EXHIBIT

Federal Aviation i---!d3=-

Administration

Memorandum

Subject:

May 20,2008

Acting Director, Airport Safety and Standards (AAS-1)

Acting Manager, Air Transportation Division (AFS-200) / ~.~ .~

Manager, General Aviation and Commercial Division (Afi800l M

Manager, 135 Air Carrier Operations Branch (AFS-250)

Manager, Commercial Operations Branch, (AFS-820) jtj, &/;)

Safety of C and D Category Aircraft Operations at the Santa Monica Municipal

Airport (SMO)

Date:

To:

From:

The Federal Aviation Administration (FAA) Flight Standards Service HQ, through the Manager, Air

Transportation Division (AFS-200), the Manager, General Aviation and Commercial Division (AFS800) and in coordination with Manager, 135 Air Carrier Operations Branch (AFS-250) and the

Manager, Commercial Operations Branch, (AFS-820), has reviewed operations of the C and D

category aircraft at the Santa Monica Airport (SMa) within the context of the City of Santa Monica's

2008 Ordinance banning operations by such aircraft.

The vast majority of turbojet airplanes operating at Santa Monica Municipal Airport (SMa), to include

C and D category types.were certified in accordance with 14 CFR Part 25, Airworthiness Standards:

Transport Category Airplanes. These certification standards apply to airplanes ranging from business

jets to large airliners. As a result of the FAA's certification process and regulations, runway lengths

should be determined on case-by-case basis and rely upon FAA-Approved Airplane Flight Manual

(AFM) data. These standards include requirements to determine the safe distances required for the

airplane to take off and land under certain conditions, airplane weights, and configurations within the

operating envelope defined for the airplane.

The rules under which the airplane is operated (i.e., 14 CFR Parts 91, 135) complement the takeoff and

landing distances determined under 14 CFR Part 25 to the specific operation and airport for each

takeoff and landing. The combination of the airplane certification rules and the operating rules provide

the requirements and parameters under which takeoff and landing operations can be safely conducted.

In other words, the safety of an aircraft's operation is a function ofthe requirements of the FAAapproved AFM and the underlying regulatory frame work.

It is noted that both types of regulations, aircraft certification (14 CFR Part 25) and operational

regulations (e.g. 14 CFR Part 91 and Part 135) specifically cover runway length requirements. The

operation of a particular aircraft/flight, including the required runway for a take off and landing, and

combined with proper pilot certification are all exclusively regulated by the FAA.
2

Based on the above, we find that C and D aircraft operations conducted as per the limitations of the

applicable AFMs and applicable operational regulations, are not inherently unsafe at SMO. Therefore,

we see no reason for the City of Santa Monica to restrict operations of C and D category aircraft at

SMO.

If you have any questions or need any clarification on the issue discussed here, please feel free to let us

know and we will be glad to assist.
Federal Aviation

Administration

Memorandum

Date: May 20, 2008

Subject:

Acting Director, Airport Safety and Standards (AAS-1)

Kansas City Aircraft Evaluation Group (AEG-11)

Long Beach Aircraft Evaluation Group (AEG-05)

Safety of C and D Category Aircraft Operations at the Santa Monica

Municipal Airport (SMO)

To:

From:

Technical Discussion and Analysis

The Federal Aviation Administration Kansas City Aircraft Evaluation Group (AEG-ll) and the Long

Beach Aircraft Evaluation Group (AEG-05) have reviewed operations of the C and D category aircraft

at the Santa Monica Airport (SMO) within the context of the City of Santa Monica's 2008 Ordinance

banning operations by such aircraft. This technical discussion and Analysis is based upon a submission

by the Los Angeles Flights Standards District Office (LAX - FSDO) and Western-Pacific Region Flight

Standards Division (AWP-200).

The City of Santa Monica recently enacted Santa Monica Ordinance No. 2251CCS § 1, which was

adopted as of 2/26/2008. It states, in pertinent part:

10.04.06.220 Conformance Requirements.

(a) Statement of Purpose and Authority. This Section is enacted pursuant to the authority of the City of

Santa Monica as the owner, operator and proprietor of the Airport to make reasonable regulations

intended to protect the safety of persons living adjacent to the Airport and flying in aircraft using the

Airport. This Section comports with agreements between the City and the Federal Aviation

Administration recognizing the City's obligation to serve category A and B aircraft at the Airport and its

right to prohibit or limit any other given type, kind or class of aeronautical use of the Airport if such

action is necessary for the Airport's safe and efficient operation.

