EXHIBIT 

# 116

ReportAddendum DESIGN STANDARDS STUDY Santa MonicaAirport

This addendum has been prepared to update information as well as address input provided by the Federal AviationAdministration (FAA)with regard to the Santa Monica Airport Design Standards Study. Specifically this addendum isintended to:

• Update statistical data regarding airport activity, in particular businessjet use.

• Update, any other existing conditions at the airport that may be relevant tothe airport design standards.

• Update design standards per Change 7ofFAAAdvisoryCircular 15/5300-13.

• Review potential runway safety

area (RSA)alternatives including:

• DoNothing Alternative • Updated EMAS Alternative in accordancewith FAAOrder 5200.9

• Net Suppression System

• Partial Runway SafetyArea

• 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 tableis updated here in Table Al to include 2002 and 2003. Traffic in 2002,

was up 2.5 percent compared to the previous year.

A-ITABLEAl

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 backtoat least 1990. The percentage oflocal operations continued a downward trend that began in 2000. Atthe same time, air taxi activity exceeded 10,000 annual operations for the first time in 2002,then grewto 11,766in2003. 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 continuetorise at the airport. According to the information recorded bythe airport as part ofits NoiseAbatement Program, there were 16,157jet operations in 2002 and 16,210 in 2003. With the decrease in total operations, the percentage ofbusiness jet activity has grownfrom7.2percent in 2000,to 11.3percent 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 at Santa MonicaAirport to be the Gulfstream IV(G-IV). For 12months endA-2ing in June of 2000 the G-IV accounted for approximately 950 operations. An updated analysis for 2003 indicates that the G-IVnow accounts forapproximately 1,200annual operations.

The updated analysis also evaluated the percentage ofbusiness jets in each Approach Category. Flight Plan data from April, July, and October was used forthe update. This ispresented in Table A3. Based upon this data, Approach Category B business jets conducted 7,188 operations in 2003 to comprise 44.4 percent ofthe business jet operations. The number ofoperations isup from6,700in the 12month period in 1999-2000, but the percentage is down from 49.6 percent. Businessjet operations in Approach Category C and D increased from 6,800 in 1999-2000to 8,932in 2003



### FACILITY UPDATE

The existing facilities have changed a minimal amount since the completion ofthe 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 wallwas installed beyondthe east end ofthe runway. Installed with funds from an FAAAlP grant in 1994, this blast wall is within the RSAstandard forallcurrent approach categories. 

### FAADESIGN STANDARD UPDATE

TheDesign 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 ofthis ACwas issued. Theprincipal changes involvedthe following:

Runway Protection Zones (RPZ). Golf courses are no longer expressly permitted in the RPZ, but may be ifa wildlife hazard assessment determines that itwill notprovide an environment attractive tobirds.

The southwestern-most tip ofthe west RPZ extends over the Penmar Golf Course. Departure turns to overfly this golf course are part of the airport's noiseabatement 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 MonicaAirport.

Runway Safety Area (RSA) Width. The RSA no longer increases in width
at higher elevations for Approach CategoryD.

A-3Table 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-4This change is not applicable to Santa

MonicaAirport as the airport's elevation isjust 175 feet above mean sea level.

Threshold Siting Criteria. Changes have been made in criteriafor various approaches and night operations. In

some cases, displacement ofthe 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 MonicaAirport.

New Instrument Approach Category. Appendix 16has been expanded
to include a new category of instrument approach, Approach Procedure with Vertical Guidance (APV). Criteriafor other instrument approach procedures have also beenchanged.

This change is not applicable to Santa MonicaAirport.



### 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 ofboth approach category B (as indicated on the previously approved ALP, as well

as in the 1984Airport Agreement), as well as approach categories C and D. Thealternatives included:

Provide Full RSA

-Categories CID: This alternative was proven to be impracticable due to the extent and cost ofrelocations 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 fromthe Category C or D RSA. Acquisition and relocation costs alone would total $132 million,with construction costs onthe 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 tobe$33million.
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 wouldbe impractical foruse. 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 involvednorelocations.
Engineered Materials Arresting System (EMAS): This alternative only applies to Categories C/D, as
more space is needed for EMAS.than forthe Category B RSA. At the time of the Design Standards Study, the FAA'spolicydidnot viewEMASas an equivalent substitute forarunway safetyarea. EMAS was to onlybe used essentially as alast resort. Eventhen, the space required for EMAS did not fit well on the runway platform at Santa Monica Airport, and did not

A-5provide any solution for the RSA on

the landing end ofthe runway. The alternative of placing EMAS beyond each end ofthe runway wouldimpact 24home,the gas station, and commercialbuildings, with an estimated total costof$79million.
Realignment ofthe runway was considered initially, but was determined

as notfeasible when itbecame evident that any adjustments would not improvethe situation, and in most cases, make it worse for a higher price. Similarly, various combinations ofthe alternatives were considered as well. Every attempt came back to Alternative 2B, which has the lowest cost, creates the least disruption tothe surrounding community, and provides for the RSAstandard within the parameters ofboth FAAOrder 5200.8and the 1984AirportAgreement.

