RPVCCA_CC_SR_2011_12_20_H_Update_2011_FAA_Proposal_Class_C_AirspaceCITY OF
MEMORANDUM
RANCHO PALOS VERDES
TO:
FROM:
DATE:
SUBJECT:
REVIEWED:
Staff Coordinator:
HONORABLE MAYOR &CITY COUNCIL MEMBERS ~
DENNIS McLEAN,DIRECTOR OF FINANCE &INFORMATION
TECHNOLOGY
DECEMBER 20,2011
UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE
DESIGNATION SURROUNDING LONG BEACH AIRPORT
CAROLYN LEHR,CITY MANAGER ~~
Matt Waters,Senior Administrative Analyst fi;J
RECOMMENDATION
Receive and file update on the 2011 revised proposal by the Federal Aviation
Administration (FAA)to establish Class C Airspace surrounding Long Beach Airport (LGB).
EXECUTIVE SUMMARY
The FAA proposed a revision to LGB airspace in 2010 (the "2010 LGB Proposal").The
City hired Williams Aviation Consultants (WAC)to study the issue.WAC concluded that
the 2010 LGB Proposal,if passed,would have had serious unintended noise and safety
concerns for Rancho Palos Verdes and South Bay residents.The City submitted a
Technical Comments letters to the FAA on September 30,2010 outlining the City's
objections and concerns.
In 2011 staff became aware of a revised 2011 LGB airspace proposal (the "2011 LGB
Proposal").WAC analyzed the new proposal and concluded that there were significant
improvements and modifications to the 2010 LGB Proposal that addressed the City's
concerns and Technical Comments expressed in 2010.WAC opined that the City's pro-
active effort in 2010 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 LGB Proposal.The City Council authorized staff to sent a comment letter and
WAC's Technical Analysis of the 2011 LGB Proposal to the FAA on October 4,2011.
Staff subsequently attended two FAA public meetings on the 2011 LGB Proposal on
October 25 and 26,2011.The majority of speakers at the meetings were Long Beach
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UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING LONG
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residents and general aviation pilots who were opposed to any change of LGB's airspace.
FAA Support Manager Rick Pfhaler,recently informed staff that the FAA would do an
internal analysis of the 2011 LGB Proposal,taking into account all public comments.At
the end of that analysis,the FAA would then proceed with one of three options:1)move
forward with a notice of public rule making (NPRM);2)withdraw the proposal;or 3)perform
more analysis and seek out additional public input.WAC's studied opinion is that the
2011 LGB Proposai will move forward with only minor revisions.
There is no further action at this time.The FAA's analysis is expected to last a minimum of
six months.Staff will continue to monitor this issue closely and will update the Council on
any significant developments.
BACKGROUND
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 to study the
2010 LGB Proposal.WAC's Technical Analysis showed that an expanded "Class C"
airspace wouid 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 WAC
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;
2)Environmental impacts,especially increased aircraft noise and air pollution from
piston-powered and turboprop aircraft;
3)Increase of GA aircraft flights across the entire Peninsuia,as well as over
neighborhoods in Redondo Beach,Hermosa Beach,Torrance and San Pedro;and,
4)Increased workioad of FAA traffic controllers,possibly impairing passenger flight
safety.
Figure 1 below depicts the current LGB Class 0 airspace;Figure 2 depicts the 2010
Proposed LGB Class C Airspace.
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UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING LONG
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December 20,2011
Page 3 of 7
,
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Figure 1 Current 2010 LGB Class D airspace
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Figure 2 2010 LGB Class C Airspace Proposal
With the assistance of WAC,the City Attorney submitted Technical Comments 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.
Staff subsequently received word of upcoming FAA public meetings in October,2011
regarding a revised proposal to create a Class C airspace surrounding LGB.WAC
reviewed the 2011 LGB Proposal (shown below in Figure 3)and advised Staff that they
believed 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
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UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING LONG
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South Bay cities,concerned residents and businesses led to the FAA's decision to
significantly modify the 2010 LGB Proposal.
Figure 3 2011 Revised LGB Class C airspace
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City staff held a conference call with Redondo Beach,Rolling Hills,Palos Verdes Estates,
Torrance and a WAC representative on September 28,2011 to discuss the FAA's 2011
LGB Proposal.All cities agreed that the FAA had made substantive changes.City staff
and WAC agreed 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 ..