(b) Prohibition. No person operating a category C or D aircraft, as defined by the FAA's standards,

shall land at or depart from the Santa Monica Municipal Airport.

The ordinance refers to categories A through D as an attempt to categorize aircraft. The intent of the

following discussion is to illustrate the basic issues from a technical point of view, and to demonstrate

from a practical perspective, how a sample of turbojet powered aircraft actually determine safe

operations into and out of the Santa Monica Airport.
14 CFR Part 14, §97 defines the various categories of aircraft as follows:

§ 97.1 Applicability.

(a) This part prescribes standard instrument approach procedures to civil airports in the United

States and the weather minimums that apply to landings under IFR at those airports.

(b) This part also prescribes obstacle departure procedures (ODPs) for certain civil airports in the

United States and the weather minimums that apply to takeoffs under IFR at civil airports in the

United States.

§ 97.3 Symbols and terms used in procedures.

As used in the standard instrument procedures prescribed in this part--

Aircraft approach category means a grouping of aircraft based on a speed of VREF, if specified,

or if VREF is not specified, 1.3 Vso at the maximum certificated landing weight. VREF, Vso,

and the maximum certificated landing weight are those values as established for the aircraft by

the certification authority of the country of registry. The categories are as follows--

(1) Category A: Speed less than 91 knots.

(2) Category B: Speed 91 knots or more but less than 121 knots.

(3) Category C: Speed 121 knots or more but less than 141 knots.

(4) Category D: Speed 141 knots or more but less than 166 knots.

(5) Category E: Speed 166 knots or more.

Generally, Category A aircraft are propeller driven aircraft certificated under CFR 14 Part 23. However,

some part 23 aircraft fall into category B, and occasionally category C. (Example: Piper Aerostar

landing flaps up, or some models of the MU-2 series).

The types of aircraft the City is attempting to prohibit from Santa Monica airport are the corporate jet

(examples are Learjets, Gulfstreams, Challengers, Citations). These are known as transport category

aircraft, and are certificated in accordance with the identical standards applied to aircraft being flown by

airlines. These standards dictate strict performance criteria and redundancy. Many of these aircraft fall

into the category C and D the city is seeking to ban from its airport. However, these aircraft can also fall

into the approach category A or B that the city claims is "Safer."

14 CFR Part 97.3 was never meant to classify a type of aircraft, or to categorize it into a type of

operation, or restrict it from landing at a particular airport. 14 CFR Part 97.3 categorizes aircraft based

on its basic approach speed for a given set of conditions, primarily based on a derived number

designated as Vref. This number is published by the manufacturer and is generally determined by

multiplying the stall speed in the landing configuration of the aircraft by the factor of 1.3. The aircraft is

then categorized by the pilot when he refers to his approach plate. A true and correct copy of the Santa

Monica VOR or GPS-A approach plate (Jeppesen version) is attached hereto and hereinafter referred to

as exhibit 1 and exhibit 2. The purpose of the categories is to maintain the aircraft in "protected

airspace" for the calculated radius of turn, based on the maximum airspeed within the given category.

This "protected airspace" is determined by calculating clearance above obstacles within the rings (A, B,

C, D, E) that the aircraft is likely to pass over in its approach category.

2
This is important because the faster the aircraft, the larger the ring, and therefore the further from the

airport the aircraft will travel when it executes a tum. In other words, the faster the aircraft travels, the

larger the radius of tum. This is reflected to the pilot at the bottom of the approach chart (exhibit 1)

wherein it permits the pilot that identifies Culve intersection to descend to 680' msl in categories A, B or

C, but the pilot is restricted to 740' msl in category D. Without Culve intersection identified, all

categories are restricted to 1,120' msl.

It is important to note this categorization system is based on the approach speed of the aircraft and not

the landing or "over the fence" speed. It does not take into account the takeoff or landing performance

data requirements. This data is determined by the FAA Approved Flight Manual (AFM) and the

capabilities of the aircraft and the applicable operational regulations. The safety margins are factored

into whether the pilot can conduct a flight to an airport for the conditions at the estimated time of

landing. Additionally, this categorization system applies only to aircraft that are being operated in the

instrument approach environment, and was never intended for any other purpose. There are many

instances where one aircraft can be operated in several categories based on legal landing weight I

published Vref I runway and environmental conditions.