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 neededtobeconsideredfurther:

• EMAS

• DoNothing Alternative

• Other Arresting Systems

• Partial Runway SafetyArea

In addition, FAA Order 5200.9 was published on March 15, 2004. The subject ofthis Order isFinancial Feasibility and Equivalency of Runway Safety Area Improvements and Engineered Material Arresting Systems. These fouralternatives 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 canbeconsidered as equivalent to a full runway safety area. From this Order, "Analysis shows that for aircraft overruns, EMAS canprovide a safety enhancement, while requiring less land disturbance and lower construction costs. EMAS does not provide a benefitfor short landings, so a standard EMAS installation might also include adisplaced threshold."

To provide the safety factor for short landings, the Order 5200.8 indicates, "Ifthe approach end ofthe runway has verticalguidance, thenprovide at least 600feet (orthe length ofthe standard RSA beyond the runway threshold, whichever is less) between the end of theEMAS bedand the runway thresholdtoaccommodate overshoots

..."

The length ofthe EMASbed is established bythe maximum takeoffweight oflargest aircraft to use the airport. At Santa Monica Airport, the maximum takeoffweight is 60,000pounds. 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. Over30percent ofthe Cand Doperations at SMOare by aircraft weighing less than 25,000 pounds. In addition, the vast majority ofcategory Aand B operations are by aircraft below this weight.

Exhibit Al includes a graph from FAAOrder 5200.9that istobeusedin determining the EMAS bed length.

A-6For use at Santa Monica Airport, the

bed wouldneed to be at least 270feet in length. Tominimize erosion ofthe bed by jet blast, it must also be at least 75feetbehind the useable end of the runway.

In Order 5200.9, the FAA also establishes a maximum feasibility cost. This maximum feasibility costis tobe applied when evaluating methods for meeting the RSAstandard. Ifneither 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 footbed length, the maximum feasible cost of the runway improvement would be approximately $12million.

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 EMASbed placed at the back end ofthis graded area. This alternative would still require the relocation ofan estimated 75homes, as well as the gas station and adjacent commercial buildings. The number ofrelocations wouldbe increased ifthe roads offeither end are relocated instead of bridged. Extending the 600 feet beyond the end ofthe runway will have less impact than the full Category

# cm RSA, but significantly more than the Category BRSA. Regardless, allthree standard alternatives would well exceedthe maximum financially feasible costof$12million. The second alternative displayed on Exhibit A2locates the EMASjust beyondthe ends ofthe runway. This is similar to Exhibit Kin 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 of255 feet. To assist in minimizing costs, a 400-footwideRSA

was utilized. This RSAwidth is permissible for C-I and C-II design according to Table 3-3 in FAA AC 150/5300-13.

The takeoffrun available (TaRA) and the takeoff distance available (TODA) would remain at the full length ofthe runway, as would the accelerate-stop distance available (ASDA). The landing distance available (LDA)wouldbe 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 abovethe financially feasible cost of$12million.

FAAOrder 5200.9 states, "Ifit is not financially feasible to improve theRSA
to standards or to an equivalent level of EMAS, the choice becomes implementing the best alternative for enhancing safety that does not exceedthe maximum feasible costfor improving theRSA."

The next subsection considers partial solutions.

A-7Exhibit Al EMAS FEASIBILITYe '"

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c; 5 '" :::; 0 ~ c-, CD c( to U) -s-, '" "0 .~ a. <:: 0 '" '; et -.J 0 <ii c-, to => '" 0 "0 s: e- "", 5 '" <C a: a:PARTIAL RUNWAY

SAFETY AREA

Tothis point the onlyfeasible alternative remains meeting Category B standards utilizing displaced thresholds. This alternative meets the design ARC on the approved ALP, as wellas complieswith the 1984Airport 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 offeither end ofthe runway. In that case, the road must either be bridged or relocated. Relocation ofa roadway requires additional residential relocation beyond what may be necessary forthe safety area itself.

Consideration was given to developing EMAS within the confines of airport property offthe west end ofthe runway. There is approximately 240 feet available before the wall along 23rd Street. This wall would need to be raised tonear the elevation ofthe west end ofthe runway. Afterproviding for the 75 feet between the runway end and the start ofEMAS, approximately 165 feet ofEMAS could be installed, assuming a vertical retaining wall up to 50 feet high could be put in place. This length ofEMAS would be sufficientdesign foraircraft weighing up to 30,000pounds. Relocating the Runway 3 threshold 125feettothe north wouldprovidefor

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 byEMAS. Atleast 600feetof the full safety area is needed offthe approach end. If this were provided within airport property, the landing distance available wouldbereduced to 4,262 feet. This is less than the LDA providedforB-II design byAlternative 2B. Obviously, less displacement would increase the LDA at the expense ofadequate RSA.

As aresult, the onlypotential forpartial improvement appears tobe adding EMAS to the west end as discussed above and depicted on Exhibit A3. The cost ofthis partial RSA alternativeisestimated at $9million.

