RPVCCA_CC_SR_2011_10_04_H_LB_Airport_Airspace_DesignationCrTYOF
MEMORANDUM
RANCHO PALOS VERDES
TO:
FROM:
DATE:
SUBJECT:
REVIEWED:
Staff Coordinator:
HONORABLE MAYOR &CITY COUNCIL MEMBERS ~
DENNIS McLEAN,DIRECTOR OF FINANCE &INFORMATIO
TECHNOLOGY
OCTOBER 4,2011
2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE
DESIGNATION SURROUNDING LONG BEACH AIRPORT
CAROLYN LEHR,CITY MANAGER o..Q.--
Matt Waters,Senior Administrative Anaiyst ~
RECOMMENDATION
1)Receive and file the Technical Analysis report prepared by Williams Aviation
Consultants regarding the Federal Aviation Administration's (FAA)revised proposal
to establish Class C Airspace surrounding Long Beach Airport;and,
2)Authorize Staff to send the draft comment letter and the Technical Analysis report to
the FAA regarding the revised proposal.
EXECUTIVE SUMMARY
The FAA proposed a revision to Long Beach Airport's (LGB)airspace in 2010 that would
have tripled the size of its existing Class 0 airspace.It had been reported that JetBlue
Airlines requested the change due to the frequency of traffic collision avoidance alerts it
had allegedly been experiencing.The City hired Williams Aviation Consultants (WAC)to
study the issue.WAC's Technical Analysis showed that an expanded "Class Coo airspace
would have significant unintended consequences for the Peninsula and other South Bay
cities.
While passenger safety is of the upmost importance,the City Council,Staff,and the City's
aviation consultants were extremely concerned about the "unintended consequences"that
could have been experienced by the City and neighboring South Bay coastal communities,
including:
1)Increased safety risks resulting from a greater number of general aviation ("GA")
aircraft flights compressed in flight areas;
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2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 2 of9
2)Environmental impacts,especially increased aircraft noise and air pollution from
piston-powered and turboprop aircraft;
3)Increase of GA aircraft fiights across the entire Peninsula,as well as over
neighborhoods in Redondo Beach,Hermosa Beach,Torrance and San Pedro;and,
4)Increased workload of FAA traffic controllers,possibly impairing passenger flight
safety.
With the assistance of WAC,the City Attorney submitted Technical Comment to the FAA in
a letter dated September 30,2010,citing the unintended consequences that were
expected to result from the proposed airspace revision.The other Peninsula cities,the
South Bay cities of Torrance,Redondo Beach and Manhattan Beach and many residents
and businesses sent comment letters expressing their concerns to the FAA as well.
The City recently became aware of a revised proposal for LGB airspace.WAC again
performed an analysis that revealed that the FAA had substantially modified the plan and
appropriately addressed each of the technical issues identified in the City's Technical
Comment letter.WAC opined that the unified response by the City and other cities,
residents and businesses played a significant role in the FAA's revised 2011 Proposed
LGB Class C airspace.
City staff held a conference call with Redondo Beach,Rolling Hills,Palos Verdes Estates,
Torrance and a WAC representative on September 28 to discuss the FAA's revised 2011
Proposed LGB Class C airspace.All cities agreed that the FAA had made substantive
changes.City staff and WAC agree that WAC's Technical Analysis,along with a letter
from the City,expressing the support of the other cities mentioned above,should be sent
to the FAA in advance of upcoming public meetings in October.All of the cities expressed
their support;Redondo Beach plans to take the issue to its City Council on October 18,
2011 for approval.Staff has contacted the staff of the City of Rolling Hills Estates to
confirm their continuing support.The draft comment (with WAC's Technical Analysis
attached to it)would:
a)Congratulate and thank the FAA for the airspace revisions contained in the 2011
LGB Class C Proposal;
b)Point out the issue of the loss of 900 feet of airspace in the harbor as shown in the
green section in figure 5;
c)Encourage the FAA to thoroughly analyze any potential issues and impacts that
arise or are identified at Hle OCtober meetings and the subsequent public comment
period;and,
d)Request that the FAA advise the City of any significant changes it considers to the
2011 LGB Class C Proposal during the comment period and before the rulemaking
step.Any changes made in airspace configuration as a result of the current public
comment period should trigger a new period for public comment.
The FY 11-12 budget includes $15,000 in City Administration/Professional Technical
Services for aviation consulting services.The budget will be sufficient to absorb the
expected costs of aviation consulting services,estimated to not exceed $6,500.
Neighboring cities have been asked to share the cost of such services.The City wasH-2
2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 3 of 9
reimbursed a total of 85%of the total cost of $15,000 for such services performed in 2010.
BACKGROUND·2010 PROPOSED LONG BEACH CLASS C AIRSPACE
In 2010,the FAA proposed a substantial change to Long Beach Airport's (LGB)airspace
designation to Class C airspace (the "2010 Proposed LGB Class C Airspace".The 2010
Proposed LGB Class C airspace would have been three times larger than the existing
Class 0 airspace surrounding LGB.It was reported that JetBlue Airlines requested the
change due to the frequency of traffic collision avoidance alerts it had allegedly
experienced.If it had been implemented,this revision was expected to increase air traffic
over the Peninsula and South Bay,and have significant noise,safety and environmental
impacts.Figure 1 below depicts the current LGB Class 0 airspace;Figure 2 depicts the
2010 Proposed LGB Class C Airspace.
C
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100
80
I 0:1-_--------..-
Figure 1 Current 2010 LGB Class 0 airspace
These concerns led to the City's retention of Williams Aviation Consultants ("WAC"),one of
the country's prominent aviation consulting firms.WAC prepared a Potential Impact
Statement followed by an in-depth Technical Analysis of the proposed airspace change.
