Dear Airport Commissioners, August 17, 2015

This document provides the logical and factual basis for the analysis of the FAA Metroplex

Proposal; it supports and expands the “Metroplex Analysis” that I sent to our City Council, City

Staff, and our Congressional Representatives - Lieu and Bass on July 1, 2015 It also provides

information the Airport Commission will need if they are to make savvy recommendations for

the City Council concerning the LA area Metroplex, and thereby augment Council’s ongoing

efforts to limit the impacts of SMO jet and turboprop operations on Santa Monica residents.

My two decades of aviation pilot operations experience and my FAA consulting lends context

for this "Santa Monica-centric" assessment of the FAA Metroplex proposal. I have taken key

parts from FAA documents to extract the FAA’s rationale, methods, and goals – and demonstrate

that agency’s expressed overarching need to free up LAX for the more intensive airline, heavy jet

operations that the FAA anticipates in the near future.

The FAA Metroplex program integrates two growing segments of aviation in the US: Rapid

growth of US commercial passenger and cargo aircraft, combined with exponential growth of

bizjet and private jet aircraft that must operate in the same IFR airspace. To accommodate this

greatly increased LAX airliner traffic, the FAA Metroplex provides both approach and departure

procedures to segregate the SMO traffic from LAX operations. Because SMO is only four miles

to the north of LAX, conflicting SMO departure operations cause serious delays for LAX. The FAA Metroplex documents (and supporting SMO instrument procedures) demonstrate no

regard for Santa Monica residents 1 who are impacted by FAA IFR operations now permitted or

the new (or changed) IFR regime that would enable an unrestricted SMO bizjet airport.

Yet, the FAA Metroplex proposal offers a rare chance for the City of Santa Monica – and our

elected representatives at all levels –, to complement ongoing legal efforts to regain control of

the Western Parcel. We can permanently help the FAA solve its central problem of fitting the

vast majority of commercial passenger flights into constricted LAX approach and departure

corridors by taking all SMO jet & turboprop operations out of the ATC (IFR) mix, now.

A. To start, let’s put ourselves in the FAA’s shoes and consider the central problem they are

trying to resolve: LAX is the 800 pound gorilla that must be fed by the FAA.

1. Los Angeles area airport arrival counts (p. 9, FAA Metroplex plan) show that commercial

air traffic at LAX far exceeds that of all the other airports combined.

2. For LAX to handle more passenger and cargo traffic, as the FAA anticipates within the

coming years, LAX needs more arrival and takeoff “slots.” Slots offer openings for

aircraft to take off and land. For airports (and airlines), slots represent the coin of the Air

Traffic Control realm. No more slots? No revenue growth. The FAA is tasked to

promote air commerce by Congress. But LAX is already world’s busiest origin and

destination airport with a record 70.5 million passengers in 2014.

3. One primary factor limiting (desired) slots at LAX is the arrival conflicts with other

aircraft operations at nearby airports. For LAX, conflicts stem from SMO, BUR, and

VNY operations – but SMO creates the longest delays (pp. 53 and 105). And departure

LAX and SMO conflicts, (well described on Metroplex pages100-105), are crucial to the

FAA and to Santa Monica residents; they will be covered in more detail later.

Sixty percent of SMO departures delay multiple LAX departures! That’s an enormous

problem for LAX – and for the FAA. These delays retard otherwise efficient operations

at LAX. Their “ripple effects” delay other flights throughout the LA metropolitan region.

And LAX delays impact national aviation system arrivals.

4. To “de-conflict” the Los Angeles airports, the FAA Metroplex plan establishes multiple

corridors dedicated to different types of IFR traffic so that traffic to SMO (and other

airports) does not impact LAX commercial operations as much (p. 93). This de-

confliction covers descents and arrivals. But SMO IFR departures (pp. 100-105 offer far

better opportunities to segregate and de-conflict SMO and LAX operations.

5. Finally, the FAA seeks to allow airliners and large transport aircraft to stay as high as

possible for as long as possible (p. 12). Lower is slower – flying higher saves fuel and

time. This holds also true for bizjets, but semi-scheduled bizjets and private jets and

turboprops have lower FAA priority than do passenger or cargo aircraft. Thus the FAA

prioritizes all bizjet operations such that they don’t conflict with the commercial

passenger and cargo aircraft – but far ahead of piston-driven, prop aircraft.

