EXHIBIT

116

Report Addendum

DESIGN STANDARDS STUDY Santa Monica Airport

This addendum has been prepared to

update information as well as address

input provided by the Federal Aviation Administration (FAA)with regard

to the Santa Monica Airport Design

Standards Study. Specifically this

addendum is intended to:

• Update statistical data regarding

airport activity, in particular business jet use.

• Update, any other existing conditions at the airport that may be

relevant to the airport design standards.

• Update design standards per

Change 7 of FAAAdvisory Circular

15/5300-13.

• Review potential runway safety

area (RSA)alternatives including:

• Do Nothing Alternative

• Updated EMAS Alternative in accordance with FAA Order 5200.9

• Net Suppression System

• Partial Runway Safety Area

• Confirm or Revise the Recommendations of the Design Standards

Study.

ACTIVITY UPDATE

Table B from the Design Standards

Study presents the annual aircraft operations as counted by the air traffic

control tower, through 2001. This table is updated here in Table Al to include 2002 and 2003. Traffic in 2002,

was up 2.5 percent compared to the

previous year.

A-I
TABLE Al

Annual Aircraft Operations

Santa Monica Airport

Itinerant Local

Year AC AT GA MIL GA MIL Total % Local

1990 0 396 131,889 384 95,132 0 227,801 41.8%

1991 0 313 143,885 858 89,732 0 234,788 38.2%

1992 0 530 148,747 2,082 76,154 0 227,513 33.5%

1993 0 385 143,943 1,885 69,037 0 215,250 32.1%

1994 0 556 144,824 1,784 91,842 0 239,006 38.4%

1995 0 578 133,853 2,056 49,148 186 185,821 26.5%

1996 0 771 144,075 1,555 54,203 24 200,628 27.0%

1997 0 902 155,380 1,485 54,255 14 212,036 25.6%

1998 5 1,584 156,074 1,825 58,158 40 217,686 26.7%

1999 4 3,746 161,589 2,092 62,797 2 230,230 27.3%

2000 0 6,691 105,450 1,391 59,194 28 172,754 34.3%

2001 0 9,604 86,753 1,428 48,427 1,657 147,869 33.9%

2002 0 11,766 87,817 1,574 50,342 0 151,499 33.2%

2003 0 10,948 84,258 1,337 46,316 0 142,859 32.4%

Operations in 2003, however, were

down to 142,859, the lowest annual

operations total dating back to at least

1990. The percentage of local operations continued a downward trend

that began in 2000. At the same time,

air taxi activity exceeded 10,000 annual operations for the first time in

2002, then grew to 11,766 in 2003. Air

taxi operations have been growing

since 1997, due primarily to the increased use of fractional aircraft,

which are generally considered as air

taxi operators.

Table A2 is an update to Table D in

the study. Business jet operations

continue to rise at the airport. According to the information recorded by the

airport as part of its Noise Abatement

Program, there were 16,157 jet operations in 2002 and 16,210 in 2003.

With the decrease in total operations,

the percentage of business jet activity

has grown from 7.2 percent in 2000, to

11.3 percent in 2003.

TABLEA2 (update)

Business Jet Activity

Santa Monica Airport

2000 2001 2002 2003

Annual Operations

Airport Total 172,754 147,869 151,499 142,859

Business Jet 12,485 13,252 16,157 16,210

Business Jet % 7.2% 9.0% 10.7% 11.3%

The Design Standards Study determined the most demanding aircraft atSanta Monica Airport to be the Gulfstream IV (G-IV). For 12 months endA-2
ing in June of 2000 the G-IV accounted for approximately 950 operations. An updated analysis for 2003

indicates that the G-IV now accounts

for approximately 1,200 annual operations.

The updated analysis also evaluated

the percentage of business jets in each

Approach Category. Flight Plan data

from April, July, and October was

used for the update. This is presented

in Table A3. Based upon this data,

Approach Category B business jets

conducted 7,188 operations in 2003 to

comprise 44.4 percent of the business

jet operations. The number of operations is up from 6,700 in the 12 month

period in 1999-2000, but the percentage is down from 49.6 percent. Business jet operations in Approach Category C and D increased from 6,800 in

1999-2000 to 8,932 in 2003

FACILITY UPDATE

The existing facilities have changed a

minimal amount since the completion

of the Design Standards Study. The

aprons on the southeast side of the

airport have been overlaid and the tiedowns reconfigured, none of which

changes the effects on the runway design standard compliance. A blast

wall was installed beyond the east end

of the runway. Installed with funds

from an FAA AlP grant in 1994, this

blast wall is within the RSA standard

for all current approach categories.

