such entities must have documentation for an agreement
with an FBO. NBAA strongly recommends removing this section – or at a minimum that
the section clearly distinguish the requirements for “Arrangers” utilizing an FBO or
another entity on the airfield on a transient basis versus the requirements for “Arrangers”
that elect to have a physical presence at SMO.
▪ Further, the term “Operator” is used to refer to both the “Arranger” as well as to
the Air Taxi and Air Charter operators that actually fly aircraft; that is confusing.
NBAA suggests making the responsibilities of each entity clear.
▪ Additionally the requirement to provide a passenger report in Paragraph 3 is
duplicative of the requirement in Section 5, Paragraph 4. To the extent required
at all, “Arrangers” should not be responsible for providing the passenger reports,
which should come directly from the Air Charter or Air Taxi operator.
(c ) Please insert into the new, proposed standards rules that will prevent companies like
Uber from turning SMO into a short‐hop, fee‐per‐ride service similar to the equivalent car
services. Such services can be ramped up quickly, with comparatively no limit on
operations. SMO was never intended to be such a facility. The impact on the community
would be too great. Furthermore, Uber and other, similar companies have demonstrated
a willingness to disregard safety and the hiring standards of its contracted drivers in
order to increase profits. They will no doubt bring this same, “profits first, at all costs”
approach to their aircraft business. They do not belong at SMO. This should apply to
both fixed and rotary wing operations.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 23 of 29
City’s Response:
As shown in the attached redline, the City has modified this section to address a number of the
concerns raised by these comments. In particular:
(1) The definition of Operator has been modified to make clear that it is intended to be
consistent with Santa Monica Municipal Code § 10.04.06.020 which defines individuals
and entities who must obtain commercial operations permits as those who “use the
Airport as a base for any commercial activity.” Accordingly, the revised draft Minimum
Standards now define an Operator as “a person or persons, firm, company, joint venture,
partnership or corporation using the Airport as a base for any Commercial Aeronautical
Activity.” Similarly, the “Statement of Concept” in Section 5 has been modified to make
clear that it applies to Air Transportation Arrangers “using the Airport as a base” to
engage in their business activities. Whether any particular Air Transportation Arranger is
using the Airport as a base for its business activities is a matter for determination on a
case-by-case basis.
(2) To avoid any confusion, Section 10 has been modified to use the term Operator only to
refer to the Air Transportation Arranger itself. The term “Contracted Carrier” is used to
refer to the individuals or entities actually flying the aircraft.
(3) The Reports requirement in Section 10.3 has been modified to make clear that if the
Contracted Carrier is operating at the Airport pursuant to Section 5 of the Minimum
Standards (in which case, the Airport Director may request reports directly from the
Contracted Carrier pursuant to Section 5.4 of the Minimum Standards), then the Air
Transportation Arranger needs only to identify the Contracted Carrier providing a
particular flight. On the other hand, if the Contracted Carrier is not operating at the
Airport pursuant to Section 5 of the Minimum Standards (and thus is not subject to the
reporting requirements in Section 5.4), the Airport Director may request a more-detailed
report from the Air Transportation Arranger.
Topic 16: Flight Paths
The City received a number of comments addressing preferred flight paths. These included:
(a) The new rules should make it clear that planes should fly over the Penmar golf course
instead of over the local neighborhoods.
(b) The new rules should make it clear that planes should fly over the Penmar golf course
instead of over the local neighborhoods. As one of the Commissioners said “if they keep
turning right after takeoff eventually we will have pilots and passengers killed and
residents injured or killed when an engine fails on takeoff.”
(c) Planes should fly over the Penmar Golf Course instead of over our neighborhood, and
the absolute enforcement of noise restrictions needs to be paramount.
(d) There are two elementary schools in the immediate vicinity and the research into the
adverse impact exposure to aircraft noise has on cognitive development is well known.
Likewise, it is my understanding that the majority of aircraft utilizing Santa Monica Airport
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 24 of 29
rely on avgas which also has a long history of cognitive and neurological harm. Any
change in operations at Santa Monica airport aimed at diminishing the negative impact
from flights over Venice is a needed welcome. Airplanes are not my area of domain nor
am I competent in facts regarding policies and procedures at Santa Monica airport.
However, a few suggestions that seem logical and within reason would be to ensure
flights are directed over the ocean instead of turning and climbing directly overhead
heavily populated areas. Likewise, there is a substantial difference in the altitudes of
planes, some are barely discernable whereas others are clear enough to read the
numbers listed on the side. Establishing a consistent and mandatory elevation of 1000 ft.
above home, businesses, and schools seems to be a general requirement of flying and
might reduce noise significantly.
(e) It would greatly enhance takeoff safety if all light aircraft pilots actually overflew Penmar
Golf Course
(f) As Sunset Park Residents, we are very concerned about the future of Santa Monica
Airport. We are so tired of the noise created by these planes (often flying extremely low
and late into the night). As you enter this next phase of negotiations, we encourage you
to assure that planes fly over the Penman Golf Course and avoid the local
neighborhoods; provide for adequate enforcement of this policy so that it cannot be
ignored.
(g) Strictly enforce "No turns before reaching Lincoln‐‐fly over Penmar Golf Course."
(Planes now routinely turn right, endangering lives).
(h) We insist aircraft of any sort fly over the Penmar golf course and not over local
neighborhoods.
City’s Response:
The City notes that the issues raised in these comments concerning flight direction for departing
planes are outside the scope of these Minimum Standards. The City recognizes, however, the
desire to encourage aircraft to comply with the Santa Monica Airport Fly Neighborly Program.
Accordingly, new Sections 4.14, 5.12, 6.8, and 10.7 have been added to the Minimum
Standards to require FBOs, Air Charter and Air Taxi Operators, Flight Schools, and Air
Transportation Arrangers to have available and provide to all pilots using their services or
providing services on their behalf brochures setting out this program, which include information
on mandatory restrictions and the preferred flight path over PenMar golf course.
Topic 17: Suitable Aircraft
The City received a number of comments requesting that the Minimum Standards include a list
of aircraft not suitable for use at the Airport and/or limit the use of certain types of aircraft (such
as jets and helicopters). These included:
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 25 of 29
(a) The new rules should not give the Airport Manager the power to help air taxi companies
eager to increase the number of flights over Santa Monica, and they should include a list
of aircraft that aren't suitable for use at SMO.
(b) I am writing to make a statement about the Minimum Standards and the right to audit the
aircraft that take off and land at Santa Monica Airport. Please consider the community
that surrounds the airport and the undue danger and stress created by unsuitable aircraft
and increasing air taxi flights.
(c) I’ve lived under the flight path of SMO for over twenty years. The last few months have
been a major improvement in flight noise overhead. I understand an airport operations
plan is being written soon. I favor clear guidance for the airport manager on what may be
flown into and out of SMO. I DON’T want our neighborhood airport used as a short hop
flight service.
(d) The new rules shouldn’t have the power to arbitrarily favor companies to increase the
number of flights over Santa Monica, and they should include a list of aircraft that aren't
suitable for SMO.
(e) Limiting non‐prop aircraft traffic -- First, the number and type of operators needs to be
strictly controlled. In terms of limiting noise pollution and maintaining/ improving air
quality, we residents demand strict limits on jets and helicopters using the airport. We
are particularly concerned about increased noise and emissions going forwards as
commercial aviation interests seek to bypass the runway limits by moving to STOL jet
raft and helicopters. The number of takeoff and landing slots for non‐prop aircraft must
be strictly limited.
(f) Provide a list of aircraft that are NOT suitable for SMO.
(g) I want the commission to limit in every way the expansion of jet traffic at the Santa
Monica airport to minimize the health impacts forced upon adjacent communities.
(h) Please do not allow the Santa Monica airport to become a “helicopter Uber” hub, with
noisy helicopters continually coming in and out in a dense residential area. Please keep
the jet traffic out. The last few months have been quieter and cleaner, at times of day
almost peaceful. This is how Santa Monica should feel. We don’t need to have jet traffic
in our residential areas. It’s detrimental to the health of the people who live here. NO
Uber helicopters.
City’s Response:
The City notes that limitations on the types of aircraft that can use the Airport, or on the number
of takeoff and landing slots for particular types of aircraft, are outside the scope of the Minimum
Standards. The City notes that a warning regarding Listed Aircraft that have been shown to be
unable to meet the maximum noise level of 95.0 dba SENEL is on the Airport’s website at:
https://www.smgov.net/Departments/Airport/Pilots/Listed_Aircraft.aspx. This list is updated as
additional aircraft are identified. As stated on the website, individual aircraft of these types may
be permanently excluded from operating at the Airport after one proven violation of Santa
Monica Airport’s maximum noise limit. See Santa Monica Municipal Code §10.04.04.050.
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 26 of 29
Topic 18: Providing Information to Air Crews
The City received a number of comments requesting that the Minimum Standards require FBOs
and other SASOs to provide to air crews certain information regarding the Airport, including in
particular its shortened runway length, slope, and unsuitability for certain aircraft. These
comments include:
(a) Language should be added that the City will require the FBO's and SASO's to pass
along information to air crews.
(b) The City should require FBO & SASOs to pass SMO and City information to aircrews.
o To improve On-Demand operators’, aircrews’, and residents’ safety.
o To improve noise code compliance.
Recommendation: Pass relevant safety information to aircrews via FBOs and SASOs.
1. SMO Runway 21 is a 3,500’ runway with a 1.2 degree down slope. According
to FAA regulations, aircrews conducting commercial operations must add an
additional 10% landing distance safety margin (in addition to the required 40%
commercial operations margin) to prevent unsafe runway excursions.
2. Because the SMO runway is now shortened to 3,500’, many jet aircraft that
had safely used SMO can no longer safely operate from the present runway. The
following aircraft types have been now determined by the City to be “listed.” They
(include Coffman aircraft types). Should “listed” aircraft use the Airport in
violation of FAA takeoff and landing requirements, the aircrew and operating
entity will be reported to the FAA and be subject to maximum City noise violation
penalties if applicable. * Willful violations by entities on the Airport may result in
loss of aviation lease. Please see (updated listed aircraft)
https://www.smgov.net/Departments/Airport/Pilots/Listed_Aircraft.aspx
3. Runway excursions are actively monitored, videotaped, and formally reported
to the FAA.
4. The City of Santa Monica rigorously enforces the 95dB noise limit as expressly
authorized by the 9th Circuit Court.
5. Pilots are urged to use their aircraft manufacturer’s noise avoidance takeoff
and climb procedure, consistent with aircrew safety.
6. Pilots using Runway 21 VFR departures are requested to gently initiate a 10%
climbing left turn to depart over the Penmar golf course – thus affording
maximum safe landing options in the event of engine failure while also
minimizing noise for surrounding residents.
City’s Response:
As set forth in the City’s Response to Topic 16 above, new Sections 4.14, 5.12, 6.8, and 10.7
have been added to the Minimum Standards to require FBOs, Air Charter and Air Taxi
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 27 of 29
Operators, Flight Schools, and Air Transportation Arrangers to have available and provide to all
pilots using their services or providing services on their behalf brochures setting out the Santa
Monica Fly Neighborly program, which include information on mandatory restrictions and the
preferred flight path over PenMar golf course. These brochures contain most of the information
referenced in these comments.
Topic 19: Audit Requirements
The City received several comments requesting that the City impose additional “audit”
requirements. These included:
(a) [W]e want the Minimum Standards to add more transparency with the ability to audit
passenger, baggage, and fuel loads of aircraft if and when it appears the operator might
be exceeding the aircraft specifications for our short, down‐sloping runway. We cannot
tell pilots how to fly, but we do have a right to audit users of our land to ensure our safety
is not being subjected to undue risk.
(b) And finally we want the Minimum Standards to add more transparency with the ability to
audit passenger, baggage, and fuel loads of aircraft if and when it appears the operator
might be exceeding the aircraft specifications. We cannot tell pilots how to fly, but we do
have a right to audit users of our land to ensure our safety.
(c) Audit use of the airport! Check fuel tanks of pilots taking off. Learn how often pilots turn
before reaching Lincoln. Measure noise levels. Measure air pollution levels.
(d) I am writing to express my support for adding more transparency applied to the minimum
standards allowing the ability to audit passenger, baggage, and fuel loads of aircraft if
and when it appears the operator might exceed aircraft specs for the shortened runway.
(e) Under the SASA, Section 5, #4 is a section called Reports: Reports. For each flight
providing commercial air transportation to persons, the Operator shall provide the Airport
Director upon request with a written report stating the type of aircraft, number of
passenger seats, and number of passengers actually carried. This section should also
include the reporting of fuel weight on board, in addition to passengers and baggage.
Without fuel, weight load information is incomplete. The reports section as noted above
should also be included under Section 4, FBOs that operate and support charters at
SMO should also be subject to audit on request. While we cannot control how a pilot
flies or how the FAA administers, we do have a right to audit operators that use our land.
and look out for the safety of the surrounding communities.
(f) Pg. 17‐5.4 Reports on type aircraft, number of passenger seats, and number of
passengers actually carried should be REQUIRED for every flight Air Taxi and Air
Charter Flight not just provided on request.
(g) Finally, we are concerned that some of the comments submitted to the City and
circulated in public forums assert that residents surrounding the airport (or the City, on
their behalf) can and should “audit” users of the airport to ensure safety. As you are
aware, operations at SMO are safe and meet all FAA requirements – and only the FAA
has responsibility for safety. Further, Section 41713 separately prohibits localities from
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 28 of 29
demanding information from carriers about their operations. Overall, minimum standards
are not and cannot be a vehicle through which to impose new restrictions on operators –
i.e., suggestions such as restricting operations after the tower closes, or requiring certain
flight paths to be flown. The latter is the exclusive province of the FAA, and the former
would require a Part 161 study under ANCA.
(h) By setting Minimum Standards to add more transparency with the ability to audit
passenger, baggage, and fuel loads of aircraft if and when it appears the operator might
be exceeding the aircraft specifications for our short, down-sloping runway we can help
keep the west side a livable place to call home.
(i) We must add more transparency: We insist on our right to audit users of our airport
because our safety is at risk; audits must delve into aircraft safety, including all payloads:
passengers, fuel, cargo and baggage.
City’s Response:
The City shares the commenters’ commitment to the safe operation of the Airport. The City
notes that aircraft manufacturers, in conjunction with the FAA, set restrictions on permissible
aircraft loads. As shown in the attached redline: (a) Section 5.3 has been added to require
Aircraft Charter Operators to comply with all applicable FAA regulations, including any such
regulations limiting the permissible weight of aircraft loads based on factors such as runway
length, weather, and aircraft operating specifications; and (b) Section 5.4 has been added to
require reports identifying the type of aircraft, number of passenger seats, and number of
passengers carried on each flight, all information relevant to determinations by the Airport
Director that Air Charter operators are not exceeding the scope of their FAA certifications. With
respect to additional “weight auditing provisions,” which would require Aircraft Charter Operators
and/or other Operators not only to comply with FAA regulations, but also to provide the City with
specific weight information and other information regarding the purpose of particular flights, or
the names of passengers on particular flights, the City notes that such information is not
typically required or needed at general aviation airports.
Topic 20: Annual Performance and Compliance Reviews
The City received the following comment suggesting an annual review of Airport Operators’
compliance with the applicable rules, regulations, and Minimum Standards:
(a) All airport operators should be subject to annual review of their compliance with rules
and regulations. These reviews should be made public in their entirety. Licenses to
operate, leases and tenancies should be made dependent on compliance and revocable
in the event of noncompliance.
City’s Response:
The City notes that the Airport Director monitors compliance with Airport regulations and rules
on a regular basis, and takes enforcement action, including declaring Operators in default under
City of Santa Monica
Second Comment Period
Responses to Comments – Airport Minimum Standards Pg. 29 of 29
their leases, when appropriate to address non-compliance. To emphasize that the terms of
Operator’s Leases and Licenses, including requirements for compliance with the Minimum
Standards, will be enforced, as shown in the attached redline, the City has added to Section 1 of
the Minimum Standards a new “Compliance” paragraph making clear that the Airport Director
shall periodically review compliance and take appropriate enforcement actions including
declarations of default.
Topic 21: Miscellaneous
The City received a number of miscellaneous comments that address issues outside the scope
of the Minimum Standards and/or contend that no Minimum Standards should be put in place.
These include the following:
(a) This entire endeavor is absurd, and a waste of public resources. Please get back to
encouraging commerce and business, and stop strangling it with more useless
regulatory red tape.
(b) I repeat, absolutely NO commercial airport use is acceptable, at all, ever, under any
circumstances! Get them out and keep them out, and SHUT IT DOWN, NOW!!!!
(c) Finally, we assert that any standard or other language herein or elsewhere by which the
city attempts to regulate interstate commerce or what has by law been left to the DOT,
FAA, TSA and other Federal Agencies should be removed. Governing law is clear and
well established in this regard, and including such features exposes the city to federal
and other claims.
(d) Has the concrete been removed on both sides of the shortened runway? If not, why not
and when?
City’s Response:
The City has drafted the Minimum Standards to avoid interfering with or intruding on areas in
which DOT, FAA, TSA, or other federal agencies have exclusive authority to regulate. The City
believes the Minimum Standards reflect an appropriate exercise of authority by the City, as
proprietor of the Airport, to set forth minimum requirements for the operation of commercial
activities based at the Airport. The City notes in this regard that many other general aviation
airports have similar sets of Minimum Standards.