Staff contacted the staff of the City of Rolling Hills Estates and confirmed their continuing
support.
At its October 4,2011 meeting,the Rancho Palos Verdes City Council approved a letter to
the FAA,accompanying the Technical Analysis prepared by WAC.The letter:
a)Congratulated and thanked the FAA for the airspace revisions contained in the
2011 LGB Proposal;
b)Pointed out the issue of the loss of 900 feet of airspace in the harbor as shown in
the green section in figure 5;
c)Encouraged 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,
d)Requested that the FAA advise the City of any significant changes it considers to
the 2011 LGB Proposal during the comment period and before the rulemaking step.
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UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING LONG
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Any changes made in airspace configuration as a result of the current public
comment period should trigger a new period for public comment.
The City Councils of Redondo Beach and Palos Verdes Estates also approved similar
letters of support for the 2011 LGB Proposal.
DISCUSSION
Staff attended both FAA Public Meetings regarding the 2011 LGB Proposal on Tuesday,
October 25,2011 and Wednesday,October 26th.The meetings were well attended with
over 120 people on the 25 th and approximately 80 on the 26 th .
The FAA moderator,Rick Pfahler,emphasized that the current proposal was a work in
progress and could be changed based upon comments received.He stated that the
significant changes to the original 2010 version were made in large measure to the over
1,400 comments received from cities,residents,pilot groups and other interested parties.
The FAA's official Long Beach Class C Airspace website states the following about the
FAA's goal for the proposed Class C airspace designation:
The goal of the proposed redesign is to better protect aI/aircraft arriving at
and departing from LGB by reducing their exposure to untracked VFR (visual
flight rules)aircraft that fly outside the current Class 0 airspace boundaries.
With Class C airspace,air traffic control/ers would know exactly which
aircraft are in the airspace and where they are heading.
Mr.Pfahler noted in his presentation that of the eighty-nine airports in the continental
United States that served a minimum of one million passengers in 2008,Long Beach is the
only one that does not have surrounding Class B or C airspace.He further noted that the
Class C proposal neither changes any existing routes nor creates new air routes used by
jets,turboprops or private pilots.The proposal would not bar general aviation aircraft from
any airspace,but it would expand the area where VFR pilots are required to communicate
with controllers.
All public speakers were opposed to the 2011 LGB Proposal.Most speakers were either
general aviation pilots associated with LGB or Long Beach residents.A number of
common viewpoints were expressed,including a strong sentiment among the pilot
community to maintain LGB's current Class 0 status,significant suspicion of the FAA and
Long Beach Airport's motivations (especially commercial airline expansion)and a lack of
confidence in the safety data and safety claims by Jet Blue that originally prompted the
consideration of Class C airspace.Mr.Pfahler encouraged speakers to email or write the
FAA with specific concerns and suggestions and assured the audience that their concerns
would be taken into account.
Staff also attended a meeting of Torrance Airport pilots on October 5,2011 about the 2011
LGB Proposal.Pilots expressed similar sentiments to those heard at the Long Beach
meetings,including doubts about the merits of Jet Blue's complaints and whether the 2011
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UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING LONG
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LGB Proposal was justified.Two pilots opined that the proposal was a "good compromise",
but most speakers were in favor of LGB maintaining its Class D status.
No attendee at either FAA meeting spoke in favor of the original 2010 LGB Proposal.Staff
recently reviewed public comments posted on the FAA's Long Beach Airspace website and
did not find any comments favoring a return to the 2010 proposal.Since changes to the
proposed plan would be based on input received during the public comment period,WAC's
initial impression is that the FAA will not seek to revert to the 2010 LGB Proposal.WAC
has further opined that the Peninsula and South Bay cities would not be adversely
impacted by the FAA either adopting the 2011 LGB Proposal or maintaining the existing
Class D LGB Airspace designation.The public comment period continues through
December 12,2011.
Possible Next Steps by the FAA -Rulemaking,Withdrawal,or Further Analysis/Public
Input.
