Analysis
of the Feasibility Study
by Jim Pearson
The proposed Oldham County Airport has
released an emotional outcry from thousands of residents. Yet,
I believe we must objectively look at the facts being used
by the Oldham County Airport Board (as supplied by the Entran
Corp.) to convince the general public that an airport is in
all of our best interests.
Before I begin, it’s important to establish my credentials. I
am a pilot with over 6,000 hours of flying experience. I
have logged flight time as a private pilot, a commercial pilot,
instructor pilot, navigator, flight engineer, and air transport
pilot. I have worked in a civilian fixed base operation
as a Part 135 commercial pilot and an instructor pilot. I
was also an instructor pilot and flight examiner in the Air Force,
and spent 6 years in aircraft accident investigation and safety-related
positions. I was the Director of Safety at a Joint Air
Force/Navy Undergraduate Pilot Training Base for two years. I
currently fly for UPS. So, I have been intimately involved
in flying for over 37 years.
I also acknowledge that it is a bit ironic
for a pilot to be against the construction of an airport. But my aviation
experience also provides me with a good understanding of the
costs & benefits, and the risks & rewards of a community
airport. So, I would like to discuss this airport proposal
from three perspectives:
- An analysis of the conclusions presented
by the Oldham County Airport Board, based on the Proposed
Oldham County Airport Report (hereafter referred to as the
feasibility study). Simply
put, the facts presented don’t support the conclusions.
- A presentation of facts contained in
the feasibility study, but not discussed in the Airport Board
briefing. Many
of these facts don’t support the conclusions presented
by the airport board. Also, additional facts will be
presented, that also counter the report’s conclusions. These
facts come from well documented reports on general aviation
trends.
- Finally, there are a number of questions
that you should demand answers to, before you commit to building
this airport. I
realize that most of you are not pilots, so it’s difficult
for you to determine what information is relevant in the feasibility
study. That is why this analysis is so important for
you to read.
I. Analysis of the Airport
Feasibility Study
(Why we need an airport)
1. GA Airports generate economic
activity. There
is no doubt that general aviation can create economic activity. However,
the question that needs to be answered, with certainty,
is whether or not general aviation will produce enough economic
activity to pay all the bills associated with an airport.
The economic viability of an Oldham County
airport is directly tied to the forecast based aircraft and
fleet mix. To develop
this forecast, it would have been logical to study all Kentucky
airports similar to what is envisioned for Oldham County. Instead,
the feasibility study relied exclusively on the surveys sent
to aircraft owners and businesses, to establish the initial fleet
size and mix. The survey respondent was merely asked if
he/she would consider moving an aircraft to Oldham County. The
respondent has no obligation to abide by any responses made on
the survey. The study made no attempt to determine the
motivation for survey responses, and adjust the findings accordingly. For
example, a surveyed pilot who lives closer to Bowman Field may
respond that he/she would move an aircraft to Oldham County,
in the hope aircraft congestion at Bowman would be lessened. However,
he/she has no intent on moving. Finally, the survey data
obtained was not subject to independent verification. As
a result, this method of forecasting the initial number
and fleet mix of aircraft for Oldham County has serious flaws
from the start. Everything else in this study depends on
an accurate forecast of the initial fleet size and mix of aircraft.
It is possible to determine the number
and fleet mix of aircraft for Oldham County, using other methods. One method would
be to build a generic airport for the Commonwealth of Kentucky,
based on data derived from similar airports to the one we envision
for Oldham County. The following table (next page) shows
14 general aviation airports in Kentucky. With the exception
of Bardstown, each airport has at least a 5,000 foot runway. Using
known population & median household income data from county
census records, and aircraft currently based at these airports,
one can create a “generic” airport for Kentucky. Simply
add up the columns and divide by 14. Once you have created
a “generic” airport, you can further refine the information
to reflect Oldham County’s population and median household
income—two major determinants of a county’s ability
to support an airport.