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Minimum Standards
For
Commercial Aeronautical Services
At
SANTA MONICA MUNICIPAL AIRPORT
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Table of Contents
SECTION 1 GENERAL INFORMATION ............................................................................................... 1
SECTION 2 APPLICATION PROCEDURES ..................................................................................... 64
SECTION 3 GENERAL REQUIREMENTS ........................................................................................ 97
SECTION 4 FIXED BASE OPERATOR .......................................................................................... 1411
SECTION 5 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
CHARTER AND AIR TAXI......................................................................................... 2017
SECTION 6 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: FLIGHT TRAINING
............................................................................................................................................ 2319
SECTION 7 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
MAINTENANCE AND REPAIR STATIONS ........................................................ 2521
SECTION 8 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: SELF‐SERVICE
FUEL PUMPS ................................................................................................................. 2723
SECTION 9 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
MANAGEMENT SERVICES ...................................................................................... 2925
SECTION 10 SPECIALIZED AERONAUTICAL SERVICES OPERATOR: AIRCRAFT
SALES OPERATOR ...................................................................................................... 3227
SECTION 11 SPECIALIZED AERONAUTICAL SERVICE OPERATOR: OTHER
AERONAUTICAL SERVICES .................................................................................... 3328
SECTION 12 SPECIAL RULES FOR A SASO CONDUCTING MULTIPLE AERONAUTICAL
SERVICES ....................................................................................................................... 3429
SECTION 13 RECOGNITION AND REGULATION OF SELF‐SERVICE AND SELF‐
FUELING RIGHTS ........................................................................................................ 3631
APPENDIX A: DEFINITIONS
APPENDIX B: INSURANCE REQUIREMENTS AND STANDARDS
APPENDIX B-1: MINIMUM INSURANCE REQUIREMENTS MATRIX
APPENDIX C: FLY NEIGHBORLY PROGRAM NOTIFICATIONS
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SECTION 1
GENERAL INFORMATION
PURPOSE
These Minimum Standards regulations supplement the Leasing and Licensing Policy
(the “Airport Leasing Policy”) in place at the Santa Monica Airport (the “Airport”) by
setting prescribminimum standards e the Minimum Standards that must be met by any
person or entity that provides or uses or seeks to use the Airport as a base for any
provide Ccommercial Aaeronautical Activityservices (an "Operator") at the Santa Monica
Airport (the "Airport") (an “Operator”). Each Operator must have a written agreement
with the City of Santa Monica (the "City").
The purpose of these Minimum Standards is to establish reasonable threshold entry
requirements for any person or entity wishing to provide commercial aeronautical
services to the public; to prevent irresponsible, unsafe or inadequate services; to prevent
unfair competition; and to make the Airport as financially self-sustaining as possible. The
establishment of these Minimum Standards does not imply any right to provide any
services at the Airport.
The adoption and enforcement of these Minimum Standards is intended to establish
reasonable threshold entry requirements that will ensure that each Operator is
reasonably fit, willing and able to perform the services it seeks to provide at the Airport;
to . These Minimum Standards are designed to promote good service and fair
competition at the Airport; and to prevent unqualified applicants from operating at the
Airport; to prevent irresponsible, unsafe, or inadequate services; and to make the Airport
as financially self-sustaining s possible. The establishment of these Minimum Standards
does not imply any right on the part of any Operator to provide any services at the
Airport.
It is the City’s policy to extend the opportunity to provide aeronautical services to any
person or entity meeting the City's Minimum Standards for such services at the Airport,
subject to availability of suitable space at the Airport (as determined by the City) to
accommodate such activities, and subject to the City’s rights under the Settlement
Agreement/Consent Decree Between The Federal Aviation Administration And The City
Of Santa Monica, approved by the court in City of Santa Monica v. United States of
America, et al., Case No. 13-CV-8046-JFW (C.D. Cal. Jan. 31, 2017) (the “Consent
Decree”). . The City’s rights under the Consent Decree include, but are not limited to,
its rights to shorten the runway at the Airport, to exercise its proprietary exclusive right to
provide any or all of the aeronautical services that are the subject of these Minimum
Standards, and to close the Airport on or after January 1, 2029.
These Minimum Standards are subordinate to the Consent Decree. To the extent that
these Minimum Standards may conflict with the provisions of the Consent Decree, the
Consent Decree shall govern.
These Minimum Standards are also subordinate to the City of Santa Monica’s Charter
and Municipal Code, including but not limited to Municipal Code Chapter 10.04, and the
Airport Leasing Policy. To the extent that these Minimum Standards may conflict with
the provisions of the City’s Charter or Municipal Code or the Airport Leasing Policy,
those City instruments shall govern. As a result, among other things, these Minimum
Standards do not alter the Municipal Code requirement that no Operator may use the
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Airport as a base for any commercial activity without an operations permit issued by the
City Manager after consideration by the Airport Commission (SMMC 10.04.06.020, .030)
or the Airport Leasing Policy requirement that all leases be approved by the City
Manager, and that certain leases be approved by the City Council.
To the extent (if any) that these Minimum Standards may conflict with the Santa Monica
Airport Operations Handbook, these Minimum Standards control.
Capitalized terms are defined in Appendix “A” to these Minimum Standards.
APPLICABILITY
All Operators shall, as a condition of conducting Commercial Aeronautical Activities at
the Airport, comply with all applicable requirements concerning such activities as set
forth in these Minimum Standards and any subsequent amendments to these Minimum
Standards. thereto. These Minimum Standards shall be deemed to be a part of each
Operator’s written agreement with the City (in whatever form, whether lLease, license,
permit or other) agreement with or from the City except to the extent any particular
provisions of these Minimum Standards unless any such provisions are waived or
modified, in writing, by an authorized representative of the City. The mere omission of
any particular standard from an Operator’s wwritten Lease, license, permit or agreement
with the City, shall not constitute a waiver or modification of such standard in the
absence of clear and convincing evidence that the City intended to waive or modify such
standard. The requirements set forth in these Minimum Standards are minimums, and all
Operators are herein are the Minimum Standards which are applicable to Operators at
the Airport and all persons are encouraged to exceed these minimums such Minimum
Standards in conducting their activities. These Minimum Standards shall be deemed to
be a part of each Operator’s Lease, license, permit or agreement with or from the City
unless any such provisions are waived or modified, in writing, by an authorized
representative of the City. The mere omission of any particular standard from an
Operator’s written Lease, license, permit or agreement with the City, shall not constitute
a waiver or modification of such standard in the absence of clear and convincing
evidence that the City intended to waive or modify such standard.
These Minimum Standards apply to every any Operator as of the date of adoption of
these Minimum Standards, and amendments to these Minimum Standards will apply to
every Operator as of the date of their amendment, provided, however, that:
(a) If an Operator has an existing written agreement with the City at the time
these Minimum Standards are adopted or amended, and if compliance
with these Minimum Standards as adopted or amended would create a
conflict with the written agreement, the written agreement shall prevail
until such time as it is amended, updated, renegotiated, renewed, or, with
the City’s approval, assigned, or a new written agreement is negotiated,
at which time Operator will fully comply with these Minimum Standards as
adopted or amended;
(b) If an Operator has an existing written agreement with the City at the time
these Minimum Standards are adopted and that agreement provides for
application of Minimum Standards following their adoption, the Operator
shall have six months from the date of adoption of these Minimum
Standards to comply with these Minimum Standards, with the exception
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that any new subleases shall be immediately prohibited and any existing
sub-tenancies at the time of adoption of these Minimum Standards shall
be immediately subject to an orderly phase-out at the discretion of the
City; and
( c) Any Operator engaging in activities covered by these Minimum Standards
without a written agreement with the City, shall have six months from the
date of adoption to comply with these Minimum Standards.
person or entity that provides aeronautical services to any third party at the
Airport.
These Minimum Standards shall not affect any lease, license, permit or agreement with
an Operator or amendment to any such an agreement that was properly executed prior
to the date of adoption of these Minimum Standards, except: (a) as provided for in such
agreement, in which case, these Minimum Standards shall apply to the extent permitted
by such agreement, subject to the Operator having six months from the date of adoption
to comply with these Minimum Standards; and (b) that any new subleases shall be
prohibited and any existing sub-tenancies at the time of adoption of these Minimum
Standards shall be subject to an orderly phase-out at the discretion of the City.
These Minimum Standards shall not be deemed to modify any existing written
agreement with the City Lease, license, permit or agreement under which an Operator is
required to exceed these Minimum Standards nor prohibit the City from entering into and
enforcing a written Lease, license, permit or agreement or amendment thereto that
requires an Operator to exceed these Minimum Standards.
Any entity currently engaging in activities covered by these Minimum Standards without
a Lease, license, permit or agreement shall have six months from the date of adoption to
comply with these Minimum Standards.
If these Minimum Standards are amended after an Operator enters into a Lease, license,
permit or agreement with the City, the entity shall not be required to comply with the
amended Minimum Standards, except as provided for in such Lease, license, permit or
agreement, until (a) such time as the entity’s existing Lease, license, permit or
agreement is amended or renewed, (b) the City approves an assignment to another
entity, or (c) the entity enters into a new Lease, license, permit or agreement with the
City.
EFFECTIVE DATE
These Minimum Standards shall become effective on _____________, 2018 (the
"Effective Date"). Each and every Operator conducting any Ccommercial Aaeronautical
Aactivity at the Airport on or after the Effective Date must hold either (a) a current and
valid Lease with the City which specifies that the Operator's Ccommercial Aaeronautical
Aactivities are a permitted use; (b) a Non-Exclusive License from the City authorizing the
Operator to engage in such Ccommercial Aaeronautical Aactivitiesy; or (c) if an
approved subcontractor for an Operator, a Commercial Operations Permit authorizing
the subcontractor to engage in or facilitate the Operator’s Commercial Aeronautical
Activities as a subcontractor of the Operator. Any such Lease, Non- Exclusive License,
or Commercial Operations Permit shall be in a form prescribed by the City that specifies
which types of Commercial Aeronautical Activitiesaeronautical services the Operator (or
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subcontractor) is authorized to provide; requires the payment of fees to the City;
imposes insurance, indemnification, and environmental obligations; and requires a
security deposit or other form of contract security.
COMPLIANCE
The Airport Director shall periodically conduct a review of each Operator’s compliance
with the terms of its Lease or Non-Exclusive License and these Minimum Standards. If
the Airport Director, in his or her discretion, determines that there has been substantial
non-compliance, the Airport Director shall notify the Operator of the non-compliance and
take steps, which may include declaring a default of the Operator’s Lease or Non-
Exclusive License, to ensure that the Operator comes into compliance with the terms of
its Lease or Non-Exclusive License and these Minimum Standards.
RIGHT TO AMEND STANDARDS
The City reserves the right to amend these Minimum Standards as the City determines
may be necessary or desirable to meet the needs of the Airport, to improve the quality of
services, to enhance competition or as otherwise deemed to be reasonable by the City.
The City further reserves the right to amend these Minimum Standards to pursue the
City’s rights under the Consent Decree, including the closure of the Airport on or after
January 1, 2029, as described in the Consent Decree.
WAIVERS
The Airport Director may, in his or her discretion, waive any requirement imposed by
these Minimum Standards for the benefit of any governmental entity providing non-profit
services to the aviation industry, performing emergency medical or rescue services to
the public by means of aircraft or performing fire prevention or firefighting operations.
Except as otherwise limited by these Minimum Standards, Tthe Airport Director may
also waive any of the Minimum Standards for non-governmental Operators if the Airport
Director, in his or her discretion, finds clear circumstances demonstrating deems such a
waiver to be in the best interest of the City. Waivers that extend for the duration of any
new lease must be approved by the City Manager (and City Council if City Council
approval is required under the Airport Leasing Policy or under specific provisions of
these Minimum Standards) after consideration by the Airport Commission. The Airport
Director shall maintain a log of all such waivers indicating for each waiver: the clear
circumstances demonstrating the basis for the waiver, the date on which it was
presented for consideration by the Airport Commission, and the date on which it was or
was not approved by the City Manager (and City Council if City Council approval was
required under the Airport Leasing Policy or under specific provisions of these Minimum
Standards). When any such If a waiver is being proposed for an Operator, then the
Airport Director shall present to the Airport Commission for consideration at one of its
public meetings a public document that attaches the log of prior waivers and identifies
the basis for the proposed waivernote in any public document submitted to the Airport
Commission or City Manager that such waiver has been proposed.
CATEGORIES OF AERONAUTICAL SERVICE OPERATORS
The following categories of Operators may provide commercial aeronautical services at
the Airport:
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1. Fixed Base Operator ("FBO")
2. Specialized Aeronautical Services Operator ("SASO")
a. Aircraft Charter and Air Taxi
b. Flight Training
c. Aircraft Maintenance and Repair Stations
d. Self-Service Fuel Pumps
e. Aircraft Management
f. Air Transportation Arranger
g. Aircraft Sales Operator
h. Other Aeronautical Services
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SECTION 2
APPLICATION PROCEDURES
1. An application to perform commercial aeronautical services at the Airport must
be made in accordance with these Minimum Standards. The application must be
signed by an authorized person and include the name, address, email address
and telephone number of the applicant and the following information:
a. For all applicants - the name, address and telephone number of each
person with a controlling interest in the applicant.
b. For a corporation - the name, address, email address and telephone
number of the corporation’s officers and directors.
c. For a partnership or joint venture - the name, address and telephone
number of each partner or member of the venture.
d. Whether any officer, director, partner or person with a controlling interest
in the applicant is also an officer, director, partner or person holding a
controlling interest in any other commercial aeronautical service Operator
at the Airport.
2. The application, together with all required supporting documentation, shall be
submitted to:
City of Santa Monica, Santa Monica Airport –
Attn: Airport Director
3223 Donald Douglas Loop South
Santa Monica, CA 90405.
3. An applicant shall furnish the following supporting documents as evidence of its
organizational and financial capability to provide the proposed aeronautical
services:
a. Business Plan - a written proposal detailing the nature of the proposed
aeronautical service to be provided, the applicant's space and facility
requirements, and the proposed location on the Airport.
b. Financial Statement - a current financial statement (for a corporation, sole
proprietorship or for all principals of a partnership or joint venture)
prepared in accordance with generally accepted accounting principles by
a certified public accountant.
c. Credit Report - a current credit report (for a corporation or for all principals
of a partnership or joint venture) covering all business activities in which
the applicant has participated within the past ten years. To satisfy this
requirement, an applicant shall furnish to the Airport with its application a
fee that the Airport shall use to perform the required credit report check.
d. Personnel - a list, with resumes, of key personnel to be assigned to the
Airport along with a description of their duties and responsibilities.
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e. Licenses and permits - copies of all licenses, certifications and permits
possessed by the applicant or its key employees to be based at the
Airport that are required to perform the proposed services.
f. Evidence of insurance that meets the applicable requirements as set forth
in Section 3 of these Minimum Standards.
g. Commercial Operations Permit Application.
h. Such other information as the Airport Director may require.
4. The Airport Director shall may deny any application to provide aeronautical
services at the Airport if, in his or her discretion, the Airport Director determines
that:
a. the applicant does not meet any applicable provisions of these Minimum
Standards;
b. the applicant has supplied the City, or any other person, with false or
misleading information or has failed to make full disclosure in its
application or in its supporting documents;
c. there is no appropriate, adequate or available space on the Airport to
accommodate the applicant at the time of application;
d. the proposed activity would conflict with existing aeronautical uses;
e. the proposed activity would require the City to spend funds or to supply
materials or manpower that the City would, in its discretion, prefer not to
spend or supply;
f. the proposed activity would require existing Operators without their
consent to reduce the amount of Airport property they use to provide
aeronautical services, result in congestion anywhere within the Airport or
interfere with the orderly activities of existing Operators;
g. the proposed service activities wouldcould be detrimental to the Airport;
h. the applicant has violated any of these Minimum Standards or any other
regulations of the City, the standards or regulations of any other airport,
or any other statutes, regulations, ordinances, laws or orders applicable
to the Airport or any other airport;
i. the applicant is currently in default, or has been in default in the past, in
the performance of any lease or other agreement with the City or at any
other airport;
j. the applicant's financial statement or credit report contains information
that creates doubt as to the applicant’s abilities to provide the proposed
services;
k. the applicant does not have or cannot demonstrate access to the
operating capital necessary to conduct the proposed operation;
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l. the applicant is unable to obtain sufficient insurance, financial sureties or
guarantors to protect the interests of the City or other appropriate
governmental entities;
m. the applicant has been convicted of any felony or misdemeanor involving
moral turpitude; except that the Airport Director, in his or her discretion,
may disregard such conviction based on consideration of the following
factors: mitigating circumstances that may exist, the nature and gravity of
the offense, the time elapsed, the nature of the aeronautical services to
which the application applies and the relatedness of the conviction to
those services, and any other factors that are related to the application
and consistent with business necessity;
n. the applicant's proposal is not in the best interest of the health, safety,
welfare or convenience of the traveling public or Airport Users;
o. the applicant is unable to qualify for unescorted access to Airport
Operating Areas, if required to provide proposed services;
p. approval of the proposed activity would be inconsistent with the Consent
Decree, the City’s Charter or Municipal Code, or ;
q. the applicant’s proposal is inconsistent with the City’s Airport Leasing
Policy; or
r. the applicant’s proposal is inconsistent with the City’s Charter or
Municipal Code.