City staff spoke with Francie Hope,with the FAA's Operations Support Group,on
November 30,2011.Although she could not offer any insights regarding the 2011 LGB
Proposal,Ms.Hope did encourage interested parties to review existing comments and
offer additional comments at the FAA's LGB Class C website.Ms.Hope also encouraged
interested parties to subscribe to the Federal Register's FAA notification system to receive
updates and articles related to Long Beach Airport.
On December 5th,City staff spoke with the FAA's Rick Pfahler to clarify the FAA's process.
Mr.Pfahler said that after the public comment period ends,the FAA would perform an
internal,multi-level agency analysis of the 2011 LGB Proposal,taking all public comments
into account.This process,according to Mr.Pfahler,would likely last through at least mid-
2012.After that analysis,the FAA would opt to go in one of three directions;a)proceed to
Notice of Proposed Rulemaking (NPRM);b)decide notto move forward with the 2011 LGB
Proposal and maintain LGB's current Class D status;or c)decide that the plan requires
more study and public input.
WAC's opinion is that the FAA will make only minor changes,if any,to the existing 2011
LGB Proposal and will proceed with an NPRM.Based upon our conversations with Mr.
Pfahler and Ms.Hope,the FAA would publish an NPRM in the FAA section of the Federal
Register.Public comment would again be accepted at that stage.After a specified period
of time,typically between 30 to 60 days,the proposed rule,with any modifications,would
again be published in the Federal Register in what is known as the "Final Rule"step.
Barring any significant challenges or judicial review,the "Final Rule"then becomes official
after 30-60 days.The rule would go into practical effect for pilots and air traffic controllers
on its VFR Chart Publication date,which takes place twice a year in July or December.
Possible Redesign of Southern California Airspace -Potential Impact on 2011 LGB
Proposal
Staff asked Mr.Pfahler if he thought a potential comprehensive redesign of Southern
California Airspace was likely,and if it could potentially have an impact on the 2011 LGB
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UPDATE TO 2011 FAA PROPOSAL FOR CLASS C AIRSPACE DESIGNATION SURROUNDING LONG
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Proposal.Mr.Pfahler opined that such a "clean slate"approach to the complicated reality
of Los Angeles airspace has been discussed for years within the FAA and would be an
advantageous approach,but for budgetary and logistical reasons,he did not believe it is
likely.He went on to say that even in the unlikely event that funds became available,just
the advance planning for such a complicated project would take many years.WAC
concurs with Mr.Pfahler's belief that Los Angeles airspace issues such as the 2011 Long
Beach Proposal will continue to be dealt with by the FAA on a piece-meal,as-needed basis
for the foreseeable future.
Staff will continue to monitor this issue as it moves forward and will keep Council informed
of any significant developments.
FISCAL IMPACT
The FY 11-12 budget includes $15,000 in the Professional Technical Services account of
the City Administration program of the General fund for aviation consulting services.The
budget will be sufficient to absorb WAC's costs of such services,which totaled $6,282.50.
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.
ATTACHMENTS
City of Rancho Palos Verdes Letter to FAA,dated October 4,2011
Technical Analysis of the 2011 LGB Proposal prepared by Williams Aviation Consultants
H-7
CITYOF
THOMAS D.LONG,MAYOR
ANTHONYM MISETlCH,MAYOR PROTEM
BRIAN CAMPB8.l,CoUNCIlMAN
DoUGLAS W.STERN,CoUNCILMAN
STEFAN WOLDWlGZ,COUNCIlMAN
October 4,2011
John Warner,Operations Support Group,AJV-W2
Western Service Area,Air Traffic Organization
Federal Aviation Administration
1601 Lind Avenue,SW,
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 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 directiol)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,direqj:ly prOVided comment letters to {he 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
30940 HAWTHORNE BLVD./RANCHO PALOs VERDES,CA 90275-5391/(310)544-5205/FAX (310)544-5291/www.PAlDSIIERDEs.COM/RPV
'.',:PRII'ITED ON RECYCLED fl>.PER
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John Warner,Operations Support Group,AJV-W2
Western Service Area,Air Traffic Organization
October 4,2011 -
Page 2 of 3
,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 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;
>Enco\Jrage 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.