Using this method, a generic airport would
have 47 aircraft, and be supported by a population base of
50,140, with a median household income of 37,406. Now, we could adjust this generic
airport to reflect the population and median household income
in Oldham County. We would find that an Oldham County could
potentially support between 52 (based on population alone) to
86 (based on median household income alone). It is my opinion
that these numbers should be averaged, to arrive at an aircraft
base of 69 aircraft. However, no adjustment was made for
the effects of market competition from Bowman Field or Clark
County Airport. Adjustment is necessary, but beyond the
scope of my analysis.
General Notes for Table 1:
1. Median household income is used because it takes into
account every household. Median family income takes into
account homes with more than 2 people.
2. Jefferson County has more than 700,000 people, and
Fayette County has more than 260,000 people, with airports designed
to serve major metropolitan areas (and more than one county). Each
city has a major scheduled airline service, which generates higher
than normal operations rates and passenger movement. Neither
airport is representative of what a general aviation airport
looks like in the state of Kentucky. As a result, Standiford
Field (with its reliever airport at Bowman Field) and Lexington
Bluegrass airport were not included in my analysis. Of
note: Bowman Field can be used to assess trends in general
aviation, but to use it as a basis for determining the number
of aircraft based in Oldham County would be an invalid comparision
(due to Jefferson County population base).
3. There are several airports included
in this study that are impacted by a major industry (Toyota),
colleges, or both. By
using
the data from 14 airports, the effects of such anomalies
are dampened.
4. The “generic” airport method for determining
the number and type of aircraft shows that there are other—more
accurate methods than a simple survey. The data used in
this table was drawn from readily available information from
general aviation websites.
5. The “break even point,” or number of aircraft
required to make an airport profitable should be determined in
the same manner, using revenue & expense data from similar
airports.
Costs Associated With Airport Operations
Oldham County’s cost to build a general aviation airport
is currently stated at somewhere between $400,000 and $500,000
(2.5% of $20 million). However, once an airport is built,
there are a number of ongoing expenses. Some include replacement
of airport lights, maintenance of instrument landing systems,
mowing, hangar repair, runway surface repairs, re-painting of
runway markings, security, fire protection, and many other unanticipated
expenses (damage caused by vandalism and nature). Finally,
someone will have to pay for the airport manager—who will
be pivotal in the success of airport operations. It is
the airport manager who will be the chief operating officer,
and responsible for executing the business plan. On this
point, the old axiom is true, “You will get what you pay
for.” The salary of a good airport manager could
be close to $67,000 (source: avjobs.com—low
end was $55,000).
Bottom Line: We—the taxpayer—can
expect to cover the annual costs not covered by general aviation
revenue. How much will that be? Unfortunately, the
airport board has already determined that infrastructure costs
associated with the airport are the responsibility of the Oldham
County taxpayer. Indeed, all 14 counties mentioned in the
study above have to cover the annual infrastructure costs of
their airports—whether or not the airport makes money. But
what about the daily operating costs? Shouldn’t the
airport users pay for these costs? Who pays for these costs
if the airport can’t generate enough revenue?
Many will insist that an Oldham County
airport can become self sufficient—that is, pay for all the annual operating costs. So,
let us examine the three general sources of revenue that are
used to pay for airport operating costs:
Fuel Sales. It is
generally assumed that pilots who relocate their aircraft to
Oldham County will also buy their aviation fuel at the Oldham
County airport. So,
profits from fuel sales will be one source of revenue. But
the cost of aviation gas is remarkably expensive, and pilots will find
the cheapest place to fill their tanks—and it doesn’t
have to be in Oldham County. Just as most of us look for
the cheapest gas prices before we fill up our tanks, pilots will
do the same. For example, the cost of aviation gas
at Bowman Field on November 28th, 2007, was $5.30. However,
the cost of aviation gas at Georgetown Scott County Airport was
only $4.24 (source: www.airnav.com/fuel). If
you were buying 100 gallons of aviation fuel, you could save
$106 by filling up in Georgetown—less than 45 miles away. So,
the actual profit from fuel sales at the Oldham County Airport
will be constantly subject to gas prices offered by other airports
in the local area.