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SECTION 3
GENERAL REQUIREMENTS
These Minimum Standards establish certain requirements to be met by every Operator
providing aeronautical services at the Airport. Such Operators must, in addition to
complying with all applicable Minimum Standards, comply with all other applicable laws,
regulations, ordinances, rules, building codes, or other provisions, including contracts,
relating to their operations at the Airport.
In addition to the Minimum Standards applicable to each specific category of commercial
service operation set forth below, every Operator providing aeronautical services at the
Airport must meet the following general requirements.
1. Property/Facilities. Unless exempted from this requirement by the Airport Director
in his or her discretion, each Operator must lease the property or facilities
required for the services it renders directly from the City.
2. Hangars and Other Buildings. If required by these Minimum Standards, the
Operator shall lease hangar space for aircraft storage and shall lease sufficient
building space to support its activities at the Airport.
3. Aircraft Parking Apron. If required by these Minimum Standards, the Operator
shall lease sufficient paved aircraft parking apron space within its leasehold
premises to meet the requirements of its aeronautical activity and shall maintain
any paved taxiways necessary for access to the Airport’s taxiway system.
4. Equipment.
a. The Operator must demonstrate that it owns, leases or otherwise has
sufficient access to all equipment required to provide the applicable
aeronautical services promptly on demand without causing any flight
delays or other operational impacts on aircraft at the Airport. All
equipment must be maintained in good operating condition and good
appearance and must be in compliance with all applicable safety
standards and regulations. All heavy equipment except aircraft must be
clearly designated with the name and logo of the Operator prominently
displayed.
b. Any Operator that is involved with towing aircraft off of its leased
premises and onto other airport property shall own or contract for
appropriate equipment to be used and for appropriate lighting to be used
during tow operations (including strobe lights).
c. All vehicles driven on Airport property must have any permits or required
registrations as required by federal, state or local law. Such vehicles also
must be operated by persons with appropriate licenses or permits and
trained under the Airport’s driver safety training program, should the
Airport require such training.
d. Any Vehicle used for Commercial purposes in the AOA must bear
identification designating the Commercial Aeronautical Operator to whom
the vehicle is assigned. The display of identification shall be in letters in
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sharp contrast to the background and shall be of such size, shape, and
color as to be readily legible during daylight hours from a distance of 50
feet.
5. Personnel and Training.
a. All personnel shall display Santa Monica Airport ID badges at all times on
their person, as required by Airport Rules. Non-Administrative personnel
in the AOA shall wear clothing that displays the identification of the
Operator in letters in sharp contrast to the background which shall be of
such size, shape, and color as to be readily legible during daylight hours
from a distance of 20 feet. Administrative personnel need not wear
uniforms.
b. An adequate number of qualified and, where applicable, licensed
employees shall be on duty at all times of operation to provide services
consistent with these Standards.
c. At least one qualified supervisor shall be on duty when any aeronautical
services are being performed by any Operator. A supervisor may be “on
duty” for purposes of this subsection if the supervisor is available by
phone, but not at the Airport, provided that in such a case an Operator
must provide the Airport Director with a list of phone numbers at which
the Airport can reach supervisors during regularly scheduled shifts.
d. Each Operator shall establish a written job description for each type of
employee to ensure that all employees are thoroughly trained and
qualified to perform the aviation tasks to which they are assigned. The
level of detail required for each job description shall be commensurate
with the technical complexity and safety risks associated with the
employee’s work. At a minimum, each job description shall include a
statement of responsibilities, as well as required skills, degrees, and
certificates. For more technically specialized work or work involving
heavy equipment or significant safety concerns, the description shall also
include what training, experience, and safety precautions are required to
perform the required tasks. Upon request, the Operator shall submit a
copy of its written job descriptions to the Airport Director or designee.
e. All personnel who will operate a vehicle on the AOA must successfully
complete the Airport’s initial training course on driving on the AOA and
any refresher training that may be required by the City.
f. Each Operator shall provide to the Airport Operations/Public Safety
Officer Unit a list of company officials and 24-hour contact information.
This list shall include:
i. the Operator’s local representative with administrative, operational
and fiscal authority over the aircraft/facility involved;
ii. the Operator’s corporate representative with administrative,
operational and fiscal authority over the aircraft/facility involved;
and
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iii. the Operator’s point of contact for emergency/security incidents.
6. Insurance Requirements.
a. All Operators shall comply with the insurance Requirements and
Standards set forth in Appendix “B” to these Minimum Standards, which
may be revised by the City. These include the requirement that all
Operators shall procure prior to commencement of service, and shall
thereafter maintain continuously in effect throughout the term of their
activities at the Airport, at the Operator's sole expense, insurance of the
types and in at least such minimum amounts as are set forth in Appendix
“B-1” to these Minimum Standards, which may be revised by the City.
b. The insurance requirements imposed by this Section may not be waived
by the Airport Director. In his or her discretion, the Airport Director may
waive, reduce or otherwise modify any of the insurance requirements set
forth in these Minimum Standards including, but not limited to, reducing
required policy limits, waiving certain coverage requirements or
authorizing larger self-insured retentions, provided, however, that in no
circumstance may an Operator be permitted to operate at the Airport
without insurance.
7. Airport Security.
a. All Operators shall comply with all applicable security requirements
adopted for the Airport by the City (including but not limited to any Airport
Security Plan issued by the City), the FAA, or the Transportation Security
Administration, and shall comply with the directives of any law
enforcement officer or other airport personnel implementing these
requirements. The City reserves the right in its discretion at any time to
impose additional security requirements, applicable to all similarly-
situated Operators.
b. Operator shall have a documented security plan consistent with its
Activity or Activities and adequate for the type of operation and services
being provided. The security plan shall be made available to the Airport
Director upon request and shall address at a minimum procedures for the
following:
i. Securing Commercial Aeronautical Operator’s Leasehold to
prevent unauthorized access to the Leasehold and the AOA of the
Airport.
ii. Monitoring and controlling access to the Airside Area of the Airport
through Commercial Operator’s Leasehold.
iii. Providing escort to vendors, customers or other visitors operating
vehicles on the AOA.
iv. Informing Commercial Aeronautical Operator’s employees,
vendors, customers and other visitors of security requirements
and procedures.
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c. The Airport Security requirements imposed by this Section may not be
waived by the Airport Director.
8. Subcontracting. A SASO may, but only with written permission from the Airport
Director, subcontract any of the services it is authorized to provide on an item by
item basis for no more than 180 days, subject to renewal with the permission of
the Airport Director.
9. No Subleasing. Subleasing shall be prohibited. Existing sub-tenancies at the time
of adoption of these Minimum Standards shall be subject to an orderly phase-out
at the discretion of the City.
10. Commercial T-Hangars. Commercial T-hangar rental shall be prohibited. Only
the City may lease and manage T-hangars for storage of general aviation
aircraft.
11. Compliance with Airport Leasing Policy, City Charter and Municipal Code. All
Operators must comply with all applicable sections of the Municipal Code and the
policies of the City of Santa Monica, including but not limited to, the following:
a. The City’s Airport Leasing Policy;
b. The City’s Charter and Municipal Code, including but not
limited to:
i. Article XXII of the City of Santa Monica Charter (the “Oaks
Initiative”) (located at
santamonica/view.php?topic=the_charter_of_the_city_of_santa_monica-
xxii&frames=on); and
ii. Chapter 10.04 of the Municipal Code.
112. Nondiscrimination. Operator shall not discriminate against any person or class of
persons by reason of race, creed, color, national origin, sex, age, sexual
orientation, gender identity, or physical handicap in providing any products,
services, or facilities or in the use of any of its facilities that are available to the
public, or in any manner prohibited by applicable regulatory measures including
without limitation Part 21 of the Rules and Regulations of the office of the
Secretary of Transportation effectuating Title VI of the Civil Rights Act of 1964, as
amended or reenacted. This non-discrimination requirement may not be waived
by the Airport Manager.
123. Legal Compliance.
a. Americans with Disabilities Act Compliance. Operator shall comply with
the Americans with Disabilities Act, as amended, to the extent required by
law.
14. b. Environmental Compliance. Operator shall comply with all
applicable federal, state, and local environmental laws and regulations.
c.15. Noise Restrictions Compliance. Operator shall comply with all applicable
federal, state, and local noise restriction laws and regulations.
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d. Airport Leasing Policy, City Charter and Municipal Code. Operator must
comply with all applicable sections of the Municipal Code and the policies
of the City of Santa Monica, including but not limited to, the following:
i. The City’s Airport Leasing Policy;
ii. The City’s Charter and Municipal Code, including but not
limited to: (a) Article XXII of the City of Santa Monica Charter (the
“Oaks Initiative”); and (b) Chapter 10.04 of the Municipal Code.
e. The legal compliance requirements imposed by this Section may not be
waived by the Airport Director.
136. Combination of Space Requirements. In his or her discretion, to reduce the
overall amount of space required, the Airport Director may adjust or combine the
minimum space requirements set forth for each type of aeronautical service if
more than one type of service will be provided by a SASO from the same
premises.
147. Required Fees and Payments. The fees and payments to be made to the City by
each Operator will be set forth in the Operator's Lease or Non- Exclusive License
and shall be reasonable and not unjustly discriminatory.
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SECTION 4
FIXED BASE OPERATOR
This section sets forth the minimum standards for a Fixed Base Operator at the Airport.
STATEMENT OF CONCEPT
An FBO provides a wide range of aeronautical services to the public. An FBO must
provide all of the following products and services at its premises at the Airport:
1. Storage of aviation fuel and other petroleum products at City’s fuel storage
facilities.
2. Aircraft and engine maintenance and repair services directed towards the
general aviation market.
3. Tie-down services.
4. Shuttle service for passengers of chartered, private and executive aircraft.
5. Arrange car rental, limo services or taxi-cab services for customers.
6. Arrange catering services for customers.
7. Marshaling and parking of aircraft.
8. Maintenance of the Airport’s Registration Log and other statistical data
concerning the FBO’s activities on the Airport.
9. Automotive maintenance for ground support equipment at the Airport.
10. Aviation maintenance and repair service with a licensed airframe and power plant
mechanic at the Airport.
11. Gate service for aircraft such as, but not limited to, passenger ramp service
baggage handling, catering, and interior cleaning of aircraft.
12. Towing service for disabled aircraft. For larger aircraft (over 30,000 lbs.) the
FBO may arrange with other qualified operators to provide this service.
13. Into-plane Fueling.
a. Aviation fuels (including both jet fuel and either, AvGas or and unleaded
AvGas once unleaded AvGas is commercially available and approved for
use) and lubricating oils shall be stored and dispensed by an FBO in
accordance with all local, state and federal laws, regulations, rules and
other requirements, as same may be amended, regarding the sale and
storage of such fuels and oils, including without limitation any rules,
regulations or minimum standards that are established by the City.
b. Prior to commencement of the operations of dispensing and selling fuels,
an FBO shall submit to the City, for review and comment, the FBO’s Spill
Prevention Control and Countermeasure Plan and Pollution Incident and
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Prevention Plan and any permit requirements necessary by local, county
and State agencies.
14. Other Services. An FBO may provide other specialized aeronautical services on
its leasehold subject to the approval of the City, through the Airport Director,
including the sale or rental of all types of consumer products normally related to
the ownership or operation of aircraft; and any other services normally performed
by similar FBOs at other airports in the United States. These requests will be
reviewed and approved on a case-by-case basis.
15. Subcontracting. An FBO shall not subcontract any fueling services or other
services that it is authorized or required to provide without the prior written
approval of the Airport Director. Subcontracting of services shall not relieve FBO
of any of its obligations or liabilities under these Minimum Standards or its Lease
or operating agreement with the City.
16. Prohibited Activities. Each FBO is expressly prohibited from engaging in any of
the following activities:
a. Provision of terminal facilities for passenger operations, other than those
covered by Federal Aviation Regulations 14 CFR Parts 91 and 135.
b. Sale of non-aviation products, except for paraphernalia associated with
the Operator’s business (i.e., t-shirts, hats, etc.) and food and beverage
amenities (i.e. vending machine snacks, sodas, etc., but not alcoholic
beverages).
c. Air shows or meets.
d. Film shoots, or displays or other public gatherings, without the express
written approval of the Airport Director.
e. Any service prohibited by law or not related to aviation.
f. Advertising of any kind unrelated to services FBO is permitted to provide
at the Airport.
g. Storage of Hazardous Materials, liquid industrial waste or any other
regulated waste that does not fully comply with all applicable
environmental laws.
h. Constructing or operating a fuel farm without the express written approval
of the Airport Director.
i. Heavy maintenance on an aircraft on a parking apron or any other area
not designated or leased for aircraft maintenance without the express
written approval of the Airport Director. This does not apply to routine line
maintenance of aircraft.
j. Parking, storing, or allowing the parking or storage of any vehicles on the
Operator’s premises that are not used in the daily operation of the general
aviation business permitted to be conducted on the premises, unless
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such vehicles are owned and operated by the Operator’s customers or
employees.
MINIMUM STANDARDS
1. Experience. An Operator proposing to operate as an FBO shall have a minimum
of 5 years’ experience as an FBO (including the fueling of aircraft). The Airport
Director may not exercise his or her discretion to waive this requirement unless
the Airport Director is satisfied, after reviewing documentation from an applicant
the Airport Director deems to be sufficient, that the proposed FBO Operator’s
management personnel have sufficient knowledge and experience to safely and
efficiently conduct FBO operations at the Airport.
2. Land. Each FBO must lease enough land to provide adequate space for
buildings, paved private auto parking, paved aircraft parking, paved pedestrian
walkways, fuel storage facilities, and all storage, servicing utilities and support
facilities as may be mutually agreed upon in writing by the City and FBO. The
minimum area required will not be less than 144,000 square feet.
3. Hangars and Other Buildings. Each FBO must lease facilities to provide at least
6,000 square feet of lounge (for crew and passengers), offices, flight planning
facilities, pilot waiting areas, and public restrooms.
4. Aircraft Parking. Each FBO must provide paved aircraft parking of a minimum of
30,000 square feet that can accommodate the largest aircraft to be handled or
serviced by the FBO.
5. Automobile Parking. Each FBO must lease a minimum of 20 paved private
automobile parking spaces excluding employee parking.
6. Fuel Storage Facilities. Depending on the location and nature of the proposed
FBO business, with the advance approval of the Airport Director in writing, which
approval may be issued by the Airport Director only after authorization by the City
Council, the FBO may be permitted to establish and operate its own fuel farm. If
a request by the FBO to establish and operate its own fuel farm is approved by
the Airport Director, the following requirements will apply:
a. The FBO shall lease sufficient land for installation of above-ground fuel
storage tanks to be constructed and operated on the FBO’s leased
premises in compliance with all applicable environmental requirements.
b. Total storage capacity shall consist of at least one (1) 10,000 gallon
storage tanks for jet fuel and one (1) 2,500 gallon storage tank for
aviation gasoline to assure adequate supplies of fuel at all times.
c. The fuel storage system must include adequate fuel spill prevention
features and containment capabilities, together with an approved fuel spill
containment and countermeasures control plan, and shall be improved
and upgraded as necessary to meet all current EPA, State, and City of
Santa Monica requirements for spill prevention, containment and
mitigation as they may be revised.
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d. The FBO shall be required to undertake at its own expense any
environmental testing of its fuel facilities which the City may reasonably
request, on or off the Airport, and to take any remedial actions determined
to be necessary or appropriate as a result of such testing.
e. The right is reserved to the City to disapprove installation of a new FBO
fuel farm if the City determines, in its discretion, that the proposed FBO
fuel farm would have an adverse effect on safety or otherwise not be in
the interest of a safe and efficient airport operation.
7. Mobile Dispensing Equipment.
a. Each FBO shall provide at least three (3) metered filter-equipped mobile
dispensing trucks for dispensing jet fuel, AvGas, and unleaded AvGas
(once commercially available and approved for use), with separate
dispensing pumps and meters required for each type of fuel.
b. At least two (2) of the mobile dispensing trucks must be used for jet fuel
with each having a minimum capacity of at least 3,000 gallons.
c. The remaining mobile dispensing truck shall provide Unleaded AvGas
with a capacity of at least 750 gallons. Until such time as unleaded AvGas
is commercially available and approved for use, standard AvGas may be
used.
d. All dispensers must have bottom-refilling capabilities and turbine fuel
dispensers must have single point refueling capabilities.
e. All dispensers shall meet all applicable safety requirements, with reliable
metering devices subject to independent inspection.
f. All equipment shall be maintained and operated in accordance with
Federal, State, City and industry requirements, including ATA 103, NFPA
407, OSHA guidelines, and Municipal Code 10.04.06.120.
8. Aircraft Service Equipment. Each FBO shall procure and maintain tools, jacks,
tugs, towing equipment, tire repairing equipment, ground power units, portable
compressed air tanks, oxygen cart and supplies, fire extinguishers, air stairs,
chocks, ropes, tie-down supplies, crew and passenger courtesy transportation
vehicles, and any other equipment appropriate and necessary for the servicing
of all aircraft types normally expected to use the FBO facilities.