WAC's analysis of the 2010 proposal identified unintended consequences that could
impact the City and neighboring South Bay coastal communities including:
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2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 4 of9
>-Flight instructional aircraft from schools based at Hawthorne,Compton,Fullerton,
Long Beach and Torrance airports would likely move from the LNLong Beach
harbor practice area (a significant portion of which would become restrictive Class C
airspace)to the Palos Verdes coastline;and
>-A greater number of general aviation aircraft would avoid the Class C airspace
entirely and opt to fly along the entire Palos Verdes coastline and over
neighborhoods in Redondo Beach,Torrance,Palos Verdes Estates,Rolling Hills,
San Pedro,Lomita and Rancho Palos Verdes.
100
80
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------ J
Figure 2 2010 LGB Class C Airspace Proposal
WAC concluded that these proposed changes,if implemented,would result in:
1)Increased safety risks resulting from a greater number of general aviation ("GA")
aircraft flights compressed in flight areas;
2)Environmental impacts,especially increased aircraft noise and air pollution from
piston-powered and turboprop aircraft;
3)Increase of general aviation aircraft flights across the entire PV Peninsula,as well
as neighborhoods in Redondo Beach,Hermosa Beach,Torrance and San Pedro;
and,
4)Increased workload of FAA traffic controllers,possibly impairing passenger flight
safety.
The City Council authorized sending a Technical Comment letter to the FAA in September
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2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 5 of 9
2010 expressing these and other concerns about the proposed LGB Class C airspace.
Other South Bay cities and numerous residents sent their written concerns as well.
DISCUSSION -2011 LGB CLASS C PROPOSAL
Staff recently received word of upcoming FAA public meetings in October regarding the
revised proposal to create a Class C airspace surrounding LGB (the "2011 LGB Class C
Proposal").WAC reviewed the 2011 LGB Class C Proposal and advised Staff that they
believe that the City's pro-active effort in 2010,including the submission of the City's
Technical Comments letter,as well as the unified comments provided by a number of
South Bay cities,concerned residents and businesses led to the FAA's decision to
significantly modify the 2010 proposal.Staff and WAC reviewed the 2011 LGB Class C
Proposal shown below in Figure 3.
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80 LOnG ilEIIoCH Il:tRO:JR A,ili.o\
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Figure 3 2011 Revised LGB Class C airspace
WAC performed a Technical Analysis that summarized its findings as follows:
"The 2011 LGB Class C proposal appears to make numerous changes in
response to the public comments received on the 2010 proposal.Many of
the impact issues identified by WAC in the analysis of the 2010 proposal
are resolved or significantly reduced by the 2011 design."
WAC's Technical Analysis of the 2011 LGB Class C proposal concludes:
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2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 6 of 9
•"The 2011 revised proposal has incorporated changes which mitigate
virtually all of the concerns identified by the City,as well as other South
Bay cities.
•No potential safety or noise issues were identified that would impact South
Bay cities [including the City].The FAA has made changes in the 2011
proposal which address,to a significant degree,each of the technical
issues identified [in the Technical Comment letter sent to the FAA by the
City]during the 2010 comment process.
•The FAA should,however,identify and thoroughly analyze any potential
impact issues identified during the upcoming public comment period."
The following is a more detailed analysis of the revised 2011 proposal's impacts:
Positive Changes -2011 LGB Class C Airspace Proposal
Many of the impact issues identified in the analysis of the 2010 proposal are resolved or
significantly reduced by the 2011 LGB Class C Airspace Proposal.The highlighted
portions of Figure 4 depict the areas of significant airspace change between the 2010
and 2011 Class C proposals.
•Positive Impact on Long Beach Airport Training Area:The elimination of the area
marked in blue in Figure 4 addressed many of the concerns offered by the pilot
community,allowing VFR aircraft to transition both North and South-bound near the
shoreline and reducing the impact on the Long Beach Airport training area.
•Significant reduction of adverse impact on Long Beach and Palos Verdes Training
Areas:The floor of the Class C airspace marked in red in Figure 4 has been raised
which has a significant beneficial impact on South Bay residents.Aircraft flying
southeast of Torrance Airport will not be forced to operate dangerously close to the
ground or seek an alternate route over South Bay cities.This change,combined
with the elimination of the blue section in Figure 4 significantly reduces the adverse
impact on both the Long Beach Airport and Palos Verdes flight training areas.
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2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 7 of9
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Eliminated
Figure 4:Areas of significant airspace change between 2010 and 2011 proposals
•Positive effect on pilots using LAX mini-route:The mini-route allows planes to fly
over arriving and departing planes at LAX.The 2010 plan proposed lowering a
section of the Class C airspace floor which could potentially affect southbound
aircraft exiting this mini-route,due to its close proximity.Planes not wishing to enter
the expanded Class C airspace would than have to tum quickly to the West,flying
over the South Bay and Peninsula.The exact number of planes this would have
affected is not known,but WAC believes it would have been a significant increase.
The changes in the 2011 revision have reduced this impact significantly.The
lowering of the floor of Class C airspace shown in orange in Figure 4 will have
minimal impact on southbound aircraft exiting the mini-route.WAC's analysis
shows that the southern portion of the orange area is close to,but does not
encompass the LAX mini-route extension.WAC's analysis concludes that even if
planes needed to alter their flight paths to steer clear of the Class C airspace,"the
amount of movement would not have any adverse impact on any South Bay City."
Minor Loss of Airspace in Revised Plan
While the Technical Analysis prepared by WAC emphasizes the positive aspects of the
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2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 8 of9
revision and the reduced impacts on the City and the South Bay,its analysis points out a
minor loss of airspace.