Can we somehow measure how sensitive pilots
are to fuel prices? If
you look at page 2-10 of the feasibility study, you will find
that 80% of the aircraft owners cite fuel prices as a major factor
when deciding where to base their aircraft (add response ratings
4 & 5 which indicate the upper two levels of importance). But,
if the airport fuel price isn’t competitive, they will
fill up somewhere else.
One more factoid: In 2007, Clark County
Airport has seen a 50% drop in fuel sales after they raised fuel
prices, in an effort to cover mounting airport expenses. Currently,
they charge $4.89 per gallon. (source: 11/28/07 phone
conversation with Melody McNames, Clark County Airport Assistant
Airport Manager).
Hangar Rental. The
hangar rental market is also subject to local market forces. So, it’s
important to understand what is available at Bowman Field and
Clark County Airport, the closest general aviation facilities. The
feasibility study states on page 2-6 that, “Many potential
tenants are on a waiting list for T-hangar space at Bowman Field.
. .The airport has 223 T-hangars on the field with an approximate
two year waiting list…”. On November 28th,
2007 I talked directly with Karen South, property specialist
at Bowman Field. She is responsible for hangar rentals. According
to Ms. South, the quote made in the report is actually misleading. There
are currently 20 people awaiting hangar space at Bowman field. However,
14 of those people already have a hangar, but simply want to
rent a cheaper one. Right now, Bowman Field
has three different hangar types offered. An oversized
hangar rents for $342 - $515. However, the standard T-hangar
rents for only $255. The oldest T-hangars rent for $181. These
older hangars don’t have electricity or electric doors—yet
they are the hangars most often requested. The feasibility
study fails to mention the oldest T-hangars at all, or their
rental cost of $181 per month.
According to Melody McNames, Clark County Regional Airport currently
has open hangars.
One more factoid: Bowman
Field has looked into adding hangars; however, the estimated
cost of a 20 hangar upgrade was nearly $1 million. At that cost, the monthly
rental for new T-hangars would have been at least $350 per month. They
decided not to continue with the project because they would have
to destroy their least expensive hangars in the renovation process. So,
it is logical to expect that the rental cost of any hangar at
an Oldham County Airport would have to be roughly the same—around
$350 per month. This would mean that any pilot moving his/her
aircraft from Bowman Field to Oldham County would pay a $1200
- $1400 annual premium for hangar space in Oldham County over
what can currently be offered at Bowman Field.
Is there a way to measure how sensitive
pilots are to paying extra for a hangar? The airport feasibility study itself
contains information that indicates an aircraft owner will probably
NOT pay more money for hangar space if it’s available somewhere
else at a cheaper price. If you look at page2-10 of the
report, you will find that 86% of the aircraft owners cites hangar
fees as a major factor when deciding where to base their aircraft
(add response ratings 4 & 5 which indicate the upper two
levels of importance). So, aircraft owners are also very
price sensitive when it comes to hangar rentals.
Flight Training. It would be generally
expected to see a flight training center relocate to Oldham County. And,
this business would have to pay office rental fees, which would
offset the building cost and hopefully generate some extra revenue
to help pay for other airport costs. However, the
airport can and will also be used by flight training centers
that will choose not relocate to Oldham County. Instead,
they will simply use the airspace to conduct multiple takeoffs
and landings. After all, the Oldham County airport traffic pattern
will offer a less congested place to practice. Remember,
there are at least four general aviation airfields within 15
minutes flying time of Oldham County. So, it is just as
reasonable to assume that flight training centers would not relocate
to Oldham County, but simply use its airspace. From these
aircraft, you will receive no revenue.
2. Aid in Recruiting New
Businesses.
