8490 South Power Road, Suite 105-181  Gilbert, AZ 85297  Office (480) 987-7823  Fax (602) 513-7388 Ken Paskar

AvTeam 51 Mac Dougal St – Suite 320 New York, NY 10012

December 8, 2010

Subject: LaGuardia (LGA) Runway 31 Future “Ultimate” RPZ Dimensions

Ken,

This letter is to follow up on my email to you in regard to the length of the future planned or

“ultimate” LGA RWY 31 RPZ.

As I stated in my email, after reviewing th e documents, letters and emails forwarded by you yesterday, it is clear that as of July 2, 2007, the Port Authority of NY & NJ (PANYNJ) long range plan included the insta llation of a Category II ILS to LGA Runway 31. Therefore, if allowed to be constructed, the proposed North S hore Marine Transfer station (NSMTS) would be located within the future, or “ultimate” RPZ associated with the planned Category II ILS instrument approach procedure.

Background

In his July 2, 2007 letter to Steven Urlass of th e FAA New York Airports District Office, Mr. Tom Bock, General Manager for Airspace, Technology & Operational Enhancements for PANYNJ, stated that PANYNJ was in the proces s of installing a glideslope on LGA Runway 31, and this glideslope would not only “allow for a cons istent flight path to the airport, but would

also reduce noise and air emissi ons for the airport neighbors.” 1 Mr. Bock also acknowledged that current landing minimums, even with the glid eslope installed would be high due to the lack of approach lighting and some ex isting obstructions, but that it was “our long term plan to study the obstructions and work to resolve them one by one with our goal to enable a CAT II approach to Runway 31.” 2

While a Category I ILS has visibi lity minimums as low as 2400 feet Runway Visual Range (RVR) (1/2 mile), a Category II ILS is designed for landing minimums half those of a standard Category I ILS, i.e. visibility minimums below 2400 feet RVR and as low as 1200 feet RVR (1/4 mile).

1 Letter from Tom Bock, PANYNJ, to Steven M. Urlass, FAA, dated July 2, 2007

2 ibidWilliams Aviation Consultants, Inc. In a letter from the City of New York Office of the Mayor to PANYNJ, dated February 20, 2008, Edward Skyler stated “establish ing a Category II ILS on Runway 31 currently appears infeasible due to the already existing obstacle environmen t, and a number of other technical issues.” 3 Mr. Skyler then goes on to s upport the installation of a Category I ILS in lieu of the Category II ILS by stating “the Port Authority can begin installation of a Cate gory I ILS at Runway 31, which will improve throughput at the airport and at the sa me time, allow the City to move forward with

the reactivation of this important facility.” 4

We agree that the installation of a Category II ILS is not feasible. However, Mr. Skyler is discounting the impact of the NSMTS on potential approach visibility minimums. Mr. Bock’s plan to remove existing obstacles one by one to im prove capacity is being set aside. The effect of Mr. Bock’s plan would make possible the inst allation of a Category I ILS with visibility minimums as low as 1/2-mile. The NSMTS will pr event visibility minimums from ever being established below 1 mile, thereby inhibiting future airport efficien cy and capacity enhancements. Mr. Skyler is also discounting the fact that the NSMTS would be located within the Runway 31 RPZ if either a Category II ILS or a Category I ILS with visib ility minimums lower than 3/4-

mile is installed.

LGA Runway 31 Runway Protection Zo ne (RPZ) – Current and Future

An RPZ is trapezoidal in shape, centered a bout the extended runway centerline, and its dimensions are a function of the type of aircraft and approach visibility minimum associated with a particular runway. Since the current instrument approach pr ocedures to Runway 31 specify approach visibility minimums of 1 mile or gr eater, the current Runway 31 RPZ is 1700 feet in length. 5 However, considering either the originally planned Category II ILS, or the City of New York’s suggested Category I ILS, both having visibility minimums lower than 3⁄4 mile, the future planned or “ultimate” RPZ for LGA Runway 31 w ould have a length of 2500 feet, as per FAA Advisory Circular (AC) 150-5300-13, Airport Design

. 6

North Shore Marine Transfer Station (NSMTS)

Notwithstanding the fact that the NSMTS lies outs ide of the current Runw ay 31 RPZ, at the time of Mr. Bock’s July 2, 2007 letter to the FAA, the proposed NSMTS would have been located

within the confines of the fu ture planned, or “ultimate” Ca tegory II ILS RPZ. The NSMTS would, as well, be located in the Runway 31 RP Z with the establishment of a Category I ILS with visibility minimums less than 3⁄4-mile.

3 City of New York Office of the Mayor letter to PANYNJ, dated February 20, 2008

4 ibid

5 FAA Advisory Circular (AC) 150-5300-13, Airport Design , Table 2-4, Runway Protection Zone (RPZ)

Dimensions

6 ibidWilliams Aviation Consultants, Inc. Conclusion

The function of an RPZ is to enhance the prot ection of people and property on the ground. This is achieved through airport control over RPZs. Such control includes clearing RPZ areas (and maintaining them clear) of incompatible objects and activities. 7 Airport operators must take into consideration, not only existing c onditions, but also planned airpor t enhancements in their land use compatibility determinations. It is, theref ore, my opinion that PANYNJ should have taken into consideration the future, or “ultimate” RP Z associated with thei r planned Runway 31 ILS instrument approach enhancements, and should have opposed the construction of the NSMTS at

its current location.

Sincerely,

Barry Yurtis VP of Domestic Operations

Attachments

7 FAA Advisory Circular (AC) 150-5300-13, Airport Design , Para 212