FAA DESIGN

STANDARD UPDATE

The Design Standards Study was prepared based upon the airport safety

design standards published in FAA

Advisory Circular (AC) 150/530-13

through Change 6. On October 1,

2002, Change 7 of this AC was issued.

The principal changes involved the following:

Runway Protection Zones (RPZ).

Golf courses are no longer expressly

permitted in the RPZ, but may be if a

wildlife hazard assessment determines

that it will not provide an environment

attractive to birds.

The southwestern-most tip of the west

RPZ extends over the Penmar Golf

Course. Departure turns to overfly

this golf course are part of the airport's noise abatement procedures.

Precision Object Free Area

(POFA). This is a new surface that

applies to new instrument approach

procedures with less than 3/ 4-mile

visibility minimums.

This change is not applicable to Santa

Monica Airport.

Runway Safety Area (RSA) Width.

The RSA no longer increases in width

at higher elevations for Approach

Category D.

A-3
Table A3

Total Jet Mix 2003

Santa Monica Airport

April July October Combined Annualized

ARC Aircraft Type Operations Operations Operations Operations % Operations

8-1 Cessna 500 8 2 0 10 0.3% 42

8-1 Cessna 501 2 10 10 22 0.6% 93

8-1 Cessna 525 104 86 54 244 6.4% 1,031

8-1 Falcon 10 8 2 4 14 0.4% 59

8-1 Raytheon 390 4 8 4 16 0.4% 68

8-1 MU 300 0 2 2 4 0.1% 17

Total 8-1 126 110 74 310 8.1% 1,309

8-11 Hawker 800XP 38 92 54 184 4.8% 777

8-11 Cessna 525A 14 26 78 118 3.1% 498

8-11 Cessna 550 72 66 50 188 4.9% 794

8-11 Cessna 560 114 122 120 356 9.3% 1,504

8-11 Cessna 560XL: 94 72 118 284 7.4% 1,199

8-11 Falcon 20 2 4 8 14 0.4% 59

8-11 Falcon 200 0 0 0 0 0.0% 0

8-11 Falcon 2000 46 44 58 148 3.9% 625

8-11 Falcon 50 28 22 18 68 1.8% 287

8-11 Falcon 900 10 8 14 32 0.8% 135

Total 8-11 418 456 518 1392 36.3% 5,879

C-I BAe 125-400 10 16 0 26 0.7% 110

C-I Bae 125-600 10 20 6 36 0.9% 152

C-I Bae 125-700 48 16 34 98 2.6% 414

C-I Beech 400 100 100 116 316 8.2% 1,335

C-I IAI 1124 Westwind 36 42 38 116 3.0% 490

C-I Lear 24 0 0 0 0 0.0% 0

C-I Lear 25 0 0 0 0 0.0% 0

C-I Lear 28 0 0 0 0 0.0% 0

C-I Lear 31 12 18 28 58 1.5% 245

C-I Lear 35 48 48 40 136 3.5% 574

C-I Lear 36 6 0 10 16 0.4% 68

C-I Lear 45 20 24 26 70 1.8% 296

C-I Lear 55 8 4 6 18 0.5% 76

C-I Sabre 60 0 0 2 2 0.1% 8

Total C-I 298 288 306 892 23.2% 3,767

C-II Bae 125-1000 4 14 2 20 0.5% 84

C-II Canadair 600/601 62 40 36 138 3.6% 583

C-II Canadair 604 52 24 34 110 2.9% 465

C-II Cessna 650 24 30 30 84 2.2% 355

C-II Cessna 680 0 0 0 0 0.0% 0

C-II Cessna 750 112 114 116 342 8.9% 1,444

C-II Embraer 135BJ 0 0 10 10 0.3% 42

C-II Gulfstream 2000 6 2 0 8 0.2% 34

C-II Falcon Series F 0 2 2 4 0.1% 17

C-II IAI 1125 Astra 24 8 12 44 1.1% 186

C-II IAI 1126 Galaxy 16 22 20 58 1.5% 245

C-II Lockheed JetStar 0 0 0 0 0.0% 0

C-II Sabre 65 2 0 4 6 0.2% 25

C-II Sabre 80 2 2 0 4 0.1% 17

C-II Gulfstream III 0 0 0 0 0.0% 0

Total C-II 304 258 266 828 21.6% 3,497

0-1 Lear 60 38 50 48 136 3.5% 574

Total 0-1 38 50 48 136 3.5% 574

0-11 Gulfstream II 0 0 0 0 0.0% 0

0-11 Gulfstream IV 92 66 122 280 7.3% 1,183

Total 0-11 92 66 122 280 7.3% 1,183

Total Activity 1,276 1,228 1,334 3,838 100.0% 16,210

A-4
This change is not applicable to Santa

Monica Airport as the airport's elevation is just 175 feet above mean sea

level.

Threshold Siting Criteria. Changes

have been made in criteria for various