In determining whether or not Oldham County
needs an airport, the feasibility study stated that businesses
would use it. However,
this conclusion is not supported by the survey conducted by Entran. The
survey data revealed that only 5 businesses out of 415 businesses
queried (less than 1%) even owned or leased an aircraft, and
only one said that he would consider relocating his aircraft
to Oldham County—should an airport be built. (See page
2-11 of the feasibility study). All other data presented
in this section came from the same 5 surveys, not from the 109
responses returned! More importantly, this survey was only
administered to businesses in Oldham County! (source:
Dec. 10, 2007 email response from Aaron Braswell, Entran Engineer) So,
the survey does not support the finding that an airport would
aid in recruiting new businesses. In fact, survey data
seems to indicate that having an airport would make no meaningful
impact on a company’s decision to relocate. In fact,
survey data from 104 of the 109 responses from Oldham County
businesses indicated that they don’t own, lease, or charter
aircraft. So, businesses will most likely continue to look
for generous tax breaks provided by the county, as the primary
motivation for moving to Oldham County. Suggestion: If
you are spending money to conduct a business survey, it would
seem prudent to ask a simple question, “What is the major
item you look for when choosing a site for your business?” Give
them a list of things (tax breaks, schools, road network, cheap
land, clean environment, airport), then ask them to prioritize
the list.
Bottom Line: Any forecast business revenue
based on having an airport in Oldham County simply isn’t
supported by the survey conducted.
3. Expedited movement of
passengers and goods.
The Airport Board would like us to believe
a general aviation airport would expedite the movement of passengers
and goods. Yes,
this is true—for the 113 pilots, (their family and friends),
who might move their personal airplanes to Oldham County. This
airport will NOT bring regional commercial transportation to
serve the thousands of citizens of Oldham County. So, we
will continue to travel 45 minutes to Louisville or 1:15 minutes
Cincinnati for personal air travel. To be honest, that’s
pretty good service. And, the overwhelming majority of
our goods will continue to arrive by ground transportation. Indeed,
our county receives express service from FedEx, UPS, and DHL. So,
113 aircraft owners—and their passengers & friends—are
the primary beneficiaries of this proposed airport. Yes,
there might be an occasional air taxi operation. But there
is no way to forecast the need or extent of air taxi service,
based on the current survey.
4. Provide direct access
for emergency services.
A general aviation airport will no doubt
provide direct access for services, such as emergency air and
police. But, is
it really needed? To answer that question, we must
objectively assess what emergency services are available right
now.
Within the county, we have eight first
response fire departments located throughout the county. There
are 19 EMT paramedics and 34 EMT Basics who provide medical
assistance.
Baptist Hospital Northeast provides a broad spectrum of healthcare
services to residents of Oldham,
Henry, Trimble, Carroll and eastern Jefferson County. Baptist
Hospital Northeast's Emergency Department is open 24 hours a
day, seven days a week. The Emergency Department serves
as the area trauma center. Treatment is provided by board-certified
physicians and a highly skilled nursing staff.
For situations requiring a time-sensitive
response, Baptist Northeast hospital has the capability to
transport accident victims from their heliport, directly to
other hospitals in Louisville—including
University of Louisville—recognized throughout the U.S.
for its treatment of trauma patients. Emergency helicopter
services are provided by Stat Care, who operates helicopters
out of Louisville and Bedford. Their dispatch time is less
than 15 minutes from the time a call is received until they arrive
at Baptist Northeast. Stat Care can also respond directly
to accident sites throughout the county further reducing response
time. An airport in Oldham County would only improve on
current service if an emergency response helicopter would permanently
relocate to this airport. According to Stat Care, they
have no plans to position a helicopter in Oldham County, should
an airport be built.
There is also a vast array of state-of-the
art hospitals in Louisville—less than 35 minutes away
by ground ambulance. These
hospitals offer leading edge technology & world renowned
surgeons. In fact, Jewish Hospital is rated in the top
50 U.S. hospitals for its excellence in the fields of heart,
neurology, neurosurgery, and respiratory disorders. If
an organ transplant is necessary, the patient will most likely
go to Louisville. Any donor organs required would be flown
in directly to the closest airport—either Standiford or
Bowman Fields.
Finally, we need to address the need for
fixed-wing air ambulance service, the type that could possibly
use the Oldham County airport. This
service would provide long distance service, generally outside
the state of Kentucky, or beyond the range of helicopter service. But,
before fixed wing aircraft service is used, a patient has more
than likely been moved to Louisville, where more extensive treatment
options are available. Should a specialty hospital be needed
at this point, a fixed wing air ambulance would most likely be
used from the closest airport--again, Standiford or Bowman Fields.