To summarize: The FAA seeks to ensure efficient, time-sensitive operations at LAX now and

for future operations. This goal is blocked by non-LAX traffic, especially the longer delays

created by SMO IFR operations. The Metroplex provides a complex, far-reaching plan that

assigns the highest incoming “corridor” or “tunnel” to large passenger and transport aircraft, the

lower altitudes to business jets, and the lowest altitudes to small prop planes.

Departing SMO IFR operations will be routed nearby the Sunset Park southern border of Santa

Monica, and then turned right to overfly the southwest corner of Ocean Park before transiting the

beach. This “early” turn permits concurrent SMO bizjet and turboprop with the LAX airline

operations. The SMO IFR departure segregation eliminates these troublesome delays – and

provides relief to both departing LAX and SMO aircraft. But at the cost of FAA system-driven,

low altitude (take-off power) bizjet and turboprop flights over Santa Monica.

B. Consider the Metroplex plan impacts on all City of Santa Monica stakeholders:

1. More jet traffic at SMO: De-confliction doesn’t just open up more LAX slots. It also

opens up SMO for more landing and take-offs - especially at the most desirable times for

commercial bizjet travelers. More (and more desirable/predictable) SMO departures

inevitably make SMO more attractive to private bizjet jet patrons.

More noise and fine particulate pollution: 1) Assigning small prop aircraft to lower

altitudes means that SMO inbound traffic will be flying low and slow over Mar Vista,

and parts of Santa Monica. Low and slow flights emit more lead particulates and more

noise on approaches, takeoffs, and climb-outs. 2) Increased bizjet fine particulates over

Santa Monica further add to the health burdens inherent in fine particulates.

C. FAA Metroplex SMO planning is based on deeply flawed or archaic historical data.

1. The FAA based its proposal on inaccurate and unrealistic views of SMO (pp. 100-105).

The Metroplex plan assumes 20 IFR departures per day. The truth is that commercially

available data from May 10 – August 10, 2015 show 8,370 IFR, mostly bizjet (with some

prop/turboprop) operations. And this dataset shows that the City of Santa Monica now

operates a tiny international bizjet airport with the attendant security, customs, and

immigration liabilities as the airport proprietor – presently outsourced to the FBO’s.

a. That’s actually an average of 93 IFR operations per day at SMO between May

and July of this year.

D. There may be an elegant solution for the FAA LAX problems and the City of Santa Monica’s

SMO problems.

1. The City Council could state its opposition to the Metroplex Plan on the basis that it

greatly increases: 1) catastrophic accident potential impacting residents (and increased

City legal liability), 2) adds to already unacceptable dangerous fine particulates, and 3)

greatly exacerbates the aircraft noise already impacting our residents. The City could re-

state its legal claim (supported by our Congressional representatives) that the FAA

immediately release the Western Parcel to its Santa Monica owner.

Recommendation to FAA: Close SMO to IFR traffic (We get the Western Parcel) and all the

LAX-SMO conflicts go away. We are happy to be of service to the FAA and to assist its

commercial mission to support airline/cargo carrier operations at LAX.

Or we can continue to operate LAX and SMO bemired in ongoing legal controversies. Under

the status quo, recall that sixty percent of SMO departures delay multiple LAX departures.

Each such IFR conflict entails 5 minutes for the SMO aircraft awaiting IFR takeoff clearance –

and each conflict also delays two LAX aircraft awaiting takeoff clearance. The first LAX delay

is 2-3 minutes and the second LAX delay is 1-1.5 minutes. These delays, with their increased

time and fuel, greatly affect LAX (and the FAA)…SMO, not so much.

These IFR conflicts which delay the airliners’ arrival or departure times at LAX, led to

subsequent late arrivals that ripple throughout the FAA Air Traffic Control system. The

domestic airlines can't and won’t tolerate these systemic impacts to their revenue.

I hope this document and the attachments will provide us with the information we need to

consider our important decisions and recommendations to the City Council regarding how to

address the FAA Metroplex proposal.

Without local actions and targeted support from our Congressional Representatives, we will all

suffer even more under the lash of SMO noise, health-robbing fine particulates, and the grossly

deficient safety framework at SMO – in my professional opinion.

