Revised Impact Assessment Released to the City and Users on September 17,2007

Introduction

The City of Santa Monica has presented an analysis that concludes that the impact of a

300-foot loss of runway length is minimal because it will impact only 235 jet takeoffs out

of a total of 9,000 jet departures annually. The City's analysis does not fully represent the

operational impacts of a shortened runway because it considers only a very limited mix of

aircraft (only certain large aircraft), does not consider landings, does not consider non-jet

aircraft, and only considers stage length as the critical variable.

Because of the large number of variables affecting aircraft performance on any given day,

even for the same aircraft model, because of operating conditions, decisions made by the

pilot in command, or different operating rules placed on Part 135 or Part 91 operators, it is

not possible to describe the exact number of flights that would be affected by a loss of

runway length. It is possible to give an estimated range of impacted operations, however.

A reliable estimate can be obtained by looking at actual flights in recent years, by aircraft

type and stage length, and the performance charts and other data for all types of aircraft

that use SMO. FAA considered the potential impact of a reduction in runway length of

300 feet from several different analytical approaches, which are explained in detail at the

end of this document.

The results using the methodologies described below indicate a number of impacted flights

estimated to be at least 1,400 takeoffs and at least 3,800 landings per year. Even a fraction

of those numbers would be considered a substantial adverse impact on operations.

FAA's analysis relied 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 fleet using

SMO and relied extensively on actual flight review information because that best

represents actual performance and operational use of the aircraft under review.

Stage Length

To accommodate the wide variety of aircraft types reviewed, the FAA opted to apply the

following stage lengths as representative of flight operations conducted from SMO:

Very Short Range (up to 100NM)

Short Range (100- 499 NM)

Medium Range (500- 1,999NM)

Long Range (more than 2,000NM)

e.g. SMO to Van Nuys

e.g. SMO to SPO

e.g. SMO to Dallas

e.g. SMO to 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 Report for 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 of this analysis, these data were accepted as representative of operations at

SMO today and into the future. This is because recent patterns in aircraft types,

destinations, and stage lengths can be expected to continue in the future.

The actual number of jet VFR operations is not 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 a result, 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 a Learjet 35 or a 1,000-mile flight by a Beech 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 a methodology 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 all Part 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 a generic

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 of weight, range, and other variables were also

accounted for. For example, a loss of 200 nautical miles in range and a loss 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 a loss of pavement.

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 on the 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 in question including decisions to not conduct

flight or to reduce payload, effect on reserve fuel, and common operational

practices.

Impact was considered to be severe when there was a necessity to reduce aircraft

useful load to a point near or below 60% because of the reduction in runway length

(loss of useful load below 60% raises the potential of eliminating flights because the

aircraft cannot be utilized for its intended purpose). In some cases, however, an

impacted operation was also defined as a reduction in operating capability, namely

in terms of payload, if the reduction was well beyond the payload level these types

of operations can currently carry to or from SMa. Aircraft operations were

analyzed for the reduction in useful load resulting in an estimate of 428 takeoffs,

re resentin 5.4% of7,800 non-commercial iet 0 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 10,200 jet commercial operations. The result was 550 takeoffs. The

fi ure of 10,2000 erations was obtained b subtractin 7,800 non-commercial

550 Takeoffs
operations from the total of 18,000 jet operations in 2006. Non-commercial and

commercial operations constitute 43% of the total jet operations while 57% are

commercial 0 erations.

~ Estimated Impacted Takeoffs by Turboprop Operators

This result was obtained by reviewing 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 on the

best estimations of operational conditions for the aircraft, including aircraft type,

destination (stage length), typical payload, and typical fuel reserve, for example,

were taken into consideration. Of the 2,613 turboprop operations, 1,326 were large

turboprop types (9,000 to 16,000 lb.), which are susceptible to takeoff restrictions in

the form of accelerate-stop and accelerate-go distance requirements. In some cases,

payload restrictions would also take place. Based on a detailed review of acceleratestop and accelerate-go distance performance, it is estimated that 15% of these

operations would be affected by a reduction of 300 feet under certain temperature

conditions.

Therefore, the number 1,326 operations was multiplied by 0.15 resulting in 199

non-commercial operations. These 199 represent 7.6% of all non-commercial

turboprop operations. In addition, based on the above-mentioned percentages, that

43% of operations are non-commercial and 57% are commercial, the number of

commercial turboprop operations was estimated to be 3,417 (57% x 2,613 noncommercial ops / 43% = 3,417).