approaches and night operations. In

some cases, displacement of the threshold may be avoided by lighting obstructions. These changes align airport design criteria with the requirements in TERPS.

This change is not applicable to Santa

Monica Airport.

New Instrument Approach Category. Appendix 16 has been expanded

to include a new category of instrument approach, Approach Procedure

with Vertical Guidance (APV). Criteria for other instrument approach procedures have also been changed.

This change is not applicable to Santa

Monica Airport.

ALTERNATIVES REVIEW

The alternatives considered in the Design Standards Study were in accordance with the guidance provided in

FAA Order 5200.8, Runway Safety

Area Program. The alternatives considered the design standards of both

approach category B (as indicated on

the previously approved ALP, as well

as in the 1984 Airport Agreement), as

well as approach categories C and D.

The alternatives included:

Provide Full RSA - Categories CID:

This alternative was proven to be impracticable due to the extent and cost

of relocations in a densely populated

urban area. A total of 138 homes, a

gas station, and at least two commercial buildings would need to be acquired and removed from the Category

C or D RSA. Acquisition and relocation costs alone would total $132 million, with construction costs on the order of $135 million, for a total estimated cost of $267 million. Category

B: This alternative would affect 18

homes and the same commercial

buildings, including the gas station.

Total costs for this alternative were

estimated to be $33 million.

Displace Runway Thresholds -

Categories C/D: Under this alternative, the Category C or D standard

would shorten the effective length of

the runway such that it would be impractical for use. In addition, costs to

improve the design standards to this

level would still be estimated at $38

million. Category B: The alternative

to utilize displaced thresholds under

the Category B standard, however,

proved to be a feasible alternative.

The costs were on the order of

$200,000, and involved no relocations.

Engineered Materials Arresting

System (EMAS): This alternative

only applies to Categories C/D, as

more space is needed for EMAS.than

for the Category B RSA. At the time

of the Design Standards Study, the

FAA's policy did not view EMAS as an

equivalent substitute for a runway safetyarea. EMAS was to only be used

essentially as a last resort. Even then,

the space required for EMAS did not

fit well on the runway platform at

Santa Monica Airport, and did not

A-5
provide any solution for the RSA on

the landing end of the runway. The

alternative of placing EMAS beyond

each end of the runway would impact

24 home, the gas station, and commercial buildings, with an estimated total

cost of $79 million.

Realignment of the runway was considered initially, but was determined

as not feasible when it became evident

that any adjustments would not improve the situation, and in most cases,

make it worse for a higher price.

Similarly, various combinations of the

alternatives were considered as well.

Every attempt came back to Alternative 2B, which has the lowest cost,

creates the least disruption to the surrounding community, and provides for

the RSA standard within the parameters of both FAA Order 5200.8 and the

1984Airport Agreement.

