## Revised Impact Assessment Released tothe Cityand Users on September 17,2007

Introduction

The CityofSanta Monica has presented an analysisthat concludes that the impact of a 300-foot loss ofrunway length isminimal because itwillimpact only 235jet takeoffs out of atotal of 9,000jetdepartures annually. The City's analysisdoes not fullyrepresent the operational impacts ofa shortened runway because it considers only avery limited mix of aircraft (onlycertain large aircraft), does not consider landings, does not consider non-jet aircraft, and only considers stage length asthe criticalvariable.

Because ofthe largenumber ofvariables affecting aircraft performance on anygiven day,

even for the same aircraft model, because ofoperating conditions, decisions made bythe pilot in command, or different operating rules placed on Part 135or Part 91 operators, itis not possible to describe the exact number offlights that would be affected by aloss of runway length. It ispossible to give an estimated range ofimpacted operations, however.

A reliable estimate can be obtained bylooking at actual flights inrecent years, by aircraft type and stage length, and the performance charts and other data for alltypes of aircraft that use SMO. FAA considered the potential impact ofareduction in runway length of 300 feet from several different analyticalapproaches, which are explained in detail atthe end ofthis document.

The results using the methodologies described below indicate anumber ofimpacted flights estimated to be atleast 1,400takeoffs and atleast 3,800landings per year. Even afraction ofthose numbers would be considered asubstantial adverse impact on operations.

FAA's analysisrelied on detailed and documented aircraft operational data containing individual IFR operations to and from SMO, aircraft type and model, N-number, and stage length. The FAA used information from performance manuals for the aircraft fleetusing SMO and relied extensively on actual flightreview information because that best represents actual performance and operational use ofthe aircraft under review.


## Stage Length

To accommodate the wide variety ofaircraft types reviewed, the FAA opted to apply the following stage lengths asrepresentative offlightoperations conducted from SMO:



## Very ShortRange (up to 100NM) ShortRange (100

-499NM) Medium Range (500

- 1,999NM) Long Range (more than 2,000NM) e.g. SMO toVanNuys e.g. SMOto SPO e.g. SMOto Dallas e.g. SMOto Teterboro

"~E~X~H~IB~IT~'" 

# i CoS

### Operational Data

The operational data used in this analysis was derived from two publications: GCR's Market Share Reportfor Santa Monica reports dated December 2004

-December 2005 and June 2006

-June 2007. These two studies yielded detailed information on individual jet operations by non-commercial operators.

For the purpose ofthis analysis, these data were accepted as representative of operations at SMO today and into the future. This isbecause recent patterns in aircraft types, destinations, and stage lengths can be expected to continue in the future.

The actual number ofjet VFR operations isnot well documented for SMO, but was estimated by the SMO ATCT to be <4,000 (about 20%) and primarily very short range positioning flights. As aresult, the final data, representing roughly 18,000 jet operations, shows the following number of flights by stage length, and percentage of total jet flights broken down by stage length from SMO:



## TOTAL IFR DESTINATIONS: TOTAL VERY SHORT STAGE LENGTH: TOTAL SHORT STAGE LENGTH: TOTAL MEDIUM STAGE LENGTH: TOTAL LONG RANGE STAGE LENGTH: 450+ 2,662 11,142 3,560 576 (14.79%) (61.9%) (19.78%) (3.2 

## %)

It is important to note that these are representative stage length classifications based on distances from SMO to destinations. Individual aircraft models and types operating from SMO have their own stage length operating characteristics which vary, sometimes significantly, from the broad classifications shown above.

A 1,500-nautical mile flight by aLearjet 35 or a 1,000-mile flight by aBeech 400 are both long range operations, not medium stage length flights. As such, these types of flights are not accounted for in the above stage length breakdown, but rather accounted for as impacted flights under amethodology that considers the operating requirements of those aircraft types.

Main Variables Used in Ascertaining Impact

Other variables, such as useful load of 60% and preserving non-stop capability, were also assessed in this analysis. Both are established FAA planning standards and criteria used in airport and runway length determinations.

