8490 South Power Road, Suite 105

- 181  Gilbert, AZ 85297  Office (480) 987

- 7823  Fax (480) 987

- 7824 

## Aeronautical I mpacts of the North Shore Marine Transfer Station

Executive Summary

Williams Avi ation Consultants was retained b y New York Metro Peterbilt to review the proposed North Shore Marine Transfer Station (NSMTS) located 1,850 ft south east of
LaGua rdia airport (LGA). The purpose of the review was to determine : (a) if construction of the building and a ssociated gantry cranes would prevent future safety enhancements to the airport’s instrument approach procedures , (b) to determine if the structures associated with the NSMTS
would be a haz ard to aircraft approaching LGA and (c) to determine t he safety issues related to the NSMTS attracting large bir ds that can be ingested into jet engines of aircraft approaching and departing LGA.

The landing phase of flight puts a significant amount of stress on pilots . During an approach and landing the pilot is controlling the aircraft, referencing several instrum ents, talking to air traffic control and looking for other aircraft. Due to the great amount of multi

- tasking and the need for concentration, the landing phase of flight is the most critical and most dangerous. Therefore, it should be the prerogative of both the airport owner and the authority that controls land use around an airport to provide pilots with accurate navigational equipment and to prevent unnecessary obstructions from interfering with an approach to the airport.

LaGuardia Airport (LGA) is one of the busiest airports in the United States. The airport has, on average, 1,038 operations per day and had over 370,000 operations in 2008. In 2009, 26
scheduled airlines were operating from the airport. The a irport has two intersecting runways which are perpendicular to each other. Aircraft that approach the airport from the southeast
utilize Runway 31. Runway 31 is the only runway at LGA that lacks a precision instrument approach such as an Instrument Landing System (ILS).

Williams Aviation Consultants concluded that the proposed NSMTS would pose a significant safety hazard to aircraft approach ing LGA. The comprehensive review found in Appendix I
concluded the NSMTS would be a significant safety hazard to aircraft for the following reasons:

1. The construction of the NSMTS buildings will severely restrict the potential Decision Altitude and visibility requirements of the proposed ILS approach procedure to Runway 31.W illiams A viation C

onsultants, Inc. 2 2. The construction of the NSMTS will attrac t a significant amount of large birds that can be ingested into the jet engines of arriving and departing aircraft thereby causing a catastrophic failure of the engine.
3. The approval of the NSMTS is in direct violation of Federal Aviation Administration’s ( FAA) Terminal Instrument Procedure Guidelines and should be determined to be a hazard to navigation by the FAA.

4. The proposed transfer station would be in the Runway Protection Zone (RPZ) of Runway 31. FAA airport design guidelines discourage any projects t hat could attract
birds within the RPZ.
5. The NSMTS will be a significant obstacle and distraction located very close to the
end of Runway 31 which pilots will need to avoid during the critical landing phase of flight

. 

### Background

The North Shore Marine Transfer Station is currently under construction on Fl ushing Bay in College Point, NY . The new transfer station will receive in excess of 2000 tons of loose garbage daily. Garbage trucks will dump their loads inside the transfer station. Wor kers will then load the garbage into containers, and lid the containers. The containers will be placed on barges and transported, by barge, through waterways that cross beneath the flight paths of LaGuardia Runways 31 and 22. The barges will pass within 50 0 feet of the end of Runway 31 and through the flight path of Runway 22.

Instrument Approach Procedure s

During periods of low visibi lity and bad weather a pilot will navigate primarily by reference to instruments rather than by outside visual references. Instrument Meteorological Conditions (IMC ) is a term used to describe the weather conditions that require the pilot to navigate using
the aircraft’s instruments. When an aircraft is approach ing an airport the pilot utilizes an Instrument Approach Procedure (IAP). Instrument approach procedures are classified as either
“non

- precision” or “precision”.

A pilot who uses a non

- precision instrument approach procedure is navigating with instruments that provide l ateral guidance only. An example of this type of instrument approach is called a “localizer approach” in which a ground based antenna array called a “localizer” transmits a signal which is received by instruments in the aircraft. Using this type of approac h m eans that the pilot only knows if the aircraft is in line with the runway but does not know if the aircraft is too high or low to complete a safe landing

. Runway 31 at LGA is equipped with a localizer.

A pilot who uses a precision instrument approach pr ocedure is navigating with instruments that provide both lateral and vertical guidance so the pilot knows if the aircraft is in line with the runway and that the aircraft is not too high or low to complete a safe landing

. An example of this type of approac h is called an Instrument Landing System (ILS) which consists of two groundW illiams A viation C

onsultants, Inc. 3 based antenna arrays. A localizer antenna provides the lateral information and a glide slope antenna provides the vertical guidance. Runway 31 is not currently equipped with an ILS

, although an ILS for Runway 31 is in the planning stages at the Federal Aviation Administration (FAA).

Each instrument approach procedure is designed to ensure aircraft will remain a safe distance from structures and terrain. The elevation to which a pilo t can safely descend is called the Decision Attitude (DA). The IAP also contains a minimum visibility requirement, which is the lateral distance an observer on the ground can see into the horizon. Visibility is reported in
statute miles or fractions of mil es. Visibility can also be expressed as Runway Visual Range (RVR) which is reported in hundred s of feet.