I will provide page references and/or extracts from the relevant FAA documents. I’ve also

provided a Word document with useful reference links. I’ll bring visual representations of the

relevant present and future FAA instrument procedures that impact Santa Monica residents.

Lastly, this link provides an informative animated display of the daily regular US commercial air

traffic: https://vimeo.com/134735552

When you look at it, please visualize the traffic that would occur through adding in the existing

20,000+ bizjets and turbojets into that mix – on top of the large jet carriers already there. That’s

what it will be like under a Metroplex Air Traffic regime. Kind of takes your breath away.

Thank you for your attention.

Warm regards,

Joe

Accompanying documents:

a. Introduction of materials to Airport Commissioners

b. Schmitz Metroplex Analysis pdf, sent to Congressman Lieu and Congresswoman

Bass (cc to City Council & City Staff)

c. FAA Metroplex proposal extracts: several tables, illustrations, and about 8-10 SMO

relevant pages

d. Word doc with supplementary (curated) links

e. The "short" SoCal Metroplex Final Report pdf

f. Requested relevant City Staff information needed for informed Airport Commission

decision-making

1 The only demonstrated FAA Metroplex concern for people on the ground remains the FAA

overflight prohibition of Disneyland below 3,000 feet above the ground.

Metroplex Overview: Purposes & Strategies to Achieve FAA Objectives

The NextGen and nation-wide Metroplex program seeks to replace FAA reliance on ground-

based navigation aids and intensive Air Traffic Controller/pilot interaction with Performance

Based Navigation systems dependent on aircraft SatNav equipment and data-linked information.

Visual depictions of FAA-desired flight profiles

What the FAA needs to continuously establish during flights under Instrument Flight

Rules which prevail over 18,000 feet and when entering the LAX Terminal Area unless the

flight is conducted under visual flight rules.

Traditional high altitude flight profile

NextGen (Metroplex) desired profile

This depends in part by using NextGen ground and integral aircraft “SatNav” technology

with Metroplex systems—nation-wide.

2 Purpose of Southern California Team Effort

The principle objective of the Southern California OST is to identify operational issues and propose

PBN procedures and/or airspace modifications in order to address them. This OAPM project for the

Southern California Metroplex seeks to optimize and add efficiency to the operations of the area.

These efficiencies include making better use of existing aircraft equipage by adding Area Navigation

(RNAV) procedures, optimizing descent and climb profiles to eliminate or reduce level-offs, creating

diverging departure paths that will get aircraft off the ground and on course to their destination faster,

and adding more direct high-altitude RNAV routes between two or more metroplexes, among others.

The OST effort is intended as a scoping function. The products of the OST will be used to scope

future detailed design efforts and to inform FAA decision-making processes concerning

commencement of those design efforts. [p.2]

JS: Nothing for people on the ground or their elected representatives, above.

Stakeholders include:

There were three rounds of outreach to local facilities, industry, and other stakeholders, including

Department of Defense, airlines, business and general aviation, airports, and others. The first

outreach focused on issue identification, the second on conceptual solutions, and the third on

summarizing the analyses of benefits, impacts, and risks. Assessments at this stage in the OAPM

process are expected to be high-level, as detailed specific designs (procedural and/or airspace) have

not yet been developed. More detailed assessments of benefits, impacts, costs and risks are expected

after the D&I phase has been completed.

JS: No human impacts or risks save aviation risks (for the FAA) are considered.

3.2 Southern California Study Area Scope The Southern California Metroplex consists of airspace delegated to the SCT and ZLA. Operations at

eight airports within the lateral confines of SCT’s airspace were examined closely due to the

complexity of the interactions between these airports:

Not germane to SMO/LAX (JS)

– Orange County (SNA)

Fuel burn modeling was performed for all of the above airports except VNY and SMO.

VNY and SMO were excluded due to low instrument flight rules (IFR) jet traffic counts.

JS: The above claim is false based on FAA Air Traffic Control data then, and now! This

claim is reasonable only in comparison to the LAX (all) IFR jet traffic, almost 300,000 per

year, mostly heavy passenger jets. See below:

3.4 Assessment Methodology Both qualitative and quantitative assessments were made to gauge the potential benefits of proposed

solutions.

