Declaration of Donald K. Stimson, Aerospace Engineer, Federal Aviation Administration,

Aircraft Certification Service

FAA Docket No. 16-02-08

I, Donald K. Stimson, declare that the following is true and correct and based on my professional

experience concerning the certification and performance of transport category airplanes.

1. My Professional Background: I have been employed as an Aerospace Engineer with the Federal

A viation Administration (FAA) for sixteen years. During that time, 1 have been in the Transport

Standards Staff of the Transport Airplane Directorate in the FAA's Aircraft Certification Service.

Prior to my employment at the FAA, I was employed at The Boeing Company as an airplane

performance engineer. I received a Bachelor of Science with Distinction in Aerospace Engineering

from the University of Virginia in 1980 and a Master of Science in Aeronautics and Astronautics

from the University of Washington in 1983.

2. My Duties and Responsibilities during my employment at The Boeing Company included

performing flight testing to determine airplane takeoff and landing performance and conducting

performance analyses and trade studies to support customer requests, design decisions, FAA

requirements, and sales guarantees. I also served as an FAA Designated Engineering Representati ve

for airplane performance.

3. The Transport Airplane Directorate has oversight responsibility for transport category airplane

design approvals and modifications worldwide, as well as oversight responsibility for over 900

production approval holders. The Transport Airplane Directorate works closely with other FAA

offices throughout the country and with foreign regulatory authorities to accomplish this mission.

The Transport Standards Staffs responsibilities include maintaining and amending 14 Code of

Federal Regulations part 25, which are the type design airworthiness certification standards for

transport category airplanes. The Transport Standards Staff is also charged with developing and

maintaining compliance guidance and policies pertaining to the airworthiness certification standards

for transport category airplanes, assure consistent application of standards, guidance, and policies by

different FAA offices, harmonize those standards, guidance, and policies to the extent possible with

foreign regulatory agencies, monitor continuous operational safety, participate in accident

investigations, prepare and issue airworthiness directives, respond to FAA and National

Transportation Safety Board (NTSB) safety recommendations, and participate on regulatory and

industry technical committees.

4. My Current Duties and Responsibilities: I am the primary FAA specialist for issues involving

airplane performance and handling qualities for transport category airplanes. My responsibilities

include developing regulatory standards, policy, and guidance on airplane performance and handling

qualities for transport category airplanes, harmonizing these standards, policies, and guidance with

foreign aviation authorities, supporting standardized application of these standards, policies, and

guidance by different FAA offices, and participating in accident and incident investigations related

to airplane performance or handling qualities.

a. I served as the team leader for several rulemaking projects that have resulted in amendments

to part 25, including Amendment 25-92, "Improved Standards for Rejected Takeoff and

Landing Performance," Amendment 25-105, "Revisions to Requirements Cortcerning

Airplane Operating Limitations and the Content of Airplane Flight Manuals for Transport

Category Airplanes," and Amendment 25-121, "Airplane Perfotmance and Handling

Qualities in Icing Conditions." I was also the team leader for developing and issuing

Advisory Circular 25.1581-1, "Airplane Flight Manual," and played a key role in developing

and issuing Advisory Circular 120-91, "Airport Obstacle Analysis."

EXHIBIT

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b. I served as the FAA representative on the airplane performance group for NTSB

investigations of the following landing overrun accidents: Southwest 737~700 at Chicago's

Midway Airport on December 8, 2005, Shuttle America ERJ~170 at Cleveland Hopkins

International Airport on february 18, 2007, and Pinnacle Airways CRJ-200 at Cherry Capital

Airport, Traverse City, MI on April 12, 2007. I also testified at the NTSB public hearing on

the Southwest 737-700 landing overrun accident at Chicago's Midway Airport.

c. I participated in the FAA Landing Perfotmance Team formed shortly after the Southwest

737-700 landing overrun accident to evaluate the adequacy ofthe regulations and guidance in

areas that came under scrutiny during the course of the investigation. I was the principal

author of Safety Alert for Operations 06012, "Landing Performance Assessmeras at Time of

Arrival (Turbojets), issued August 31, 2006 resulting fmmthe FAA Landing Performance

Team's findings and recommendations.

d. I served as technical advisor to the FAA representative on an Aviation Rulemaking Advisory

Committee tasked with recommending harmonized U.S. andE.uropean operating

requirements for airplane performance, including takeoff and landing performance. This

effort began in 1998 and ended in 2002. From 2004 to 2006. I served astechnical advisor to

the FAA representative to the International Civil Aviation Organization (ICAO) for a project

to update ICAO's takeoff and landing performance standardsand.guidance for large

airplanes.

e. I am currently the FAA co-chair for the Takeoff and Landing Performance

Assessment Aviation Rulemaking Committee task.edwith reviewingtegulations

affecting certification and operation of airplanes and airports for airplane takeoff.and

landing operations on runways contaminated by snow, slush, ice, or standing water.