Transport Category airplanes are certificated in accordance with 14 CFR Part 25. They usually have a

maximum gross takeoff weight of more than 12,500 lbs, require two pilots, and in some cases, a Flight

Engineer. The Pilot in Command (PIC) is required to hold a type rating and must maintain the same

currency requirements as the pilot of a 14 CFR Part 23 aircraft. The pilot must maintain the additional

currency requirements listed in 14 CFR Part 61.57 and complete an annual Pilot Proficiency Check

(PPC) in accordance with 14 CFR Part 61.58. The Second in Command (SIC) must meet the

requirements of 14 CFR Part 61.55.

Flight crews that fly for On-Demand Air Carriers under 14 CFR Part 135 or a fractional operators under

14 CFR Part 91K must meet even more stringent training and checking requirements in addition to

Flight and Duty time limitations. The PIC must meet all of the above requirements plus receive

recurrent training and checking every six months. The SIC is required to receive recurrent training and

checking on an annual basis. Companies that operate these types of aircraft often incorporate additional

internal risk assessment tools audits into their flight departments. These requirements are being driven

in many cases to become industry standards by the Insurance and Financing Companies that underwrite

the aircraft.

14 CFR Part 25 certificated Transport Category Aircraft meet stringent performance requirements

regarding takeoff, departure, enroute and landing phases of flight. In addition to the "structural

limitations" such as maximum certificated takeoff weight, they become further limited by such factors

as density altitude, runway available, runway condition, weather, departure obstacle clearance

considerations, and crew pairings. The most restrictive of these limitations is required to be complied

with.

Transport Category aircraft performance requires that when the failure of the most critical engine

occurs, the aircraft maintains the performance capability to stop on the remaining runway, or continue

the takeoff with the remaining engine(s). Similar limitations exist for landing. When operated at legal

weights, the 14 CFR Part 25 aircraft can always land on the available runway or execute a go around I

missed approach with an inoperative engine.

3
TAKE OFF

When computing the takeoff requirements of Part 25 Transport Category aircraft, the pilot must

compute a maximum weight for the aircraft so that he has what is known as "Balanced Field Length."

This means that should an engine fail at the most critical moment of the takeoff roll (V 1), the aircraft

will be able to safely stop on the runway remaining (NOTE: The benefit of thrust reversers is not

included in this computation) or continue the takeoff and be at least 35 feet above the end of the runway,

and continue the takeoff profile in a predetermined takeoff flight path (Climb Requirement). The

aircraft performance must be able to meet the following three diagrammed conditions:

\/1 STOP

I-ABORT-I

o 0 0

r-- ACCEL / STOP OISTANCE-1

RElEASE

BRAKE RElEASE

BRAKE

IENGINE FAILURE AT Vtl

V1. VR VLOF

I I I

I~ Accel / Go Distance --"'1~I

The pilot normally controls the weight of the aircraft by how much fuel he puts on board, which dictates

the distance the aircraft can safely fly. The pilot can utilizes Aircraft Flight Manual (AFM) performance

charts and graphs or computerized programs derived from the AFM. Many operators subscribe to

commercial services that provide these calculations.

LANDING

In order to meet the 14 CFR Part 25 landing performance requirements, the aircraft must be able to:

Land and come to a complete stop from 50 Ft AGL and Vrefat the approach end of the runway. The

total distance required is the sum of the distance from Vrefand 50 ft AGL to touchdown, and the distance

from touchdown to a complete stop. An added safety margin is provided by not taking into account the

benefit of thrust reversers when computing the runway required.

If operating under 14 CFR Part 135 or 14 CFR Part

121, the aircraft must be able to land and stop within

60% of the available runway. If an operator is granted

Eligible on Demand status and is authorized to use a

Destination Airport Analysis Program, the aircraft must

be able to land and stop with 80% of the available

runway.

Stop without exceeding the brake energy limit. If brake

energy is a limiting factor, a chart is provided in the

AFM to determine the maximum brake energy limited

landing weight.

4

Landing Path Profile

One Engine Inoperative

VREF

LANDING CLIMB

(ALL ENGINE ~

32% MIN. GRADIENT) ~

~

VREF+1D

APPROACH-CLIMB

~ (ENGINE-OU;

2.1% MIN.