At a November 20, 2003 meeting, a

group of FAA representatives from

both the Western-Pacific Region and

FAA Headquarters in Washington,

D.C. suggested that the following alternatives needed to be considered further:

• EMAS

• Do Nothing Alternative

• Other Arresting Systems

• Partial Runway Safety Area

In addition, FAA Order 5200.9 was

published on March 15, 2004. The

subject of this Order is Financial Feasibility and Equivalency of Runway

Safety Area Improvements and Engineered Material Arresting Systems.

These four alternatives have been considered and are discussed below.

EMAS ALTERNATIVE

As indicated above, guidance for

EMAS installation has now been established under FAA Order 5200.9 so

that it can be considered as equivalent

to a full runway safety area. From

this Order, "Analysis shows that for

aircraft overruns, EMAS can provide a

safety enhancement, while requiring

less land disturbance and lower construction costs. EMAS does not provide a benefit for short landings, so a

standard EMAS installation might

also include a displaced threshold."

To provide the safety factor for short

landings, the Order 5200.8 indicates,

"If the approach end of the runway has

vertical guidance, then provide at least

600 feet (or the length of the standard

RSA beyond the runway threshold,

whichever is less) between the end of

the EMAS bed and the runway threshold to accommodate overshoots ..."

The length of the EMAS bed is established by the maximum takeoff weight

of largest aircraft to use the airport.

At Santa Monica Airport, the maximum takeoff weight is 60,000 pounds.

It should also be noted that EMAS is

currently designed to be effective for

aircraft with a maximum takeoff

weight of at least 25,000 pounds.

Over 30 percent of the C and D operations at SMO are by aircraft weighing

less than 25,000 pounds. In addition,

the vast majority of category A and B

operations are by aircraft below this

weight.

Exhibit Al includes a graph from

FAA Order 5200.9 that is to be used in

determining the EMAS bed length.

A-6
For use at Santa Monica Airport, the

bed would need to be at least 270 feet

in length. To minimize erosion of the

bed by jet blast, it must also be at

least 75 feet behind the useable end of

the runway.

In Order 5200.9, the FAA also establishes a maximum feasibility cost.

This maximum feasibility cost is to be

applied when evaluating methods for

meeting the RSA standard. If neither

the standard RSA nor the standard

EMAS are below this cost, then it is

not financially feasible to improve the

RSA to standards or an equivalent

levelofEMAS.

The financial feasibility of the RSA

improvement at SMa can be determined from the second graph shown

on Exhibit AI. For the 270 foot bed

length, the maximum feasible cost of

the runway improvement would be

approximately $12 million.

Exhibit A2 depicts the standard

EMAS solution as it would be employed at Santa Monica Airport. This

would require 600 feet of safety area

behind each runway threshold, with

the EMAS bed placed at the back end

of this graded area. This alternative

would still require the relocation of an

estimated 75 homes, as well as the gas

station and adjacent commercial

buildings. The number of relocations

would be increased if the roads off either end are relocated instead of

bridged. Extending the 600 feet beyond the end of the runway will have

less impact than the full Category cm

RSA, but significantly more than the

Category B RSA. Regardless, all three

standard alternatives would well exceed the maximum financially feasible

cost of $12 million.

The second alternative displayed on

Exhibit A2 locates the EMAS just beyond the ends of the runway. This is

similar to Exhibit K in the earlier report, except that the new installation

standards would require 345 feet of

safety area beyond the runway ends,

and a subsequent landing threshold

displacement of 255 feet. To assist in

minimizing costs, a 400-foot wide RSA

was utilized. This RSA width is permissible for C-I and C-II design according to Table 3-3 in FAA AC

150/5300-13.

The takeoff run available (TaRA) and

the takeoff distance available (TODA)

would remain at the full length of the

runway, as would the accelerate-stop

distance available (ASDA). The landing distance available (LDA) would be

reduced to 4,732 feet. Provided both

roads . could be bridged, relocations

would be to 32 residences as well as

the gas station and commercial building. Again, the costs would still be

well above the financially feasible cost

of $12 million.

FAA Order 5200.9 states, "If it is not

financially feasible to improve the RSA

to standards or to an equivalent level

of EMAS, the choice becomes implementing the best alternative for enhancing safety that does not exceed the

maximum feasible cost for improving

the RSA."

The next subsection considers partial

solutions.