~
TlLOng
Mayor
H-9
John Warner,Operations Support Group,AJV-W2
Western Service Area,Air Traffic Organization
October 4,2011 -
Page 3 of3
Cc Rancho Palos Verdes City Council
Rancho Palos Verdes City Manager
City of Palos Verdes Estates
City of Redondo Beach
City of Rolling Hills
City of Rolling Hills Estates
City of Torrance
William C.Withycombe,Regional Administrator FAA Western-Pacific Region
Attached:Technical Analysis Report Prepared by Williams Aviation Consultants
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'r ~)i[fiamsJIviation Consuftants
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 Class 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 Control 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 available 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 potential impact on IFR
operations from both a safety and efficiency standpoint must be analyzed 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 International Airport]Mini Route and increased
potential for proximity 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
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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.
Z H-12
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 S 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 controller to controller 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 block 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 .
54
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,0 '000 80
-1 C /P
EL82.'9·C
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......LJ?!TO'
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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-13
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 Class 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-14
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.
19 100
80
"
Figure 4'
Impact of Area B
Area B,depicted in darker green in Figure 4,would compress traffic that was unable or unwilling to establish
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 published "Mini Route"over LAX (Figure
5).Aircraft exiting the Mini Route southbound would be required to contact ATC immediately upon leaving the
route and establish 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 substantial.
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.
,Source:FAA Power Point Presentation,June 22 and 23,2010.
Williams Aviation consultants,Inc.
5 H-15
MINI ROUTE
VFR ONLY
Santa
Monica
Bay
ATC
CLEARANCE
REQUIRED HAWTHORNE &
405 FREEWAY
(VPLSR)
eTC LAX TWR
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REOUlilEMEtoiTS OF FA~91.215 Ana 91 ,131 SHAL!..9E MET
MINI ROUTE tJORTHBOUNO:Ourlng normal 'DWlH oparatin<a hours:,0600.2000 LCL.Hawlt'lorno
TOw(j;i21.1 will cooralnate tran:sltiofls through the Mini ROule.After normal tower oparatlng
hour~.conleet LAX TOWIH 1151,8.Prot;r.'od to HOlwtl1ornc &.<105 Fu~eway {VPI.SRj ~1 2500 ',E.nl~r the
Lo::Angeles Class B e;s~abliIHlod on and follow thoU S~n'D Monica 128 radial LHim itxUlno me Cl.1SS a.
MINt ROUTE SOUTHBPUND:Ou;iny normal tOWi!r oplJrottng hours,0700·2;00 LeL.5arltB MonIca.
Tower 120.1 VIlli coordinate-lr;m,itiol'l!J,Ullough tho Mini Route.After normol towcr'op~rnUng hours,
contacl LAX Tow;;Jr 119.6.Pr.oeccel to LOyDla Maryml)unt Un ,",Drs"y (1.MU)3t 2500'.Enter Ule los
Ang~le!l Class B 951ablllih.-d on..,net lollow the 5J,"ta Monic.a I,2El r::.dlal until gaUlna tne-Closs B.
NOl!!;Remllin cliir of E1ri!vo airspace uolil clODrgnce.is rccol"ed.FllU:U::I-wlng,non-turbojol
l.\ircrift only.LAX mll~00 In il \"It!!>t tulfiu or O'Jil'r-g;ian (Qvnl'rillly mldniih\~o O~J.O I.el.'
c0l1fi9ur~UOll OJ;nc repon~ng a €:elllnll of (II luo~t :300{l'nnd V'I:::/bllltv of at leas1 thU:"ll mile::>.
Hawlhornf)and S:ilnto MonIca AJrp04'15 muS1 b13 VFR.
REMAIN CLEAR QF THE CLASS II UNTIL RECEIVING SPECIFIC ATe APPROVAL 10 I:PfTm
Figure 5
Williams Aviation consultants,Inc.
G H-16
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.
"•
c
....
19
I
Figure i'
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-17
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 180 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 general aviation aircraft currently flying over coastal Southern California using the
Mini-Route and visual flight rules ("VFR")will divert around the Class 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 Hills,Rolling Hills Estates,
Lomita,San Pedro and Rancho Palos Verdes.
Williams Aviation consultants,Inc.
8 H-18
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.