This result was multiplied by 7.6% to estimate the number of affected commercial

turboprop takeoffs. The result was 259 takeoffs. The resulting number of affected

turboprops takeoffs is 199 + 259 = 458.

448 Takeoffs
This result was obtained by documenting the takeoff/takeoff field length/balanced field

requirements for 18 different aircraft types using SMa based on the best estimations of

operational conditions for the aircraft. All of the 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, in this study, takeoff requirements exceeding

4,700 feet (representing a loss of300 feet) were considered impacted because the aircraft

capabilities are restrained (e.g., weight penalty) at the outset and thus sensitive to a loss of

runway length below 5,000 feet. The 18 types of aircraft studied here were reported by the

City in its 2001 Design Standards Study. The total number of operations for these 18 types of

aircraft was obtained by adding the annualized operations for each type as reported by the City

in its 2004 Addendum #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 on the best estimations of operational conditions

for the aircraft.

Total operations at SMa increased 12.5% between 2003 and 2006. Assuming each category

of operation increased by the same general amount, the number of operations by these 18

aircraft types in 2006 was estimated to be 8,935 x 1.125 = 10,051. That total was divided by

2 to obtain the number of takeoffs. It was further reduced by 22% to eliminate local shortrange VFR operations. The resulting estimated number of takeoffs by these 18 aircraft 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 a result, takeoff requirements were added for these

types. In addition, the City did not report operations by several impacted aircraft types.

Examples include the Hawker 4000 and the Gulfstream G 150. As a result, operations

information for these es was estimated and incor orated into the anal sis.
All of the 20 aircraft types and groups have an operational runway requirement for landing

that exceeds 2,820 feet, which is the equivalent of 60% of 4,700 feet in available runway

length at SMO if 300 feet were removed. A landing within 60% of available runway is a

requirement under Part 135 and a requirement used by the vast majority of Part 91K operators

at SMO.

Although there are variations from aircraft type to aircraft type, in this 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) at the outset and thus

sensitive to a loss of actual runway length below 5,000 feet.

The 20 types and groups of aircraft studied here were reported by the City in its 2001 Design

Standards Study. The total number of operations for these 20 types and groups of aircraft 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

C-I 2,870 feet 245 3,885

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

of operation increased by the same general amount, the number of operations by these 20

aircraft types in 2006 was estimated to be 12,654 x 1.125 = 14,235. That total was divided

by 2 to obtain the number of landings. It was further reduced by 22% to eliminate local shortrange VFR operations. The resulting estimated number of landings/takeoffs by these 20

aircraft types in 2006 is 14,235 -+- 2 = 7,117, minus 22% = 5,551. Because it is estimated that

70% of 18,000 total operations (3,600 Part 135 Ops + 9,000 Part 91K=12,600) are either Part

135 or actually Part 91K operations that adhere to the Part 135 landing distance requirement,

the total of 5,551 landings was multiplied by 0.7 to generate a final total of3,885 affected

landings.

Note: The City did not report take off information on several aircraft types even though those

aircraft are impacted. Examples include the HS-125-700 and Falcon 20. As a result, landing

requirements were added for these types.
Estimated Impacted Take Offs Based on the Analysis of Several Specific Aircraft

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

Total HS-125 operations, all models, for 2003 were 1,450. Total operations at SMO

increased 12.5% between 2003 and 2006. Assuming each category of operation

increased by the same general amount, the number of HS-125 operations in 2006

was estimated to be 1,450 x 1.125 = 1,630. That total was divided by 2 to obtain

the number of takeoffs. It was further reduced by 22% to eliminate local short-range

VFR operations. The resulting estimated number of IFR 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 at 23,000 lb. at

68°F. If the temperature is 86°F, a take off would be limited at 22,000 lb. This is

about 3,500 lb. below max weight. If300 feet of runway is removed, at the same

temperature of 86°F, a further weight penalty of 800-1,000 lb. would be the result.

At a weight of about 21,000 Ib, the aircraft's useful load is limited to 60%.

However, a review of the performance data and comments from operators, indicates

that some but not all Hawker 800 operations would be impacted. Therefore, it is

assumed that 50% ofHS-125 operations would be adversely affected by payload or

range limitations, resulting in a reduction of 318 take offs (50% of 636 take offs). It

is believed this is a conservative 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 of Beech 400

operations in 2006 was estimated to be 1,350 x 1.125 = 1,462. That total was

divided by 2 to obtain the number of takeoffs only. It was further reduced by 22% to

eliminate local short-range VFR operations. The resulting estimated number ofIFR

takeoffs by Beech 400 aircraft in 2006 is 1,462 +- 2 = 731, minus 22% = 570.