5. Enhance Infrastructure.
While an airport would enhance the infrastructure,
would this be a meaningful enhancement? What is the condition of the
current infrastructure? Specifically, what is the condition
of our primary and secondary roads—something that serves
the overwhelming majority of Oldham County citizens. What
is the state of our water supply system, storm drainage, or sewage
treatment system? Could our EMS services be enhanced? I
realize that this $20 million can’t be used to take care
of these issues. However, an airport will have annual expenses
that will compete with other infrastructure requirements for
limited funding.
II. Facts Not Presented by the
Airport Feasibility Study
1. Market Reaction to an
Oldham County Airport. The
report did not make a strong case in proving that there is major
overcrowding at the local airports. So, an increase of
105 aircraft in Oldham County will come at the expense of other
regional fixed base operations. The report also didn’t
address the reaction of businesses at Bowman Field and Clark
County Regional Airports, when it forecast the based aircraft
and fleet mix baseline for Oldham County. Obviously, regional
fixed base operators will take steps to keep their customers
right where they are.
2. Driving Distance to Airport. The
airport feasibility study stated that nearly 74% of the aircraft
owners say that driving distance has a major impact on where
they hangar their aircraft. However, only 26 of the survey
respondents live in Oldham County (16%). So, the location
of the proposed airport is critical. Remember 101 pilots
(62%) of the survey respondents live in Jefferson County, where
Bowman Field is located. If they live closer to Bowman
Field than the selected airport site in Oldham County, then—according
to the survey-- they would probably elect to stay at Bowman Field.
3. Impact of Aviation on
the Oldham County Environment.
Environmental issues caused airport officials to cancel or indefinitely
postpone expansion projects at 12 of the 50 busiest U.S. airports
in the last 10 years [source: GAO 2000c]. The
dominant concern was noise, followed by water quality and then
local air quality. In the future, noise and local air quality
are expected to be the most significant concerns. So, the
impact to Oldham County’s environment is something we must
take seriously—before we build an airport. Specifically,
we must address the true impact of aircraft noise and lead emissions.
Effects of Aircraft Noise. The
air into which second-hand noise is emitted and on which it
travels is a shared public
good. It belongs to no one person or group, but to everyone. People,
businesses, and organizations, therefore, do not have unlimitedrights
to broadcast noise as they please. On the contrary,
they have an obligation to use the shared airspace in ways that
are compatible with or do not detract from other uses.
The effects of general aviation noise are
something that has not been adequately addressed in the current
study. Regardless
of the site eventually selected for an airport, there will be
families who must cope with the constant sound of aircraft noise. Nighttime
flights repeatedly wake neighbors. Repeatedly waking people
up at night in their own homes is one of the most uncivil things
people can do to each other. Moreover, sleep loss and its
resulting health effects cause billions of dollars in lost productivity,
thousands of car and workplace accidents, and strained family
and friend relations. So, how do we avoid/mitigate the
effects of noise?
In its feasibility study, ENTRAN has provided
noise contour overlays for 75d and 65d day-night noise levels
(DNL). The
reason 65d DNL was chosen is that it is the threshold for federal
funding of noise mitigation. So, the 65d DNL has to do
with who pays for noise abatement initiatives. It has nothing
to do with whether or not people are annoyed with the sound of
aircraft noise. While federal and industry investments
can be applied to reduce aircraft noise above 65d DNL, it is
left up to local authorities to address noise levels below 65d
DNL. So, before we build an airport, let’s make a
concerted effort to understand the true relationship between
noise and its impact on the citizens of Oldham County.
In 1983, the FAA requested NASA Langley
Research Center to review the literature on "state of the art" sleep interference
research. This study was part of a larger reevaluation
of nighttime noise events.