9. Hours of Operation. Each FBO shall provide aircraft fueling and line services
during the hours of 7 a.m. to 911 p.m. Monday thru Friday and from 8 a.m. tohru
911 p.m. on Saturdays and Sundays.
10. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards:
a. Full-Time Manager: All activities of the FBO shall be conducted under the
guidance and supervision of a full-time FBO Manager who must have
demonstrated experience in FBO supervision and operations and must be
approved in advance by the Airport Director, which approval the Airport
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Director retains discretion to deny. The FBO Manager must be vested
with full power and authority to direct and conduct the FBO operation.
The FBO Manager shall be assigned to the Airport and shall be available
during normal business hours.
b. Line Service: At least two (2) fully trained and qualified fuel service
personnel shall be on duty at all times while the facility is open for
business. And adequate staff shall be on duty to ensure that aircraft are
able to be marshalled onto FBO’s leased area expeditiously without
interfering with Airport operation in the AOA. One must be a responsible
supervisor trained in accordance with 14 CFR §§ 139.321(b)(6) and
(e)(1).
c. Maintenance: At least one (1) FAA-certificated aircraft mechanic shall
promptly be available upon request. The FBO can meet this requirement
with mechanics employed by the FBO, or by contracting with an on-call
Specialized Aeronautical Service Operator authorized to conduct Aircraft
Maintenance at the Airport, provided that the Airport Director approves
such contract.
d. All personnel shall be suitably uniformed.
e. There shall be at least one person on duty during the hours of 7 a.m. to
911 p.m. Monday thru Friday and from 8 a.m. tohru 911 p.m. on
Saturdays and Sundays to act as supervisor, customer service
representative, ramp attendant, and dispatcher for General Aviation
activity, unless otherwise agreed in writing by the City. If an FBO
deplanes passengers outside of the hours provided in this subsection,
then the FBO shall staff sufficient personnel to perform necessary
functions for those passengers and for safe operation of the aircraft.
f. All fuel service personnel shall have successfully completed an approved
line technician safety course. A National Air Transportation Association
(NATA) course or equivalent is acceptable.
g. Supervisors and all other personnel dispensing fuel must have received
initial and required recurrent training in accordance with 14 CFR §
139.321. Training records for all personnel providing fueling services
must be maintained on file at the Airport and be available for inspection
by the City.
11. Insurance Requirements. Each FBO shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with the City.
12. Airport Security. Each FBO shall comply with all security requirements specified
by Section 3 or otherwise applicable as a matter of law.
13. Required Fees and Payments.
Lease: The FBO shall enter into a lease agreement providing for the payment of
rent for leased space and facilities.
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Fuel Flowage: In addition to the rent to be paid under its lease with the City, the
FBO shall pay the City any fuel flowage fees or other fees that are specified in its
lease.
14. Fly Neighborly Program. The FBO shall maintain on its premises copies of, and
shall provide to each pilot using the FBO, a Pilot’s Guide for the type of aircraft
being flown by that pilot (fixed wing, jet, or helicopter), in the form attached as
Appendix C or such similar form as may be provided by the Airport Director.
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SECTION 5
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT CHARTER AND AIR TAXI
STATEMENT OF CONCEPT
An Aircraft Charter or Air Taxi Operator is a person, firm or corporation engaged in the
business of providing commercial air transportation (persons or property) to the general
public for hire under FAR Part 135 and using the Airport as a base for engaging in this
business.
MINIMUM STANDARDS
1. Facilities.
a. If providing facilities for customer use at the Airport through an FBO
operating at the Airport, the Operator shall provide the Airport Director
with documentation confirming the FBO’s agreement to provide such
facilities and establishing that the FBO has complied with all the terms of
its Iease with the AirportCity and all applicable provisions of these
Minimum Standards, and, upon a determination by the Airport Director
that these requirements have been satisfied, shall enter into a Non-
Exclusive License with the City for provision of services.
b. Otherwise, the Operator shall lease from the City an area of sufficient
size, shape, and location as mutually agreed upon to provide at least
1,000 square feet of floor space for office, restrooms, and customer
lounge for customer use. The Operator shall lease from the City an area
of sufficient size, shape, and location as mutually agreed upon to provide
at least 1,000 square feet of floor space for office, restrooms, and
customer lounge for customer use. All office/lounge space shall be
properly heated and lighted. The Operator shall provide sufficient
automobile parking space to accommodate employees and customers
parking with no on-street parking. Paved walkways with all points of
access conforming to the criteria specified in the Americans with
Disabilities Act (ADA) as required by the act will be provided by the
Operator. Adequate hard surfaced aircraft ramp must be provided within
the leased area, sufficient to accommodate the Operator’s activities,
operations, and adequate tie-down facilities. If the Operator utilizes
existing facilities, which may not meet the minimum sizes outlined in this
section, the minimum square footage requirements may be determined by
the availability of facilities and through written agreement with the City.
2. Aircraft. The Operator shall provide for charter one or more aircraft, which may
be single- or multi-engine, or helicopterssingle-engine aircraft, and may provide
one or more multi-engine aircraft. All aircraft must be equipped for and capable
of use under instrument conditions, and either owned by or under written lease to
Operator. All aircraft must meet the requirements of the FAA and the FAR Part
135 certificate held by the Operator.
3. FAA Approvals. The Operator shall have and provide copies to the City of all
appropriate certifications, approvals and FAA issued operating certificates. Any
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time certifications or approvals are modified, the updated documentation
reflecting the changes shall be provided to the City within three calendar days.
Only air charter and air taxi activities authorized by the FAA and appropriate City
approvals may be conducted at the Airport under this section, and all such
activities must be conducted in accordance with all applicable FAA regulations,
including any such regulations limiting the permissible weight of aircraft loads
based on factors such as runway length, weather, and aircraft operating
specifications.
4. Reports. For each flight providing commercial air transportation to persons, the
Operator shall provide the Airport Director, upon request made by the Airport
Director within 180 days after the flight, with a written report stating the type of
aircraft, number of passenger seats, and number of passengers actually carried.
5. Employees. If certified to engage in on-demand common carriage for persons or
property, the Operator shall employ the number of employees required by 14
CFR Part 135.
6. Mitigation Measures. As described in the Municipal Code, § 10.04.06.030(d),
applications for air carrier service at the Airport “shall identify and assess the
effects of the service on community aircraft noise exposure, automobile traffic,
and other significant environmental impacts and propose appropriate mitigation
measures. Environmental assessment shall be in accordance with State and City
laws and procedures.” As used in the Code, “air carrier” service includes
commuter service, air charter and air taxi operations, freight, cargo, express, and
mail service, indirect air carriers and other commercial flight operations
certificated by the Federal Aviation Administration .
7. Hours of Operation. If leasing premises to provide customer services pursuant to
Section 5.1(b) above, Tthe Operator shall have its premises open and services
available to customers at least two (2) hours prior to and one (1) hour after each
flight offered by the Operatoreight (8) hours daily, five (5) days per week, and
shall provide on-call service at all other hours.
8. Personnel and Training. The Operator shall have in its employ suitably
uniformed and trained personnel in such numbers as are required to meet the
minimum standards set forth in this category, but never less than two FAA
currently certificated commercial pilots appropriately rated to conduct the flight
activity offered by Operator. The Operator shall have available sufficient qualified
personnel for checking in passengers, handling of luggage, ticketing and for
furnishing or arranging for suitable ground transportation.
9. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 and Appendix B
of these Minimum Standards and its Lease with or Non-Exclusive License from
the City.
10. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
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11. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
12. Fly Neighborly Program. The Operator shall provide to each pilot flying for the
Operator a Pilot’s Guide for the type of aircraft being flown by that pilot (fixed
wing, jet, or helicopter), in the form attached as Appendix C or such similar form
as may be provided by the Airport Director.
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SECTION 6
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
FLIGHT TRAINING
STATEMENT OF CONCEPT
A Flight Training Operator may provide instruction to pilots in dual and solo flight
training, in fixed wing aircraft, and any related ground school instruction as is necessary
for preparation to taking an FAA written examination and flight check ride for various
category or categories of pilot’s licenses and ratings.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease from the City an area of sufficient size,
shape, and location to provide sufficient area to accommodate all of the
Operator’s activities and operations as described below. The Operator shall
provide at a minimum:
a. At least 1,000 square feet of floor space for an office, shop, restrooms,
customer lounge, classroom, and briefing room space to support flight-
training activities.
b. For aircraft using a hangar, sufficient area for parking the Operator’s
aircraft.
c. For aircraft not using a hangar, tie-down spaces of sufficient area for
parking the Operator’s aircraft.
d. Sufficient automobile parking space to accommodate employees and
customers parking with no on-street parking.
e. Paved walkways with all points of access conforming to the criteria
specified in the Americans with Disabilities Act (ADA) as required by the
act will be provided by the Operator.
f. Copies of all applicable federal, state and local licenses to operate a flight
training facility, including but not limited to any approvals required under
14 CFR Part 61 or 14 CFR Part 141.
2. Equipment. The Operator shall have available for use in flight training, either
owned or under written lease to the Operator, not less than two (2) properly
certificated aircraft, at least one (1) of which must be equipped for and capable of
use in instrument flight instruction, unless the Operator is only providing sport
pilot training.
3. Personnel. The Operator shall have on duty, on a full- time basis, at least one
(1) flight instructor who is currently certificated by the FAA to provide the type of
flight training offered; and shall have available for call, on a part-time basis, at
least one (1) flight instructor who is currently certified by the FAA to provide the
type of flight training offered. The Operator shall provide a currently certified
ground school instructor as needed; this requirement may be satisfied by a
certificated flight instructor with appropriate experience in ground school
teaching. The Operator shall have its premises open and services available in
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day and night hours as necessary to meet demand for training, and shall have an
employee in the facility at all times that flight or ground training is being
conducted.
4. Maintenance of Aircraft and Space for Maintenance. If the Operator is
conducting Aircraft Maintenance on Aircraft owned or leased or operated by (and
under the full and exclusive control of) the Operator, then the Operator must
lease at least 1,500 square feet of hangar space for such Aircraft Maintenance,
including employee work areas, shop areas, and storage.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
8. Fly Neighborly Program. The Operator shall maintain on its premises copies of,
and shall provide to each person being trained, a Pilot’s Guide for the type of
aircraft on which the person is being trained (fixed wing, jet, or helicopter), in the
form attached as Appendix C or such similar form as may be provided by the
Airport Director.
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SECTION 7
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT MAINTENANCE AND REPAIR STATIONS
STATEMENT OF CONCEPT
An Aircraft Repair Station Operator provides maintenance, repair, rebuilding, alteration
or inspection of aircraft or any of their component parts. Two types of Aircraft Repair
Station Operators are permitted at the Airport: (1) Aircraft Repair Stations and (2) Minor
and Specialized Maintenance and Repair Operators.
An Aircraft Repair Station must be certificated by the FAA under FAR Part 145 to
perform aircraft maintenance and shall provide only those maintenance and inspection
services permitted by its FAA certification. An Aircraft Repair Station Operator may also
sell aircraft parts and accessories on a non-exclusive basis.
A Minor and Specialized Maintenance and Repair Operator may provide either or both of
the following types of maintenance and repair services:
a. A Minor Maintenance and Repair Operator may provide aircraft airframe and
engine inspection, maintenance and repair on general aviation aircraft that is not
required to be performed by a Repair Station certificated under 14 CFR Part 145.
Services may include minor aircraft airframe and engine inspection, maintenance
and repair, and sale of incidental parts and accessories.
b. A Specialized Minor Aircraft Maintenance and Repair Operator may provide
maintenance and repair of aircraft radios, propellers, instruments, and
accessories for general aviation aircraft. This category shall include the sale of
new and/or used aircraft radios, propellers, instruments, and accessories on a
non-exclusive basis.
MINIMUM STANDARDS
1. Hangars and Shops. The Operator shall lease a hangar or shop facilities of at
least 5,000 square feet to conduct its business.
2. Aircraft Apron. If necessary for its operations, the Operator shall lease at least
4,000 square feet of paved aircraft parking and storage area to support its
activities, unless the City agrees in writing to a lesser leased area.
3. Aircraft Service Equipment.
a. Aircraft Repair Station Operators shall at all times maintain an adequate
supply of all necessary parts, equipment and accessories as needed for
its business operations.
b. Minor and Specialized Maintenance and Repair Operators shall provide
sufficient equipment, supplies and parts to provide minor repairs,
inspections and preventative Maintenance as defined in FAA regulations
at 14 CFR Part 43, including machine tools, jacks, lifts and testing
equipment.
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c. If the Operator is involved with moving aircraft, the Operator shall have,
lease or contract with an FBO at least one aircraft tug of sufficient power
or braking weight to handle any aircraft that the Operator is permitted to
service under the Operator’s FAA certificate.
d. The Operator shall own, lease or otherwise have available all of the tools
and equipment required under the Operator’s FAA certificate.’
4. Hours of Operation.
a. The Repair Station shall be open and have services available at least
eight (8) hours a day, five (5) days a week.
b. The Operator shall provide for services during off-hours through an “on-
call” system.
5. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards:
a. The Operator shall have in its employ, and on duty during its hours of
operation under Section 7.4.a above, trained personnel in such numbers
as are required to meet contract requirements and FAA regulations, in a
safe and efficient manner, but never less than one (1) person who is an
employee of the Operator and is currently certified by the FAA with
ratings appropriate to the work being performed, and who holds an
airframe, power plant or an aircraft inspector rating. The requirements of
this subsection regarding inspector ratings shall not apply to radio shop
repair stations, if any.
b. During its hours of operation under Section 7.4.a above, the Operator
shall maintain a responsible person in charge to supervise its operations
on the Airport who has authority to represent and act for and on behalf of
the Operator.
c. All employees shall be suitably uniformed.
6. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
7. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
8. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 8
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
SELF-SERVICE FUEL PUMPS
STATEMENT OF CONCEPT
A Commercial Self-Service Fuel Operator provides and operates a commercial self-
service fueling facility from which pilots may fuel their aircraft. A commercial self-service
fueling facility may or may not be attended. Commercial self-service fueling is distinct
from self-fueling, in which an aircraft owner or operator performs services on its Owned
Aircraft with its Own Employees and Own Equipment.
MINIMUM STANDARDS
1. Land. The Operator shall lease, at a minimum, 8,000 square feet to provide
sufficient land for a retail self-service aviation fueling pump and corresponding
underground fuel storage tank (or a retail self-service aviation fueling pump and
the installation of a new above-ground fuel storage tank), supporting reporting
equipment and credit card authorization, and to provide fueling and dispensing
services to customers.
2. Services. The Operator shall operate a commercial self-service fueling facility
and shall provide retail aviation fueling and dispensing services to Airport users,
including the retail distribution of either 100 low lead AvGas or and unleaded
AvGas (once unleaded AvGas is commercially available and approved for use).
The City, in its discretion, may allow subcontracting for these services after
reviewing a request for approval in writing.
3. Equipment, Operations, and Spill Control.
a. Equipment. The Operator must demonstrate that it owns, leases or
otherwise has sufficient access to all equipment required to provide
storage and dispensing operations at the Airport. All equipment shall be
maintained and operated in accordance with Federal, State, City and
industry requirements, including ATA 103, NFPA 407, OSHA guidelines,
and Municipal Code 10.04.06.120.
b. Operating procedures. The Operator shall develop and maintain
Standard Operating Procedures (SOP) for fueling and shall ensure
compliance with all applicable federal, state and local requirements or
standards, including those set forth in Advisory Circular 150/5230-4B -
Aircraft Fuel Storage, Handling, Training, and Dispensing on Airports,
ATA 103, NFPA 407, OSHA guidelines, Municipal Code 10.04.06.120,
and ASTM best management practices. The SOP shall include the
following:
i. a training plan,
ii. fuel quality assurance procedures,
iii. a schedule for inventory, inspections, and maintenance
procedures;
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iv. record keeping procedures, and
v. emergency response procedures for fuel spills and fires,
including prevention measures;
vi. information regarding the control of access and security for fuel
and oil dispensing areas.
The SOP shall be submitted to the City not later than ten (10) business
days before the Operator commences operation at the Airport.
c. Spill Prevention and Containment. Prior to transporting or dispensing
aviation fuel or oil onto the Airport, the Operator shall provide the City with
a Spill Prevention Contingency and Control Plan (SPCC) that meets
regulatory requirements for fuel and oil storage facilities. An updated copy
of such SPCC Plan shall be filed with the City at least ten (10) business
days prior to actual implementation. Such plan shall describe, in detail,
those methods that shall be used by the Operator to clean up any
potentially hazardous fuel spills. The plan should include Equipment to be
used, emergency contact personnel and their telephone numbers, and all
other details as to how the Operator would contain such a spill. This plan
should also describe, in detail, what methods the Operator intends to use
to prevent any such spill from occurring.
4. Hours of Operation. The facilities shall be open and have services available
during the hours of 7 a.m. to 911 p.m. Monday thru Friday and from 8 a.m. tothru
911 p.m. on Saturdays and Sundays.
5. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
in its employ, and on duty during business hours, trained personnel in such
numbers as are required to meet FAA regulations and any applicable terms
specified in the Operator’s Lease with or Non-Exclusive License from the City, in
a safe and efficient manner. All employees shall be suitably uniformed.