If the pilot cannot see the runway environment upon descending to the DA, a missed approach procedure is executed. The missed approach procedure contains the instructions that the pilot
follows to ensure that the aircraft will remain a safe distance from structures and terrain as the pilot navigates away from the airport and the aircraft increases in altitude.

I n order to maximize the number of possible operations and provide pilots with a safe option to approach an airport during periods of inclement weather and low visibility

, it is desirous to design instrument approach procedures that allow pilots to descend to the lowest possible
elevation

, before the pilot must decide whether it is safe to land on the runway. Structures located near the airport often prevent the decision altitude from being set at its lowest possible elevation. In this situation a pilot may not be able to descend below the l owest cloud layer and therefore cannot land at the airport.



### Issue s

Impact to Runway 31 Instrument Approach Procedure

LGA has two Runway s; 4/22 and 13/31. It is safer for aircraft to land into the wind

. T herefore,

i n the event of a crosswind on Runway 4 /22 it is preferable for aircraft to land on Runway 31.
Since Runway 31 does not have a precision instrument approach, when visibility is below 1 mil e, arriving flights cannot use Runway 31 a nd are forced to fight the crosswind on Runway 4 to land

o r t h e y m u s t d i v e r t t o a n o t h e r a i r p o r t

. Strong winds crossing Runway 4/22 substantially limit the use of that runway. The FAA, Air Traffic Control System Command Center reports: “If the wind [across the runways at LaGuardia] is strong enough to force the use of only one runway for purposes of avoiding a significant cross wind component on the other runway, the airport Arrival Rate [can be substantially reduced] which would c ause demand to exceed capacity f o r a p e r i o d

o f s e v e r a l h o u r s

. ”W illiams A viation C

onsultants, Inc. 4 An ILS installation on Runway 31 , with visibility requirements as low as 1⁄2 mile, would eliminate the need for pilots to land in a c ross wind and allow the use of Runway 31 in nearly all
inclement weather conditions

, thereby making LGA a saf er and more efficient a irport.

There are, at present, three obstr uctions in the flight path for Runway 31 that prevent the full use of an ILS system for Runway 31. Two of these obstructions are silos employed for the storage of asphalt and cement located directly across Flushing Bay from the runway. Both of these obstructions could be removed or lowered, at minimal cost

. The other obstruction is the existing
transfer station , currently scheduled for demolition, which penetrate s a surface used in designing the instrument approach by only 3 ft. It also is believed that this penetration is an obstruction light on the transfer station which could also be lowered at minimal cost.

The construction of the NSMTS will eliminate the possibility of implementing an instrument approach procedure to Runway 31 with visibility requirements as low as 1⁄2 mile and a Decision
Altitude as low as 219 ft AMSL

. The NSMTS will instead require that the visibility requirem ent
be set at 1 mile and the Decision Altitude be set at 311 ft AMSL.

According to the United States Standard for Terminal Instrument Procedures 8260.3B, the proposed transfer station should not be approved because it will penetrate the obstacle clearanc e surfaces (OCS) for an ILS procedure. According to these guidelines, proposed obstructions shall not penetrate the OCS.

Bird Attractant and Runway Protection Zone

Not only will the NSMTS impact the proposed ILS

, but the transfer station will also attract large
birds and

, t here fore

, there will be a risk of wildlife ingestion and catastrophic failure of the aircraft’s jet engines

. In the past nine months there have been three reported bird strikes at LGA, including the bird strike that brought down US AIR Fl ight 1451. T he garbage processed at the NSMTS will leave that facility by barge, also a bird attractant that will pass within 5 00 feet of Runway 31, and Runway 22 at LaGuardia Airport.

The NSMTS would also be located in the runway protection zone (RPZ) for Runway 31 which extends 2,500 ft from the end of the runway. According to FAA guidelines bird attractant s, such as waste management facilities should not be constructed within the RPZ.

T he NSMTS would be outside the RPZ if the FAA was not planning to install an ILS for Runway 31 with visibility minimums lower than 3⁄4 of a mile. But FAA guidelines state clearly that the calculation of the RPZ is determined not only by existing navigation aids, but by any plans to install a modern ILS navigation aid on that Runway.

Proximity of Approaching Aircraft

The NSMTS will rise 100 .06 feet Above Mean Sea Level (AMSL) and above the level of Flushing Bay . In normal operations, the approach path for an aircraft l anding on R unway 31 willW illiams A viation C

onsultants, Inc. 5 pass less than 70 feet vertically and less than 350 feet horizontally from the NSMTS structure. As stated previously, the landing phase of flight places a tremendous amount of stress on the pilot. As a pilot approaches Runway 31, the NSMTS structures and birds flying around the facility will undoubtedly be a distraction to pilots approaching Runway 31. The transfer station’s proximity to approaching aircraft could place the aircraft, its passengers , crew and people on the ground in jeopardy

.8490 South Power Road, Suite 105

- 181  Gilbert, AZ 85297  Office (480) 987

- 7823  Fax (480) 987

- 7824 Appendix I



## Aeronautical I mpacts of the North Shore Marine Transfer Station

Issue:

Williams Avi ation Consultants was retained b y New York Peterbilt to review the proposed North
Shore Marine Transfer Station (NSMTS) located 1,850 ft south east of LaGua rdi a airport (LGA). The purpose of the review was to determine : (a) if construction of the building and a ssociated
gantry cranes would prevent future safety enhancements to the airport’s instrument approach procedures , (b) to determine if the structures assoc iated with the NSMTS would be a hazard to aircraft approaching LGA and (c) to determine the safety issues related to the NSMTS attracting large birds that can be ingested into jet engines of aircraft approaching and departing LGA.