Concerning Arousal from Sleep: After
lengthy study, NASA concluded the following:
- The threshold level of a noise which
will cause arousal from sleep depends on sleep stage and
the age of the subject, among other things. Noise levels
which can cause sleep disturbance cover a range of 35 to
70 decibels.
- In a normal 8-hour sleep night, more
time is spent in lighter stages of sleep in the last half
than in the first half. This
implies that airport use restrictions limiting early morning
flight from 3 a.m. to 7 a.m. are particularly important.
- Little or no physiological adaptation
to sleep interference from noise occurs.
- Psychological annoyance from the
effects of sleep interference from aircraft noise is probably
more significant than the direct physiological consequences.
- The maximum acceptable single
intrusive level is 55 decibels.
[source: Aviation Noise Effects, Federal Aviation
Administration, Washington D.C., Mar 85. www.nonoise.org/library/ane/ane.htm]
There have been countless studies since
the NASA study that link the effects of sleep deprivation on
the productivity of workers. So, if aircraft noise levels create a disruption
of sleep patterns on an “ongoing” basis, then it
is logical to conclude that the productivity of Oldham County
residents exposed to this type of noise will be negatively impacted.
Factoid: The National Commission on Sleep
Disorders estimates that sleep deprivation costs $150 billion
a year in higher stress and reduced workplace productivity.
A second opinion was given by the Noise
Pollution Clearinghouse, upon examination of the FAA’s Noise Abatement Policy—2000. The
Noise Pollution Clearinghouse is a non-profit organization that
works with communities to reduce all levels of noise in the workplace
and residential areas. They concluded the following:
Night flights that wake family members impose a significant
impact on citizens. “The FAA has, in its Proposed
Noise Abatement Policy, ignored sleep disturbance as a significant
impact. Sleep disturbance is mentioned only four times
in the approximately 25,000 word document. It is, however,
the most extreme and disturbing noise impact. And it
is the fastest growing impact, paralleling the growth of night
time flights. Sleep loss results in decreased workplace
productivity and contributes to thousands of automobile accidents
each year, leads to irritability and strained relations with
family and friends, and lowers student performance in schools”.
(Source: The Noise Pollution Clearinghouse Comments
to the FAA Regarding Aviation Noise Abatement Policy 2000. www.nonoise.org)
Single event levels greater than
45 dBA indoors significantly impact education in schools,
religious services in churches, family life in homes, and
worker productivity in offices. The
following are typical recommended background noise levels for
various facilities.
- Private residences: 25-30 dB
- Courtrooms 25-30 dB
- Churches 25-30 dB
- Classrooms 25-30 dB
Intrusions greater than 45 dBA represent a significant impact.
(Source: The Noise Pollution Clearinghouse Comments
to the FAA Regarding Aviation Noise Abatement Policy 2000. www.nonoise.org)
So, what does all of this mean? It is my opinion that
any environmental impact study includes a noise contour analysis
for each proposed site that shows a 45d and 55d DNL contour. By
doing so, airport planners have the necessary tools to determine
how many Oldham County residents are impacted by the type of
noise levels that are relevant to a discussion about noise. Noise
at the 45d & 55d are sufficient to wake a sleeping person.
Decibel Noise Equivalents:
55d DNL—conversational speech at
a foot away
45d DNL— voice level used to wake
a sleeping person
35d DNL—quiet conversation
(Source: Earthlink.net)
Effects of Leaded Aviation Fuel. Aviation
fuel contains lead—one of the last few areas where the
EPA has failed to set a mandate for unleaded gas. In 2002,
general aviation emitted 125.5 annual tons, or about 88% of lead
from all mobile sources.
(Source: National Emissions Inventory for Lead,
U.S. EPA, 2002)
The EPA readily admits that “lead is a very toxic element,
causing a variety of effects at low dose levels.” Numerous
federal agencies, including the EPA, the Occupational Safety
and Health Administration, the Food and Drug Administration,
and the Department of Health and Urban Development, have implemented
regulations controlling lead content and use. While the
EPA has successfully mandated the phase-out of lead in gasoline
for automobiles, it has been oddly reluctant to address the aviation
fuel problem for the last 10 years. In fact, it has repeatedly
refused to establish any timeline for the transition from leaded
fuel to unleaded fuel. (Incidentally, it mandated a switch
for all NASCAR vehicles by 2008). This seems odd, since
there are hundreds of studies that directly link exposure to
lead with health problems. So, what is the risk caused
by the use of leaded fuel in general aviation aircraft?