The qualitative assessments are those that the OST could not measure but would result from the

implementation of the proposed solution. These assessments included:

fety (Notably absent re: FAA waives of SMO for Class C and D jets, JS)

congestion

and repeatability, with associated more accurate fuel planning

-based navigational aids (NAVAIDs)

(This is the primary FAA objective for de-confliction in my view, JS)

Task complexity, for example, can be lessened through the application of structured PBN procedures

versus the use of radar vectors, but quantifying that impact is difficult. Reduced communications

between pilot and controller, as well as reduced potential for operational errors, are examples of

metrics associated with controller task complexity that were not quantified.

For the quantitative assessments, the OST relied on identifying changes in track lengths, flight times,

and fuel burn. Most of these potential benefits were measured by comparing a baseline case with a

proposed change using both fuel burn tables based on the European Organization for the Safety of

Air Navigation (EUROCONTROL) Base of Aircraft Data (BADA) fuel burn model and a flight

simulator, which was used to establish a relationship between simulator fuel burn results and BADA

tables. The quantitative analyses compared full-time use of current procedures under baseline

conditions with full-time use of the procedures proposed by the OST.

Arrival conflicts and costs. (Sorry, I can’t cut and paste pp 50-52 with charts from

the FAA PDF—but it’s covered in the Metroplex text below)

4.3.5.4 BUR, VNY, and SMO Small Prop Arrival

– There are inefficient vertical and lateral paths on the current procedure. Prop aircraft are typically forced to lower altitudes early due to conflictions with other Los Angeles area flows.

– This arrival also procedurally shares lateral and vertical airspace with LAX arrival traffic, which

adversely affects the efficiency of all FIM flows.

– The proposed replacement, as shown in Figure 55, is designed as a PBN procedure.

– This STAR would be procedurally deconflicted from the LAX SYMON arrivals and would offer airport transitions to BUR, VNY, and SMO with improved vertical profiles.

– The procedure would take existing turboprop and small prop flights and mimic the proposed

CANYN and AALL STARs into BUR and VNY. (Lower and slower over Mar Vista for props, JS.)

JS: The Metroplex image on p. 93 can’t be pasted. But text below follows.

Benefits

– With improved profiles and segregated flows from the LAX arrival stream, this procedure will enhance safety and efficiency for small props to BUR, VNY, and SMO.

– Due to low traffic counts, no modeling was done for this procedure.

4.3.5.5 BUR, VNY, SMO, CMA, and OXR New East Arrival

JS: FYI, This provides new SatNav routes into FAA “Reliever Airports” including SMO.

– Due to the lack of a published route, SCT requested an arrival procedure from the PSP area for

BUR, VNY, SMO, CMA, and OXR airports. Currently, arrivals are routed north to the DAG VOR,

then join current STARs or are vectored in the vicinity of PSP.

– The OST developed an RNAV STAR that mimics the ONT SETER STAR to PETIS then

terminates at a waypoint south of DARTS. The proposed route as shown in Figure 56 would

significantly reduce flight track miles and allow for OPD benefits.

Benefits

– With improved profiles and a repeatable, predictable path separated from other Los Angeles Basin

airports, this procedure will enhance efficiency for arrivals from the PSP area to the BUR, VNY, SMO, CMA, and OXR airports.

– This is a new proposed procedure with no baseline; therefore no modeling was done.

(From Metroplex proposal pp. 93-94)

The SMO/LAX de-confliction FAA analysis below is vital.

JS: This is, by far the critical Metroplex change for Santa Monica. It renders SMO a

predictable, segregated — bizjet friendly airport. It removes interference with LAX and offers

SMO operations that are independent of LAX departures. Further, it presumes FAA control

of the Western Parcel for this plan to possible work. Please read below!

4.4 Other Southern California Issues

4.4.1 SMO/LAX Interactions

– Current SMO procedures inhibit independent operations with LAX departures. Limiting factors include runway configurations and the proximity of the airports (4 NM).

– Excessive ground delays occur at SMO due to LAX departure demand. LAX operations are also

adversely affected since Runways 24L/R departures are held until the SMO departures are separated

from the LAX departure paths. Similarly, SMO departures from Runway 21 must be held until LAX departures are separated from the SMO departure areas.