At 15,700 lb., 23°C, the Beech 400A has a field length requirement of 5,280 feet.

The 570 takeoffs by Beech 400 aircraft were classified as impacted because of the

field length requirement, and because there is a significant weight penalty with the

loss 0000 feet of runway 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 for these types were 1,260 in 2003. Total

operations at SMO increased 12.5% between 2003 and 2006. Assuming each

category of operation increased by the same general amount, the number of Learjet

35,45,55 operations in 2006 was estimated to be 1,260 x 1.125 = 1,416. That total

was divided by 2 to obtain the number oftakeoffs and was further reduced by 22%

552 Takeoffs
to eliminate local short-range VFR operations. The resulting estimated number of

IFR takeoffs by these Learjet models in 2006 is 1,416 +- 2 = 708, minus 22% = 552.

16,500 lb. was determined to be an approximate yet adequate threshold for

operational impact as this is a common normal operational takeoff weight found in

this type of operations by these aircraft out of SMO.

~ Canadair/Bombardier CL600 Series Takeoffs

This result was obtained by adding all operations of Can adair 600.601 and 604.

Total operations for these models were 1,050 for 2003. Total operations at SMO

increased 12.5% between 2003 and 2006. Assuming each category of operation

increased by the same general amount, the number of CL600 operations in 2006

was estimated to be 1,050 x 1.125 = 1,181. That total was divided by 2 to obtain 590 88 Takeoffs take offs.

Affected CL-600 flights were estimated to be 15% of all CL600 Series flights. This

in turn yields an estimated number of impacted take offs at 88. With balanced field

requirements as high as 5,700 feet, a typical Challenger 601 runway requirement at

SMO can be 4,900 feet. A loss of300 feet can equal a loss 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 of the G-IV, which would include

any G350 or G450 as well. Total operations for these models were 1,183 in 2003.

Total operations at SMO increased 12.5% between 2003 and 2006. Assuming each

category of operation increased by the same general amount, the number of GIV 99 Takeoffs operations in 2006 was estimated to be 1,183 1.125 = 1,330. That total was divided

by 2 to obtain the number of takeoffs only. The estimated number ofIFR takeoffs

by these models in 2006 is 1,330 -i- 2 = 665. As with the CL600 Series, affected GIV flights were estimated to be 15% of all G-IV flights, which in turn results in 99

impacted take offs. A G-IV-SP can have a balanced field length requirement of

5,450 feet. As such, at 64,000 lb., it already operates with weight penalties.

Sub Total for 39% of Jet 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% of all 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 of jet operations (18,000-7,019=10,981).

However, before computing a final 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 a loss of300 feet in a typical takeoff
scenario from SMO. The resulting total of 5,500 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 in a final affected

number of984. It is noted that this estimate is conservative because many of the

aircraft purposely removed from this calculation still have limitations in terms 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 for these models were 1,183 in

2003. Total operations at SMO increased 12.5% between 2003 and 2006. Assuming

each category of operation 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 2 to obtain the number of landings only. The estimated number of

landings these models in 2006 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 is 665 minus 22% = 518. Except for local VFR flights, all

G-IV landings were classified as impacted, as a reduction below 4,870 feet could

effectively restrict landing weights to below 45,000 lb. This is a very 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 for these types were 1,260 in 2003. Total

operations at SMO increased 12.5% between 2003 and 2006. Assuming each

category of operation increased by the same general amount, the number of Learjet

35,45, 55 operations in 2006 was estimated to be 1,260 x 1.125 = 1,416. That total

was divided by 2 to obtain the number of landings and was further reduced by 22%

to eliminate local short-range VFR operations. The resulting estimated number of

landings by these Learjet models in 2006 is 1,416 -7- 2 = 708, minus 22% = 552. In

this type of aircraft, weights restrictions at about 13,000 lb. are an adequate

threshold for operational impact because 13,000 lb. is a common normal operational

weight found in this type of operations by these aircraft as they operate in and out of

SMO.