Risk of Leaded Fuel. The use of leaded
aviation gasoline results in the emission of both organic and
inorganic lead-containing compounds. Organic alkyl lead
compounds such as tetraethyl lead (“TEL”) are emitted
into the air mostly from fueling operations. TEL decomposes
fairly quickly to inorganic forms of lead once dispersed into
the air, water, or soil. For example, the half-life of
TEL in summer atmospheres is approximately 2 hours and is on
the order of several days in winter atmospheres.
Inorganic forms of lead enter the environment
from the decomposition of organic alkyl lead compounds (explained
in the previous paragraph), and more significantly, as tailpipe
emissions from the gasoline combustion process. Inorganic forms of lead are highly
persistent in the environment. Any condensation process—rain,
mist, dew--removes lead particles from the atmosphere and deposits
them on soil and water surfaces. Lead emitted as emission
particles may remain airborne for up to ten days and may thus
be transported far from the original source.
So, the areas surrounding airports are
especially contaminated because of the high volume of air traffic. Lead-based aviation
fuel particulates can end up far from the original source, blown
into surrounding fields, forests, streams and waterways. When
they are deposited in farm soil, forage areas, and ponds, they
expose us, without our knowledge or control, to this poison.
So, here is an example of where we all
know there is a health risk associated with leaded fuel. The EPA cannot—or
will not—set a level of acceptable exposure to lead from
aviation fuel, or set a timeline for the elimination of leaded
fuel in general aviation aircraft. So, we must make the
decision, based on all the evidence available. We can’t
simply say, “Well the EPA didn’t set a limit, so
it must be O.K”.
4. Safety
versus Risk. On
the very first page of the airport feasibility study states, “Oldham
County officials also believe a new airport in the county would
improve safety in the area.” (page 1.1) This conclusion
was based on the fact that air traffic exported to Oldham County
would relieve the high volume of air traffic in the Greater Louisville
area. And, an Oldham County airport would serve as an emergency
airfield for aircraft maneuvering overhead. While that
is an admirable goal, the fact is that you are actually transferring
multiple levels of risk from Bowman Field to Oldham County.
Currently, general aviation activity in
airspace above Oldham County consists primarily of maneuvering—which includes
stalls, simulated forced landings, steep turns, and spins. In
2005, 11.3% of all pilot related accidents occurred while aircraft
were in maneuvering flight. (Source: 2006 Nall Report) But,
the risks associated with maneuvering flight remains the same,
whether or not an airport is built in Oldham County.
However, if you place an airport in Oldham
County, the overall level of risk increases because aircraft
are now conducting more than just maneuvering flight. Aircraft are taking off,
climbing, descending for approach, and landing. These are
defined by the FAA as critical phases of flight,
because inattention or preoccupation with things not related
to flying the aircraft can have catastrophic results. (Other
critical phases now include taxi out for takeoff and for Part
121 pilots, any flight below 10,000 feet MSL.) In
2004 and 2005, 65% of all general aviation accidents occurred
in the takeoff/climb, descent/approach, and landing phases of
flight—all critical phases of flight. Now, the more
takeoffs and landings you make, the greater is your exposure
to risk. If you recall, the feasibility study estimates
that there will be 51,380 takeoffs or landings the first year
alone—introducing significantly more risk exposure than
what Oldham County residents currently experience.
Risk exposure also increases, based on
who’s doing the
flying. The majority of aircraft based at an Oldham County
airport would be used for personal flying. While personal
flying makes up only half of all general aviation flying, they
have disproportionately higher number of accidents. For
2005, here’s the percentage of accidents attributed to
personal flying, based on the critical phases of flight:
- 73% of all takeoff/climb accidents
- 84% of all descent/approach accidents
- 84% of all go around accidents
- 64% of all landing accidents (Source: 2006 Nall
Report)
So, the risk of an aircraft accident in
Oldham County will go up. The more takeoffs and landings made at the Oldham County
airport, the more risk you incur. Concurrently, the risk
of an aircraft accident around Bowman Field will go down, because
there will be fewer aircraft operations in the critical phases
of flight. In that regard, the feasibility study is correct.
