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: Ihave been employed as an Aerospace Engineer with the Federal Aviation Administration (FAA) for sixteen years. During that time, 1have 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 

# 1:T7EI1f~b. I served as the FAA representative onthe airplane performance group forNTSB investigations ofthe following landing overrun accidents: Southwest 737~700at Chicago's Midway Airport on December 8, 2005, Shuttle America ERJ~170atCleveland Hopkins International Airport on february 18,2007, andPinnacle Airways CRJ-200 atCherry Capital Airport, Traverse City, MIonApril 12,2007. Ialso testified atthe NTSB public hearing on the Southwest 737-700 landing overrun accident atChicago's Midway Airport.

c. Iparticipated 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 ofthe 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. Iserved as technical advisor to the FAA representative on an Aviation Rulemaking Advisory Committee tasked with recommending harmonized 

### U.S. andE.uropean operating requirements forairplane performance, including takeoff andlanding performance. This effort began in 1998 and ended in2002. From2004 to2006. Iserved astechnical advisor to the FAA representative to the International Civil Aviation Organization (ICAO) for aproject to update ICAO's takeoff andlanding performance standardsand.guidance for large airplanes.

e. I am currently the FAA co-chair forthe Takeoff and Landing Performance Assessment Aviation Rulemaking Committee task.edwithreviewingtegulations affecting certification and operation ofairplanes and airports for airplane takeoff.and landing operations onrunways contaminated by snow, slush, ice, or standing water.

5. The vast majority ofexisting turbojet airplanes, including those that operate atSanta Monica Muni (SMO), were certified in accordance with 14CFRpart 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 offand landunder theconditions, airplane weights, and configurations within the operating envelope defined forthe airplane

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

orreject atakeoff ifan engine fails at themost critical point inthe takeoff. For both takeoffand landing, the probability ofthe failure ofany system neededto ShOWc{.')lllpliance with the certification requirements must be inversely related to the severity ofthe failure. Failures that could result in a catastrophic outcome must beextremely 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 underpart 25 tothe specific operation and airport for each takeoff. The combination ofthe airplane certification rules andthe operating rules provide the requirements and parameters under which takeoff and landing operations can be safely conducted.

8. Runway Safety Areas (RSA) arenot considered during aircraft certification nor do they enter into the determination ofthe minimum runway length required under airplane operating rules. Airplanes must be able to safely operate regardless ofthepresence or absence ofan RSA. FAA~approved Airplane Flight Manual (AFM) limitations andperfonnance information, developed in accordance with the airplane certification requirements, areusedto show compliance with the requirements applicable to that operation. When those requirements aremet. there is no aircraft performance regulatory basis for prohibiting that operation.

9. Itis incorrect to categorically assume that operations ofCategory C and Dairplanes into and out of SMO are less safe than operations ofCategory AandB airplanes. Airport design standards do notdetermine whether agiven airplane can safely landortake offat agiven airport; this is the function

ofthe 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) andthe operating environment (for example, airport elevation, runway surface condition (dry orwet), runway length and slope, and atmospheric conditions such aswind andtemperature) todetermine the conditions under which takeoff andlanding operations canbeconducted. Airplane approach categories only categorize airplanes interms oftheir approach speed atthe maximum certificated landing weight. They are not intended to and should notbeused as asale criterion for determining whether or not a takeoff or landing can be safely conducted, norfor evaluating the relative safety risk ofdifferent airplanes for takeoff orlanding

10.There can a significant performance overlap intake offand landing capability between Category B, C, and D airplanes. The approach category is determined bythe landing approach speed atthe maximum certificated weight. At lighter weights, the landing approach speed will be lower. Depending on the weight ofthe airplane, the landing approach speed ofaCategory CorD airplane CanbeJessthan that ofaCategory B airplane operating at aheavier weight. Also, because the stopping performance ofagiven Category C orD airplane may be betterthan that of agiven Category B airplane, the Category C orD airplane may be able to land ina shorter distance than the Category B airplane even ifthe landing approach speed ishigher. The landing distance depends not only on the landing approach speed, but also onthe capability ofthe airplane's braking system (including anti-skid system efficiency, ifthe airplane has an anti-skid system), spoilers and speedbrak.es (ifthe airplane has them), time delays associated inusing any deceleration means, and the airplane's lift and drag characteristics onthe ground inthe landing configuration. An airplane's approach category has an even lesser relationship toits takeoffperformance capability, since the takeoff configuration (and hence takeoff speeds) islikely to be different than the landing configuration, and the airplane's thrustJweight ratio, which is notreflected inthe airplane's approach category, is avery important factor fortakeoffperformance 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 andlanding performance requirements. These differences may include airplane design features, operating procedures, andpilot training. Examples ofairplane design features that provide enhanced takeoff and/or landingsafety include items such as autothrottles, autobrake systems, automatic spoilers, enhanced flight deck displays, andthrustreversers.

12.It is incorrect to assume that because anairplane is in approach category Cor D, itcannot safely operate at SMO, orthat such operations categorically carry ahigher risk.

I declare under penalty ofperjury thatthe above istrue and correct.
April 23, 2008

Donald K Stimson