•Minor Loss of Airspace Top Usable Altitude in Harbor Area:The area in green in
figure 5 shows the only remaining area of impact in the 2011 proposal according to
WAC's analysis.The top usable altitude is reduced in the revision from 4,500
AMSL to 3,599 AMSL.The elimination of Class C airspace to the eastern portion of
the practice area allows aircraft affected by this 900 foot reduction,to shift
operations a short distance to the east or south.Previous concern about a large
scale shift of practice activity to the west along the Palos Verdes coastline has been
eliminated.WAC describes this as a relatively minor loss of airspace.Aircraft
affected by this 900 foot reduction can shift their operations a short distance to the
east or south.
Figure 5:Minor loss of airspace in Harbor area
While the 2011 LGB Class C airspace proposal is certainly a welcome development,staff
recommends that the City send a comment letter to the FAA that:
a)Congratulates and thanks the FAA forthe airspace revisions contained in the 2011
LGB Class C Proposal;
b)Points out the issue of the loss of 900 feet of airspace in the harbor as shown in the
green section in figure 5;
c)Encourages the FAA to thoroughly analyze any potential issues and impacts that
arise or are identified at the October meetings and the subsequent public comment
period;and,
H-8
2011 (REVISED)PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING
LONG BEACH AIRPORT
October 4,2011
Page 90f9
d)Requests that the FAA advise the City of any significant changes it considers to the
2011 LGB Class C Proposal during the comment period and before the rule making
step.Any changes made in airspace configuration as a result of the current public
comment period should trigger a new period for public comment.
WAC and staff concur that it would also be beneficial for neighboring cities to provide their
comments and feedback to the FAA.Staff and WAC believe that a unified response by the
City and other South Bay cities will not only send a strong message to the FAA in favor of
the positive modifications in the 2011 Proposal,but also strongly encourage the FAA to
keep South Bay cities involved and informed of any changes as the public comments and
rulemaking process moves forward.
Staff and a WAC representative held a conference call on September 28,2011 to discuss
this issue in depth.The Cities of Palos Verdes Estates,Redondo Beach,Rolling Hills,and
Torrance all expressed their support for the substantial improvements made by the FAA.
Redondo Beach staff plans to take the issue to its Council for approval on October 18,
2011.Staff has contacted the staff of the City of Rolling Hills Estates to confirm their
continuing support.The support of the other cities is included in the City comment letter to
the FAA that is attached to this report.The Technical Analysis prepared by WAC will be
attached to the comment letter.City of Rancho Palos Verdes staff intends to attend the
October 25 and 26 FAA meetings in Long Beach,as well as an FAA meeting at Torrance
Airport on October 5,and will report back to the neighboring cities and the City Council on
any significant developments.
FISCAL IMPACT
The FY 11-12 budget includes $15,000 in City Administration/Professional Technical
Services for aviation consulting services.The budget will be sufficient to absorb the
expected costs of such services,estimated to not exceed $6,500.Neighboring cities have
been asked to share the cost of such services.The City was reimbursed a total of 85%of
the total cost of $15,000 for such services performed in 2010.
ATIACHMENTS
Technical Analysis of the Revised (2011)LGB Class C Airspace Proposal prepared by
Williams Aviation Consultants
Draft Comment Letter to FAA,dated October 4,2011
H-9
'vi Ji(fiams Aviation Consu{tants
Technical Analysis of the Revised (2011)Long Beach Airport (LGB)Class C Airspace Proposal
BACKGROUND
In September,2010,Williams Aviation Consultants,Inc.(WAC)was tasked to prepare a written Technical
Analysis of the Federal Aviation Administration's (FAA)proposal to establish Class C Airspace around Long Beach
Airport and Revise Orange County (SNA)Class C Airspace.The Analysis discussed in-depth the potential impacts
to the residents of the City of Rancho Palos Verdes and other coastal cities should the proposed Ciass C airspace
be implemented.This analysis served as the basis for technical comments submitted to the FAA by various South
Bay communities during the established comment period.
WAC determined that significant potential existed for impacts that had not been anticipated or analyzed by the
FAA.These "Unintended Consequences"had potential significant adverse impact on the residents of the City of
Rancho Palos Verdes and other neighboring communities.The September 2010 analysis concluded:
"The change from the current Class D airspace to the more restrictive and larger Class C Airspace will
cause significant change in uncontrolled VFR (Visual Flight Rules)aircraft routing.Some of these changes
will be related to the fact that the Radar Approach Controi facility (TRACON)in San Diego will be the
controlling facility for some of the Class C Airspace.Other reasons include the loss of a significant
portion of the LA/Long Beach Harbor Training Area,proximity to and impact on the published LAX "Mini
Route"and reduced airspace avaiiable for TOA (Torrance Zamperini Airport)operations.
The impact on IFR (Instrument Flight Rules)traffic into and out of airports in the vicinity of the proposed
Class C airspace will be minimal.However,the anticipated compression of uncontrolled VFR aircraft may
increase the number and severity of proximity incidents for aircraft conducting instrument operations
and increased controller workload may delay some IFR operations.The potentiai impact on IFR
operations from both a safety and efficiency standpoint must be anaiyzed by the FAA prior to the
implementation of the proposed Class C airspace.
The unintended consequence of compression of uncontrolled VFR aircraft activity is a major safety
concern associated with this airspace change proposal.The FAA has not provided any data on how
existing operations within the published VFR Practice Areas or at HHR (Hawthorne Airport),TOA or any
other airport will be affected by the airspace change.The impact of the difference in access between
Class D and Class C airspace and the related safety issues (impact on the VFR practice areas,operations
at adjacent airports,use of the LAX [Los Angeles Internationai Airport]Mini Route and increased
potential for pcoximity to terrain incidents)associated with the compression of uncontrolled VFR aircraft
must be analyzed by the FAA prior to the Class C implementation.A public comment period should be
established to allow input regarding this analysis."