– Interactions between SMO and LAX also create complex ATC coordination. Three facilities are

involved in the coordination of a SMO departure, as LAX ATCT, SMO ATCT, and SCT are all

involved in the release process. If SMO procedures were deconflicted from LAX departures, verbal

coordination between facilities could be minimized.

– The OST and SCT developed PBN procedures to and from SMO that would deconflict the flows

from Runways 06L/R and 24L/R at LAX.

4.4.1.1 Runway 03 RNAV Approach Concept

JS: This NEW approach takes aircraft down to 300 feet, at a distance of 1 mile or less (depending

on aircraft category) from the runway.

– The OST developed an RNAV straight in approach to SMO Runway 03 as shown Figure 61.

– The RNAV approach is designed to maintain vertical deconfliction from the LAX Runway 07 final approach course.

– The courses of the RNAV approach to SMO Runway 03 and the Runway 06 approach to LAX will

diverge by more than the minimum separation requirement of 15 degrees after crossing the LAX

final.

Benefits

– This approach enables greater independent operations.

– A straight-in RNAV Runway 03 approach creates a previously unavailable option.

JS: Figure 61 shows a straight-in approach with a heading of 030. But the published instrument

approach elsewhere displays a heading 048 or over Ocean and Sunset Park with a descent down to

300 feet above the ground 1 mile from the approach end of Runway 03. Runway 21 now has a

similar straight-in approach down to 250 feet above the ground. Neither approach is yet authorized.

The FAA SMO and LAX departure – deconfliction plan:

4.4.1.4 Runway 21 RNAV SID

– The OST designed an RNAV SID with multiple transitions as shown in Figure 64 that is procedurally deconflicted from LAX Runways 24L/R departures.

– The proposed SMO Runway 21 SID is procedurally deconflicted from LAX departures by

approximately 3.25 miles, which meets minimum separation requirements.

JS: The red course line at the lowest point of the angle just past Lincoln is the only definitive

ground reference in the Metroplex document. This single graphic answers all the questions

that City Staff may have informally, or formally, asked the FAA about Runway 21 ground

track. This diagram also shows the LAX and SMO runway orientation—and it portrays the

means by which the FAA will use to solve the departure conflict between SMO and LAX.

Benefits

– The deconfliction of the SMO and LAX procedures will result in reduced vectoring, improved fuel

planning, reduced departure and arrival delays, and minimized interfacility coordination.

– The new procedures will allow for simultaneous operations at both airports with the sole constraint

being limitations to the 270 degree heading that is used for prop aircraft from LAX Runways 24L/R.

(From Metroplex p. 104 above)

(From Metroplex p. 105 below)

– CAASD completed a study in 2009 estimating the delay impacts of SMO/LAX interactions3. This

report details fuel and operating costs associated with delays at SMO and LAX interactions between

LAX Runways 24L/R and SMO Runway 21. The delay estimates were recently updated to reflect

current fuel costs. The updated delay savings due to deconflicted procedures are detailed below.

Analysis Assumptions

Only jets will use the new SID

96% of jet operations RNAV capable (Slightly optimistic as of 2015, JS)

20 IFR jet departures per day (False according to FAA links and commercial datasets, JS)

Average SMO IFR delay for release for jets: 5.4 min/departure

2 LAX departures delayed for each SMO departure

First departure delayed 2-3 minutes

Second departure delayed 1-1.5 minutes

60% of SMO IFR departures impact LAX departures

Annual cost savings associated with new SMO SID for fuel savings alone (not including other

ADOC)

LAX impact: $110,000 – $160,000

SMO impact: $100,000 (Conflicts with City reported benefits of 350-300K)

Total: $210,000 – $260,000

Schmitz comment: By far the biggest impact resides in freeing LAX departures. The fuel is

trivial; the FAA doesn’t care about impacts on residents. City of Santa Monica ownership

and control of the Western Parcel would permanently eliminate any conflicts with LAX.

Conversely de-confliction renders SMO more “open”, predictable, and desirable for

bizjets. Please note the FAA changed and added procedures that render SMO more easily

accessible to turboprop and jet aircraft, below:

The new approach procedures permit Instrument Weather landings with 1 mile visibility and

300 feet ceilings using internal aircraft navigation equipment. Thus, these approaches render

SMO a 24/7/365 all-weather airport should the City of Santa Monica noise restrictions be

overruled administratively by the FAA or by subsequent legal challenges. Joe Schmitz, PhD

FAA Metroplex Overview and Analysis

Below, I have summarized my “takeaways” from the FAA’s demonstration and workshop covering

the Metroplex proposal, held on June 17, 2015 at the Santa Monica Library.