6. Insurance Requirements. The Operator shall provide evidence of insurance
coverage specified in Section 3.
7. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
8. Permits. The Operator shall have, and shall make available to the City on
request, evidence of all federal, state and local licenses, certificates and permits
that are required.
9. Fuel Revenues and Flowage Fees. The Operator shall pay to the City on a
monthly basis two types of fees: percentage revenue and a fuel flowage fee.
These fees may be based on fuel sale revenues and amounts, and may be
specified in the Operator’s Lease with or Non-Exclusive License from the City.
The Operator also may be required to pay other required fees and payments as
specified in the Operator's Lease with or Non-Exclusive License from the City.
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SECTION 9
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT MANAGEMENT SERVICES
STATEMENT OF CONCEPT
An Aircraft Management Services Operator is a person, firm or corporation engaged in
the business of providing aircraft management including, but not limited to, flight
dispatch, flight crews, or aircraft maintenance coordination to the general public, under a
long-term contract. Management contracts must be in writing and must identify each
managed aircraft by registration number, type and model, and must be for a term of at
least six months. Contracts must be bona fide, exclusive and comprehensive, covering
all aspects of aircraft operation including, without limitation, fees and charges, insurance,
inspection, maintenance and repair during the term of the contract. Management
contracts may be “wet” or “dry,” and with or without crew.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease adequate space and facilities at the Airport to
store park or hangar managed aircraft, to store equipment, to operate its
business, and to accommodate its employee parking requirements. Leased
space must include sufficient work space for any aircraft upon which
maintenance or repairs are being performed by the Operator.
2. Equipment. The Operator must have the use of sufficient and appropriate
equipment to serve the types of aircraft being managed. The Operator must
have computer hardware and accounting software adequate to provide
comprehensive records of all revenues and expenses of aircraft management as
well as required aircraft maintenance.
3. Hours of Operation. The Operator shall have services available as required by its
customers.
4. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
trained and suitably uniformed personnel sufficient to provide services desired by
contract customers.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. Each The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 10
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIR TRANSPORTATION ARRANGER
STATEMENT OF CONCEPT
An Air Transportation Arranger Operator is a person, firm or corporation, whether or not
certificated by the FAA, using the Airport as a base to engaged in the business of
arranging commercial air transportation (persons or property) to the general public for
hire, which commercial air transportation is provided by one or more persons, firms or
corporations engaged in the business of providing commercial air transportation
(persons or property) to the general public for hire under FAR Part 135 or any other
section of the FAR (the “Contracted Carrier”)FAA certificated operators (“the Contracted
Operators”) pursuant to agreement with the Air Transportation Arranger Operator.
MINIMUM STANDARDS
1. Facilities or License.
a. If providing facilities for customer use at the Airport through either an FBO
or a Contracted Carrier Air Charter or Air Taxi Operator operating at the
Airport pursuant to Section 5 of these Minimum Standards, the Operator
shall provide the Airport Director with documentation confirming the
FBO’s or Contracted CarrierAir Charter or Air Taxi Operator’s agreement
to provide such facilities and establishing that the FBO or Contracted
Carrier Air Charter or Air Taxi Operator has complied with all the terms of
its Iease with the Airport and all applicable provisions of these Minimum
Standards, and, upon a determination by the Airport Director that these
requirements have been satisfied, shall enter into a Non-Exclusive
License with the City for provision of services.
b. Otherwise, the Operator shall lease from the City an area of sufficient
size, shape, and location as mutually agreed upon to provide at least
1,000 square feet of floor space for office, restrooms, and customer
lounge for customer use, in accordance with the requirements set forth in
Section 5.1.b of these Minimum Standards.
2. Contracted Carrier Operator Compliance. The Operator shall provide the City
with documentation establishing that each Contracted Carrier Operator operating
at the Airport pursuant to Section 5 of these Minimum Standards satisfies the
requirements set forth in Sections 5.2 through 5.11 of these Minimum Standards
and that any other Contracted Carrier Operators hasve all required FAA
certifications and compliesy with all applicable FAA regulations.
3. Reports. For each flight providing commercial air transportation to persons, the
Operator shall provide the Airport Director, upon request made within 180 days of
the flight, with a written report identifying the Contracted Carrier that provided the
flight and, if that Contracted Carrier is not operating at the Airport pursuant to
Section 5 of these Minimum Standards, stating the type of aircraft, number of
passenger seats, and number of passengers actually carried.
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4. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 and Appendix B
of these Minimum Standards and its Lease with or Non-Exclusive License from
the City.
5. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
6. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
7. Fly Neighborly Program. For any flight provided by a Contracted Carrier that is
not operating at the Airport pursuant to Section 5 of these Minimum Standards,
the Operator shall provide to the pilot of that flight a Pilot’s Guide for the type of
aircraft being flown by that pilot (fixed wing, jet, or helicopter), in the form
attached as Appendix C or such similar form as may be provided by the Airport
Director.
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SECTION 11
SPECIALIZED AERONAUTICAL SERVICES OPERATOR:
AIRCRAFT SALES OPERATOR
STATEMENT OF CONCEPT
An Aircraft Sales Operator is an Operator engaged in the sale of more than three new or
used Aircraft during a 12-month period. This excludes individuals selling personally
owned Aircraft, unless the individual purchased the Aircraft for the primary purpose of
resale.
MINIMUM STANDARDS
1. Facilities. The Operator shall lease adequate space and facilities at the Airport to
store, park or hangar Aircraft to be sold, to store equipment, to operate its
business, and to accommodate its employee parking requirements. Leased
space must include sufficient work space for any aircraft upon which
maintenance or repairs are being performed by the Operator.
2. Equipment, License and Certifications. The Operator shall have sufficient and
appropriate equipment to serve the types of aircraft being stored and sold as
appropriate for its business. If the Operator offers flight demonstration for Aircraft
offered for sale, then the Operator shall also be properly certificated by the FAA,
hold appropriate ratings and medical certifications for providing flight
demonstration, and employ personnel authorized to fly such Aircraft for such
demonstration purposes.
3. Hours of Operation. The Operators shall have services available as required by
its customers.
4. Personnel and Training. In addition to the general personnel and training
requirements in Section 3 of these Minimum Standards, the Operator shall have
trained personnel sufficient to provide services desired by customers.
5. Insurance Requirements. The Operator shall provide evidence of insurance
coverage in the types and with the limits specified by Section 3 of these Minimum
Standards and its Lease with or Non-Exclusive License from the City.
6. Airport Security. The Operator shall comply with all security requirements
specified by Section 3 or otherwise applicable as a matter of law.
7. Required Fees and Payments. The Operator may be required to pay other
required fees and payments as specified in the Operator's Lease with or Non-
Exclusive License from the City.
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SECTION 12
SPECIALIZED AERONAUTICAL SERVICE OPERATOR:
OTHER AERONAUTICAL SERVICES
STATEMENT OF CONCEPT
There may be other types of aeronautical services provided or to be provided at the
Airport that are not covered by the Minimum Standards set forth above and they may not
warrant the establishment of specific Minimum Standards at this time. Any existing
provider of such services must meet the general requirements of Section 3 of these
Minimum Standards.
1. Existing services not covered by specific category minimum standards.
a. Specialized Aeronautical Service Operators not covered by the specific
minimum standards in Sections 4 through 11 must meet all the
requirements of this section and Sections 3 and 14, including the
requirement that they have a Non-Exclusive License to provide services
at the Airport.
b. The City may require that the Operator lease space on the Airport.
c. Operators covered by this provision may be required to pay other
required fees and payments as specified in the Operator’s Lease with or
Non-Exclusive License from the City.
2. Application for new specialized aeronautical service operations. If and when an
applicant proposes to conduct a specialized aeronautical service that is not
currently conducted at the airport and is not covered by any of Sections 4
through 11 of these Standards, the City may adopt applicable Minimum
Standards for such service, taking into consideration the desires of the applicant,
the needs of the City and the need for such service at the Airport. At a minimum,
all aeronautical service providers at the Airport must comply with Section 3,
General Requirements.
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SECTION 13
SPECIAL RULES FOR A SASO CONDUCTING
MULTIPLE AERONAUTICAL SERVICES
STATEMENT OF CONCEPT
This section would apply to any Specialized Aeronautical Services Operator that
engages in any two (2) or more of the specialized aeronautical services for which
Minimum Standards have been developed. The sale of aviation fuels is not included in
this section because only FBOs are permitted to engage in the sale of aviation fuels.
MINIMUM STANDARDS
1. Land. If required by these Minimum Standards, the Operator shall lease, from the
City an area that is equal to the total area required by the sum of the minimum
land areas required under the individual specialized services the Operator is
providing.
2. Hangars and Other Buildings. If required by these Minimum Standards, this
Operator shall lease hangar facilities providing a total square footage that is
equal to the total area required by the sum of the minimum hangar size required
under the individual specialized services the Operator is providing. The hangar
must have a door that meets the largest width and height requirements of the
individualized services the Operator is providing.
3. Aircraft Apron. If required by these Minimum Standards, the Operator shall lease
paved aircraft parking apron that provides a total square footage that is equal to
the total area required by the sum of the minimum apron areas required under
the individual specialized services the Operator is providing.
4. Hours of Operation. The Operator shall maintain the longest hours of operation
required elsewhere in these Minimum Standards for any of the aeronautical
services it provides.
5. Personnel. In addition to the general personnel and training requirements in
Section 3 of these Minimum Standards, the Operator shall have in its employ and
on duty during the appropriate business hours, suitably uniformed, trained
personnel in such numbers as are required to meet these Minimum Standards for
the aeronautical services to be provided. Multiple responsibilities may be
assigned to meet the personnel requirements for each specialized aeronautical
service being performed.
6. Equipment. The Operator shall provide all of the facilities, equipment and
services required to meet the Minimum Standards for each of the aeronautical
services it provides.
7. Insurance. The Operator shall obtain, as a minimum, that insurance coverage
which is equal to the highest single coverage requirement of all the aeronautical
services being performed by the Operator.
8. Required Fees and Payments. The Operator shall pay all fees applicable to each
and every service that it provides at the Airport.
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9. Applicability of Specific Provisions. The provision of multiple types of services by
the Operator shall not exempt the Operator from any of the requirements
otherwise applicable to each of the services provided.
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SECTION 14
RECOGNITION AND REGULATION
OF SELF-SERVICE AND SELF-FUELING RIGHTS
RIGHT TO SELF-SERVICE AND SELF-FUELING
An aircraft owner may perform services, including Self-Fueling, on the owner’s Own
Aircraft utilizing the aircraft owner’s Own Employees and Own Equipment.
In the interests of safety and fairness, a Person desiring to Self-Fuel must hold a current
Non-Commercial Annual Operational Permit from the Santa Monica Fire Department
and be granted Self-Fueling rights by the City in a Lease, Non-Exclusive License, or
Non-Commercial Self-Fueling Permit. Any Person not party to a Lease or Non-Exclusive
License granted by the City may only have permission to Self-Fuel such Person’s
Owned Aircraft if such Person (a) holds a valid and current Non-Commercial Self-
Fueling Permit from the City, and (b) is in and continues to be in compliance with all City,
state and federal requirements applicable to aircraft fuel handling practices.
If an aircraft owner does not exercise the right to Self-Fuel, that owner’s aircraft may be
fueled or otherwise serviced at the Airport only by those Operators authorized to provide
such services at the Airport under a Lease or Non-Exclusive License approved by the
City.
NON-COMMERCIAL SELF-FUELING PERMIT
1. General
A Person desiring to Self-Fuel that Person’s Owned Aircraft, and not holding Self-
Fueling rights under a Lease or Non-Exclusive License, shall have a reasonable
opportunity to qualify for and receive a Non-Commercial Self-Fueling Permit. Each
Person conducting non-commercial Self-Fueling at the Airport shall comply with the
following minimum standards. Any Person desiring to Self-Fuel its Owned Aircraft may
only do so using its Own Employees and its Own Equipment. Third-party employees
and equipment can never be used for Self-Fueling.
Self-service fueling by an aircraft owner or operator at an FBO’s self-service pump is not
Self-Fueling and does not require a Self-Fueling Permit.
2. Permit/Approval
a. No Person shall engage in Self-Fueling activities unless a valid Non-
Commercial Self-Fueling Permit authorizing such activity has been
obtained from the City.
b. The Permit shall not reduce or limit Permittee’s obligations with respect to
these Self-Fueling minimum standards, which shall be incorporated in the
Permit by reference.
c. An applicant for a Permit shall provide evidence that any aircraft to be
fueled by the applicant is an Owned Aircraft. At any time after a Permit is
issued, the Permittee, upon request by the Airport Director or delegee,
shall provide evidence that all aircraft being Self-Fueled are Owned
Aircraft.
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d. The Airport Director will make binding determinations about whether
specific aircraft qualify as Owned Aircraft for purposes of Self-Fueling.
e. A Person seeking to Self-Fuel on the basis of a Long Term Lease for any
aircraft must obtain insurance to cover all of its interest and activities with
respect to the leased aircraft or be a named insured under the policy of
the lessor and must attach true and correct copies of the lease and a
complying certificate of insurance to such Person’s application for a Non-
Commercial Self-Fueling Permit, as updated by such Person before there
are any changes in the aircraft such Person seeks to Self-Fuel.
f. A Person seeking to Self-Fuel aircraft on the basis of a Long Term
Management Contract for any aircraft must obtain insurance to cover all
of its interests and activities with respect to the aircraft or be named as an
insured under the policy of the aircraft owner and must attach true and
correct copies of the management contract and a complying certificate of
insurance to such Person’s application for a Non-Commercial Self-
Fueling Permit, as updated by such Person before there are any changes
in the aircraft such Person seeks to Self-Fuel.
g. A Person seeking to Self-Fuel using facilities or equipment that are under
a Long Term Lease or other written agreement must obtain insurance to
cover all of its interests and activities with respect to the subject of the
agreement or be a named insured under the policy of the equipment
owner and must attach true and correct copies of the agreement and a
complying certificate of insurance to such Person’s application for a Non-
Commercial Self-Fueling Permit as updated by that Person before there
are any changes in the facilities or equipment to be used for Self-Fueling
by such Person.
3. Fuel Storage and Delivery
a. Permittee shall arrange and demonstrate that satisfactory arrangements
have been made for the storage and delivery of fuel in accordance with
this Section 14.
b. Fuel Storage Facilities. A Permittee may be authorized to establish its
own fuel farm only with the advance written approval of the Airport
Director, which approval may be issued by the Airport Director only after
authorization by the City Council,. A Permittee authorized by the City to
install its own fuel tank may lease land and construct or install an above-
ground fuel storage facility at a location approved by the Airport Director
in writing. If a request by the Permittee to use its own fuel farm is
approved by the Airport Director, after obtaining authorization from the
City Council, the following requirements will apply:
i. The Permittee shall lease sufficient land for installation of above-
ground fuel storage tanks to be constructed and operated on the
Permittee’s leased premises in compliance with all applicable
environmental requirements.
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ii. All fuel storage must be above-ground. In no event shall the total
storage capacity be less than 10,000 gallons for Jet Fuel or 2,500
gallons for Avgas.
iii. The fuel storage system must include adequate fuel spill
prevention features and containment capabilities, together with an
approved fuel spill containment and countermeasures control
plan, and shall be improved and upgraded as necessary to meet
all current EPA requirements for spill prevention, containment and
mitigation as they may be revised.
iv. The Permittee shall be required to undertake at its own expense
any environmental testing of its fuel facilities which the City may
reasonably request, on or off the Airport, and to take any remedial
actions determined to be necessary or appropriate as a result of
such testing. The right is reserved to the Airport Director to
disapprove installation of a new fuel farm if the facility would have
an adverse effect on safety or otherwise in the judgment of the
Airport Director not be in the interest of a safe and efficient airport
operation.
v. In no event shall fuel delivery trucks be used for fuel storage on
the Airport. Vehicles used to deliver fuel to the Airport will transfer
fuel to storage tanks or, if approved, directly to the Permittee’s fuel
dispensing trucks, and depart the Airport.
c. Permittee shall be liable and indemnify the City for all leaks, spills, or
other damage that may result through the handling and dispensing of fuel.
d. Fuel delivered shall be clean, bright, pure, and free of microscopic
organisms, water, or other contaminants. Ensuring the quality of the fuel
is the responsibility of Permittee.
4. Fueling Equipment
a. Permittee shall utilize a single mobile dispensing truck that has the
following minimum capacity: (1) for Avgas or jet fuel, 750 gallons; (2) for
MoGas, 80 gallons. for each type of Fuel to be dispensed with a
minimum capacity of 750 gallons. Avgas or MoGas dispensing trucks
shall have a maximum capacity of 1,200 gallons and jet fuel dispensing
trucks shall have a maximum capacity of 3,000 gallons. All Refueling
Vehicles shall be capable of bottom loading, and turbine fuel dispensers
must have single point refueling capability.
b. Each Refueling Vehicle shall be equipped and maintained to comply at all
times with all applicable safety and fire prevention requirements or
standards, as may be amended, including without limitation, those
prescribed by:
i. National Fire Protection Association (NFPA) 407, OSHA
guidelines, the California Fire Code, and Municipal Code
10.04.06.120;
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Page | 39
ii. 14 CFR Part 139, Airport Certification, § 139.321
“Handling/Storing of Hazardous Substances and Materials”; and
iii. applicable FAA Advisory Circulars (AC) including AC 150/5210-
20, Ground Vehicle Operations on Airports”; and AC 150/5210-5D,
"Painting, Marking and Lighting of Vehicles Used On An Airport".