### Other variables were based on regulatory requirements such as Part 135 and Part 91K landing distance computations, fuel reserve requirements (part 91 and NBAA reserves). For example, the landing distance for allPart 135 operations would be only 2,848 feet if 300 feet were removed from runway 21-03.
Depending on aircraft type and certification, takeoff needs were not limited to ageneric takeoff distance or takeoff roll, but rather accelerate-stop, accelerate-go, balanced field, second climb segment, and possible combinations, when appropriate.
Specific operational values in terms ofweight, range, and other variables were also accounted for. For example, aloss of 200 nautical miles in range and aloss of 500 pounds in weight capability (in some aircraft 200 lb.) were used as guidelines and benchmarks. Finally, analyzing impact was not limited to jet aircraft; several turboprop types and even some piston-powered aircraft would be affected by aloss ofpavement.
Methodologies Considered in Ascertaining Impact

~ Very Likely Impacted Takeoffs by Non-Commercial Jet Operators

This result was obtained by individually reviewing all 7,800 operations conducted by non-commercial operators at SMa and identifying the aircraft type/stage length combinations that would be likely to be impacted based onthe best estimations of operational conditions for the aircraft, including aircraft type, destination (stage length), typical payload, and typical fuel reserve, for example. This identification of affected flights was conservative and generally based on replicating the decisions of operators/PICs concerning the flight inquestion including decisions to not conduct flight orto reduce payload, effect on reserve fuel, and common operational practices.
Impact was considered to be severe when there was anecessity to reduce aircraft useful load to apoint near orbelow 60% because ofthe reduction inrunway length (loss ofuseful load below 60% raises the potential ofeliminating flights because the aircraft cannot be utilized for its intended purpose). In some cases, however, an impacted operation was also defined as areduction inoperating capability, namely interms ofpayload, ifthe reduction was well beyond the payload level these types ofoperations can currently carry to orfrom SMa. Aircraft operations were analyzed forthe reduction inuseful load resulting inan estimate of428 takeoffs,
re resentin 5.4% of7,800 non-commercial iet0 erations. 428 Takeoffs

~ Impacted Takeoffs by Commercial Jet Operators

This result is an estimate obtained by applying the 5.4% ratio identified above to all remaining 10,200jet commercial operations. The result was 550 takeoffs. The fi ure of 10,2000 erations was obtained b subtractin 7,800 non-commercial 550 Takeoffsoperations from the total of 18,000jet operations in2006. Non-commercial and

commercial operations constitute 43% ofthe totaljet operations while 57% are commercial 0 erations.

~ Estimated Impacted Takeoffs by Turboprop Operators

This result was obtained byreviewing all 2,613 operations conducted by noncommercial turboprop operators at SMO covering the period 2006-2007. Aircraft type/stage length combinations that would be likely to be impacted based onthe best estimations ofoperational conditions forthe aircraft, including aircraft type, destination (stage length), typical payload, and typical fuel reserve, for example,

were taken into consideration. Ofthe 2,613 turboprop operations, 1,326 were large turboprop types (9,000 to 16,000 lb.), which are susceptible totakeoff restrictions in the form ofaccelerate-stop and accelerate-go distance requirements. In some cases, payload restrictions would also take place. Based on adetailed review ofacceleratestop and accelerate-go distance performance, itis estimated that 15% ofthese operations would be affected by areduction of300 feet under certain temperature conditions.
Therefore, the number 1,326 operations was multiplied by 0.15 resulting in 199 non-commercial operations. These 199represent 7.6% ofall non-commercial turboprop operations. In addition, based onthe above-mentioned percentages, that 43% ofoperations are non-commercial and 57% are commercial, the number of commercial turboprop operations was estimated to be 3,417 (57% x2,613 noncommercial ops /43% =3,417).

This result was multiplied by 7.6% to estimate the number ofaffected commercial turboprop takeoffs. The result was 259 takeoffs. The resulting number ofaffected turboprops takeoffs is 199

### +259 =458. 448 TakeoffsThis result was obtained by documenting the takeoff/takeoff field length/balanced field

requirements for 18different aircraft types using SMa based onthe best estimations of operational conditions for the aircraft. All ofthe aircraft used have operational runway requirements that exceed 4,700 feet, and many exceed 5,000 feet. Although there are variations from aircraft type to aircraft type, inthis study, takeoff requirements exceeding 4,700 feet (representing aloss of300 feet) were considered impacted because the aircraft capabilities are restrained (e.g., weight penalty) atthe outset and thus sensitive to a loss of runway length below 5,000 feet. The 18types ofaircraft studied here were reported by the City in its 2001 Design Standards Study. The total number ofoperations for these 18types of aircraft was obtained by adding the annualized operations for each type as reported by the City in its 2004Addendum #1 (2003 data) resulting in 8,935 operations.