On August 23,2011 The FAA released a revised LGB Class C airspace proposal (Attachment 1).This proposal is
referred to as the "New Proposal"or "2011 LGB Class C Airspace Proposal".
Williams Aviation consultants,Inc.
1
H-10
Current Conditions
LGB currently is served by Class D airspace which is significantly smaller and less restrictive to users than is Class
C.The FAA's current Class D airspace surrounds LGB with a 5 mile radius.The arc of the radius of the FAA's
current LGB Class D airspace barely extends past the 710 freeway to the west,barely past the 91 freeway to the
north and just past the shoreline near the LA/Long Beach harbor area.The LGB Control Tower is the only
controlling facility for aircraft operating within the Class D Airspace.Figure 1 depicts the current Class D
airspace.
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Figure 1,Current LGB Class D Airspace'
1 From a presentation of the Orange County Flight Center by the Southern California Airspace Users Work Group Education
Subcommittee.
Williams Aviation consultants,Inc.
2
H-11
2010 Class C Proposal
In the FAA's 2010 proposal,LGB Class C airspace would extend west to the 110 Freeway (its western edge),
north to the 91 freeway (its northern edge)and south out over the ocean 3 to 5 miles engulfing the entire
LA/Long Beach harbor area.The proposed airspace would be about 3 times larger than the existing Class D
airspace.The significant increase in airspace to the south and west would require VFR pilots to receive control
instructions from the Radar Approach Control facility in San Diego for access to some parts of the Class C
airspace.This requires additional controlier to controlier coordination and is significantly less efficient than the
single control entity (LGB Tower)currently providing the service.Figure 2 depicts the 2010 proposed Class C
Airspace.The numbers within each biock of airspace indicate the base and top altitudes of the Class C airspace
Above Mean Sea Level (AMSL)in hundreds of feet.SFC indicates the base of the class C Airspace is the surface.
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80
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Figure 2,2010 LGB Class C Airspace Proposal'
2 Source:FAA Power Point Presentation,June 22 and 23,2010,
Williams Aviation consultants,Inc.
3
H-12
2010 Proposal Design Concerns
The floor of the proposed Class C airspace west of LGB meets the technical requirement of being 1,200 feet
above terrain.However,terrain only 100 feet below the Class C airspace floor is less than 3 miles from the Class
C airspace western boundary.The proximity to higher terrain will limit,to an unknown extent,the number of
aircraft electing to fly under the floor of the proposed Ciass C airspace.Those aircraft will fly west of the Class C
boundary over residential areas of the south bay.(Figure 3 depicts the Class C airspace proximity to terrain.
Figure 3
Williams Aviation consultants,Inc.
4
H-13
Of most concern to the residents of Rancho Palos Verdes and other coastal cities in the 2010 Class C proposal
was the addition of restricted airspace west and south of LGB airport.Figure 4 depicts one of two areas of
greatest concern.
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Figure 4'
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Impact of Area B
Area B,depicted in darker green in Figure 4.would compress traffic that was unable or unwiiling to estabiish
two way radio communications with Air Traffic Control (ATC)prior to entering Class C airspace.This compression
would occur to the west of the 110 freeway or at very low altitude under Area B.
Of particular concern was the potential impact to aircraft utilizing the pubiished "Mini Route"over LAX (Figure
5).Aircraft exiting the Mini Route southbound would be required to contact ATC immediately upon leaving the
route and estabiish two way communications very rapidly to enter Class C airspace or divert south or southwest
bound to avoid inadvertent entry into the Class C airspace.This would have placed the majority of these aircraft
west of the route currently used.The magnitude of the traffic and the distance west of normal was unknown but
was believed to be sub,tantia!.
This area would also restrict the airspace available for aircraft departing Torrance Airport to the northwest to
make a right turn after takeoff.A significant number of aircraft would execute a left turn after takeoff to avoid
operating at extremely low altitude below the proposed Class C floor.
3 Source:FAA Power Point Presentation,June 22 and 23,2010.
Wiliiams Aviation consultants,Inc.
S
H-14
MINI ROUTE
VFR ONLY
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CLEARANCE
REQUIRED HAWTHORNE &
405 FREEWAY
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MINI ROUTE NORTHBOUND:During normal tOWN operating hO\Jr!:.0500·2000 Let...Hawlhorno
Tower i21.1 will cooralnalt!mm~ition5 through the Mini Rou:c.Arter normal tower opara.llng
hours,conlact LAX Towsl 119.B.Proc;r.cd to Hilwlhornc &405 Freeway (VPL.SR;at 2500'.Enter tht!
Los Angeles Clas;,B &5~abli,hDd on and follolN th:e S~nIQl Monic:!128 radial until ulll110 the Clas5 B_
MINI ROUTE SOUTHBOUND:Ou;iny nOlmal ~ower oporAtlng nours,0700·2100 LCL.Sonta Monica
Ta....·er 120.1 will cODr~lni1tC'tr.r.n~i1ion,Ihrough tho ~Iinj Route.After normol tower operating hours.
contact LAX Towill 119.B.?r<>ceeCl 10 Loyola Marymount Unlvurslty (LMU~OIl 2500'.Enter tile los
Ar'lgeles erGS5 8 o!Olnblllihod on Olnd tallow the Sllnta Monic,;]120 nil dial until aKIUno the Class 8.
NoTe:Remllin clear 01 Elril\'O airspace unlil clearance 15 recol\lod.Fbatl·wlng.non·~urbojl'Jl
aircrnft Olltr.LAX mu::;t tiD I;)jJ..wc~t traffln or ower-Q;Qan (g'llnt'riJ.lly midniglll to OG30 L.CLI
confiouriHlofl ;100 reponing a ceJllno of ill IOO:lt :lOCi),sod v[!:/bllltv of iJl IOi3:il lhr~o mile::;.