5. Spill Prevention and Containment. Prior to transporting Fuel onto the Airport, the
Permittee shall provide the City with a Spill Prevention Contingency and Control
Plan (SPCC) that meets regulatory requirements for above ground Fuel storage
facilities. An updated copy of such SPCC Plan shall be filed with the City at least
ten (10) business days prior to actual implementation. Such plan shall describe,
in detail, those methods that shall be used by the Permittee to clean up any
potentially hazardous Fuel spills. The plan should include Equipment to be used,
emergency contact personnel and their telephone numbers, and all other details
as to how the Permittee would contain such a spill. This plan should also
describe, in detail, what methods the Permittee intends to use to prevent any
such spill from occurring.
6. Operating procedures. In accordance with all applicable Regulatory Measures
and appropriate industry practices, the Permittee shall develop and maintain
Standard Operating Procedures (SOP) for fueling and shall ensure compliance
with standards set forth in NFPA 407, the California Fire Code, and Municipal
Code 10.04.06.120. The SOP shall include a training plan, fuel quality
assurance procedures, record keeping, and emergency response procedures for
fuel spills and fires. The SOP shall also address the following: (1) bonding and
fire protection, (2) public protection, (3) control of access to fuel dispensing
vehicle storage areas, and (4) marking and labeling of fuel dispensing vehicles.
The SOP shall be submitted to the City not later than ten (10) business days
before the Permittee commences Self-Fueling at the Airport.
7. Licenses, Certifications, and Permits. Permittee shall have, and shall make
available to the City on request, evidence of all federal, state and local licenses,
certificates and permits that are required to conduct Self-Fueling.
8. Reporting
a. Permittee shall report all Fuel delivered to the approved Permittee’s fuel
storage facility, if any, and into Permittee’s Aircraft during each calendar
month and submit a summary report along with appropriate fees and
charges due the City on or before the 10th day of the subsequent month.
b. Permittee shall during the term of the Permit and for three (3) years
thereafter maintain records identifying the total number of aviation Fuel
gallons purchased and delivered. Records (and meters) shall be made
available for audit to the City or representatives of the City. In the case of
a discrepancy, Permittee shall promptly pay, in cash, all additional rates,
fees, and charges due the City, plus annual interest on the unpaid
balance at the lesser of 18% or the maximum rate allowable by law from
the date originally due.
9. Personnel
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Page | 40
a. Only the Permittee’s Own Employees may conduct Self-Fueling
operations on the Permittee’s aircraft. All Employees of the Permittee
conducting Self-Fueling must be properly trained in Aircraft refueling, in
compliance with 14 CFR § 139.321.
b. There must be a minimum of two (2) trained individuals present during
Self-Fueling activities.
10. Limitations on Self-Fueling Rights.
a. A Permittee may not sell or dispense fuels to based or transient aircraft
that are not Owned Aircraft of the Permittee. Any such sale or dispensing
shall be grounds for immediate revocation of the Permit. Revocation
upon first violation will be for a period of one (1) year. Revocation upon a
second violation shall be permanent.
b. Once unleaded Avgas is commercially available and approved for use,
self-fueling using leaded Avgas or MoGas will no longer be permitted.
11. Insurance. Except as otherwise provided for in these Minimum Standards,
Permittee shall maintain, at a minimum, the coverages and policy limits set forth
in Appendix B – Insurance Requirements.
12. Required Fees and Payments. Fuel flowage fees and any other payments to be
made to the City by each Permittee will be set forth in the Permittee's Non-
Commercial Self-Fueling Permit and shall be reasonable and not unjustly
discriminatory.
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APPENDIX A
DEFINITIONS
The following terms shall have the following meanings:
AERONAUTICAL ACTIVITY – Any activity that involves, makes possible, or is required
for the operation of aircraft or that contributes to or is required for the safety of such
operations. Activities within this definition, commonly conducted on airports, include, but
are not limited to, the following: general and corporate aviation, air taxi and charter
operations, scheduled and nonscheduled air carrier operations, pilot training, aircraft
rental and sightseeing, aerial photography, crop dusting, aerial advertising and
surveying, aircraft sales and services, aircraft storage, sale of aviation petroleum
products, repair and maintenance of aircraft, sale of aircraft parts, parachute or ultralight
activities, and any other activities that, because of their direct relationship to the
operation of aircraft, can appropriately be regarded as aeronautical activities.
AIRPORT – Santa Monica Airport (SMO).
AIRPORT DIRECTOR – the Airport Director of the Santa Monica Airport or the duly
authorized representative of the Airport Director.
AIRPORT USER – a person who operates an aircraft at the Airport.
AIR OPERATIONS AREA or AOA – that portion of the Airport used or intended to be
used for landing, take off or surface maneuvering of aircraft including the hangar and
cargo areas and aircraft parking aprons.
AIRPORT LEASING POLICY -- Santa Monica City Council Airport Leasing and
Licensing Policy (“Airport Leasing Policy”).
APRON or RAMP – those areas of the Airport within the AOA designated for the
loading, unloading, servicing, or parking of aircraft.
CITY – the City of Santa Monica, California. The City may delegate its powers to the
Airport Director or such other City staff member as the City may choose.
COMMERCIAL – conducted with the intent or purpose of generating or securing
earnings, income, compensation or profit, whether or not such objectives are
accomplished.
CONSENT DECREE – the Consent Decree between the City and the United States in
the U.S. District Court, City of Santa Monica v. United States, Dkt. No. 2:13-cv-08046
(C.D. Cal. 2017), dated January 31, 2017.
FAA – Federal Aviation Administration, or any successor agency.
FIXED BASE OPERATOR (FBO) – an operator that furnishes a full range of
aeronautical activities and services to the public, including fueling and line services to
General Aviation aircraft.
FUELING OPERATIONS – the receipt, storage, handling, movement, delivery and
dispensing of fuel for aircraft at the Airport, including the installation, use and
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maintenance of fueling equipment, and the operations and supervision of all personnel
engaged in fueling activities.
GENERAL AVIATION – all aviation operating under FAR Part 91 (with the exception of
government aircraft operations) and FAR Part 135 operations to the extent permitted in
these Minimum Standards.
INDIVIDUAL – An Operator’s agent, employee, supplier, contractor, tenant, invitee or
other party that has been granted access to the Operator’s premises.
LEASE – an agreement with the City for the exclusive use of designated airport land
and/or facilities.
LONG TERM LEASE – a written lease for one or more aircraft, with adequate
consideration, for a term of at least six months and terminable within six months only for
cause which provides that the primary care, custody and control of the aircraft is in the
Person applying to conduct Self-Fueling Operations and contains substantially all terms
and conditions standard in the industry for that type of lease.
LONG TERM MANAGEMENT CONTRACT – a written management contract for
specified aircraft, with adequate consideration, for a term of at least six months and
terminable within six months only for cause which provides that the primary care,
custody and control of the aircraft is in the Person applying to conduct Self-Fueling
Operations and contains substantially all terms and conditions standard in the industry
for that type of contract. The management contract must provide that the Person
applying to conduct Self-Fueling Operations is responsible for all maintenance, all pilot
service, and all scheduling of the aircraft that are subject to the managements contract.
MUNICIPAL CODE – the City of Santa Monica Municipal Code.
NON-COMMERCIAL SELF-FUELING PERMIT – a written document issued by the City
authorizing Self-Fueling at the Airport.
NON-EXCLUSIVE LICENSE – an agreement with the City granting permission for the
conduct of specified commercial aeronautical services on the Airport, but not granting an
exclusive right to provide those services or the exclusive use of any Airport property or
facilities.
OPERATOR – a person or persons, firm, company, joint venture, partnership or
corporation using the Airport as a base for providing any Ccommercial Aaeronautical
Activity service at the Airport.
OWNED AIRCRAFT – for FAA Part 91121 or Part 135 operators, aircraft listed on that
operator’s then-current Part 91121 or Part 135 Certificate and for all other operators:
aircraft used exclusively by that Person and titled and registered with the FAA in that
Person’s own name; aircraft used by that Person as lessee under a Long Term Lease,
or aircraft used by that Person under a Long Term Management Contract.
OWN EMPLOYEES – employees of the Person applying to conduct Self-Fueling
Operations for whom all state and federal employment taxes are paid by that Person.
OWN EQUIPMENT – facilities or equipment that is used exclusively by and titled in the
name of the Person applying to conduct Self-Fueling Operations or is used by that
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Person subject to a Long Term Lease or written purchase, financing or use agreement
for such facilities or equipment, with adequate consideration, for a term of at least six
months and terminable within six months only for cause which provides that the primary
care, custody and control of the facilities or equipment is in the Person applying to
conduct Self-Fueling Operations and contains substantially all terms and conditions
standard in the industry for that type of agreement.
PERMITTEE – a Person who has been issued and holds a valid and current Non-
Commercial Self-Fueling Permit.
PERSON – an Individual, firm, company, joint venture, partnership or corporation.
REPAIR STATION – a facility utilized for the repair of aircraft approved and certificated
by the FAA under 14 CFR Part 145. Activities may include repair and maintenance of
airframes, power plants, propellers, radios, instruments and accessories.
SELF-FUELING – a Person’s conduct of Fueling Operations for that Person’s Own
Aircraft, using that Person’s Own Equipment and conducted by that Person or the
Person’s Own Employees. Self-fueling may be permitted by a Lease or Non-Exclusive
License authorizing commercial services or by a Non-Commercial Self-Fueling Permit.
SPECIALIZED AERONAUTICAL SERVICES OPERATOR (SASO) – an Operator that
is authorized to engage in one or more of the following specialized aeronautical support
services:
a. Aircraft Charter and Air Taxi
b. Flight Training
c. Aircraft Maintenance and Repair Stations
d. Self-Service Fuel Pumps
e. Aircraft Management
f. Air Transportation Arranger
g. Aircraft Sales Operator
h. Other Aeronautical Services
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APPENDIX B
INSURANCE REQUIREMENTS AND STANDARDS
The City has established the following minimum insurance requirements and standards
for Operators providing of commercial aeronautical services at the Santa Monica
Municipal Airport:
A. The Operator shall procure and maintain at its own expense for the duration of the
Operator’s activities and/or use of leased premises at the Airport insurance as set
out in the Minimum Insurance Requirements Matrix (Appendix B-1) against claims
for injuries to persons or damages to property that may arise from or in connection
with activities and/or the use of leased premises at the Airport by the Operator, its
agents, representatives, employees or subcontractors.
B. If the Operator maintains broader coverage or higher limits than the minimums
required in Appendix B-1, the City of Santa Monica requires and shall be entitled
to any broader coverage and higher limits maintained by the Operator. Any
available insurance proceeds in excess of the specified minimum limits of
insurance and coverage shall be available to the City of Santa Monica.
C. The insurance policies are to contain, or be endorsed to contain, the following
provisions:
i. Additional Insured Status: The City of Santa Monica, its officers, officials,
employees and volunteers are to be covered as additional insureds on the
CGL policy with respect to liability arising out of the use, occupancy,
operations or maintenance of leased premises, including work or
operations performed on behalf of the Operator.
ii. Primary Coverage: For any claims related to Operator’s activities and/or
use of leased premises at the Airport, the Operator’s insurance shall be
primary coverage at least as broad as Insurance Services Offices Form CG
20 01 04 13 as respects the City of Santa Monica, its officers, officials,
employees and volunteers. Any insurance or self-insurance maintained by
the City of Santa Monica, its officers, officials, employees or volunteers
shall be in excess of the Operator’s insurance and shall not contribute with
it.
iii. Notice of Cancellation: Each insurance policy required herein shall state
that coverage shall not be cancelled except after notice has been given to
the City of Santa Monica.
iv. Waiver of Subrogation: Operator hereby grants to the City of Santa
Monica a waiver of any right of subrogation which any insurer of said
Operator may acquire against the City of Santa Monica by virtue o f
payment of any loss. Operator agrees to obtain any endorsement that may
be necessary to affect this waiver of subrogation, but this provision applies
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regardless of whether or not the City of Santa Monica has received a waiver
of subrogation endorsement from the insurer.
v. Claims Made Policies: If the pollution liability policy provides “claims
made” coverage: the Retroactive Date must be shown and must be before
the commencement of the Operator’s lease; the insurance must be
maintained and evidence of insurance must be provided for at least 3 years
after the expiration of the Operator’s lease; and if the policy is cancelled or
not renewed, and not replaced with another “claims made” policy form with
a Retroactive Date prior to the effective date of the lease, the Operator
must purchase “extended reporting” coverage for a minimum of 3 years
after lease expiration.
vi. Indemnification and Hold Harmless. Operator shall defend, indemnify,
save, protect, and hold harmless the City of Santa Monica, the Santa
Monica Airport, the Santa Monica Airport Commission, and the Santa
Monica City Council, individually and collectively, and their representatives,
officers, officials, employees, agents, and volunteers from any and all
claims, demands, damages, fines, obligations, suits, judgments, penalties,
causes of action, losses, liabilities, administrative proceedings, arbitration,
or costs at any time received, incurred, or accrued by the City of Santa
Monica, the Santa Monica Airport, the Santa Monica Airport Commission,
and the Santa Monica City Council, individually and collectively, and their
representatives, officers, officials, employees, agents, and volunteers as a
result of, or arising out of Operator's activities, actions, or inactions. In the
event a party indemnified hereunder is in part responsible for the loss, the
indemnitor shall not be relieved of the obligation to indemnify; however, in
such a case, liability shall be shared in accordance with California
principles of comparative fault.
Operator shall accept total responsibility, defend, indemnify, save, protect,
and hold harmless the City of Santa Monica, the Santa Monica Airport, the
Santa Monica Airport Commission, and the Santa Monica City Council,
individually and collectively, and their representatives, officers, officials,
employees, agents, and volunteers in the event of an environmental
contaminating accident or incident caused by Operator, its employees, its
vendors or any other personnel used by the Operator to maintain
Operator's improvements, vehicles, equipment, or aircraft.
Nothing herein shall constitute a waiver of any protection available to the
City and the City Council, individually and collectively, and its
representatives, officers, officials, employees, agents and volunteers under
the State of California’s governmental immunity act or any similar doctrine
or statutory provision.
D. All insurance shall be placed with insurers authorized to conduct business in
California with a current A.M. Best rating of no less than A:VII, unless otherwise
acceptable to the City of Santa Monica.
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E. Operator shall furnish the City of Santa Monica with original certificates and
amendatory endorsements (or copies of the applicable policy language effecting
coverage provided by this clause). All certificates and endorsements are to be
received and approved by the City of Santa Monica before the lease commences.
However, failure to obtain required documents prior to the work beginning shall not
waive the Operator’s obligation to provide them. The City of Santa Monica
reserves the right to require complete, certified copies of all required insurance
policies, including the endorsements required herein, at any time.
AP
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7‐20‐2018 Draft
Redline to 6‐5‐2018 Airport Commission Meeting Draft
APPENDIX C
FLY NEIGHBORLY PROGRAM NOTIFICATIONS
¹
Santa Monica Airport
VFR Pilot’s Guide Address: Santa Monica Municipal Airport
3223 Donald Douglas Loop South
Santa Monica, CA 90405
Phone: 310.458.8591
Noise: 310.458.8692
Noise Email: noise@smgov.net
Fax: 310.572.4495
Email: airport@smgov.net
Web: www.santamonicaairport.org
SMO Fly Neighborly, Fly Quietly
FIXED-WING PROPELLER AIRCRAFT
Contact Us
Photography courtesy of Chad Slattery.
Golf Course
Noise
Managment
Office
Airport
Administration
Building
Air Traffic
Control Tower
21
3
Runway
Runway
SMO
AIRPORT DIAGRAM
SMO VOR 110.8
Transient
Parking
FBO
Self-Serve Fuel
www.santamonicaairport.org | 310.458.8591
Santa Monica Airport (SMO)
Fly Neighborly Program
Welcome to the neighborhood and the Santa Monica
Municipal Airport, one of the busiest single–runway general
aviation airports in the nation. We hope you will enjoy your
time with us. This brochure introduces you to the Santa
Monica Airport’s Fly Neighborly Program and will help you
operate your aircraft in the least impactful manner possible
while providing a safe environment.
The Airport is in the heart of a neighborhood surrounded
by over 130,000 residents. The City of Santa Monica is
proactively committed to its extensive noise mitigation
program, which includes a maximum allowable noise level,
limited aircraft operations hours, and requested VFR noise
mitigation fl ight paths and procedures. This brochure is
designed to assist you with compliance of these procedures;
helping you be a good neighbor.
The City and Airport staff recognize that pilots truly are the
key to a successful noise mitigation program. We greatly
appreciate your help and cooperation in making the Airport
a good neighbor.
DISCLAIMER: The procedures described in this brochure are not intended to
preempt the prerogatives or responsibilities of the pilot-in-command, confl ict with
safe aircraft operations, or interfere with ATC instructions or any domain that is the
exclusive authority of the FAA.