Leariet 35 C-I 5,550 feet 574 Challen er 604 C-II 5,700 feet 465 Leariet 45 C-I 4,860 feet 296 IAI Astra C-II 5,200 feet 186 HS-125-700 C-I 4,900 feet 414 Falcon 20 B-II 5,400-6,500 feet 59 Cessna Excel B-II 4,700 feet 1,200 3,919 Le ac 600 C-II 5,500 feet 42 Hawker 4000 C-II 5,200 feet 50 est. " Takeoffs Falcon 2000 B-II 5,100 feet 625 Beech 400 C-I 5,280 feet 1,335 Falcon 50 B-II 4,700 feet 287 GI50 C-II 4,850 feet 100 est. " Leariet 60 D-I 5,450 feet 574 Sabreliner 65 C-II 5,450 feet 25 Gulfstream GV D-II 4,800 feet 1,183 Learjet 55 C-I 5,000 feet 76 Citation X C-II 5,200-5,880 feet 1,444

This result was obtained by documenting the runway length requirement for 20 different aircraft types and groups using SMa based onthe best estimations ofoperational conditions for the aircraft. Total operations at SMa increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased bythe same general amount, the number ofoperations by these 18 aircraft types in2006 was estimated to be 8,935 x 1.125 = 10,051. That total was divided by 2to obtain the number oftakeoffs. Itwas further reduced by 22% to eliminate local shortrange VFR operations. The resulting estimated number oftakeoffs by these 18aircraft types in 2006 is 10,051 -7- 2

### = 5,025, minus 22% 

### = 3,919. Note: The City did not report takeoff information on several aircraft types even though those aircraft are impacted. Examples include the HS-125-700 and Falcon 20. As aresult, takeoff requirements were added forthese types. In addition, the City did not report operations by several impacted aircraft types. Examples include the Hawker 4000 and the Gulfstream G150.As aresult, operations information for these es was estimated and incor orated into the anal sis.All ofthe 20 aircraft types and groups have an operational runway requirement for landing

that exceeds 2,820 feet, which isthe equivalent of60% of4,700 feet in available runway length at SMO if300 feet were removed. A landing within 60% ofavailable runway is a requirement under Part 135 and arequirement used by the vast majority ofPart 91K operators at SMO.
Although there are variations from aircraft type to aircraft type, inthis study, landing requirements exceeding 2,820 feet (equivalent to 4,700 feet) were considered impacted because the aircraft capabilities are restrained (e.g. weight penalty) atthe outset and thus sensitive to aloss ofactual runway length below 5,000 feet.

The 20 types and groups ofaircraft studied here were reported by the City in its 2001 Design Standards Study. The total number ofoperations forthese 20 types and groups ofaircraft was obtained by adding the annualized operations for each type as reported by the City in its 2004 Addendum #1 (2003 data) resulting in 12,654 operations.

B-I1 3,180 feet 794 B-I1 2,865-3,180 feet 2,703 B-1 3,000 feet 59 B-I1 3,125 feet 625 B-1 2,950 feet 287 B-I1 3,520 feet 135 C-I 2,960 feet 1,335 C-1 3,500 feet 414 3,885 C-I 2,870 feet 245 C-1 2,900 feet 642 Landings C-I 3,140 feet 296 C-I 3,250 feet 76 C-1 3,400 feet 8 C-I1 3,050-3,300 feet 583 C-I1 3,300 feet 465 C-I1 2,900-3,220 feet 355 C-I1 3,410 feet 1,444 C-I1 3,500 feet 431 0-1 3,420 feet 574 D-I1 3,200 feet 1,183

Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofoperations by these 20 aircraft types in2006 was estimated to be 12,654 x 1.125 = 14,235. That total was divided by 2to obtain the number oflandings. Itwas further reduced by 22% to eliminate local shortrange VFR operations. The resulting estimated number oflandings/takeoffs by these 20 aircraft types in 2006 is 14,235 -+-2= 7,117, minus 22% = 5,551. Because itis estimated that 70% of 18,000 total operations (3,600 Part 135 Ops 

### +9,000 Part 91K=12,600) are either Part 135 oractually Part 91K operations that adhere to the Part 135 landing distance requirement, the total of5,551 landings was multiplied by 0.7 to generate afinal total of3,885 affected landings.