T his analysis included ou r review of a proposed Instrument Landing System (ILS) approach designed by the Federal Aviation Administration (FAA) for Runway 31, as well as a review of an independent study by QED Consultants which suggested alternative ILS designs and examined the pos sible impacts of the proposed transfer station. Williams Aviation Consultants
also reviewed additional ILS alternatives to determine if it is possible to reduce the Decision Altitude ( DA)/Decision Height (D H ) 1 and visibility requirements. Figure 1 displays the location and elevation of the proposed Marine Transfer Station as well as the location and elevation of
other structures in the vicinity of the transfer station.

1 All terms used in this report are further defined in the Glossary found in Appendix IIAppendix I W illiams A viation C

onsultants, Inc. A 1

- 2 Figure 1



### Instrument Approach Procedure Analysis

Backg r ound

During periods of inclement weather and low visibility a pilot approaching the airport will utilize an instrument approach procedure. The instrument approach procedure is designed to allow the pilot to descend to the lowest possible altitude while maintaining a safe distance between the aircraft and all obstacles. It is desirous to have the instrument approach procedure designed to allow pilots to descend to the lowest possible altitude and with the lowest possible visibility in order to maximize safe airport operations throughout the year

.
If the pilot cannot see the runway environment upon descending to the Decision Altitude, a missed approach procedure is executed. The missed approach procedure contains the instructions that the pilot follows to ensure the aircraft will remain a saf e distance from structures and terrain as the pilot navigates away from the airport and increases in altitude.

There are several types of instrument approach procedures that provide navigational guidance to pilots during periods of low visibility . For the purposes of this discussion, the ILS instrument approach procedure will be analyzed because it provides the pilot with the lowest possible DAAppendix I W illiams A viation C

onsultants, Inc. A 1

- 3 and most commercial a ircraft are equipped with the necessary instruments to fly this type of instrument approach.

The guidelines for designing an ILS approach are contained in the United States Standard for Terminal Instrument Procedures (TERPS) FAA O rder 8260.3B. The TERPS guidelines use a
combination of imaginary sloping surfaces called Obstacle Clearance Surfaces ( OCS), Glide Qualification Surface (GQS ), obstacle identification s urfaces (OIS) and Missed Approach
Surfaces to determine the DA and visibility requireme nts for an instrument approach

.

Obstacle Clearance Surfaces (OCS)

T he OCS is made up of three separate surfaces called the W, X and Y surfaces. The W surface rises at a slope dependent on the Glide Path Angle (GPA) of the aircraft. The GPA is the angle
at which the aircraft descends down to the DA. The X surface rises at a slope of 4:1 from the side
of th e W surface. The Y surface rises at a slope of 7:1 from the side of the X surface. Figure 2 displays how these surfaces relate to each other as they extend from the runway end.

Figure 2

If an obstacle penetrates the above surfaces, the glide path is firs t increased to eliminate the penetration. The DA is then increased if the penetration cannot be eliminated by increasing the glide path. As shown in Figure 3 , Chapter 3

, paragraph 3.8 of the United States Standard for
Terminal Instrument Procedures Order 8 260.3B only allows existing obstructions to penetrate the OCS. Proposed obstructions are not to penetrate the OCS.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 4 Figure 3

Glide Qualification Surface (GQS)

The GQS extends from the runway threshold along the runway centerline and extends to the DA point (Figure 4

)

. It limits the height of obstructions between the DA and runway threshold

. The GQS

, must be free from penetration. If the GQS is penetrated, an instrument approach procedure with positive vertical guidance is not authorized.

Figure 4

– Runway 31 Glide Qualification Surface

– The proposed transfer station is less than 1 4 0 ft outside the surface that determines if a precision instrument approach procedure can be authorized to Runway 31

.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 5 Obstacle Identification Surfaces (OIS)

The re are two different obstacle identification surfaces (OIS) which extend from the runway threshold and increase in height at a slope of 20:1 and 34:1 . These surfaces are used to determine the visibility requirements for the instrument approach procedure. If t he 34:1 surface is penetrated the visibility for the approach cannot be lower than 3⁄4 of a mile /Runway Visual Range (RVR) of 4,000 ft. If the 20:1 surface is penetrated the visibility for the approach cannot be lower than 1 mile/ 5000 RVR.