1. Let me begin with my observations of the FAA staff who hosted this workshop: FAA safety

representatives from their Air Traffic Organization (ATO) were completely absent. None of the

FAA folks would address community impacts (noise, pollution or safety) with Santa Monica

residents. The FAA Metroplex workshop demonstrated the regulatory capture of the FAA by

the general aviation, airline, and aviation business special interests. I spoke at length with

Shawn Kozica, the senior FAA official, after informing the FAA staff that I’d provided a high-

level safety seminar for the FAA (ATO) in 2005. Mr. Kozica was quite responsive.

Improving the capacity, flexibility, and economy (fuel and time-saving) achieved through newer

navigation and communication technology seemed to be the only goals that the FAA advanced.

However worthy, the achievement of these goals should not come at the expense of the needs of

tens of millions of Americans who live near or below flight paths of general aviation airplanes.

Yet, FAA concern for the Metroplex impacts on communities was notably absent. Any basic,

comprehensive systems (or safety) analysis would have made it abundantly clear that such

changes must inevitably have huge, negative repercussions on the residents who live in the

homes located below the intensive, semi-private bizjet operations.

Now let’s turn to the specifics of the Metroplex proposal:

1. The important impact that the proposed Metroplex will have on Santa Monica (and adjacent

neighborhoods) is that: It “locks” into place the presently missing, all-weather and procedural

infrastructure that would allow SMO to become an all-weather, intensive 24/7 bizjet airport.

2. The FAA will partly resurrect the “dreaded 250 degree heading” jet departure, a compromise

that slightly delays this turn, but makes it a somewhat sharper turn further north. This change

will negatively impact property values in Santa Monica, decreasing the tax base in the Ocean

Park neighborhood and along the beach. This heading is also likely to impact tourist

satisfaction with our hotels and depress tourist revenues, in the longer term. More low altitude,

high-power jet instrument training overflights will exacerbate this harm.

3. Increasing numbers and more serious complaints from adversely affected Santa Monica

residents and tourist-related business owners will become inevitable.

4. Although the City of Santa Monica now ”accepts” the present airport hours, the FAA (by law)

controls all airspace operations. Thus, we must carefully consider the differences between

existing operations and the proposed Metroplex operations going forward.

Existing SMO alternate IFR minimums permit filing instrument flight plans to SMO.

Existing VOR or GPS-A now permit IFR approaches and landings with 600 foot ceiling and

one mile of visibility weather 24/7 at SMO.

Note that existing 250 VOR or GPS-A departure IFR training and departure traffic has

increased markedly over the past year.

The proposed FAA Metroplex would have the following future impacts:

The new 03 and 21 approaches will lower the ceiling and visibility to as low as 300 foot ceiling

and one mile of visibility 24/7 and thus permit inbound IFR flights at 048 degrees heading -

over houses at as low as 300 feet. They will also permit more low altitude circling approaches

(below 600 feet during actual weather conditions that are now infrequent but sometimes occur).

The new Metroplex package provides the instrument flight control infrastructure needed for an

all-weather, quasi-scheduled, bizjet airport. It increases SMO’s need for more frequent

instrument training procedures that require aircraft to directly overfly Santa Monica residents on

the missed approach heading of 250 degrees. Given the greatly increased volume of bizjet

instrument training in this future—this change alone will make residential life more onerous.

Last, the new proposed early turn over Santa Monica as IFR traffic that departs north to de-

conflict with LAX departures is hugely problematic for Santa Monica residents. Pilots almost

always “lead” their turns to the North in order to not over-shoot their course and avoid

seeming sloppy and “behind their aircraft” to their flight crews. Turning early also saves a bit

of time and fuel—as was demonstrated by the preponderance of “early turns” in the 24 hour

tracks that were clearly displayed by the FAA on Google Earth displays during the workshop at

the Santa Monica Library. The new FAA departure will further exacerbate those early turns.

De-conflicting the LAX and SMO operations opens the door for a Santa Monica bizjet airport.