A-7
Exhibit Al

EMAS FEASIBILITY

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PARTIAL RUNWAY

SAFETY AREA

To this point the only feasible alternative remains meeting Category B

standards utilizing displaced thresholds. This alternative meets the design ARC on the approved ALP, as

well as complies with the 1984 Airport

Agreement. This subsection considers

other partial solutions.

Runway 21 is the preferential runway

from the standpoint of winds, airspace, as well as noise abatement.

Thus, partial solutions directed to the

traffic operating primarily on this

runway were considered.

From the previous analyses it is evident that the project becomes financially infeasible when it crosses the

roadways off either end of the runway.

In that case, the road must either be

bridged or relocated. Relocation of a

roadway requires additional residential relocation beyond what may be

necessary for the safety area itself.

Consideration was given to developing

EMAS within the confines of airport

property off the west end of the runway. There is approximately 240 feet

available before the wall along 23rd

Street. This wall would need to be

raised to near the elevation of the west

end of the runway. After providing for

the 75 feet between the runway end

and the start of EMAS, approximately

165 feet of EMAS could be installed,

assuming a vertical retaining wall up

to 50 feet high could be put in place.

This length of EMAS would be sufficient design for aircraft weighing up to

30,000 pounds.

Relocating the Runway 3 threshold

125 feet to the north would provide for

a standard EMAS at the far end of

Runway 21. This would result in the

runway length being reduced to 4,862

feet.

The safety area on landing is not addressed by EMAS. At least 600 feet of

the full safety area is needed off the

approach end. If this were provided

within airport property, the landing

distance available would be reduced to

4,262 feet. This is less than the LDA

provided for B-II design by Alternative

2B. Obviously, less displacement

would increase the LDA at the expense of adequate RSA.

As a result, the only potential for partial improvement appears to be adding

EMAS to the west end as discussed

above and depicted on Exhibit A3.

The cost of this partial RSA alternative is estimated at $9 million.

OTHER ARRESTING SYSTEMS

According to a report prepared by Boeing Commercial Airlines Group, there

are an estimated 2,000 aircraft arresting systems installed in 64 countries

worldwide. Most of them are associated with military facilities, including

airports used jointly by civilian and

military aircraft. There are three basic types of arresting systems available. In addition to EMAS, there are

also arresting cables and barriers.

Arresting cables are commonly associated with military operations. The

cable system involves a cable spanning

the width of the runway that must be

A-8
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PARTIAL RSA CONSIDERATIONS
engaged by an arresting gear hook on

the aircraft. Since virtually all general aviation aircraft are not equipped

with arresting gear, this is not a practical alternative for Santa Monica Airport.

Arresting barriers stop an aircraft by

absorbing the momentum of the aircraft in an overrun area, beyond the

operational runway. The common arresting barrier systems are net devices. Exhibit A4 depicts a typical

barrier set-up. For use to stop civilian

aircraft, the net system would need to

be in place at all times. Thus the pilot

would have to treat the net as an obstruction that would need to be

cleared on departure or arrival.

At Santa Monica Airport, the incline

at the west end of the runway might

allow the barrier to be placed at a

lower elevation such that it does not

penetrate the approach slope. Another concern with utilizing such a

system at a general aviation airport is

the wide range in aircraft sizes that

are involved. Aircraft currently utilizing Santa Monica Airport range from

light single-engine aircraft weighing

only a few thousand pounds, to the

maximum weight of 60,000 pounds.

The deceleration "G"-loading on a

small aircraft running into a net device designed to absorb the energy

necessary to stop a G-IV could severely damage the smaller aircraft

and seriously injure its passengers.

Based upon the design information

available to date, an arresting barrier

system is not recommended.

In addition, the net device will still

need to be placed a distance beyond

the runway end. There will also need

to be a distance beyond the net location to allow for a safe deceleration of

the aircraft. This is space that is not

readily available at SMa.

DO-NOTHING ALTERNATIVE

The "Do-Nothing" or "No Action" alternative is historically considered as

a base line comparison in environmental documents. It can also be utilized as the "base case" in benefit-cost

analysis, provided the benefits and the

costs can be substantially quantified.