Missed Approach Procedure Surfaces

A missed approach area is evaluated to ensure that an aircraft will remain a safe distance from obstacles in the event that a pilot cannot see the runway during an instrument approach and must therefore execute a missed approach. The a rea considered for obstacles has an initial width eq ual to the OCS and expands uniformly as it extends from the decision altitude point (Figure 5 ) . If obstacles penetrate the missed approach procedure surface, the DA must be increased to prevent penetratio n. Section 1a takes into account that an aircraft will continue to descend slightly after reaching the DA. Section 1b increases at a slope of 28.5:1 and assumes the aircraft has begun to increase in altitude. Section 1C is a sloped surface which increases at a slope of 7:1 from the sides of Section 1b and 1a.

Figure 5

– Missed Approach SurfacesAppendix I W illiams A viation C

onsultants, Inc. A 1

- 6 Analysis:

Five ILS alternatives were analyzed to determine how the proposed transfer sta tion would impact potential DA and visibility requirements for an ILS ap proach to Runway 31 at LGA. The results were then compared with the QED and FAA analysis for consistency. The five ILS alternatives included:

1. An o ffset ILS approach to the north 2. An offset ILS approach to the south 3. Straight in ILS approach 4. Straight in ILS with key obstacles lowered 5. Straight in ILS with 3 degree glide slope and all off

- airport obstacles lowered (test for Cat II ILS feasibility)

Existing obstacle data for the analysis was derived from FAA documents. Figure 6 and Figure 7 display the height and location of key obstacles that would impact the proposed ILS approach:

Figure 6Appendix I W illiams A viation C

onsultants, Inc. A 1

- 7 Figure 7Appendix I W illiams A viation C

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- 8 The proposed Transfer Station location and elevation data was derived from the FAA documents and is displayed in Figure 8

.

Figure 8



### Analysis of ILS Approach to the North:

Presently, Runway 31 is equipped with a localizer instrument approach. This type of instrument approach procedure consists of a ground based antenna array called a “localizer” which transmits a signal that i s received by instruments in the aircraft. A localizer only provides the pilot with lateral information, therefore, the pilot only knows if the aircraft is lined up with the runway but does not know if the aircraft is too high or low to land safely.

The c urrent localizer approach is offset slightly to the south. The QED report and FAA analysis reviewed alternatives which included further offsets to the south and a “straight in” ILS approach. An offset to the north was not studied in the QED report or FAA a nalysis.

In order for an offset ILS approach to the north to meet TERPS requirements, the localizer
antenna would need to be located on the south side of the R unway 13/31 . This would allow aircraft to cross the extended runway centerline at a safe distance from the runway. Figure 9 displays where the l ocalizer antenna would need to be located (shown in yellow) in order for an
ILS approach that is offset to the north

, to be feasible.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 9 Figure 9

Conclusion: A n ILS approach that is offset to the north would n ot be feasible because the localizer antenna would need to be located on the south side of Runway 13/31. There is not sufficient land on the south side of the runway for a localizer antenna. Aircraft using the taxiways would also pass in front of the local izer which would reflect the localizer signal and
make the localizer unusable. An ILS approach that is offset to the north is not feasible.



### Analysis of ILS A pproach Offset to the South:

Both the QED and FAA analysis studied an ILS approach that is offset t o the south. A Freedom
of Information Act (FOIA) request of the proposed ILS procedure package revealed that the FAA is planning on implementing this offset ILS approach.

The controlling obstacle for this approach is an existing 345 ft AMSL building as sho wn in Figure 10 . This controlling obstacle requires that the Glide Path Angle is increased to 3.07 degrees. The existing 108 ft AMSL “cement stack” penetrates the OCS and missed approach segments of the instrument approach. Unless these “cement stack” pene trations are lowered or removed, the DA must be increased to 311 ft AMSL.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 10 Figure 10

When the proposed transfer station was included in the obstructions it was revealed that the proposed structure would penetrate the OCS . H owever the effect on the DA woul d not be greater than the existing 108 ft AMSL cement stack (Figure 11 )

. Therefore, provided that the other obstacles are not lowered or removed, the proposed transfer station would not necessitate an
increase to the DA of the offset ILS approach.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 11 Figure 11

The TERPS guidelines state that proposed obstructions shall not penetrate the OCS (Figure 12 )

. The proposed transfer station will penetrate the offset OCS by 21.2 ft. According the TERPS guidelines, the proposed transfer station should not be approved b y the FAA.

Figure 12

An analysis of the 34:1 OIS , for the proposed off

- set ILS approach to Runway 31, revealed that several existing structures penetrate this surface (Figure 13 and Figure 1 4 )

. The structures that penetrate the 34:1 OIS include the: ceme nt stack, localizer antenna, fence, the exis t ing transfer
station and existing 97 ft building. The proposed transfer station would also penetrate the 34:1 OIS. Due to these existing and proposed penetrations, the visibility requirements of this approach

co uld not be less that 3⁄4 mile or 4,000 ft RVR.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 12 Figure 1 3

– Top view of the 34:1 OIS

Figure 1 4

– Side view of 34:1 OIS

– Proposed transfer station penetrates by more than 37 ft

An analysis of the 20:1 OIS revealed that only two existing structures penetra te this surface (Figure 15 and 16

) . The structures that penetrate the 20:1 OIS include the: localizer antenna and

on

- airport fence. The proposed transfer station would also penetrate the 20:1 OIS. Due to these existing and proposed penetrations, the visibi lity requirements of this approach could not be less that 1 mile or 5,000 ft RVR. It is worth noting that the two existing penetrations could be eliminated if the localizer antenna were moved further away from the runway and the fenceAppendix I W illiams A viation C

onsultants, Inc. A 1

- 13 lowered. Eliminating these two existing penetrations would be reasonable in order to reduce the visibility requirements of this approach. If the proposed transfer station were constructed, this option would not be feasible.