The FAA rationale for their new early turn procedure is to save the airlines $250,000 per year in

fuel and flight time. However, the increased noise alone will reduce Santa Monica (and LA)

property values and our existing tax base, perhaps by many millions. This financial toll does

not even consider the (scientifically demonstrated), life-threatening health damage over the

entire West LA area from increased ultra-fine, jet exhaust particulates. Please see Paulson,

2013; Hudda, et al., 2014; and other peer-reviewed articles. a

The FAA Metroplex proposal demonstrates the agenda and priorities of the FAA and of the

perverse, self-serving AOPA and NBAA special interests that have captured the FAA policy-

makers. A workable solution does not entail infighting with LA authorities about simultaneous

jet departures. Rather, we should collaborate and curtail instrument bizjet departures at SMO to

serve the public interests of all constituents.

Conclusions

Most important—de-conflicting SMO and LAX—would permit simultaneous intensive IFR

operations at both airports. This policy offers SMO to the fractional jet corporate interests.

The FAA proposal transforms SMO from a “FAA reliever airport” into a regional jetport with Santa

Monica as a prized destination. It offers us a “Trojan Horse,” one that disguises its real intent: To

marry simultaneous intensive, public airline operations at LAX with ongoing and intensive semi-

private jet bizjet operations at SMO. This multibillion dollar proposal diverts public land into

lucrative private use – scarce public goods into lucrative private profits.

Our airport does not now, but should, regularly report the number, scope, and types of these

instrument airport operations to the Airport Commission and to the City Council. The Airport

Commission can then correlate airport operations with adverse SMO impacts on Santa Monica

residents in the Sunset Park and Ocean Park areas: ranging from the sheer volume to the noisy and

sometime late night-time operations—and then our inform City Council decision-makers.

1. Thus, the proposed Metroplex environment paves the way for the operational regime that AOPA

and NBAA lobbyists must have to realize their plans to turn SMO into a regional jetport: The

essential instrument weather condition (IMC) capabilities and the matching instrument flight

regulations & procedures (IFR) regulatory structure needed for intensive bizjet operations.

2. Once established, the Metroplex-enabled bizjet reality will be hugely “difficult to kill” in spite

of overwhelming Santa Monica voter support for the resident-friendly Measure LC and

conclusive rejection of the AOPA-NBAA sponsored Measure D during the 2014 election.

3. If the FAA, AOPA, and NBAA future vision comes to pass, any road to a vibrant 21st Century

green, creative, and high-tech economy for the entire West-side of this Los Angeles region will

be foreclosed by mid-20th Century dirty, unsafe, health-endangering infrastructure. It will also

foreclose “green” economic expansion for Santa Monica and West L.A. for decades to come.

4. Many billions of dollars in opportunity costs will have been sacrificed, including tens of

thousands of high-tech and creative economy jobs that could have provided the basis for a

greatly strengthened regional economy, and recreational opportunities that enhance the quality

of life for so many—a future that will truly benefit all our kids and grandkids.

5. Who gains from a burgeoning regional jetport? The privileged few. Who pays? The many

hundreds of thousands of people who pay prices in unhealthy, polluted air, inadequate safety

protections, oppressive overhead noise, and the loss of precious recreational space.

Summary

Aside from the inevitable detriments to safety, health, and quality of life—the FAA (and AOPA-

NBAA) vision for the Santa Monica Airport complex embodied in the Metroplex proposal is, quite

literally, toxic to the municipal economic health and of the West-side area. It will, inevitably,

preclude high-tech, creative alternatives that would catalyze the potential for enormous economic

benefits and eliminate park and leisure facilities that would improve the well-being of all residents

in the years to come.

In short, the FAA would condemn this beautiful and desirable area back to the dirty smoke-stack

economy of the past century when the air quality of Los Angeles was a national disgrace.

Eventually a bizjet will crash into the densely populated four-city area that tightly surrounds SMO.

We should oppose the FAA Metroplex proposal.