Note: The City did not report take offinformation on several aircraft types even though those aircraft are impacted. Examples include the HS-125-700 and Falcon 20. As aresult, landing requirements were added for these types.

## Estimated Impacted Take Offs Based on theAnalysis ofSeveral Specific Aircraft

~ Hawker HS-125 400/6001700/800/800XP Takeoffs

Total HS-125 operations, all models, for2003 were 1,450. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofHS-125 operations in2006
was estimated to be 1,450 x 1.125 = 1,630. That total was divided by 2to obtain the number oftakeoffs. Itwas further reduced by 22% to eliminate local short-range VFR operations. The resulting estimated number ofIFR takeoffs by HS-125 aircraft in 2006 is 1,630 -i- 2

### = 815, minus 22% 

### = 636.

With a 5,000-foot runway, an HS-125-700 is limited to take off at23,000 lb. at 68°F. Ifthe temperature is 86°F, atake offwould be limited at 22,000 lb. This is about 3,500 lb. below max weight. If300 feet ofrunway isremoved, atthe same temperature of 86°F, afurther weight penalty of 800-1,000 lb. would be the result. At aweight ofabout 21,000 Ib,the aircraft's useful load is limited to 60%.
However, areview ofthe performance data and comments from operators, indicates that some but not all Hawker 800 operations would be impacted. Therefore, itis assumed that 50% ofHS-125 operations would be adversely affected bypayload or range limitations, resulting in areduction of318 take offs (50% of636 take offs). It isbelieved this is aconservative figure. 318 Takeoffs

~ Beech 400 Takeoffs

Total Beech 400 operations, all models, for 2003 were 1,300. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category of operation increased by the same general amount, the number ofBeech 400 operations in2006 was estimated to be 1,350 x 1.125 = 1,462. That total was divided by 2to obtain the number oftakeoffs only. Itwas further reduced by 22% to eliminate local short-range VFR operations. The resulting estimated number ofIFR takeoffs by Beech 400 aircraft in2006 is 1,462 +- 2 =731, minus 22% =570.

At 15,700 lb., 23°C, the Beech 400A has afield length requirement of5,280 feet. The 570 takeoffs by Beech 400 aircraft were classified as impacted because ofthe field length requirement, and because there is asignificant weight penalty with the loss 0000 feet ofrunway that adversely affect its useful load. 570 Takeoffs

~ Learjet 31/35/45/55 Takeoffs

This result was obtained by adding all operations of Series 30 Learjet, Learjet 45 and Learjet 55. Total operations forthese types were 1,260 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofLearjet 35,45,55 operations in2006 was estimated to be 1,260x 1.125 

### = 1,416. That total

was divided by 2to obtain the number oftakeoffs and was further reduced by 22% 552 Takeoffsto eliminate local short-range VFR operations. The resulting estimated number of

IFR takeoffs by these Learjet models in2006 is 1,416 +- 2= 708, minus 22% = 552.
16,500 lb. was determined to be an approximate yet adequate threshold for operational impact asthis isacommon normal operational takeoff weight found in this type ofoperations by these aircraft out of SMO.

~ Canadair/Bombardier CL600 Series Takeoffs

This result was obtained by adding all operations ofCanadair 600.601 and 604. Total operations forthese models were 1,050 for 2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofCL600 operations in2006
was estimated to be 1,050 x 1.125 = 1,181. That total was divided by 2to obtain 590 88 Takeoffs take offs.

Affected CL-600 flights were estimated to be 15% ofall CL600 Series flights. This inturn yields an estimated number ofimpacted take offs at 88. With balanced field requirements as high as 5,700 feet, atypical Challenger 601 runway requirement at SMO can be 4,900 feet. A loss of300 feet can equal aloss of2,000 lb., and this is significant for all flights to mid-continent and beyond.