Figure 15

– Top view of 20:1 OISAppendix I W illiams A viation C

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- 14 Figure 16

- Side view of 20:1 OIS

– Proposed transfer station penetrates by 3 ft

Conclusion: The proposed transfer station will penetrate the OCS but would have no effect on the DA of an offset ILS approach because the existing 108 ft AMSL cement stack has a
greater impact on the OCS then the proposed transfer station. The TERPS guidelines, however, state that proposed obstructions “shall not penetrate the OCS”. According the FAA’s TERPS guidelines the proposed transfer station should not be approved because it is a

p roposed obstruction.

The proposed transfer station will also penetrate the 20:1 OIS. Two existing structures already penetrate the 20:1 OIS

. H owever it may be possible to eliminate these penetrations by moving the localizer antenna and reducing the fence h eight. If the 20:1 OIS were free from penetration the visibility requirements for this approa ch could be reduced from 1 mile/ 5,000'

RVR to 3⁄4 mile/

4,000' RVR. Constructing the proposed transfer station would make this option of reducing the visibility requi rements to the offset ILS no longer feasible.



### Analysis of “straight

- in” ILS Approach:

Both the QED and FAA analysis studied a “straight

- in” ILS approach. The controlling obstacle for this approach is an existing 345 ft AMSL building as shown in Figure 17

. This controlling obstacle requires the Glide Path angle be increased to 3.08 degrees. The existing 108 ft AMSLAppendix I W illiams A viation C

onsultants, Inc. A 1

- 15 “cement stack” penetrates the OCS and missed approach segments of the instrument approach.
Unless these “cement stack” penetrations can be lowere d or removed, the DA must be increased
to 312 ft AMSL.

Figure 1 7Appendix I W illiams A viation C

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- 16 When the proposed transfer station was included in the obstructions analysis, it was revealed that the proposed structure would penetrate the OCS . H owever , provided that the other obstacles are not lowered or removed, the effect on the DA would not be greater than the existing 108 ft
AMSL cement stack (Figure 1 8 )

. Therefore, the proposed transfer station would not necessitate
an increase to the DA of the straight

- in ILS approach.

Figure 1 8

The TERPS guidelines state that proposed obstructions shall not penetrate the OCS (Figure 1 9 )

. The proposed transfer station will penetrate the straight in OCS by 8.4 ft. According the TERPS guidelines, the proposed transfer station should not b e approved by the FAA.

Figure 1 9Appendix I W illiams A viation C

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- 17 An analysis of the 34:1 OIS revealed that several existing structures penetrate this surface (Figure 20 and 21 ) . The structures that penetrate the 34:1 OIS include the: cement stack, localizer antenna, fence, existing tran sfer station and existing 97 ft building. The proposed transfer station would also penetrate the 34:1 OIS. Due to these existing and proposed penetrations, the visibility requirements of this approach could not be less that 3⁄4 mile or 4,000 ft

RVR.

Figure 20

– Top view of 34:1 OIS

Figure 21

- Side view of 34:1 OIS

– Proposed transfer station penetrates by more than 37 ftAppendix I W illiams A viation C

onsultants, Inc. A 1

- 18 An analysis of the 20:1 OIS revealed that only two existing structures penetrate this surface (Figure 22 and 23 ) . The structures that p enetrate the 20:1 OIS include the: localizer antenna and

on

- airport fence. The proposed transfer station would also penetrate the 20:1 OIS. Due to these existing and proposed penetrations, the visibility requirements of this approac h could not be less
that 1 mile/5 ,000 ft RVR. It is worth noting the two existing penetrations could be eliminated if the localizer antenna were moved further away from the runway and the fence lowered. Eliminating these two existing penetrations would be reasonable in order to r educe the visibility requirements of this approach. If the proposed transfer station were constructed, this option
would not be feasible.

Figure 22

– Top view of 20:1 OISAppendix I W illiams A viation C

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- 19 Figure 23

- Side view of 20:1 OIS

– Proposed transfer station penetrates by 3 ft

Conclusion: The proposed transfer station will penetrate the OCS but would have no effect on the DA of straight

- in ILS approach unless the existing 108 ft AMSL cement stack cannot be lowered or removed, in which case the proposed transfer station beco mes the controlling obstacle. The TERPS guidelines state that proposed obstructions “shall not penetrate the OCS”. According the FAA’s TERPS guidelines the proposed transfer station should not be approved becau se it is a proposed obstruction and it penetra tes the OCS.