Hawthornu and Santa Monica Airports mus:btl VFR.
REMAIN CLEAR OF THE CLASS B UNTIL RECEIYUiG SPECIFIC ATe APPROVAL 10 ENTER
Figure 5
Williams Aviation consultants,Inc.
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H-15
The second area of significant concern is shown in Figure 6.
Figure 6
Area C,identified in darker green in Figure 6,extends south to the breakwater and East to the shoreline.
The 2010 proposed Class C Airspace eliminated almost all the usable airspace north of the breakwater in the
Long Beach/LA Harbor Flight Training Area (LGB Practice Area).In addition,a significant amount of airspace in
the eastern portion was also reduced.The FAA airspace change would likely have caused flight instructional
aircraft to move from the LA/Long Beach harbor Flight Training Area to other areas along the coastline south of
LAX.Figure 7 depicts the Long Beach/LA Harbor and Palos Verdes VFR Practice Areas.
Figure 7'
4 From a presentation of the Orange County Flight Center by the Southern California Airspace Users Work Group Education
Subcommittee.
Williams Aviation consultants,Inc.
7
H-16
The impact an South Bay cities
The WAC Analysis of the 2010 proposal identified many potential significant adverse impacts to the residents of
the City of Rancho Palos Verdes and other neighboring south bay communities.The analysis listed these as
"unintended consequences".They included:
1.Flight instructional aircraft from schools based at Hawthorne,Compton,Fullerton,Long Beach and
Zamperini Field (Torrance)airports would likely move from the LA/Long Beach harbor practice area (a
significant portion of which would become restrictive Class C airspace)to other portions of the Palos
Verdes coastline.
2.A greater number of general aviation aircraft departing from Zamperini Field (Torrance)will avoid the
Class C airspace:
a.Departing west,turning south along the entire Palos Verdes coastline,over neighborhoods in
Redondo Beach,Torrance (Torrance Beach).Palos Verdes Estates and Rancho Palos Verdes;or
b.Departing west,turning 1BO degrees right and flying along the northeastern and eastern edges
of the Palos Verdes Peninsula over and near neighborhoods along the Western Avenue corridor,
including Rolling Hills,Rolling Hills Estates,Lomita,San Pedro and Rancho Palos Verdes.
3.A greater number of generai aviation aircraft currently flying over coastal Southern California using the
Mini-Route and visual flight rules ("VFR")wili divert around the Ciass C airspace,instead flying:
a.Along the entire Palos Verdes coastline,over neighborhoods in Hermosa Beach,Redondo Beach,
Torrance (Torrance Beach).Palos Verdes Estates and Rancho Palos Verdes;or
b.Along the northeastern and eastern edges of the Palos Verdes Peninsula over and near
neighborhoods along the Western Avenue corridor,including Rolling Hilis,Rolling Hilis Estates,
Lomita,San Pedro and Rancho Palos Verdes.
Williams Aviation consultants,Inc.
B
H-17
The New FAA Proposal
The FAA proposes to establish a significantly modified Class C airspace over and around Long Beach Airport
(LGB).The new proposed LGB Class C airspace is depicted in Figure 8.
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Figure 8'
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2010 vs.2011 comparison
The 2011 LGB Class C proposal appears to make numerous changes in response to the public comments received
on the 2010 proposal.Many of the impact issues identified by WAC in the analysis of the 2010 proposal are
resolved or significantly reduced by the 2011 design.
5 Southern California Airspace Users Working Group (SCAUWG),August 24,2011.
Williams Aviation consultants,Inc.
9
H-18
The highlighted portions of Figure 9 depict the areas of significant airspace change between the 2010 and 2011
Class C proposals.
19
Eliminated
Figure 9
The area highlighted in blue in Figure 9 has been eliminated in the 2011 proposal.The base altitude (floor)of
the 2011 proposal has been raised to 3,600 feet AMSL in the area shown in red.The floor of the airspace
depicted in orange has .been lowered to the surface.The upper limit of the 2011 Class C has been raised to meet
the base ofthe overlying LAX Class B airspace.
Impact of the Design Changes
The increase in height of the top of the proposed Class C has no apparent impact on the South Bay cities.
The elimination of the area depicted in blue addresses many of the concerns offered by the pilot community.
The change allows VFR aircraft to transition North and South bound near the shoreline.This change also
significantly reduces the impact of the 2010 proposal on the eastern portion of the LGB Practice Area.
Williams Aviation consultants,Inc.
10
H-19
The raising of the floor of the Class C airspace in the area shown in red has the most beneficial impact on the
residents of the South Bay.
This change,along with the elimination of the area shown in blue,significantly reduces the adverse impact on
the LGB/PV Practice Areas.Figure 10 shows the only remaining area of impact,highlighted in green,caused by
the 2011 proposal.The depicted area is reduced from that currentiy available by 900+feet (the top usable
altitude is reduced from 4,500 feet AMSL to 3,599 feet AMSL).The elimination of Class C airspace in the eastern
portion of the practice area allows aircraft affected by this 900 foot reduction,to shift operations a short
distance to the east or south.The previous concern about a large scale shift of practice activity to the west has
been eliminated.
19
,
Figure 10
The raising of the floor within the red area shown in Figure 9 also dramatically reduces the impact on Torrance
(Zamperini Field)Airport.Aircraft operating southeast of the airport are no longer forced to operate dangerously
close to terrain or seek-an alternate route.
This change also reduces the adverse impact on the LAX Mini Route (Figure 5).The 2010 proposal placed Class C
airspace directly in front of southbound aircraft exiting the Mini Route.This required the pilot to almost
instantly receive permission to enter the Class C airspace or alter his/her route of flight to the southwest to
avoid unauthorized entry into the airspace.The impact on the residents of the South Bay Cities was unknown
but believed to be potentially significant.