[Signed]

Joseph Schmitz, PhD; Airport Commission Member, Santa Monica, CA. 1, a

1. This letter reflects the personal views of the author. a. Journal article references furnished on request.

2. Attachment 1 provides the overhead view of the dense residential housing which surrounds SMO.

Attachment 1

USGS digital orthophoto of Santa Monica Airport in California of the Santa Monica Airport with its 4,973

foot-long runway (characterized by some as “the aircraft carrier surrounded by a sea of homes”). 1,2,3,4

1. The FAA has long (and imprudently) waived its own runway safety environment rules, perhaps due

to the impossibility of providing runway overruns or departure safety zones given the implausibly of

buying the surrounding land (worth billions) at taxpayer expense for runway buffers or adequate

safety arresting zones.

2. Santa Monica is reportedly the most densely populated Southern California beach community. In

2010 the Santa Monica population density stood at 11,000 residents per square mile (US Census).

3. When a bizjet eventually lands short or fails to safely abort its take-off—it will crash into homes that

were built during WW2 or shortly afterward to either win WW 2 or to provide workers for Douglas

Aircraft in the peace that followed. We won WW 2! And it’s way past time to demobilize!

4. A bizjet crash in less dense regions would be a tragic accident. In Santa Monica (or LA) that crash

could devastate an entire city block of homes. It would lead to a national (preventable) disaster for

the entire Los Angeles region and we would all regret that we had not done more to prevent it.

July 18, 2015 Request for City Staff Written Documents for Airport Commission

1. Based on Mr. Patuscha’s comments to the Airport Commission, July 27, 2015: What formal communications has City Staff had with the FAA regarding the initiation of Runway 21 take-off turn point – e.g. the specific geographical location of the right turn initiated after the original 210 take-off heading and airfield departure?

a. Mr. Patuscha said that the City specifically asked the FAA if the right turn to 256 degrees for jets was at a specific point on the ground, initiated after a point, or initiated to intercept a specified course. Is there any City staff written request to the FAA to clarify this matter?

b. What, if any, answer did the City receive from the FAA?

2. Mr. Patuscha indicated that Staff was (either going consider or would) hire a consultant to help ask the FAA to waive its own 3.25 mile separation standard for conflicting IFR traffic—unlikely at best given the national ramifications for the FAA to agree to any such an exception based solely on local concerns about future Santa Monica noise complaints.

a. Did Staff pursue this strategy? With what results?

3. Where is the present geographical point that the current PEVEE TWO DEPARTURE requires the turn to heading 256 for jets? Where is the proposed Metroplex right turn now located? Please note the FAA proposed action procedures that are designed to achieve “segregation” in the FAA Metroplex table below. How does this segregation change the geographical routing for the flight paths of departing aircraft? What areas of Santa Monica will be then be overflown by jets as they takeoff and begin their right turn?

4.

5. How many gallons of Jet A fuel did SMO sell last year? Do you have the yearly totals of Jet A fuel for the past five years?

6. Last month the City provided the SMO five-year history of propeller Aircraft Operations and Noise Violations to the Airport Commission. Please provide the comparable five-year history of jet and turboprop Aircraft Operations and Noise Violations at SMO.

7. How did Staff arrive at the $250-300,000 savings from idling at SMO reported to Airport Commissioners at the July 27, 2015 meeting? This “savings” conflicts with the FAA Metroplex analysis data.

8. Given the looming FAA Metroplex comment deadline and Staff’s receipt of the Schmitz Metroplex Analysis (as a courtesy) almost one month earlier, why did Staff not discuss the implications of SMO and LAX departure conflicts—and the anticipated consequences of de-confliction upon SMO and LAX? This seems especially problematic since de-conflicting opens-up more, and more predictable, SMO take-off “slots” and thus invites more intensive SMO bizjet operations as was expressly raised in the June 30 Schmitz Metroplex analysis “Conclusions” section.

9. If City Staff disagrees with any of the premises, analyses, or conclusions of: 1) the Schmitz initial Metroplex Analysis (June 28, 2015) or, 2) the Schmitz August 17, 2015 Metroplex Analysis and my City Staff/City Council recommendations, I request Staff provide their written, specific objections to the Airport Commission prior to our August Airport Commission meeting.

10. City Staff should ground their objections by including the relevant portions of the expressed FAA policies, goals, constraints and analyses contained in the “Optimization of Airspace and Procedures, Southern California Metroplex,” Final Report.

11. I also request that Staff also pass this request for information to my Airport Commission colleagues in their August information packets.

Thank you. Joe Schmitz, PhD. Airport Commission Member