When the primary need involves

safety design standards, however, doing nothing is difficult to justify as a

"base case" condition because the

safety concerns are not mitigated.

Under FAA Order 5200.8, the "Do

Nothing" alternative would be an RSA

Determination along the lines of

Paragraph 8.b.(4), "The existing RSA

does not meet current standards, and

it is not practicable to improve the

RSA."

Even when the full standard is not

practicable, Order 5200.8, Appendix 2

still recommends improving the RSA

to the extent practicable, even when it

results in an irregularly shaped RSA.

This indicates further, that the "Do

Nothing" alternative is the least desirable alternative for safety enhancement.

Continuation of the present condition

by doing nothing could readily be perceived as negligence on behalf of the

airport owner. In a letter to the Santa

Monica Airport Manager dated February 3, 2004, Mr. David Bennett, FAA

A-9
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Source: "Minimizing the Impact of Runway Arresting Systems on Commercial Airplane Operations",

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Exhibit A4

ARRESTING BARRIER SYSTEM
Director of Airport Safety and Standards, indicated, "Aircraft operating

on the existing runway at Santa

Monica, within the parameters set

forth in respective FAA-approved flight

manuals and conforming to the applicable Federal Aviation Regulations

governing the operation. of aircraft, are

operating safely."

While that is well and good for aircraft

operational requirements, the runway

safety area is specifically designed to

minimize injury and damage when an

aircraft overshoots or undershoots a

runway. In other words, the RSA is

designed for when things go wrong on

landing or takeoff. Within the last few

years, things did go wrong at Santa

Monica Airport for a Cessna 340 aircraft that ran off the west end of the

runway before being stopped by the

non-standard guard rail and landscaping. Both passengers aboard perished. Another recent incident at

nearby Burbank Airport where a

commercial jet overran the runway reinforces the importance of the RSA.

Mr. Bennett further writes in his letter, "...no FAA official has the authority to indemnify the City of Santa

Monica, nor accept any responsibility

that has not been specifically assigned

to the FAA under statute." With the

FAA's recent emphasis on runway

safety areas, and the fact that modifications to standards are not issued for

RSAs, the City of Santa Monica remains at the highest liability risk under the "DoNothing" alternative.

A-I0

CONCLUSION AND

RECOMMENDATIONS

As requested by the FAA, this

amendment or update to the Design

Standards Study for Santa Monica

Airport considers some additional alternatives not specifically discussed in

the original document. As indicated in

attached correspondence from Mr.

David Bennett, Director of Airport

Safety and Standards, the FAA has

agreed to make a Runway Safety Area

Improvement Program determination

for Santa Monica Airport based upon

proposed safety enhancements presented by the City of Santa Monica.

The most important and basic factors

that must be considered in the recommendation of any proposed safety

enhancements at Santa Monica Airport are:

1) Compliance with the 1984 Airport

Agreement

2) The General Utility Airport designation refarenced in the Airport

Agreement and the subsequent Approved Airport Layout Plans of 1986

and 1991

3) Potential liability to the airport

owner and operator, the City of Santa

Monica

The 1984 Airport Agreement established the intent of the agreement

with regards to design standards and

the aircraft to be served in Section 5 -

Airport Layout Plans and Section 8

-Commitment to Operate Airport.
Based upon communication through

meetings and correspondence, FAA

representatives appear to believe the

1984 Agreement requires the airport

to be capable of handing all types of

general aviation aircraft within Airport Design Group II. According to

Section 8 of the Agreement, however,

that is not the case. Section 8 reads,

"The Airport will be capable of accommodating most kinds of general aviation aircraft, generally consistent with

Group II Design standards set forth in

FAA Advisory Circular 150/5300.4B

dated February 24, 1983."

The second paragraph in Chapter One

of the referenced advisory circular

reads, "The standards, recommendations, and guidance material in this

Advisory Circular (AC) define an airport suitable for the less demanding

Aircraft Approach Category A and B

airplanes, i.e., airplanes with approach speeds of less than 121 knots.