100
80 l~IG BEACH HI~RBaR AREA
sa:NrC FOR or::-All.S
Figure 85
EM MY &F2'1A
OIL PLATFORMS
~~-------
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.
g
H-19
The highlighted portions of Figure 9 depict the areas of significant airspace change between the 2010 and 2011
Class C proposals.
19
Eliminated
••4 i ....
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 of the 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-20
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 currently avaiiable 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 aiiows 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.
Figure 10
The raising of the floor within the red area shown in Figure 9 also dramaticaiiy 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.
Wiiiiams Aviation consultants,Inc.
11 H-21
The proposed increase in base altitude in the red area of Figure 9 aliows the southbound piiot significantly more
time to establish 2-way radio communications with ATe.if the pilot elects to avoid the Ciass C airspace,the
required diversion is significantly reduced from that necessary with the 2010 airspace design.
The lowering of the floor of the proposed Ciass C airspace depicted in orange in Figure 9 has minimai 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 shoreline/LGB Practice Area elected
to alter their route of flight to assure remaining clear of the Class C airspace,the amount of movement wouid
not have any adverse impact on any South Bay City.
Figure 11
Conclusion
Our analysis of the 2011 LGB Class C proposal revealed:
The proposal has incorporated changes which address virtualiy ali 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.
Wiliiams Aviation consultants,Inc.
12 H-22
Attachment 1
Federal Register I Vnl.7li.No.1 li:11 TUI:sclay.August 2:1.:lOll I Proposmi Ruli~s
(;.mn'III~·.hils illloph~11 ilnd rn:lllin~
Cfllllpliillll:U willllh,~Tr.IlISlllIrl C,-ulillla ,\1).
IS~llllll ill Fort Worth.TI~XilS.lUi hlll'!:1.
2011.
Kim Smith.
MlIlIlIl-.'Cr,1/00IJrr:m[llJin.'I.:/l1mlf!,tlin:mft
CerlifimtiOlI,'it:n';I;l!,
11-1~nlll:.21l11-11471 FilUlI11-1'!-1I:n,.;;.mill
DllUNG CODE "ilD-l3-P
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 71
Proposed Establishment of Class C
Airspace tor Long Beach,CA;Public
Meetings
AGENCY:FllCltllill A\'jalicm
Allminisimliun (FAA!.DOT.
ACTION:Nlllkn ur ml~tllings.
SUMMARY:This nuli':t:ilnllllunr.t!S IWtI
fm:l-finlling infllrmal airsJlilCI!rntmlil1J.:s
III sillidl infnrmllliun frllm airsplIct!
llSl!rs lind nlhnrs.clInt:t:rning a prujlflSlIl
In I:slahlish Clas...C ai~pacc al LlIng
Ot:ach.(:A.Tlw purpo:m or IhtiSt:
ml:l:lings is 111 pnl\'idtl inlnrnsltid parth:s
an opporlunily 10 pmslml vinw....
n:(:Clmml~ntlalilins.anti cllnuncnl ...un Ihll
prnpn....al.All eumnuml...rt.'cei\'lltl during
Ihese mt:dinJ.:s will 1m cunsidemcl prior
III any i...suam:tlilf il nt)lict:flf pnlpllSlltl
rulcma!:.inJ.:.
DATES:Thll infllmml ai~pael~ffiwJling."
will he ht!ld lin (klllhcr 25 lIml 2fi,2Ull.
Mr.e1inJ.:s will run from 6 1',01.until
!J p,m.Cllmml:nls mu"'llm rt.'CI~i\'lnllln
llr !mfllri!Dt:n~m"tlr 1Z,ZOll.
ADDRESSES:TIlt!mcdings willlJll htlld al
Ihl:Hnlitlay Inn LlIn~Dcach Airpurl.
2li40 N,Lllkt~wl"ld 01\'11..long Dtlach,
C/\!)()U15,5IiZ-5!li-l4111.
ClImnwlJts:Slmtl l:umnwnls nn Iht!
prnpnsill.in Iriplic41It:,In:luhn Wilrnnr.
Ol'llrillil1ns Sup purl Cruup,AIV-W2,
Weslt:rn :-illrvicl~!\rn41,Air Tmffic
Orgi\nh~illilln,FIllh~ral AvinlillO
Allministration,Hln1 Lind !\n:OlIll,
SW.,({tmlllo,WA !ll105i.