Not to Scale
Arrival
Departure
Pattern Flight
Santa
Monica
Pier
No right turns
prior to shoreline
Venic
e
B
l
v
d
No left turns
prior to
Lincoln Blvd
Not For Navigational Use
Marina del Rey
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o
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s
e
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r
s
e
Mandatory Restrictions
The following procedures and limitations are enforced per the
City’s Aircraft Noise Ordinance. Violations may result in the
imposition of fi nes and/or exclusion from Santa Monica Airport.
Maximum Noise Level: 95.0 dBA Single Event Noise
Exposure Level (SENEL) as measured 2,200’ from
either ends of the runway.
Intersection departures are prohibited.
Formation takeoffs and landings are prohibited.
Touch and go, stop and go and low approaches are
prohibited weekends, holidays, and weekdays one half
hour after sunset until 7am the following day.
Prior Permission Required from the Airport Director
for dual wheel aircraft in excess of 60,000 lbs. MCLW
Call (310) 458-8591.
Mandatory Night Departure Curfew
No takeoffs or engine starts, including Auxiliary Power Units
(APU) between 11pm and 7am Monday through Friday or
until 8am on weekends. Exceptions are allowed for bona fi de
medical or public safety emergencies only. Contact Airport
Administration.
Voluntary Night Arrival Curfew
11pm and 7am Monday through Friday or until 8am on weekends.
Pilots are requested to avoid operations during this time period
due to the negative noise impact on the community.
Note: Compliance with the Airport Ordinance is mandatory
unless deviations are made necessary by weather, ATC
instructions or clearances, infl ight emergency or other safety
considerations.
Fixed-Wing Propeller Aircraft Procedures
Frequencies
CTAF 120.1 MHz
ATIS 119.15 MHz or (310) 450-4620
Tower 120.1 MHz (0700 to 2100 local)
Ground Control 121.9 MHz (0700 to 2100 local)
Unicom 122.95 MHz (after hours)
VOT 113.9MHz
SMO VORTAC 110.8 MHz
Traffi c Pattern
Left Traffi c Runway 21
Right Traffi c Runway 03
Pattern Altitude 1,370 feet MSL Single-Engine
1,870 feet MSL Multi-Engine
Instrument Approach Procedure
VOR Runway 21
RNAV (GPS) Runways 03 & 21
Airfi eld Information
Field Elevation 170 feet MSL
Runway 21 170 feet MSL
Runway 03 126 feet MSL
Runway Length/Width 3,500 feet X 150 feet (ASPH)
Runway Slope 1.2% down SW
Runway Lighting MIRLs, PAPI R03, REIL & PAPI R21
Maximum Weight 60,000 lbs. Maximum Certifi ed
Landing Weight (dual wheel)
Fixed Based Operator
Atlantic Aviation
2828 Donald Douglas Loop North, Santa Monica, CA 90405
Phone: 310-396-6770 Frequency: 122.95 MHz
Fuel – JetA, 100LL
Aeroplex
Self-serve Fuel Station
Fuel: 100LL
Located Southwest of the fi eld
VFR Departures
Westerly Flow: Runway 21
Standard traffi c pattern is left. Please over-fl y the Penmar Golf
Course west of SMO. This procedure requires an initial 10° left
turn over the VOR and then a right turn to overfl y the length of
the golf course. Please do not initiate the left 10° turn prior to
the VOR (See map).
Special Flight Rules Area: Runway 21
Right climbing 270° turn at shoreline to head southeast along
SMO 132° radial at 3,500 feet MSL (see map.)
Mini Route
Remain outside class B airspace until receiving clearance from
LAX tower. SMO tower will coordinate transitions through the
Mini Route. Crossing altitude 2500’
Easterly Flow: Runway 03
Standard traffi c pattern is right. Turn crosswind over 405 FWY.
Special Flight Rules Area: Runway 03
Left climbing 270° turn to fl y southeast along the SMO 132°
radial at 3,500 feet MSL. No crosswind turns prior to the
405 FWY.
VFR Arrivals
Runways 03/21
Maintain pattern altitude or above as long as practical.
Special Flight Rules Area Arrivals
Contact SMO Tower for north crossing midfi eld to enter right
traffi c (see map.)
Noise Mitigation Policies
Fly Neighborly, Fly Quietly
(SFRA) RUNWAY 21
Santa
Monica
Pier
No right turns
prior to shoreline
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e
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l
v
d
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l
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o
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e
SMO VOR 110.8
Air to Air Freq. 128.55
225° c
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r
s
e
Fixed Wing VFR Operations Only Santa Monica Airport Information
Procedures for Special Flight Rules Area
Santa Monica Airport
Pilot’s Guide
HELICOPTERS
Address: Santa Monica Municipal Airport
3223 Donald Douglas Loop South
Santa Monica, CA 90405
Phone: 310.458.8591
Noise: 310.458.8692
Fax: 310.572.4495
Email: airport@smgov.net
Web: www.santamonicaairport.org
Frequencies
CTAF 120.1 MHz
ATIS 119.15 MHz or (310) 450-4620
Tower 120.1 MHz (0700 to 2100 local)
Ground Control 121.9 MHz (0700 to 2100 local)
Unicom 122.95 MHz (after hours)
VOT 113.9MHz
SMO VORTAC 110.8 MHz
Tr a f fi c Pattern
Left Traffi c Runway 21
Right Traffi c Runway 03
Pattern Altitude 1,370 feet MSL Single-Engine
1,870 feet MSL Multi-Engine
Instrument Approach Procedure
VOR or GPS-A Runway 21
Airfi eld Information
Field Elevation 170 feet MSL
Runway 21 170 feet MSL
Runway 03 126 feet MSL
Runway Length/Width 3,500 Feet X 150 Feet (ASPH)
Runway Slope 1.2% down SW
Runway Lighting MIRLs, PAPI R03, REIL & PAPI R21
Maximum Weight 60,000 lbs. Maximum Certifi ed
Landing Weight (dual wheel)
Photography courtesy of Chad Slattery.SMO Fly Neighborly, Fly Quietly www.santamonicaairport.org | 310.458.8591
BUSINESS
PARK
Golf Course
Noise
Managment
Office
Airport
Administration
Building
Air Traffic
Control Tower
21
3
Runway
Runway SMO VOR 110.8
Helipad
Parking Restricted
2 hours only
Atlantic Aviation
122.95MHz
Helicopter
Landing Location
NOISE SENSITIVE
HELICOPTER
LANDING LOCATIONS
East Overflow
Ramp
FBO
SMO Fly Neighborly ProgramContact Us
Fly Neighborly Program
Welcome to the neighborhood and the Santa Monica
Municipal Airport, one of the busiest single–runway general
aviation airports in the nation. We hope you will enjoy your
time with us. This brochure introduces you to the Santa
Monica Airport’s Fly Neighborly Program and will help you
operate your aircraft in the least impactful manner possible
while providing a safe environment.
The Airport is in the heart of a neighborhood surrounded
by over 130,000 residents. The City of Santa Monica is
proactively committed to its extensive noise mitigation
program, which includes a maximum allowable noise level,
limited aircraft operations hours, and requested VFR noise
mitigation fl ight paths and procedures. This brochure is
designed to assist you with compliance of these procedures;
helping you be a good neighbor.
The City and Airport staff recognize that pilots truly are the
key to a successful noise mitigation program. We greatly
appreciate your help and cooperation in making the Airport
a good neighbor.
DISCLAIMER: The procedures described in this brochure are not intended to
preempt the prerogatives or responsibilities of the pilot-in-command, confl ict with
safe aircraft operations, or interfere with ATC instructions or any domain that is the
exclusive authority of the FAA.
Not to Scale
Mandatory Restrictions
The following procedures and limitations are enforced per the
City’s Aircraft Noise Ordinance. Violations may result in the
imposition of fi nes and/or exclusion from Santa Monica Airport.
Maximum Noise Level: 95.0 dBA Single Event Noise
Exposure Level (SENEL) as measured 2,200’ from
either ends of the runway.
Formation takeoffs and landings are prohibited.
Formation fl ying within Class D airspace is highly
discouraged unless necessary for an emergency.
Helicopter fl ight training is prohibited.
Mandatory Night Departure Curfew
No takeoffs or engine starts including Auxiliary Power Units (APU)
between 11pm and 7am Monday through Friday or until 8am on
weekends. Exceptions are allowed for bona fi de medical or public
safety emergencies only. Contact Airport Administration.
Voluntary Night Arrival Curfew
11pm and 7am Monday through Friday or until 8am on weekends.
Pilots are requested to avoid operations during this time period
due to the negative noise impact on the community.
Note: Compliance with the Airport Ordinance is mandatory unless deviations
are made necessary by weather, ATC instructions or clearances, infl ight
emergency or other safety considerations.
Helicopter Procedures
These helicopter procedures are derived from a Letter of
Agreement between the City of Santa Monica and the FAA.
Helicopter Departures RWY 21
Depart via runway and offset left at the VOR to over-fl y the
length of the Penmar Golf Course. Please make all turns at
shoreline (see map).
Helicopter Departures RWY 03
Depart via runway and proceed straight out to 405 FWY before
executing left or right crosswind
VFR Helicopter Arrivals
Enter midfi eld 90 degrees to the runway at or above 900
feet MSL and execute descending turn to runway. Whenever
possible, do not commence descent until established over the
Airport or Business Park located north of the runway.
Public Use Helipad Parking (Restricted to 2 hours)
The Helipad is located on the south side of runway 03/21.
When landing on the helipad, avoid fl ying over the Airport
Observation Deck at the Airport Administration Building and
stationary or taxiing aircraft to minimize rotor wash. Remain
clear of the runway at all times unless approved by the ATC.
Contact Atlantic Aviation for overnight or long term parking.
(310) 396 6770
Noise Mitigation Policies
Fly Neighborly, Fly Quietly
Fixed Based Operators Providing Transient Services
Atlantic Aviation
2828 Donald Douglas Loop North, Santa Monica, CA 90405
Phone: 310-396-6770 Frequency: 122.95 MHz
Fuel – JetA, 100LL
Aeroplex
Self-serve Fuel Station
Fuel: 100LL
Located Southwest side of the fi eld
IMAGE CUT OFF
Arrival
Departure Runway 21
Departure Runway 3
Map Key
21
3
BUSINESS
PARK
For Noise Mitigation purposes,
cross the Airport boundary
at or above 900’ MSL
No Right Turns Prior to Shoreline
Santa
Monica
Pier
Li
n
c
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B
l
v
d
L
i
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c
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B
l
v
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Venic
e
B
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SMO VOR
110.8
Marina del Rey
Golf C
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s
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Helicopter Operations (Not for Navigational Use)
JET AIRCRAFT
Santa Monica Airport
Pilot’s Guide
Address: Santa Monica Municipal Airport
3223 Donald Douglas Loop South
Santa Monica, CA 90405
Phone: 310.458.8591
Noise: 310.458.8692
Noise Email: noise@smgov.net
Fax: 310.572.4495
Email: airport@smgov.net
Web: www.santamonicaairport.org
SMO Fly Neighborly, Fly Quietly www.santamonicaairport.org | 310.458.8591
Golf Course
Noise
Managment
Office
Airport
Administration
Building
Air Traffic
Control Tower
21
3
Runway
Runway SMO VOR 110.8
FBO
JET AIRCRAFT
AIRPORT DIAGRAM
ATTENTION: Turbine aircraft prohibited from parking
in the transient parking area in the vicinity of the
Airport Administration Building.
Contact the Airport Office for further information.
Atlantic Aviation
122.95MHz
Santa Monica Airport (SMO)
Fly Neighborly Program
Welcome to the neighborhood and the Santa Monica
Municipal Airport, one of the busiest single–runway general
aviation airports in the nation. We hope you will enjoy your
time with us. This brochure introduces you to the Santa
Monica Airport’s Fly Neighborly Program and will help you
operate your aircraft in the least impactful manner possible
while providing a safe environment.
The Airport is in the heart of a neighborhood surrounded
by over 130,000 residents. The City of Santa Monica is
proactively committed to its extensive noise mitigation
program, which includes a maximum allowable noise level,
limited aircraft operations hours, and requested VFR noise
mitigation fl ight paths and procedures. This brochure is
designed to assist you with compliance of these procedures;
helping you be a good neighbor.
The City and Airport staff recognize that pilots truly are the
key to a successful noise mitigation program. We greatly
appreciate your help and cooperation in making the Airport
a good neighbor.
DISCLAIMER: The procedures described in this brochure are not intended to
preempt the prerogatives or responsibilities of the pilot-in-command, confl ict with
safe aircraft operations, or interfere with ATC instructions or any domain that is the
exclusive authority of the FAA.
Photography courtesy of Cessna Aircraft Company.
Not to Scale
Contact Us
The following aircraft have been shown to be unable to
meet the maximum noise level of 95.0 dBA SENEL and are
permanently excluded from operating at Santa Monica Airport
after one violation and subject to misdemeanor prosecution:
Piaggio Aero P.180 Avanti (I&II), Aero Delfi no l-29, BAC Jet
Provost, North American B-17, B-25, Casa Saeta, De Havilland
Vampire, Venom, Sea Vixen, Douglas DC-9, A-4 Skyhawk,
English Electric Lightening, Folland, Gnat, Fouga CM 170
Magister, Gates Learjet 23, 24B, 24BA, 25, 25B, 25D, 25F, 28;
Gloster Meteor, Grumman F9F Panther/Couger, Gulfstream II,
IIB, III; Hansa HFB 320, Hawker Hunter, Jet Commander 1121,
IAI Westwind 1123, HS125-1A, 3A; Lockheed T-33/Canadian
Silver Star, Lockheed F-1-4 Starfi ghter, Lockheed 1329 Jetstar,
VC-121A Constellation; Morane-Saulnier Paris II, Mikoyan
Gurevich MIG 15, MIG 17, MIG 19, MIG 21; North American
F86/Canadair CL-13 Abre, North American Rockwell Sabreliner
39,40A, 60, 60A, 70, 75, 80. This list may be updated. Please
contact the Noise Management Offi ce for current aircraft list.
IFR Engine Start Procedures
Contact Ground Control on 121.9 MHz for IFR clearances.
Contact Ground Control one minute prior to actual engine
start. Do not start engines prior to advising ATC.
Auxiliary Power Unit (APU) Limitations
Limit APU usage to thirty (30) minutes.
Reverse Thrust Use
Use minimum reverse thrust necessary for safety.
Turbine Aircraft Parking Restrictions
Turbine aircraft prohibited from parking in the transient parking
area in the vicinity of the Airport Administration Building.
Contact the Airport Offi ce for further information.
Jet Aircraft Procedures
Mandatory Restrictions
The following procedures and limitations are enforced per the
City’s Aircraft Noise Ordinance. Violations may result in the
imposition of fi nes and/or exclusion from Santa Monica Airport.
Maximum Noise Level: 95.0 dBA Single Event Noise
Exposure Level (SENEL) as measured 2,200’ from either
ends of the runway.
Intersection departures are prohibited.
Formation takeoffs and landings are prohibited.
Prior Permission Required from the Airport Director
for dual wheel aircraft in excess of 60,000 lbs. MCLW
Call (310) 458-8591.
Mandatory Night Departure Curfew
No takeoffs or engine starts including Auxiliary Power Units (APU)
between 11pm and 7am Monday through Friday or until 8am on
weekends. Exceptions are allowed for bona fi de medical or public
safety emergencies only. Contact Airport Administration.
Voluntary Night Arrival Curfew
11pm and 7am Monday through Friday or until 8am on weekends.
Pilots are requested to avoid operations during this time period
due to the negative noise impact on the community.
Note: Compliance with the Airport Ordinance is mandatory unless deviations
are made necessary by weather, ATC instructions or clearances, infl ight
emergency or other safety considerations.
Santa Monica Airport Information
Frequencies
ATIS 119.15 MHz or (310) 450-4620
Tower 120.1 MHz (0700 to 2100 local)
Ground Control 121.9 MHz (0700 to 2100 local)
Unicom 122.95 MHz (after hours)
VOT 113.9MHz
SMO VORTAC 110.8 MHz
Traffi c Pattern
Left Traffi c Runway 21
Right Traffi c Runway 03
Pattern Altitude 1,370 feet MSL Single-Engine
1,870 feet MSL Multi-Engine
Instrument Approach Procedure
VOR or GPS-A Runway 21
RNAV (GPS) Runway 03 & 21
Airfi eld Information
Field Elevation 170 feet MSL
Runway 21 170 feet MSL
Runway 03 126 feet MSL
Runway Length/Width 3,500 feet X 150 feet (ASPH)
Runway Slope 1.2% down SW
Runway Lighting MIRLs, PAPI R03, REIL & PAPI R21
Maximum Weight 60,000 lbs. Maximum Certifi ed
Landing Weight (dual wheel)
Fixed Based Operators Providing Transient Services
Atlantic Aviation
2828 Donald Douglas Loop North, Santa Monica, CA 90405
Phone: 310-396-6770 Frequency: 122.95 MHz
Fuel – JetA, 100LL
Aeroplex
Self-serve Fuel Station
Fuel - 100LL
Located Southwest of the fi eld
Noise Monitor LocationsNoise Mitigation Policies
Warning—Listed Aircraft
Fly Neighborly, Fly Quietly Ph
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SANTA MONICA CITY COUNCIL AIRPORT LEASING AND LICENSING POLICY
Purpose. The purpose of this Airport Leasing and Licensing policy is to establish
and declare City policy on matters related to airport leasing. This Leasing Policy
shall be used by the City Manager to analyze leasing and licensing issues, to
present leasing and licensing recommendations to the City Council, and to
render leasing and licensing decisions under the authority granted by the City
Council.