Williams Aviation consultants,inc.
11
H-20
The proposed increase in base altitude in the red area of Figure 9 allows the southbound pilot significantly more
time to establish 2-way radio communications with ATe.If the pilot elects to avoid the Class C airspace,the
required diversion is significantly reduced from that necessary with the 2010 airspace design.
The lowering of the floor of the proposed Class C airspace depicted in orange in Figure 9 has minimal impact on
southbound aircraft after exiting the LAX Mini Route (Figure 5).The southern portion of the orange area is in
very close proximity to but does not encompass,the extension of the LAX Mini Route (Figure 11).Even if north
and south bound aircraft transitioning between the LAX Mini Route and the shoreiine/LGB Practice Area elected
to alter their route of flight to assure remaining clear of the Class C airspace,the amount of movement would
not have any adverse impact on any South Bay City.
~
VINCEN
THCiMA
BRIDGE
(VPLVf)
Figure 11
Conclusion
Our analysis of the 2011 LGB Class C proposal revealed:
The proposal has incorporated changes which address virtuaily all of the 2010 Class C Airspace Proposal issues
identified by the South Bay Cities.
No potential safety or noise issues impacting South Bay Cities were identified.The FAA has made changes in the
2011 proposal which address,to a significant"degree,each of the technical issues identified during the 2010
comment process.
The FAA should,however,identify and thoroughly analyze any potential impact issues identified during the
upcoming public comment period.Any changes made in airspace configuration as a result of the current public
comment period should trigger a new period for public comment.
Williams Aviation consultants,Inc.
12
H-21
Attachment 1
'---=,;:r--"",
52596 Federal Rogislerl Vol.7ti,Nil,'Ili:J/Tunsc!uy.AUlJust 2:1,21111/Proposcd Rulw;
[;ermaIlY.II.<IS illlulllml ami nJ(llIinl~
coUlIlIi.lItel)willi Ih.!Tr.llIsflort Cll1iltl,l AU.
ISSlIed in For1 Wot1h.T'lXiiS,011 111Ill!J.
:nit.
Kim Smith.
,\ll1nfljN!f.t/nton:mft nin.'f.1/1m/l~.Ain:m!l
CcrtifiLlllirm !'i4.'f1'it:t!.
IFR ''''::.?lI11_?Io&i'!."11"..111-21-11;Q 0&:'."ul
IJIL.l.lHG COot ~"l)..I)..$'
DEPARTMENT OF TRANSPORTATION
Fooeral Avlotion Administration
14 CFR Part 71
Proposed Establishment of Clan C
Airspaco for long Beach.CA;Public
Meetings
AGENCY:Ft:dlJt'i,llhiillilln
Administmliull (FAA!.OUr.
ACTION:Nulil:l!llf ml~llin~s.
SUMUARY:This nulkl)imnuunc:t:s tWll
ral:l·lilltling infurnlill ain.p'u.:u lIluuting.'i
III sulit;it illfllrlllnlilln frmll ilirsl'lIclJ
lISI:rs llntllllllllrs.l:om:tJrning i1 propnsal
IlIltShlhlish Cluss C airspaOJ nl Long
Dl!m:h.CA.TIl\)PllfllllSl!(If IhllS!!
medings is III prllvidu inlurl:slt:d IJiHlil!S
an llJlJlnrlunily 10 preSl:n1 \·illWS.
mC:llmml!ntlaliclOs.and r..nmnwnls 11111111:
IInlpUSiII.All C;llmmllnls fllc:lli\'I!llllurinH
Ihm"l ml.'tllinHs will hll wnsilhm:d prinr
III an~..issuilnct;uf u nolkl!of pnlpuS(ld
rulcmlUkin~
DATES:The infllnnul .lirsflacil ml.'tllings
will be hilld lin Ocluber 25 and :W.20 II.
ML't!lings will run fmm 6p.m.unlil
!I p.m.Cllmmenls musl be rt:cei\'etl un
or bcfllrc lJecumlll:r 1l.ZOl1.
ADDRESSES:ThlJ OllltJling...will 1m held 011
Ihu Holillay Inn Long Dench Airporl.
;W4lJ N.LllkllwtJlIl!01\'11 ..LonJ.:Quach.
C/\\101115.5112-5Hi-14lJl.
ClImlll/m/s:Sllne!comml:nls on 11111
propUS'11.in triplic..<Ile.In:Jnhn W4Irnl!r.
Opcratiuns SUJll'tlfl Gruup.:\JV-W2.
WL'Sltlrn Sun:icu/\m<i.Air Tr-uffic
Oq;;lI1iZillillll.FL'(loml A\'ialiun
Atlminislmliun.1001 Lint!"\,cnuu.
SW..Runlun.\VA 9UOSi.
FOR FURTHER INFORMATION CONTACT:I'al
Anclersun (U:lII)5:li-51~7 or Rick
I'f..hlilr.(IISII)S:li-511:1tI.FAA Supporl
ManaJ.:I:rs.Sllllllll~m California
·mACON.!I1i5 I\1:url1\'Villal{lIild.San
Dingo.CA 921 Z(i:.
SUPPLEMENTARY IN~ORMATlON:
Meelin~PrOl:edurcs
lal DOllr:-.uplm :10 minutcs prior III Iht]
LICAinning Ilf cac:h meding.Thc
medinAs will Ill:infnrmal in nalurullntl
willlHI amduch:1I hv nnt:nr mure
rl:llmslJnlali\'lJs llf Ilil:FAA Wt:sltJm
SI:I"1..ice Area.A fCl'mscnlilli\'t:fnlm IllI:
FAA willllruslJnl a !lriding nn 11m
rrnpilsell cslilhlishmenl nfC-lass C
uirspucu ill LunA Deaeh.CA.El.II.:h
par1idpanl will hn gi\'t~an npl'orlunily
III ddi\'cr climmenis or makl!a
pwscnlillillll,ailimugh a limt:limililluy
btl impnsed.Only cumnltJnls l:uncmning
Ihe propnsalln t$lahlish LunA DI:adl
elm's C airsjlil(:n will 1m ilC:t:tJjllc!l!.