The other airports need to be designed

and maintained to the standards, and

to the extent physically feasible, to the

recommendations in AC 150/5300-12,

Airport Design Standards- Transport

Airports, current edition." This clearly

indicates that the intent of the

Agreement was for the airport to be

maintained to accommodate B-II aircraft. If the intent were to accommodate C and/or D aircraft, then AC

150/5300-12 would have been referenced by the 1984 Agreement.

The 1984 ALP was adopted with the

understanding that the Airport would

operate under what would become the

B-II standards. Section 5 specifically

states, "The Airport Layout Plan submitted and approved by the FAA on

January 31, 1984 (City Map No. SMOA-II

1) is incorporated by reference into this

agreement and shall guide the development and improvement of the Airport for the duration of this Agreement." The broadest definition of General Utility in FAA AC 150/5300-4B,

dated September 23, 1983, was as follows:

"General Utility - Stage II. This type

of airport serves large airplanes in

Aircraft Approach Category A and

B and usually has the capability for

precision approach operations. This

airport is normally designed for

airplanes of Airplane Design

Groups I and II. It may also be designed to serve Approach Category A

large airplanes in Airplane Design

Group III. JJ

This clearly indicates that General

Utility is defined within ARC B-II and

A-III. There is no mention or suggestion of a design involving Approach

Categories C or D.

This is further supported and documented in both the 1986 and the 1991

ALP updates that were approved and

signed by the FAA Western Pacific

Region's Supervisor of the Standards

Section. The Airport Data Table on

the 1986 ALP indicated that the Airport Design Classification to be "General Utility." In the Runway Data Table of the 1991 ALP, the Runway

Classification remained General Utility, and the Airport Reference Code

was indicated to be B-II.

Thus, the 1984 Agreement, and subsequently the 1986 and 1991 ALPs, set

forth the B-II standard for Santa

Monica Airport. To consider altern a-
tives involving an upgrade for approach category C and/or D would be

in violation of the agreement, as well

as be contrary to the ALP. To change

the ARC on the ALP to C-II or D-II

would require environmental approval

through both the National Environmental Policy Act (NEPA) as well as

the California Environmental Quality

Act (CEQA). Based upon the history

and land use surrounding the Santa

Monica Airport, environmental approval of such a change would be

costly and time-consuming, if not impossible to attain. Unless the City of

Santa Monica has interest in sponsoring and approving an ARC upgrade,

considering such a change is entirely

moot anyway.

That leaves only the consideration of

practical alternatives to meet B-II design standards. There is nothing under current Federal Aviation Regulations requiring that Santa Monica

Airport has to meet design standards.

The FAA does have a policy in place to

require a runway be brought up to design standards if runway-related construction is federally funded. Since

Santa Monica Airport is not requesting such funding, there is no requirement to undertake any design standard improvements, unless the airport

was to apply for a new instrument approach.

Beyond a desire to enhance safety for

both the airport users and the surrounding community, the City's primary concern should be its potential

liability with regard to the lack of any

runway safety area. The FAA guidance and emphasis in recent years has

placed a priority on the runway safety

A-12

area. Subsequently, airports without

an adequate RSA are now more open

to potential litigation in the event that

an aircraft does overshoot or undershoot the runway for whatever reason.

Mr. Bennett's correspondence confirms

that the FAA does not have the authority to indemnify the City of Santa

Monica, nor accept any responsibility

that has not been specifically assigned

to the FAAunder statute.

Alternative 2B maintains the entire

runway length, although it does displace the thresholds by 300 feet each.

By applying declared distances, in accordance with FAA Order 5200.8, the

takeoff run available (TORA) and the

takeoff distance available (TODA) are

the full 4,987 feet of the runway. The

accelerate-stop distance available

(ASDA)will be 4,687 feet in both directions, and the landing distance

available (LDA) will be 4,387 feet. A

review of Table E in the Design Standards Study, indicates that the airport

will still be able to readily accommodate Approach Category B business jet

aircraft. The aircraft that would have

problems would be the Approach

Category C and D aircraft that the

airport was never designed for in the

first place.

As a result, the recommendation

remains to pursue the implementation of Alternative 2B. This alternative is the most practical alternative to meet the FAA runway safety

area design standards. The development costs of implementing this improvement are minor when compared

to all other options. Alternative 2B

meets the mandates of the 1984 Airport Agreement as well.