~ G-IV Takeoffs

This result was obtained by adding all operations ofthe G-IV, which would include any G350 or G450 as well. Total operations forthese models were 1,183 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofGIV 99 Takeoffs operations in2006 was estimated to be 1,183 1.125 = 1,330. That total was divided by 2to obtain the number oftakeoffs only. The estimated number ofIFR takeoffs by these models in2006 is 1,330 -i-2= 665. As with the CL600 Series, affected GIV flights were estimated to be 15% ofall G-IV flights, which inturn results in99 impacted take offs. A G-IV-SP can have abalanced field length requirement of 5,450 feet. As such, at 64,000 lb., italready operates with weight penalties.

Sub Total for 39% ofJet Operations

Note: This subtotal was obtained by adding all affected take offs by the five (5) 1,627 Take Offs aircraft types above. The total, 1,627 constitutes 23% ofall operations conducted by HS-125s, Beech 400s, Learjets, CL-600s, GIVs, which amounted to approximately 7,019 total operations.

~ Estimated Remaining Affected Takeoffs by All Other Aircraft Types

This result was obtained by multiplying the affected ratio of23% (on 7,019 984 Takeoffs operations) by the remaining number ofjet operations (18,000-7,019=10,981). However, before computing afinal number, the 10,981 total was first divided by 2 to eliminate about 5,500 operations by several aircraft types (e.g., straight-wing Citations) that would not be as affected by aloss of300 feet inatypical takeoffscenario from SMO. The resulting total of5,500 operations was multiplied by the

23% ratio and resulted in 1,262 affected takeoffs. That total was further reduced by 22% to eliminate local short-range VFR operations, resulting inafinal affected number of984. Itisnoted that this estimate is conservative because many ofthe aircraft purposely removed from this calculation still have limitations interms of second climb segment requirements and can still have balanced field constraints at certain wei hts and tem eratures. Total Affected Takeoffs 2,611 Takeoffs

~ Impacted G-IV Landings

Note: This result was obtained by adding all operations ofGIV, which would include any G350 or G450 as well. Total operations forthese models were 1,183 in 2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number of GIV operations in 2006 was estimated to be 1,183 1.125 = 1,330. That total was divided by 2to obtain the number oflandings only. The estimated number of landings these models in2006 is 1,330 -7- 2= 665. To best represent the possibility that some very short range flights may not be affected, the 665 total was reduced by 22% to eliminate local short-range operations. The resulting estimated number of landings by G-IV aircraft is665 minus 22% = 518. Except for local VFR flights, all G-IV landings were classified as impacted, as areduction below 4,870 feet could effectively restrict landing weights to below 45,000 lb. This is avery low weight for the G-IV and therefore critical. 518 Landings

~ Impacted Part 135 Learjet 31/35/45/55 Landings

This result was obtained by adding all operations of Series 30 Learjet, Learjet 45 and Learjet 55. Total operations forthese types were 1,260 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofLearjet 35,45, 55 operations in2006 was estimated to be 1,260 x 1.125 = 1,416. That total

was divided by 2to obtain the number oflandings and was further reduced by 22% to eliminate local short-range VFR operations. The resulting estimated number of landings by these Learjet models in2006 is 1,416 -7- 2= 708, minus 22% = 552. In this type ofaircraft, weights restrictions at about 13,000 lb. are an adequate threshold for operational impact because 13,000 lb. isacommon normal operational weight found inthis type ofoperations by these aircraft asthey operate inand out of SMO.

Because itis estimated that 70% of 18,000 total operations (3,600 Part 135 Ops 

### + 9,000 Part 91K=12,600) are either Part 135, for which a60% landing calculation is required, or Part 91K operations that use the Part 135 landing distance requirement, the total of5521andin swas multi lied b 0.7 to enerate afinal total of386 386 Landingslandings.

~ Impacted Part 135 Learjet 60 Landings

This result was obtained by adding all operations ofLearjet 60. Total operations for these types were 640 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofLearjet 60 operations in2006 was estimated to be 640 x 1.125 = 720. That total was divided by 2to obtain the number oflandings and
was further reduced by 22% to eliminate local short-range VFR operations. The 196Landings resulting estimated number of landings by Learjet 60 aircraft in2006 is720 -i- 2= 360, minus 22% = 280. On landing, the aircraft isweight limited. At atypical landing weight, its Part 135 landing requirement isabout 2,880 feet, which means that the actual length ofthe runway should be no less than 4,800 feet. Because itis estimated that 70% of 18,000 total operations (3,600 Part 135 Ops 

### +9,000 Part 91K=12,600) are either Part 135, for which a 60% landing calculation isrequired, or Part 91K operations that use the Part 135 landing distance requirement, the total of 280 landings was multiplied by 0.7 to generate afinal total of 196affected landings.