The proposed transfer station will also penetrate the 20:1 OIS. Two existing structures already penetrate the 20:1 OIS however it may be possible to eliminate these penetrations by moving the localizer antenna and reducing the fence height. If the 20:1 OIS were free from penetration the visibility requirements for this approach could be reduced from 1 mile (5,000' RVR) to 3⁄4 mile (4,000' RVR). Constructing the proposed transfer station would make this option of reducing the visibility requiremen ts to the straight

- in ILS no longer feasible.Appendix I W illiams A viation C

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- 20 

### Straight in ILS with 3 degree glide slope and all off

- airport obstacles lowered (T est for Cat II ILS feasibility)

ILS approaches can be divided into three categories. An ILS is considered to be Category I if the instrument approach has a Decision Height (DH) not lower than 200 feet above the touchdown zone. A Category 2 instrument approach has a DH not lower than 100 feet above the touchdown zone. A Category III approach can have a DH as low as 0 feet.

An analysis was completed to determine how the proposed transfer station would impact the feasibility of a Cat II ILS approach. This analysis assumed th at all the off

- airport obstacle s were lowered so as to not penetrate the 34:1visibility surface and an OCS associated with a 3 degree glide slope. Therefore this analysis assumed the following reductions:

1. The 108 ft AMSL cement stack was lowered 25 ft to a height of 83 ft AMSL 2. The existing 97 ft AMSL building was lowered 2 ft to a height of 95 ft AMSL 3. The exis ting 69 ft AMSL transfer station was lowered 3 ft to a height of 66 ft ASML 4. The existing 345 ft AMSL building was lowered 8 ft to a height 337 ft AMSL (Note: It is believed this reduction is applicable only to an antenna on the Skyline Towers 6 )

The anal ysis also assumed that the on

- airport obstacles including the fence and localizer antenna were either moved or approved as exceptions by the FAA. It was also assumed that all on

- airport requirements were fulfilled including the introduction of an airport l ighting system, dual glide slope antennae, aircraft clearance areas and relocation of ILS antenna.

Th e analysis revealed that the new air traffic control tower (ATCT) penetrated the missed approach obstacle clearance surfaces associated with a straight

- in instrument approach as shown in Figure 24

.Appendix I W illiams A viation C

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- 21 Figure 24

Figure 25 displays that the new air traffic control tower penetrated the missed approach segment by 15 ft.

Figure 25

Assuming the existing structures were reduced, the new Air Traffic Control tower would then penetrate the missed approach segment of the obstacle clearance surfaces. A DA of 219 AMSL would be required to mitigate the penetration of the new Air Traffic Control Tower. The visibility requirements for this approach could also be red uced to 1⁄2 mile/RVR o f 2,400 ft.

Conclusion: The TERPS design guidelines for a CAT II ILS approach include a requirement for the CAT I ILS to achieve a DH of 200 ft and visibility of 1⁄2 mile. The penetration of the new Air Traffic Control tower to the misse d approach segment of the CAT I ILS surfaces makes a CAT II ILS not feasible. Therefore th e impact of the proposed transfer station on the feasibility of a CAT II ILS approach is not applicable.Appendix I W illiams A viation C

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- 22 

### Straight in ILS with key obstacles lowered

An analysis was completed to determine how the proposed transfer station would impact a straight in ILS approach assuming key obstacle were lowered so as to not penetrate the 34:1visibility surface and on airport obstacles including the fence and localizer antenna wer e either moved or approved as exceptions by the FAA

. This analysis also assumed all on

- airport requirements were fulfilled including the introduction of an airport lighting system. Therefore this analysis assumed the following reductions:

1. The 108 ft AMSL cement stack was lowered 25 ft to a height of 83 ft AMSL 2. The existing 97 ft AMSL building was lowered 2 ft to a height of 95 ft AMSL 3. The existing 69 ft AMSL transfer station was lowered 3 ft to a height of 66 ft ASML

The controlling obstacle for this app roach is an existing 345 ft AMSL building as shown in Figure 26 . This controlling obstacle requires the Glide Path angle be increased to 3.08 degrees.

Figure 26

Assuming the existing structures are reduced, the new Air Traffic Control tower would then penetrate the missed approach segment of the obstacle clearance surfaces as shown Figure 27 . A DA of 21 9 AMSL would be required to mitigate the penetration of the new Air Traffic Control
Tower. The visibility requirements for this approach could also be reduced to 1⁄2 mile/ RVR of 2,4 00 ft.Appendix I W illiams A viation C

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- 23 Figure 27

The introduction of the proposed transfer station into t his analysis revealed that the DA would need to be increased to 248 AMSL . The 20:1 OIS would also be penetrated; therefore the visibility requirements would be increased to 1 mile/5,000 ft RVR.

Conclusion: Assuming that key obstacles could be reduced in height so as to n ot penetrate the 34:1 OIS, the DA could be reduced to 21 9 AMSL and visibility requirements reduced to 1⁄2 mile/RVR of 2,400 ft. The propo sed transfer station would substantially impact this scenario in that the DA would be increased to at least 248 AMSL and the visibility requirements increase d to 1 mile/5,000 ft RVR.

Bird Attractant and Runway Protection Zone

The NSMTS will receive in exc ess of 2000 tons of loose garbage daily. Garbage trucks will dump their loads inside the transfer station. Workers will then load the garbage into containers, and lid the containers. The containers will be placed on barges and transported, by barge, throug h waterways that cross beneath the flight paths of LaGuardia Runways 31 and 22. The barges will pass within 500 feet of the end of Runway 31 and through the flight path of Runway 22.