Because it is 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 is

required, or Part 91K operations that use the Part 135 landing distance requirement,

the total of5521andin s was multi lied b 0.7 to enerate a final total of386

386 Landings
landings.

~ Impacted Part 135 Learjet 60 Landings

This result was obtained by adding all operations of Learjet 60. Total operations for

these types were 640 in 2003. Total operations at SMO increased 12.5% between

2003 and 2006. Assuming each category of operation increased by the same

general amount, the number of Learjet 60 operations in 2006 was estimated to be

640 x 1.125 = 720. That total was divided by 2 to obtain the number of landings and

was further reduced by 22% to eliminate local short-range VFR operations. The 196 Landings resulting estimated number of landings by Learjet 60 aircraft in 2006 is 720 -i- 2 =

360, minus 22% = 280. On landing, the aircraft is weight limited. At a typical

landing weight, its Part 135 landing requirement is about 2,880 feet, which means

that the actual length of the runway should be no less than 4,800 feet. Because it is

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 is required, or

Part 91K operations that use the Part 135 landing distance requirement, the total of

280 landings was multiplied by 0.7 to generate a final total of 196 affected landings.

~ Impacted Part 135 Citation X Landings

This result was obtained by adding all operations of Citation X aircraft. Total

operations for these types were 1,444 in 2003. Total operations at SMO increased

12.5% between 2003 and 2006. Assuming each category of operation increased by

the same general amount, the number of Citation X operations in 2006 was

estimated to be 1,444 x 1.125 = 1,624. That total was divided by 2 to obtain the

number of landings and was further reduced by 22% to eliminate local short-range 443 Landings VFR operations. The resulting estimated number of landings by these Learjet

models in 2006 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 it is 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

is required, or Part 91K operations that use the Part 135 landing distance

requirement, the total of 663 landings was multiplied by 0.7 to generate a final total

of 443 landings.

~ Impacted Part 135 CL600 Series Landings

This result was obtained by adding all operations of CL600 Series aircraft. Total

operations for these types were 1,050 in 2003. Total operations at SMO increased

12.5% between 2003 and 2006. Assuming each category of operation increased by

the same general amount, the number of CL600 Series aircraft operations in 2006 322 Landings

was estimated to be 1,050 x 1.125 = 1,181. That total was divided by 2 to obtain the

number of landings and was further reduced by 22% to eliminate local short-range

VFR operations. The resulting estimated number of landings by these Learjet

models in 2006 is 1,181 -i- 2 = 590, minus 22% = 460. The CL600 Series aircraft

were classified as impacted because at typical landing weights, these aircraft have

landing distance requirements that exceed 3,000 feet, and therefore, under Part 135,
the actual runway requirement is 5,000 feet. In addition, a loss of 300 feet would

result in a fuel/weight penalty of about 2,000 lb. which is significant in this type of

aircraft. Because it is estimated that 70% of 18,000 total operations (3,600 Part 135

Ops + 9,000 Part 9IK=12,600) are either Part 135, for which a 60% landing

calculation is required, or Part 91K operations that use the Part 135 landing distance

requirement, the total of 460 landings was multiplied by 0.7 to generate a final total

of 322 landings.

409 Landings

~ Impacted Part 135 Beech 400 Landings

This result was obtained by adding all operations of Beech 400 jets. Total

operations for these types were 1,335 in 2003. Total operations at SMO increased

12.5% between 2003 and 2006. Assuming each category of operation increased by

the same general amount, the number of Beech 400 operations in 2006 was

estimated to be 1,335 x 1.125 = 1,501. That total was divided by 2 to obtain the

number of landings and was further reduced by 22% to eliminate local short-range

VFR operations. The resulting estimated number of landings 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 at usually would take 3,500 feet at heavy

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 it is estimated that 70% of 18,000 total operations (3,600 Part 135 Ops +

9,000 Part 9IK=12,600) are either Part 135, for which a 60% landing calculation is

required, or Part 91K operations that use the Part 135 landing distance requirement,

, the total of 584 landings was multiplied by 0.7 to generate a final total of 409

landings.

~ Estimated Affected Landings by All Other Aircraft Types

This result was obtained by multiplying the affected ratio of32% described above

by the remaining number of jet operations (18,000-6,912=11,088). The resulting

total of 11,088 operations was reduced by 4,000 operations of straight wing

Citations jets that would not be as affected in many landings scenarios resulting in

7,088 operations. This was multiplied by the affected ratio of 32% resulting in 2,268

affected landings. That total was further reduced by 22% to eliminate local shortran e VFR 0 erations, resultin in an affected number of 1,769.

1,769 Landings