~ Impacted Part 135 Citation X Landings

This result was obtained by adding all operations ofCitation X aircraft. Total operations for these types were 1,444 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofCitation X operations in2006 was estimated to be 1,444 x 1.125 = 1,624. That total was divided by 2to obtain the number oflandings and was further reduced by 22% to eliminate local short-range 443 Landings VFR operations. The resulting estimated number oflandings by these Learjet models in2006 is 1,624 -i- 2= 812, minus 22% = 663. The Citation X was classified

as impacted because under Part 135, landing weights are restricted to below 26,000 lb. Because itis estimated that 70% of 18,000 total operations (3,600 Part 135 Ops 

### +9,000 Part 91K=12,600) are either Part 135, for which a60% landing calculation isrequired, or Part 91K operations that use the Part 135landing distance requirement, the total of663 landings was multiplied by 0.7 to generate afinal total of443 landings.

~ Impacted Part 135 CL600 Series Landings

This result was obtained by adding all operations ofCL600 Series aircraft. Total operations for these types were 1,050 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofCL600 Series aircraft operations in2006 322 Landings
was estimated to be 1,050 x 1.125 = 1,181. That total was divided by 2to obtain the number oflandings and was further reduced by 22% to eliminate local short-range VFR operations. The resulting estimated number oflandings bythese Learjet models in2006 is 1,181 -i-2= 590, minus 22% =460. The CL600 Series aircraft

were classified as impacted because attypical landing weights, these aircraft have landing distance requirements that exceed 3,000 feet, andtherefore, under Part 135,the actual runway requirement is 5,000 feet. In addition, aloss of300 feet would

result in afuel/weight penalty ofabout 2,000 lb. which is significant inthis type of aircraft. Because itis estimated that 70% of 18,000 total operations (3,600 Part 135 Ops 

### +9,000 Part 9IK=12,600) are either Part 135, forwhich a60% landing calculation isrequired, orPart 91K operations that use the Part 135 landing distance requirement, the total of460 landings was multiplied by 0.7 to generate afinal total of322 landings.

409 Landings ~ Impacted Part 135 Beech 400 Landings

This result was obtained by adding all operations ofBeech 400jets. Total operations for these types were 1,335 in2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each category ofoperation increased by the same general amount, the number ofBeech 400 operations in2006 was estimated to be 1,335 x 1.125 = 1,501. That total was divided by 2to obtain the number of landings and was further reduced by 22% to eliminate local short-range VFR operations. The resulting estimated number oflandings by these Learjet models in 2006 is 1,501 -7-2= 750, minus 22% = 584. Under Part 135, this aircraft

was classified as impacted because the available 2,800 feet (60% rules) imposes drastic weight penalties on landing when atusually would take 3,500 feet atheavy weights. Landing requirements are about 3,000 feet (or an actual runway length of 5,000 feet) and this is not uncommon at landings weights commonly seen at SMO. Because itisestimated that 70% of 18,000 total operations (3,600 Part 135 Ops 

### + 9,000 Part 9IK=12,600) are either Part 135, for which a60% landing calculation is required, orPart 91K operations that use the Part 135 landing distance requirement,

, the total of 584 landings was multiplied by 0.7 to generate afinal total of409 landings.

~ Estimated Affected Landings byAll Other Aircraft Types

This result was obtained by multiplying the affected ratio of32% described above by the remaining number ofjet operations (18,000-6,912=11,088). The resulting total of 11,088 operations was reduced by 4,000 operations ofstraight wing Citations jets that would not be as affected inmany landings scenarios resulting in 7,088 operations. This was multiplied bythe affected ratio of32% resulting in2,268 affected landings. That total was further reduced by 22% to eliminate local shortran eVFR 0 erations, resultin inan affected number of 1,769. 1,769 Landings