The North Shore Marine Transfer Station expansion, despite its planned facility enclosure, barge trash containers, and other potential mitigating efforts, will attract large numbers of medium to large sized birds; in particular, high concentrations of C rows and Gull s.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 24 Exposed trash from inadequately

- sealed containers, per ipheral trash spill over onto barge surfaces and continuous odors emanating from barges and the facility, will serve as powerful bird attractants as these vessels transit runway centerline. The presence of these birds pose high
risks to aircraft.

In the p ast nine months there have been three reported bird strikes at LGA, including the bird strike that brought down US AIR Flight 1451. T he garbage processed at the NSMTS will leave that facility by barge, also a bird attractant that will pass within 5 00 feet of Runway 31, and Runway 22 at LaGuardia Airport.

The NSMTS would also be located in the runway protection zone (RPZ) for Runway 31 which extends 2,500 ft from the end of the runway (Figure 28 ). According to FAA guidelines (Advisory Circular 150

- 520

- 33) bi rd attractant s, such as waste management facilities should not
be constructed within the RPZ.

Figure 28

Were there no plans to install an ILS for Runway 31, the RPZ for that runway would extend only 1,700 feet, and the NSMTS would be outside the RPZ. Bu t FAA airport design guidelines (Adivsory Circular 150

- 5300

- 13) state clearly that the calculation of the RPZ is determined not only by existing navigation aids, but by any plans to install a modern ILS navigation aid on that Runway.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 25 Proximity of Approachi ng Aircraft

The NSMTS will rise 100 feet above the level of Flushing Bay . In normal operations, the approach path for an aircraft landing on R unway 31 will pass less than 70 feet vertically and less
than 350 feet horizontally from the NSMTS structure. As s tated previously, the landing phase of flight places a tremendous amount of stress on the pilot. As a pilot approaches Runway 31, the NSMTS structures and birds flying around the facility will undoubtedly be a distraction to pilots approaching Runway 31. T he transfer station’s proximity to approaching aircraft could place the aircraft, its passengers , crew and people on the ground in jeopardy

.

Consultants Conclusions:

A n ILS approach that is offset to the north would not be feasible because the localizer a ntenna would need to be located on the south side of Runway 13/31. There is not sufficient land on the south side of the runway for a localizer antenna. Aircraft using the taxiways would also pass in front of the localizer which would reflect the localizer signal and make the localizer
unusable. An ILS approach that is offset to the north is not feasible.

The proposed transfer station will penetrate the OCS for both a “Straight

- in” and offset ILS approach. These penetrations will result in the NSMTS being t he controlling obstacle, unless
the existing 108 ft AMSL cement stack cannot be lowered or removed. The TERPS guidelines, however, state that proposed obstructions “shall not penetrate the OCS”. According the FAA’s TERPS guidelines the proposed transfer st ation should not be approved because it is a proposed obstruction.

The proposed transfer station will also penetrate the 20:1 OIS for both the “straight

- in” and offset ILS approaches . Two existing structures already penetrate the 20:1 OIS, however it may
b e possible to eliminate these penetrations by moving the localizer antenna and reducing the fence height. If the 20:1 OIS were free from penetration the visibility requirements for this approach could be reduced from 1 mile (5,000' RVR) to 3⁄4 mile (4,000' R VR). Constructing the proposed transfer station would make this option of reducing the visibility requirements to the offset ILS no longer feasible.

The TERPS design guidelines for a CAT II ILS approach include a requirement for the CAT I ILS to achieve a DH of 200 ft and visibility of 1⁄2 mile. The penetration of the new Air Traffic Control tower to the missed approach segment of the CAT I ILS surfaces makes a CAT II ILS not feasible. Therefore th e impact of the proposed transfer station on the feasibility o f a CAT II ILS approach is not applicable.

Assuming that off airport obstacles could be reduced in height so as to not penetrate the 34:1 OIS, the DA could be reduced to 219 AMSL and visibility requirements reduced to 1⁄2 mile/RVR of 2,400 ft. The proposed transfer station would impact this scenario in that the DA would be increased to 248 ft AMSL and the visibility requirements increased to 1 mile/5,000 ft
RVR.Appendix I W illiams A viation C

onsultants, Inc. A 1

- 26 According to the United States Standard for Terminal Instrument Procedures 8260.3B, the proposed transfer station should not be approved because it will penetrate the OCS for the offset ILS as designed by the FAA. According to these guidelines, proposed obstructions shall not penetrate the OCS. Constructing the proposed transfer station will prevent t he DA from being reduced to as low as 219 ft AMSL should key obstacles be reduced in height in the future. The proposed transfer station would also eliminate the possibility of reducing the visibility requirements of this approach from 1 mile (5,000' RVR) to 1/2 mile ( 2
, 4 00' RVR)
because the struct ure will penetrate the 20:1 OIS

.
Exposed trash from inadequately

- sealed containers, peripheral trash spill over onto barge surfaces, and continuous odors emanating from barges and the facility, will serve as power ful bird attractants as these vessels transit runway centerline. The presence of these birds pose high risks to aircraft.