OTHER ARRESTING SYSTEMS
Accordingto areport prepared byBoeing Commercial Airlines Group, there

are an estimated 2,000 aircraft arresting systems installed in 64 countries worldwide. Most ofthem 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 alsoarresting cables and barriers.
Arresting cables are commonly associated with military operations. The cable system involves acable spanning the width ofthe runway that must be

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Exhibit A3 PARTIAL RSA CONSIDERATIONSengaged by an arresting gear hookon

the aircraft. Since virtually all general aviation aircraft are not equipped with arresting gear, this is not apractical alternative forSanta MonicaAirport.
Arresting barriers stop an aircraft by absorbing the momentum ofthe aircraft in an overrun area, beyond the operational runway. The commonarresting barrier systems are net devices. Exhibit A4 depicts a typical barrier set-up. Foruse to stop civilian aircraft, the net system wouldneed to beinplace at all times. Thus the pilot wouldhave to treat the net as an obstruction that would need to be cleared ondeparture orarrival.

At Santa Monica Airport, the incline at the west end ofthe 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 ageneral aviation airport is the wide range in aircraft sizes that

are involved. Aircraft currently utilizing Santa MonicaAirport range from light single-engine aircraft weighing only a few thousand pounds, to the maximum weight of60,000pounds.

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 systemisnotrecommended.

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 alsobeutilized 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 tojustify as a "base case" condition because the safety concerns are notmitigated.

Under FAA Order 5200.8, the "Do Nothing" alternative wouldbe 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 tothe extent practicable, evenwhen it results in an irregularly shaped RSA. This indicates further, that the "Do Nothing" alternative is the least desirable alternative for safety enhancement.

Continuation ofthe present condition by doingnothing couldreadily beperceived as negligence on behalf ofthe airport owner. In a letter to the Santa MonicaAirport 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",

Airport Technology, Boeing Commercial Airplanes Group: Page 26, Figure 1

Exhibit A4 ARRESTING BARRIER SYSTEMDirector ofAirport 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. ofaircraft, are operating safely."

Whilethat iswelland goodforaircraft 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 RSAis designed forwhen things gowrong on landing ortakeoff. Within the last few years, things did go wrong at Santa MonicaAirport for a Cessna 340 aircraft that ran offthe west end ofthe 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 commercialjet overran the runway reinforcesthe importance ofthe 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 underthe "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. Asindicated in attached correspondence from Mr. David Bennett, Director of Airport Safety and Standards, the FAA has agreed tomake a Runway Safety Area Improvement Program determination for Santa Monica Airport based upon proposed safety enhancements presented bythe City ofSanta 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 ofSanta 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 ofhanding all types of general aviation aircraft within Airport Design Group II. According to Section 8 ofthe Agreement, however, that is not the case. Section 8 reads, "TheAirport will be capable ofaccommodating most kinds ofgeneral aviation aircraft, generally consistent with GroupIIDesign standards setforth in FAA Advisory Circular 150/5300.4B dated February 24, 1983."

The secondparagraph 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 ofless than 121 knots. The other airports need to be designed and maintained to the standards, and
to the extentphysically 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. Ifthe intent were to accommodate C and/or D aircraft, then AC 150/5300-12 would have been referencedbythe 1984Agreement.

The 1984 ALP was adopted with the understanding that the Airport would operate under what would becomethe B-II standards. Section 5 specifically states, "TheAirport Layout Plan submitted and approved by the FAA on January 31, 1984 (CityMap 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." Thebroadest definition ofGeneral Utility in FAA AC 150/5300-4B, dated September 23, 1983, was as follows:

"General Utility

- Stage II. This type ofairport 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 GroupIII. JJ

This clearly indicates that General Utility is defined within ARCB-II and A-III. There is no mention or suggestion of a design involving Approach Categories CorD.

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 ofthe 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 tobeB-II.

Thus, the 1984 Agreement, and subsequently the 1986and 1991ALPs, set forth the B-II standard for Santa Monica Airport. To consider alterna-tives involving an upgrade for approach category C and/or D would be in violation ofthe agreement, as well

as be contrary to the ALP. Tochange the ARC on the ALP to C-II or D-II wouldrequire environmental approval through both the National Environmental PolicyAct (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, ifnot impossible to attain. Unless the City of Santa Monicahas interest in sponsoring and approving an ARC upgrade, considering such a change is entirely mootanyway.

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. TheFAAdoeshave apolicyinplaceto require arunway bebrought up to design standards ifrunway-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 fora 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 ofany runway safety area. The FAA guidance and emphasis inrecent years has placed apriority onthe runway safety

A-12 area. Subsequently, airports without

an adequate RSA are now more open topotential litigation inthe event that

an aircraft does overshoot or undershootthe runway forwhatever reason. Mr.Bennett's correspondence confirms that the FAA does not have the authority to indemnify the City ofSanta Monica, nor accept any responsibility that has notbeen specificallyassigned tothe 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 ofthe 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 ofTable E in the Design Standards Study, indicates that the airport will still be able to readily accommodate Approach Category Bbusinessjet aircraft. The aircraft that wouldhave 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 ofAlternative 2B. This alternative isthe 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 ofthe 1984AirportAgreement as well.