(li)'nWlTllJclinAs will hn OPI!1l In all
PlJrstlllS on a sPiH:t:'i\\'ailahlu IHisis.
Thnn:willuu ntllldlTlis.~itln fmlllr olher
chargn tll a\lund IInt.l parlidpaltl.
(el Any !ltlrSun wishing III maku a
prCSI!lltllliolltu 11111 FAA JlanHi will he
asked III siUn in .mtll:slimah!Ihe
ilmllunl uf timc I1IJIJdclC.1 fur such
)lwsunlalilln.This will permil Ihe pill10l
til allllt:altl ,In apJlOlJlrillltl anltlunl nf
lime fur Ililr:h pn.'Scnler.'l1u:st!mL'tlling...
will nnt he ntljllumud unlill!\'t:ryllntJ lin
Ihe lisl has had an npJlurlllllil~'til
at.ltln.'Ss Ihe pant!!.
(t1ll'usiliun I'''pcrs or ulher hamluul
rnilltlrhll flJllItin~lulhn suhslnnclI nf
Iht!Sll lnlJCllings will 1m aCCl!plml.
I'arlidpants wishing 10 submil hamioul
mnll!rinl should pn:stml nn ori~imll and
l\Vn l!l1pillS (:Il:uJlics Inlnl)lolhl:
pnlSiding ullicl!r.Ther'l shuuld he
addiliunal copies lIf meh handoul
a\'ililahItJ fllr 1IIIwr nllundells.
(Il)Thl.~l:1I11Jelinj.;S will nul hll
fnrmally nJcunltlC.1.Hnwc\'er.•1 ~uml\lal)'
uf CIlmmtmls lIlilcllJ nlllllJ Ollll:lin:.;s will
1M:Iilt:cl in lhll dockili.
Agenda for lhe Meetings
-Si~n·in.
-l'rosunlaliun uf nltJding prclcl,lum..~.
-FAA briuIing on Ihu pwpll:>ml
l:slahlishllll!nlllf tim l:li\sS l:AirslJaclJ
Amll.
-Sulicilation ofpuulic l:urnl1lcnls.
-Closinl;cummt:nls.
L"sutld in Wasbin~lon.nco on ....ngllsl lG.
2011.
Gary A.Norrk.
t\r:lin~Mflntlgcr..-Urs/lOCl!.J/t",!u/I/liuns und
/\rc l'fUCL'tlrm:s GnJllJl.
IFIt Uu.:.20II-"'!I·n~FiI...1 U--Z",!-Il;U:~:'unol
BlLUUO COD!UI0-13-I'
FEDERAL TRADE COMMISSION
16 CFR Parts 239,700,701.702 and
703
Request for Comment Concerning
Interpretations of the Magnuson-Moss
Warranty Act;Rule Governing
Disclosure of Written Consumer
Product Warranty Terms and
Condltlons;Aule GovernIng Pre--Sale
Availability of Written Warranty Terms;
Aule Governing Informal Dispute
Settlement Proceduros:end Guides for
the Advertising of Warranties and
Guarantees
AGENCY:FL'tlllnll Trudu Cummbsinll.
ACTiON:HCIIU\.'Sl fur public olmnwnl.
SUMMARY:I\S IJ[lrl uf its sysh:malit:
fC\'iow nf all FL'tlcfill Tradc Cornmis.....inn
1":\FTC"ur ..COmmis.....iun ..)rulu:>and
l;uidlJS.Ihn Fn.:St~l...Imhlie cmnmlJnl
nn a Sill urwaffimly-reialL'd
Inlt!llircialillns.Kules ilnd Guidcs:ils
lnltJrpn!llllinns IIflhl:Magnusnn·MIIs.....
Wamll11y Act ("Inlorllrulalillns"or
"Rule iOlI"):its Ihile Gm'urning
lJisdnSIlrt!of Writhm \,llnSumur Pwtlut:l
Warrant\'Tmms .lntl l:tllllillillns ("Ruin
iO!"):ils ]{ule Gm·t!rninj.;Pru·Sah:
A\,..i1auilih·uf Wrilton Wolrromt"Ttlrms
("I{ull!7lJ2·"):ils Rulu G'l\"emin~
Infurmal DisJlUIl:Selllllmcni l'nll:lltlunJS
("Hule iO:r');'1I1t1 ils GUilltJS fur Ihe
Atlvcrtising Ilf Wilmlntic:.ilntl
Guaranlel:!>("Guides").Thu
Cummission ruquc..'Sls public cumnwnl
lin Ihe lI\·crillll:usls.henufils.neClJSsih'
;mtl n'1:Ulilhlr~'anti L"ClInumic:impilcl of
IhtJSC Inlerpmlalinns.Rulus amI Guides.
DATES:Wrilhm cummtmts mu:.llw
n]t:eivc~d nn ur Ill~fllrc Oclnllllr 2·1.2Ul1.