5. The vast majority of existing turbojet airplanes, including those that operate at Santa Monica Muni

(SMO), were certified in accordance with 14 CFR part 25, Airworthiness Standards: Transport

Category Airplanes. These certification standards apply to airplanes rangingfrom business jets to

large airliners. These standards include requirements to determine tbeminimum safe distances

required for the airplane to take off and land under the conditions, airplane weights, and

configurations within the operating envelope defined for the airplane ..

6. For takeoff, the current part 25 certification rules requite that an airplan.e be able to safely contiaae

or reject a takeoff if an engine fails at the most critical point in the takeoff. For both takeoffand

landing, the probability of the failure of any system needed to ShOWc{.')lllpliancewith the certification

requirements must be inversely related to the severity of the failure. Failures that could result in a

catastrophic outcome must be extremely improbable.

7. The rules under which the airplane is operated (i.e., parts 91, 121, 1.25,135) relate the miniIhUlll safe

takeoff and landing distances determined under part 25 to the specific operation and airport for each

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

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

8. Runway Safety Areas (RSA) are not considered during aircraft certification nor do they enter into

the determination of the minimum runway length required under airplane operating rules. Airplanes

must be able to safely operate regardless of the presence or absence ofan RSA. FAA~approved

Airplane Flight Manual (AFM) limitations and perfonnance information, developed in accordance

with the airplane certification requirements, are used to show compliance with the requirements

applicable to that operation. When those requirements are met. there is no aircraft performance

regulatory basis for prohibiting that operation.

9. It is incorrect to categorically assume that operations of Category C and D airplanes into and out of

SMO are less safe than operations of Category A and B airplanes. Airport design standards do not
determine whether a given airplane can safely land or take off at a given airport; this is the function

of the airplane certification and operating rules. The airplane certification and operating rules take

into account the airplane design features and characteristics (for example, airplane weight,

configuration, engine thrust, stopping capability, speeds, and procedures) and the operating

environment (for example, airport elevation, runway surface condition (dry or wet), runway length

and slope, and atmospheric conditions such as wind and temperature) to determine the conditions

under which takeoff and landing operations can be conducted. Airplane approach categories only

categorize airplanes in terms of their approach speed at the maximum certificated landing weight.

They are not intended to and should not be used as a sale criterion for determining whether or not a

takeoff or landing can be safely conducted, nor for evaluating the relative safety risk of different

airplanes for takeoff or landing

10. There can a significant performance overlap in take off and landing capability between Category B,

C, and D airplanes. The approach category is determined by the landing approach speed at the

maximum certificated weight. At lighter weights, the landing approach speed will be lower.

Depending on the weight of the airplane, the landing approach speed of a Category CorD airplane

Can be Jess than that of a Category B airplane operating at a heavier weight. Also, because the

stopping performance of a given Category C or D airplane may be better than that of a given

Category B airplane, the Category C or D airplane may be able to land in a shorter distance than the

Category B airplane even if the landing approach speed is higher. The landing distance depends not

only on the landing approach speed, but also on the capability of the airplane's braking system

(including anti-skid system efficiency, if the airplane has an anti-skid system), spoilers and

speedbrak.es (if the airplane has them), time delays associated in using any deceleration means, and

the airplane's lift and drag characteristics on the ground in the landing configuration. An airplane's

approach category has an even lesser relationship to its takeoff performance capability, since the

takeoff configuration (and hence takeoff speeds) is likely to be different than the landing

configuration, and the airplane's thrustJweight ratio, which is not reflected in the airplane's approach

category, is a very important factor for takeoff performance capability.

11. In addition to the above, there may be other differences between different airplanes, independent of

the approach category, that provide additional safety benefits over and above adherence to the

applicable takeoff and landing performance requirements. These differences may include airplane

design features, operating procedures, and pilot training. Examples of airplane design features that

provide enhanced takeoff and/or landing safety include items such as autothrottles, autobrake

systems, automatic spoilers, enhanced flight deck displays, and thrust reversers.

12. It is incorrect to assume that because an airplane is in approach category Cor D, it cannot safely

operate at SMO, or that such operations categorically carry a higher risk.

I declare under penalty of perjury that the above is true and correct.

April 23, 2008

Donald K Stimson