The NSMTS would also be located in the runway protection zone (RPZ) for Runway 31 which extends 2,500 ft from the end of the runway. According to FAA guidelines (Advisory Circular
150

- 520

- 33) bird attractants, such as waste management facilities should not be constructed
within the RPZ.

It is Williams Aviation Consultant’s professional opinion that the NSMTS should not be permitted to be constructed. As outlined in this report the proposed NSMTS would pose a significant safety hazard to aircraft approaching LG A and prevent an Instrument Landing System approach from achieving the lowest possible DA and Visibility minimums . Th is comprehen sive review concluded the NSMTS would be a significant safety hazard to aircraft for the following reasons:

1. The construction of the NSMTS buildings will severely restrict the potential Decision Altitude and visibility requirements of the proposed ILS appro ach procedure to Runway 31.
2. The construction of the NSMTS will attract a significant amount of large birds that can be ingested into the jet engines of arriving and departing aircraft thereby causing a catastrophic failure of the engine.
3. The approval of th e NSMTS is in direct violation of Federal Aviation Administration’s (FAA) Terminal Instrument Procedure Guidelines and should be determined to be a hazard to navigation by the FAA.
4. The proposed transfer station would be in the Runway Protection Zone (RPZ) of Runway 31. FAA airport design guidelines discourage any projects that could
attract birds within the RPZ.

5. The NSMTS will be a significant obstacle and distraction located very close to the end of Runway 31 which pilots will need to avoid during the crit ical landing phase of flight.Appendix II

– Acronyms and Definitions

A 2

- 1

ASBL

– Approach Surface Base Line

- A horizontal line tangent to the surface of the earth at the runway threshold (RWT) point, aligned with the final approach course.

Category I (CAT I) Approach

- A precision instrument approach and landing with a decision height not lower than 60m (200 ft) and with either a visibility not less than 800m (2400 ft), or a runway visual range not less than 550m (1800 ft).

Category II (CAT II) Approach

- A precisi on instrument approach and landing with a decision height lower than 60m (200 ft) but not lower than 30m (100 ft) and a runway visual range not less than 350m (1200 ft).

DA

– Decision Altitude

- A specified altitude in reference to mean sea level in an ap proach with vertical guidance at which a missed approach must be initiated if the required visual references to continue the approach have not been established.

DH

– Decision Height

- The height, specified in mean sea level (MSL), above the highest

runway elevation in the touchdown zone at which a missed approach must be initiated if the required visual reference has not been established.

DME

- Distance Measuring Equipment

- On many instrument landing system procedures, a DME transmitter is placed at or n ear the localizer or glide slope transmitter to provide runway distance information for the pilot. The pilot has a DME receiver on board the aircraft which displays the distance from the DME transmitter.

FTP

– Fictitious Threshold Point

- The equivalent o f the landing threshold point (LTP) when the final approach course is offset from runway centerline. It is the intersection of the final course and a line perpendicular to the final course that passes through the LTP.

GPA

– Glide Path Angle

- The angular displacement of the glidepath from a horizontal plane that passes through the LTP/FTP. This angle is published on approach charts.

GPI

– Ground Point of Intercept

- A point in the vertical plane containing the glidepath where the vertical path intercepts the ASBL. GPI is expressed as a distance from RWT.

GQS

– Glide Qualification Surface

- The GQS extends from the runway threshold along the runway centerline extended to the DA point. It limits the height of obstructions between DA and RWT. When obstructio ns exceed the height of the GQS, an approach procedure with positive vertical guidance (ILS, MLS, TLS, GLS, VNAV, etc.) is not authorized.

IFR

- Instrument Flight Rules

- When you are operating under instrument flight rules, you can fly in the clouds wit h no reference to the ground or horizon. Instrument flight rules govern flight operations in weather conditions below VFR minimums.Appendix II

– Acronyms and Definitions

A 2

- 2

ILS

- Instrument Landing System

– A precision instrument approach system that normally consists of a localizer and glide s lope electronics and visual aids, namely an outer marker, middle marker and approach lights.

LTP

– Landing Threshold Point

- The LTP is a 3D point at the intersection of the runway centerline and the runway threshold.

OCA

– Obstacle Clearance Area

- The area, defined by criteria, that is evaluated for obstacles.

OCS

– Obstacle Clearance Surface

- An inclined obstacle evaluation surface associated with a glidepath. The separation between this surface and the glidepath angle at any given distance fr om GPI defines the MINIMUM required obstruction clearance at that point.

OEA

– Obstacle Evaluation Area

- The area, defined by criteria, that is evaluated for obstacles.

OIS

– Obstacle Identification Surface

– A 20:1 and 34:1 surface which is used to det ermine the visibility requirements of an IAP.

RVR

– Runway Visual Range

- RVR is a system of measuring the visibility along the runway. An instrumentally derived value, it represents the horizontal distance a pilot will see down the runway from the approa ch end. RVR is based on the sighting of either high intensity runway lights or the visual contrast of other targets, whichever yields the greater visual range.

RWT

– Runway Threshold

- The RWT marks the beginning of that part of the runway usable for land ing. It extends the full width of the runway. The RWT geographic coordinates identify the point the runway centerline crosses the RWT.