FOR FURTHER INFORMATION CONTACT:Pal
Antll:rsllll (1I:1lI)5:1i-5U4i or Rick
Pfahlnr,11l5H}5:Ji-511:1O.FA,\Suppnrl
Managnr,.;,Snutht:m Cillifurnia
TR,\CON,!JH5 Kt~arnr Villa I(Oilll.San
Dit}~(I,CA !12126:
SUPPLEMENTARY INFORMATION:
Meeting Prot:edure."
(a)Dum'"npt~n 311 minultls prim Itlthl:
be:.;innin~llftlachmedin:.;_Thl:
nu.'t:linHs will be infurmal in ",1Ium lind
wililm cundllclecll1\'tlnll fir mllm
n~JlmSl!lllillh'll'"IIf Ilil:F AA Wt~lI:rn
St~r\'icll "TIm.1\n:pTl:scnlali\'l~frum Ihtl
FAA willl'TI:senl :l hrielinH un Ilu:
JlTllllIISed eslilhlishmenlllfClas...(:
airsput:n ,II Llln~Dtlill:h,CA.En(:h
Jlilrlidl'unl will he gh'lln nn IIpptlrlunity
III ddi"l:r Ulmnlt~nl...Clr makt~il
prusllnlll1iUI1.allbuugh i1lil1wlimil milY
Ilt~imjlllSml,Only Cllmml~nl...t:lIOCt:rninJ;
Ihl!proJlllsaltu ilslahlish Lun:.;DmH:b
Cia......C airspace will btl lIcceplt:d.
(hi Tho meelil1H'"willllt~"fll~n 10 nil
Ilt:rsllOS un il SlliICIHI\'nilahh:Imsis.
Then:will 1m nlllldmis."iun flm ur uthllr
I:haq;tl In allend and parlidflall~.
h:ll\ny pt:rsun wishing In ma!:'t:n
prcsenlillinn Itllhe I:""flnnel will he
a...kl~dICl sign in llncll!slimuhl Ihl:
amlumtllf lin1\!nt:t:lll:tl fur such
pmsl:nlalion.Thi...will pt~rmilllll:pant:!
hi allm::alt:an i1J1J1nJpriilln amounl llf
lillltl fflr llo1C:h pmsl:nlt:r.'I'hl:sc mUdin:.;s
will nul 1m adjuurned unlil U\'cl')'unt:nn
Ihl:Iisl Ims hiltl an Ill'lIur1unily III
illltires...Ihe Jlilm:1.
ltlll'usitilln pal'llrs ur 1I11wr ImOllllul
malt:rial ndnting IlIlht:Sll!JstUIll:l:of
Ihl:SB mt:ulings willlltlllt:CllpllHl.
Participants wishinJ.:In sulJmil hanclnUI
mutnrial should ]lms{lnl an miginal ami
lwo cupit~s (:1 copies llllallin ll1t:
pmsiding IIfficnr.Tlwrn should 1Jt:
iIlltlilillOUI Cllpil:S llfnm:h hanlillul
n\'i1ililhll~for ollu:r utlttndt:cs.
lt~1 Tht~st:mt~t:linJ;."will nlll hi:
fllrnmll~'n!l:lIfflt.'Cl.Huwt:\'ilr.;1 summar\,
uf commenls mndo '1ItI1l:nWlllinw;wilf
lmlilt:t1 in Ihe tlocke!.
l\gend"for (he Meetin~s
-Si~n·in.
-I'wscntatillO nf met!ling pnlcl.'tlun:s.
-FAt\briefin:.;nn 11m flwpllsed
1:slnlJlishmllnl clf Ihu (:Ias."C I\irspace
,\n:it,
-Stllidlaliltn llf puIJIit:t:t1ll1nu:nls.
-(.:Illsing communIs.
1~~lIml in WilshinV.lllll.1X.:.lilt :\u\!.u$1 IIi.
:!1lI1.
"ur)'A,NU(I!k.