-.."".; ~ •••GRADIENT)

--~_VREF~1.3VSO- :7

50' ------a- I

THRESHOLD ~tDISTANCE~LANDING IJi

EFFECTIVE RUNWAY

I LENGTH
Climb (Balked landing Climb) (Minimum 3.2% gradient) in landing configuration with all engmes

operating.

Climb (Approach Climb) (Minimum 2.1% gradient) with landing gear up, flaps at the approach setting,

and one engine inoperative.

If any of these requirements can not be met, the landing weight is reduced to the lowest weight to meet

these requirements. These performance limits are "Operating Limitations". They define the maximum

landing weight for the particular scenario. Again, these are "Operating Limitations", not just advisory

information.

fiELD

I ENTGH

lIM:TED

i'ERFORMANCE

SECTIOr. 62

AFM

AIRPLANE CONDiTIONS

AiRPORT CONDITiONS

ATMOSPHERE CONDmONS

CLIMB

LIMITED

PERFOPMANCE

SECTION63

AFI.<

OBSTACLE

ClEAR."NC E

SECTION 6.6.

AFI,f

TIRE SPEED

LIMITS

SECTION E 4.

AFM

STRUCTURAl

OPERATIONAL

WEIGHT L'MITS

SEcnO'll

AFM

REDUCE AND

__-----I OPTIt,IIZE

TO WEIGHT

NO

GINISHE0

Operating a 14 CFR Part 25 aircraft as described above, into and out of Santa Monica is accomplished

safely in compliance with federal regulations and in accordance with the FAA Approved Flight

Manuals. 14 CFR Part 91.103 requires all pilots, for all flights, regardless of the kind of aircraft they are

flying, to determine the required runway lengths at the airports of intended use, and to compute the

takeoff and landing distance data for their aircraft. An analysis of several different makes and models of

aircraft utilizing a wide range of operating weights that frequent Santa Monica Airport has been derived

from the individual aircraft flight manuals data. Runway 21 is utilized the most because of the westerly

prevailing winds.

5
Given Conditions: Aircraft Assumptions:

Airport: KSMO Anti Ice:

OFF

Runway: 21 Anti Skid:

ON

Runway length: 4,987 Bleed Air:

ON

Runway slope: -1.2% (downhill) Thrust Reverse:

Armed

Condition: Dry, no contamination Spoilers/Speed brakes:

Armed

Barometric Pressure: 29.92 Hg APR: Armed

Temperature: 20°e. Rudder Boost:

ON

Wind: Calm

NOTE: Aircraft as equipped (some aircraft mayor may not have the above equipment)

TAKEOFF & LANDING DATA

The following Table displays the maximum values for the conditions stated.

14CFR§91 § 135 § 135

Maximum Max. Max. Landing Max. Landing § 97 Ale Type Takeoff Wt. Wt.

Weight Landing Wt. 60% 80% Category

100% Non-E.O.D. E.O.D.

G-550 80,299 75,300 75,300 75,300 B,C, D

G-IVSP 71,087 66,000 66,000 66,000 B,C, D

DA-900EX 47,534 44,500 40,127 44,500 B,C

CL-604 42,994 38,000 38,000 38,000 B,C

LR-60 22,221 19,500 N/A 17,832 C

LR-55 19,878 21,000 16,694 21,000 C

CE-550B 14,800 13,500 13,500 13,500 A, B

N/A: Not Authorized

An On-Demand Air Carrier operating a Lear 60 as detailed above is not able to utilize Santa

Monica Airport when using the 60% rule in accordance with 14 CFR Part 135.385. In order

to utilize the 80% rule, an Air Carrier must meet additional requirements and be authorized

Eligible On Demand Operations in accordance with 14 CFR Part 135.4.

6
Exhibit 1

AL-5G23 iFAAI

VOR or GPS-A

SANTA MONICA MUNI (SMO)

MISSEDAPPROACH: Climo tc 4' 00 via SMa R-250

and FIM R·' .IS to SADDE Inl and hold.

V

III Ci-ding ~ot ou'horized Northwes' of Rwy 3-21.

SOCAL AI!? CON

128.5 381.6

SANTA MONICA TOWER· GND CON UNICOI.'.

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