By adopting the Airport Lease Policy, the City Council seeks, to the extent
consistent with the Consent Decree signed by the City of Santa Monica and
the U.S. Justice Department on behalf of the Federal Aviation
Administration, to have an airport tenant mix that:
Is harmonious with the nearby built environment by protecting the health
and safety of Airport neighbors.
Maintains a sustainable Airport Fund that is independent from the General
Fund and other subsidies.
Comports with any applicable legal requirements and protects the City’s
rights that relate to leases at the Airport.
Continues to provide opportunities for arts, education, and culture,
including, but not limited to, the Artist Space Program administered in
conjunction with Cultural Affairs Division.
Establishes practices and procedures for evaluating potential leasehold
interests, and for lease management and administration.
Fosters uses and practices that are sensitive to the environment and
protect the health of Airport neighbors and users and protect the City from
future environmental damage exposure.
General Provisions. The majority of the Airport revenue is derived from
leases. To help support the Airport’s fiscal self‐sufficiency, all rents, fees, and
charges must reflect fair market value. To achieve the goals of the Leasing
Policy, the policy shall be managed in a manner consistent with the following
standards:
SECTION A: USES
1. Authorized Uses: Authorized uses include: (a) uses required by the Consent
Decree; and (b) low intensity uses that are compatible with surrounding uses,
serve the adjacent community, and are consistent with the City's
environmental goals and policies. Examples of uses in category (ab) include,
but are not limited to: parks and open space, arts/cultural, creative space,
professional theaters, museums, artist studios, art galleries, photograph
studios, uses customary or incidental to the production or distribution of
motion pictures, educational facilities, professional and general offices,
public or private schools existing prior to September of 1984, warehouses,
self‐storage/public mini‐warehouses, and restaurants with 500 square feet of
floor area or less; and b) uses required by the Consent Decree signed by the
City of Santa Monica and the U.S. Justice Department on behalf of the
Federal Aviation Administration.
2. Conditionally permitted uses: Parking and automobile storage lots and
structures. Restaurants with over 500 square feet of floor area. Theaters.
New public or private schools or educational institutions.
3. Prohibited Uses: Prohibited uses include: any use involving the
manufacture, processing, storage, or treatment of products, which by
nature of the operation is likely to be obnoxious or offensive to the
surrounding environment; construction of new general office buildings; any
use not specifically authorized as a permitted or conditionally permitted
use; and high intensity uses that are incompatible with the surrounding
residential uses.
SECTION B: TERMS AND CONDITIONS
1. Term for Hangars. All hangars shall be leased on a month‐to‐month basis.
2. Term for Tie‐Downs. All tie‐downs shall be leased on a month‐to‐
month basis.
3. Term for Aeronautical Service Providers. Consistent with the terms
of As stipulated by the Consent Decree, aeronautical service providers
may be offered up to three‐year lease terms that comport with this
Leasing Policy and the Minimum Standards for Commercial
Aeronautical Services at Santa Monica Municipal Airport (the
“Minimum Standards”), so long as the expiration date of the lease
does not extend beyond December 31, 2028. And, are required to
meet the Airport’s Minimum Standards for Aeronautical Service
Providers.
4. Term for Non‐Aviation Tenants. Lease terms may be month‐to‐month or
longer. However, no lease shall have a term that goes beyond December
31, 2028.
5. Environmental Responsibility. New requests to lease and existing leases
shall be reviewed to assess potential negative effects on the
environment. The City may require environmental studies or testing as
appropriate and necessary, and any needed remediation shall be
performed prior to establishment of new uses. All lessees shall be
responsible for any environmental contamination, resulting from their
prior use, as a condition to a renewed or extended lease. Environmental
clean‐up will be required as a condition of any renewal or extension. At
the time of the application, an assessment of the proposed use will be
conducted, and appropriate insurance and/or remediation requirements
will be incorporated into the lease based on proposed usage.
6. Rates. All new and renewed leases will be leased at prevailing market
rates and rates will be adjusted to stay current with market conditions
and as new/renewed leases arise.
7. Percentage Rent Provision. In addition to a base rent, the City may elect
to require that certain leases include a percentage rent provision, which
can be differentiated by categories of sales. The City shall have the right
to audit tenant's financial records to ascertain that the gross sales figures
reported by the tenant are accurate.
8. Existing Tenants. All existing airport tenants will be given the opportunity
to submit a lease application to the City. The City is under no obligation
to offer lease agreements. Submitting an application to the City does not
obligate the City to enter into lease negotiations, offer a lease
agreement, or execute a lease agreement. The decision to execute a
lease agreement will be made solely within the City’s discretion as
landlord and property owner.
9. Whole Building Leases. Whole building leases may, at the City’s
discretion, be subject to public Requests for Proposals intended to
optimize leasehold occupancy and the self‐sustainability of the airport.
Tenants under a whole building lease shall be responsible for
maintenance and repair of said buildings.
10. Transfer of Interest. Space sharing is prohibited without the written
consent of the City, and granting or withholding consent will be
conditioned on express standards and conditions set forth in the lease.
11. Lease and License Areas. Operation and improvements to lease and
license areas are subject to the City’s standard regulatory rules, review
and approval process.
12. Triple Net Leases. The City may require tenants to pay all property taxes
and assessments (including Possessory Interest Tax), insurance, and
utilities.
13. Commercial Operations Permit (COP). Prospective tenants proposing to
use the Santa Monica Airport to engage in an activity that requires a
business license from the City, are required to acquire a commercial
operations permit issued by the City Manager. All COPs will be presented
to the Airport Commission for their recommendation and comment prior
to City Manager’s approval.
14. Master Tenants. Master tenant agreements are to be phased out in an
orderly transition.
15. Sub‐Leasing. New sub‐leasing shall be prohibited. Existing sub‐tenancies
shall be subject to an orderly phase‐out at the sole discretion of the City.
16. Insurance. Airport lease agreements shall minimize the City’s financial
and economic risk, by incorporating reasonable indemnification and
insurance provisions.
17. Daily and Transient Users. Daily and transient uses shall be permitted.
SECTION C: PERFORMANCE STANDARDS
1. Compatible and Harmonious. All lessees shall use the airport and any airport
property in a manner that is compatible with City policies and with the
adjacent residential uses; to encourage activities that complement adjacent
residential and commercial uses; to establish practices that are sensitive to
the environment and protect the City from future environmental exposure;
and for aeronautical service providers, comply with the Airport’s Mminimum
Sstandards.
1.2. All City‐owned buildings appropriate and suitable for leasing may be
subject to a public procurement and solicitation process to identify
prospective tenants and licensees whose financial and professional
experience, and products and/or services are consistent with the Leasing
Standards set forth herein.
2.3. All prospective tenants must submit a Lease or License Application to
the City. Information contained in the Lease Application shall describe the
proposed use for the available space; provide information about the
respondent; provide references; describe in detail the financial capability of
the respondent to perform; and set forth preliminary terms and conditions.
3.4. Hangars
a. Hangars that have a land lease agreement with the City will be on a
month‐to‐month tenancy under a City approved lease agreement
which will be updated as deemed necessary by the City.
4.5. Recruitment for artist day studios will adhere to the criteria set forth
by the Cultural Affairs Division of Community and Cultural Services
Department. Candidate tenants for available Artist Day Studio space are
required to file Program applications for screening purposes, and qualifying
artists are selected only from the screened waiting list.
SECTION D: MAINTENANCE AND TENANT IMPROVEMENTS
1. All leaseholders shall be responsible for maintaining their facilities in
attractive and safe condition, in compliance with applicable building and life
safety codes and all applicable environmental laws, ordinances, regulations
and other city standards.
2. Facilities will be inspected prior to new or extended leasehold occupancy and
refurbished, by the City or tenant (at the City’s election), to a decent, safe
and sanitary condition appropriate for use. If tenant makes improvements to
the facility as a mutually agreed upon condition of a lease, the City must first
review and approve the proposed design and scope of work. All necessary
building permits must be obtained and the work must be inspected for
compliance with applicable code(s). Appropriate rental credits for the
approved work performed may be negotiated as part of the lease. Any
Tenant Improvement Credit that exceeds two months’ worth of tenant
monthly rent must be approved by the Airport Director.
3. Each tenant or licensee will be responsible for interior maintenance and
repair at its sole expense, and the City generally will retain responsibility for
maintenance and repair of roofs, building exteriors, landscaping and common
use parking for all Airport‐managed leaseholds unless otherwise specified in
the lease or license. Tenants who lease whole buildings from the City will be
responsible for any and all maintenance, repair and improvements including
roofs, building equipment and exteriors of the facilities as well as interior
maintenance and repairs.
4. Tenants shall respond to the City’s written inquiries regarding any complaints
or issues. Tenant will provide an action plan for improvement if so requested
by the City.
5. As applicable, the above requirements may be incorporated in leases,
licenses and other agreements. In addition, the City may add to any Lease or
License further or different or additional operational and performance
standards as the City concludes are appropriate to the particular Tenant’s
operation.
6. Upon confirmation that the proposed tenancy is consistent with this Leasing
Policy, a lease agreement will be prepared for review by the City Attorney
and execution by the prospective tenant before being referred to the City
Manager for approval. Leases for terms greater than terms specified in these
guidelines require City Council approval.
SECTION E: LEASE APPROVALS AND & DELEGATION OF AUTHORITY
1. The City Manager has the authority to negotiate and execute month‐to‐
month leases, leases with aeronautical service providers, and leases that
expire prior to or on December 31, 2028, provided the City Manager finds the
proposed use is consistent with this Leasing Policy, the Minimum Standards,
and the Consent Decree. To be valid, such leases must be on the basis of
written agreements prepared and approved as to form by the City Attorney.
Leases for terms of occupancy of more than five years or with an expiration
date beyond December 31, 20282, or otherwise outside the parameters
established by this Policy, will require City Council approval.
2. The City may cooperate with commercial real estate brokers who are
authorized to negotiate leases on behalf of prospective tenants.
SECTION F: GENERAL PROVISIONS
This Leasing Policy may be altered by the City at any time, in its sole discretion, and
shall not create any right or reliance interest for any person.
1
Vernice Hankins
From:Andrew Wilder <andrew@andrewwilder.com>
Sent:Tuesday, August 14, 2018 12:07 PM
To:councilmtgitems
Cc:Council Mailbox; Ted Winterer; Terry O’Day; Pam OConnor; Kevin McKeown Fwd; Tony
Vazquez; gleam.davis@gmail.com; Sue Himmelrich; Peter Donald
Subject:Item 3-K, Minimum Standards for Commercial Aeronautical Services
Dear City Council Members,
First, I'd like to commend Staff on a great job developing the Minimum Standards for
Commercial Aeronautical Services. They were especially flexible in providing a second comment
period, which ultimately enabled a much better set of standards. Thank you.
I, along with the rest of the Airport Commissioners, voted to approve recommendation of the
current draft Minimum Standards.
However, there are three concerns that the Commission wants to bring to your attention. This is
noted in the Staff Report, and I believe Commissioner Schmitz will be presenting to you tonight as
well.
1. The growth of "Uber"-style On-Demand Aircraft Operations is likely to cause issues in the
future. Regulation at the Federal level is unclear, as this is a new "disruptor" category of air
transportation. Our concern is that this can diffuse responsibility and accountability for aircraft
operations. This is what drives the next two points.
2. Service Operators should be required to provide Takeoff & Landing Safety Information. SMO
is a unique airport closely surrounded by homes. Although we cannot tell pilots how to fly, we can
help ensure they are aware of the unique challenges of flying into and out of SMO. For example,
the Runway 21 is at a 1.2% downslope, but pilots may not be aware of this, and this changes the
landing calculations significantly. (This may not be obvious because the Airport Diagram notes a
1.2% upslope on Runway 3, but that runway is used only ~5% of the time. By requiring Service
Operators to provide this information, we can help ensure pilots are aware of this and are able to
fly more safely.)
3. LLC Aircraft Insurance Minimums should be higher than what is currently proposed in the
Minimum Standards. Aircraft owners and operators are increasingly using the LLC structure to help
limit their liability in case of an accident; the current draft requires only $1 Million General
Liability Coverage for Aircraft Charter/Air Taxis and Air Transportation Arrangers. We believe this
to be insufficient, considering the proximity and value of life and property on the ground. Staff
raised the minimum in other categories to $2 Million -- these categories should require at least this
much coverage as well.
Thank you very much!
Sincerely,
Andrew Wilder
Airport Commission Vice-Chair
Item 3-K
08/14/18
1 of 4 Item 3-K
08/14/18
1
Vernice Hankins
From:Council Mailbox
Sent:Tuesday, August 14, 2018 2:21 PM
To:Ted Winterer; Gleam Davis; Pam OConnor; Sue Himmelrich; Terry O’Day;
Councilmember Kevin McKeown; Tony Vazquez
Cc:councilmtgitems; Rick Cole; Katie E. Lichtig; Anuj Gupta; Stelios Makrides; Suja
Lowenthal
Subject:FW: August 14, 2018 - Agenda Item 3K. SMO Minimum Standards for Commercial
Aeronautical Services
Council‐
Please see the email below re: SMO minimum standards.
Thank you,
Stephanie
From: reddenfx@aol.com [mailto:reddenfx@aol.com]
Sent: Tuesday, August 14, 2018 2:07 PM
To: Council Mailbox <Council.Mailbox@SMGOV.NET>
Subject: SMO: August 14, 2018 ‐ Agenda Item 3K. SMO Minimum Standards for Commercial Aeronautical Services
Dear Council:
Please raise the airport minimum insurance liability for commercial services to sufficient level to match potential loss...
As explained with clarity in greater detail by Ben Wang, the minimum insurance requirements for the medium to larger
planes currently using SMO for flight operations far too low... Ben Wang provides several instances of FAA case
documentation...
Absurdly, this liability minimum is inadequately set at 2 million? Really? Really.
With home values and the earning capacity of residents subject to loss, 25 million per occurrence is more appropriate.
Unlike other airports surrounded by empty land, or industrial space, SMO is inset in a swath of very pricey homes on both
approaches...and occupants with earnings and imputed economic value to match. We all matter, but damages will be set
based on income and prices.
Thank you for applied some thought to this matter...after a brief moment of sober reflection, it's sadly clear that fuel laden
jet plane crash will result in a large exposure...
Jim Redden
Item 3-K
08/14/18
2 of 4 Item 3-K
08/14/18
1
Vernice Hankins
From:Council Mailbox
Sent:Tuesday, August 14, 2018 2:23 PM
To:Ted Winterer; Gleam Davis; Pam OConnor; Sue Himmelrich; Terry O’Day;
Councilmember Kevin McKeown; Tony Vazquez
Cc:councilmtgitems; Rick Cole; Katie E. Lichtig; Anuj Gupta; Stelios Makrides; Suja
Lowenthal
Subject:FW: August 14, 2018 - Agenda Item 3K. SMO Minimum Standards for Commercial
Aeronautical Services
Council‐
Please see the email below re: SMO minimum standards.
Thank you,
Stephanie
From: Ben [mailto:bcwang@yahoo.com]
Sent: Tuesday, August 14, 2018 1:14 PM
To: Council Mailbox <Council.Mailbox@SMGOV.NET>
Subject: SMO: August 14, 2018 ‐ Agenda Item 3K. SMO Minimum Standards for Commercial Aeronautical Services
Dear City Council:
The draft Minimum Standards require aviation service providers to carry insurance. However, the insurance
requirements are TOO LOW.
The City’s response is that these insurance levels are common at other GA airports, and the FAA might deem higher levels
unreasonable. The information I provided below shows that the required insurance levels can be much higher. The insurance levels
should be as high as possible to cover a major catastrophic accident. This is important because (for example) if an aircraft crashes into
the neighborhood causing property damage or injury to people, how much damage or injury would be covered? How much
are lives and homes worth?
Links:
(1) See last page of Staff's current proposed Minimum
Standards: https://www.smgov.net/uploadedFiles/Departments/Airport/20180713.Santa%20Monica%20Minimum%20Standards.PC2.
Clean.pdf
(2) See FAA Part 16 Case:
Final Decision and Order, Flamingo Express v. City of Cincinnati, FAA Docket No. 16-06-04, Page 16, (Aug. 7, 2007)
"The Associate Administrator finds that the Director’s findings of
fact are correct; a $20 million aircraft liability insurance requirement,
as applied to Complainant’s proposed Part 121 scheduled operations
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for aircraft seating less than 30 but more than 9 passengers, is not
unreasonable or inconsistent with Grant Assurance 22."
http://part16.airports.faa.gov/pdf/16-06-04.pdf
(3) See ACRP Research on Minimum Standards:
Pages 45-46, show ranges for Insurance Coverage
https://iowadot.gov/aviation/pdfs/acrp_lrd_011.pdf
The industry research in 2011 shows that Commercial General
Liability had a mean insurance requirement of $4 million, with a high
of $25 million. So why is SMO requiring only $1 to 2 million
for Commercial General Liability in 2018???
Thank you for reviewing this.
—Ben
===============
Ben Wang
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