:klint!,"e/nll/wr.Jlir5pm:I!.IIf.'i!"/u'itJlIsllnd
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IFil n.....21111-21~N Fil",llJ-22-11;1l;~;'1l1111
DILLING COOE .-91G-13-P
FEDERAL TRADE COMMiSSiON
16 CFR Parts 239,700,701,102 and
703
Request for Comment Concerning
Interpretations of the Magnuson-Moss
Warranty Act;Rule Governing
Disclosure of Written Consumer
Product Warranty Terms and
Conditions;Rule Governing Pre-Sole
Availability of Written Warranty Terms;
Rule Governing Informal Dispute
Settlement Procedures;and Guides for
the Advertising of Warranties and
Guarantees
AGENCY:Ft:dunll Tr.IlIt!Climmissilln.
ACTION:KtlfIUl:...1 fur Jluhlic cllmmcnl.
SUMMARY:A...pari nf i1:-:sysh:malit:
n:dl:\\'nf all FI!tlcral Trill]l:Commissiun
("AFTC"Ilr "l:lmlmis...illO'·)rull:'"nnd
gUillt:s,lilt:FT(;"'I!t~ks fluhlit:t:llmnwnl
un"Stlilifwilrmnl\,·rt:lall:l!
Inlt:rpn:latillns.J(u'ltJS :Inll Guilll:"":it ...
Inlurjlrctalifms llf Ihl:Milgnuslln-Mfl~"
WilrrilOly t\etl"lnlerl'rHlalillns"ur
"J(ule 7(10"':its Rull~l:n\'llrning
DisdllSUrll 01"Wrilten Consurnur I'rmillcl
Warranty Turms and Conditiuns ("lhJlu
ifIl"l:ils 1':1I1t:GunrninH Prt:-S<1111
t\vuilalJililv IIfWrillnn Warr.ml\'"\,rolS
{"Rule 70i"I:ils Rult:GII\'I~rning
Infllrmal Ui ...putl:St:llll~01enll'rtlcllllun~s
("Rull:iO:\"):,lOll ils Cuidt::i for Ihl~
AtI\'tJrlisinJ;flf WarmnlillS <lnd
CUarilnltll:S ('·CUillus").Thll
CnmmissitlO n:flucsis Jluhlit:Cllmmllnl
nn the ll\'I:mll cfI ...ls,benefits,ncellssil\'
nnd rcgulalllr~'<lntl':CllOmnic impacl c',f
IheSt:Inltlrpruhllillns.RultJS antI Cuilll:s,
DATES:Wrilh:n comment...mu...IIM:
n:ctli\'l!ll un or ht!flln:Octnher 24.2m 1.
ADDRESSES:Inltm:slml par1il:s may 1i1t!'1
l:llInmonl unlint:or nn papt!r IW
fullo\\'in:.;Ihl':inslruclions in Ihe
Kt:Clul~sl I'llr Commenl IUlrtiun llf Ihn
SUPPLEMENTARY INFORMATION St:c:ILfln
1>t~IIIW.Writl!"MUJ;nuslln-Mllss
Warranly t\d I':ull~IhlVit:\\',1li CFR I'ml
iOU,1'1 "j-!·lllli,··llO )'llUr cfllnml~lll,anti
lilt!yuur cOUlnumt llnlint~atllftJls:l/
flt:/wIJlif:.t:fJlJIIlWnlu'ul'ks,f.'lltlll/tt:!
IlllmJIII.Vnllr..~tltlJlrlJl hy flllluwing IIll:
inslruclinns lin Iht:Wt:h-hilscll furm.If
Yllu pn:fl:r III lilt:your CllInl111:nloll
l'ilpl~r,mllil or dt:li\'er your cllmmnnl III
Ihll flllillwing 1I11t1wss:Fl!tlt:nll Trallt~
Cnmmis.o.;illn,omcl:nf Ihe St:cmlllry.
ROllm H-1 t:IIAnnux C),IiOO
Pennsylvania A\'t:nm:,NW.,
Wilshingllln.DC :W5HO.
FOR FURTHER INFORMATION CONTACT:
S\'I~llanil S.Cans.AlInrntl\·,Di\'isilln IIf
Mark.t:lin:,;I'r.It:lil.':s,Durc·au IIf
Con...umm I'nlhlClinl1.Ft:dr:ral "filtll~
Cnmmis."iun,H-211li.GOO I'ennsyl\'ania
Williams AViation conSUltants,Inc.
1
H-23