ADDRESSES:lntl:n:slml partitls may filtl a
mlllment IInlinlJ or lin ]Iapur hy
folluwing Ihl:instructions in Ilw
Ik'f]UllSI for Cumllluni Illirtillllllf 11m
SUPPLEMENTARY INFORMATION suclinn
belli\\'.Wrilo"Ma::;nuslln·Mllss
Warrnnl~'1\t:IHule I{c\,it:w.10 CFR l'ilrJ
iOO.I'll.j.jOO.··1111 "uur cllmmunl,anti
filII )'lIur cllmmtlnl ;lI1lintl al li1'I's:l1
ftCfwlJJif:.t:/IlIluwnlll·lJrks.cuml/,,:1
ItTlmrnlyruJr.sanpnn hy flJllnwinl;Iht:
inslruc;liuns un Ilw Wcb-llilscl!furnl.If
yuu jlmfur III fill!yuur cllmnwnl 1111
flilpm.mllil or dl!li\'t~r Yllur tnmmc!I11 III
Ihll flllluwing ilddrcs....:FwllJfill Trillh:
CllIllmis....illll.OmCl!(If Ihu SIJcn:lilr\,.
Rllllm H-11:1 (AnmJx t:J,!iUti .
I'tJlllls\'lvnnia 1\\'lll1ue.NW ..
Washfnglun.DC 2lJ!illU.
FOR FURTHER INFORMATION CONTACT:
S\'dlnnn S.Gilns.AUurnt:\·.Ui\'isiun IIf
Milrkt:lin:.;I'l"ilclit:l~.Durellllllf
Cunsumur I'mltr.lilln,FI~dtJfill Trillll:
Cummis..~iun.H-2I1li.GUO I'cnnsyh''1niil
Williams AVIatIon consultants,Inc.
1
H-22
October 4,2011
John Warner,Operations Support Group,AJV-W2
Western Service Area,Air Traffic Organization
Federal Aviation Administration
1601 Lind Avenue,SW (fix spacing)
Renton,WA 98057
Subject:Proposed Long Beach Airport (LGB)Class C Airspace FR Doc 2011-
21424 Filed 8-22-11;8:45am
Dear Mr.Warner:
On behalf of the City of Rancho Palos Verdes,I am writing to express my
appreciation for the opportunity to comment on the 2011 LGB Class C Airspace
proposal.I'd like to express our thanks to the Federal Aviation Administration for
successfully addressing many of the concerns the City expressed during the
2010 airspace proposal comment period.Williams Aviation Consultants (WAC),
at the behest of the City of Rancho Palos Verdes,performed a Technical
Analysis of the 2011 LGB Class C Airspace proposal.The Cities of Palos
Verdes Estates,Redondo Beach,Rolling Hills,Rolling Hills Estates (support
pending)and Torrance have also expressed their support for the revised 2011
LGB Class C Airspace proposal,based upon the Technical Analysis performed
by Williams Aviation Consultants (attached).
WAC also performed a Technical Analysis,with the financial support of the afore-
mentioned cities,of the 2010 LGB Class C Airspace Proposal.Based upon the
Technical Analysis and pursuant to the direction of the City Council,the City
Attorney sent Technical Comments to the FAA in a letter dated September 30,
2010.A number of South Bay cities,some at the direction of their respective
City Councils,directly provided comment letters to the FAA regarding the 2010
LGB Class C Airspace Proposal.Concerned Peninsula and South Bay
residents,organizations and businesses also provided comments directly to the
FAA expressing concerns about the unintended consequences that would result
from the proposed airspace change.
Among the many issues raised in WAC's analysis of the 2010 proposal was a
finding that an undetermined level of aircraft activity,including planes using the
LAX mini-route,would opt to fly around the Class C airspace and divert over
populated portions of the Palos Verdes Peninsula and other areas of the South
Bay.The exact location and magnitude of this traffic was unknown but believed
to be potentially significant.Additionally,the 2010 proposal eliminated most of
the usable airspace north of the breakwater as well as the entire eastern portion
H-23
John Warner,Operations Support Group,AJV-W2
Western Service Area,Air Traffic Organization
October 4,2011
Page 2 of 3
of the practice area.Based on pilot comments and WAC's analysis,it was
determined that a significant number of aircraft would move training and practice
to other locations,especially the practice area along the Palos Verdes Peninsula
coastline.While the volume and precise location of this activity was unknown,the
potential impact was believed to be significant.
Modifications to the revised proposal,including adjustments to the altitude levels
and the reduction in scope of the Class C airspace,appear to have satisfactorily
addressed these and other concerns.However,the revised 2011 plan does
eliminate about 900 feet of airspace over the harbor (the top usable altitude is
reduced from 4,500 AMSL to 3,599 AMSL).WAC considers this loss of airspace
a minor issue.
While there is still a concern that some as yet unrecognized unintended
consequence of the new proposed Class C implementation will occur,we believe
the specific concerns identified during the 2010 process have been adequately
mitigated in the current 2011 LGB Class C Airspace proposal.
Again,on behalf of the City Council,I would like to:
~Congratulate and thank the FAA for the airspace revisions contained in
the 2011 LGB Class C Proposal;
~Point out the issue of the loss of 900 feet of airspace in the harbor as
shown in the green section in figure 5;
~Encourage the FAA to thoroughly analyze any potential issues and
impacts that arise or are identified at the October meetings and the
subsequent public comment period;and,
~Request that the FAA advise the City of any significant changes it
considers to the 2011 LGB Class C Proposal during the comment period
and before the rulemaking step.Any changes made in airspace
configuration as a result of the current public comment period should
trigger a new period for public comment.
Sincerely,
Tom Long
Mayor
Cc Rancho Palos Verdes City Council
Rancho Palos Verdes City Manager
City of Palos Verdes Estates
City of Redondo Beach
City of Rolling Hills
H-24
John Warner,Operations Support Group,AJV-W2
Western Service Area,Air Traffic Organization
October 4,2011
Page 3 of 3
City of Rolling Hills Estates (Support pending)
City of Torrance
Attached:Technical Analysis Report Prepared by Williams Aviation Consultants
H-25