In summary: For each phase of flight
(takeoff, climb, descent, approach, landing), a person’s
overall risk is a based on the risk in that flight phase, coupled
with the number of times you expose yourself to that flight phase. So,
an airport in Oldham County actually increases the risk of an
aircraft accident in the county. Let me be clear: The
total number of general aviation accidents is relatively low,
only 1,436 mishaps occurred in 2005. This equates to an
accident rate of 7.2 mishaps for every 100,000 hours flown (source: 2006
Nall Report). However, it is 80 times
higher than the airlines. (source: NTSB, Air
Accident Digest, Feb 6, 2007) I don’t
make this comparison to show that general aviation is dangerous,
I make it to demonstrate that there are higher levels of risk
associated with general aviation operations. For most pilots,
the risk involved with general aviation flying is acceptable. However,
many folks perceive the risk as too high. For them, perception
is reality.
5. Unfavorable Trends in General Aviation. The
following trends in general aviation were not addressed by the
airport feasibility study. Some of these facts directly
contradict findings & conclusions in the report.
- Estimated General Aviation flight hours
are no longer increasing. From
2003 to 2006, flight hours have dropped by nearly 3.2 million
hours. That represents a 12% decline in general aviation
flying.
- 2001—25,431,000
- 2002—25,545,000
- 2003—25,998,000
- 2004—24,888,000
- 2005—23,168,000
- 2006—22,800,000
Source: NTSB Aviation
Accident Statistics www.ntsb.gov/aviation
- As of the end of 2006, there were 597,109
active certificated pilots. This number has been declining steadily since
1980, when there were 827,000 certificated pilots. This
represents a decline of 28%, or nearly 1% per year.
- Declines by type of certification:
- Student Pilot—93,064 to 84,866 (-8%). This
is a certificate for pilots training to become private pilots. It’s
much like a learner’s permit.
- Recreational Pilot—340 to 239 (-30%). Less
training required, but more restricted. Limited to
flight within 50 NM, carrying no more than one passenger,
and restricted to day/VFR flying only.
- Private Pilot—251,561 to 219,233 (-13%) This
certificate is critical, since it is an entry level prerequisite
for all advanced certificates (commercial, ATP, or
flight instructor). While 2007 data is not fully available,
private pilot certification continues to decline by 5% through
the first three quarters of 2007.
- Commercial—121,858 to 117,610 (-3%). Allows
pilot to fly for compensation, in a wide variety of general
aviation operations (banner tow, aerial application, sight
seeing).
Source: FAA Certificated
Pilots, AOPA Online, May, 2007
- From 2000 to 2003, there has been a
4% decline in the number of single engine aircraft flown. In
the same time period, there has been a 13% decline in the
number of multi-engine aircraft flown.
Source: U.S. Air Carrier Operations, CY 2000 – 2003, www.NTSB.gov. No
later data available from NTSB).
III. Questions That Must Be Sufficiently Answered.
As magistrates, you are charged with looking
out for the interests of all Oldham County residents. When determining whether
or not an airport is in the best interest of the county, you
cannot simply rely on the report of a single working group—one
whose sole interest is to prove the economic viability of an
airport. You have a duty to demand answers to tough questions. You
have a duty to seek out opposing views—and this may involve
spending money. However, I am giving you this analysis—free
of charge. I’m also providing you with a list of
tough questions that need answers:
1. How do we determine the true economic
impact of a general aviation airport? Is historical data based
on Kentucky airports more predictive than an economic forecast
from a different state?
2. Can we rely on simple survey data or forecast models
that use Louisville’s Standiford and Bowman Fields (two
of the three airports modeled by Entran) to determine the number
and type of aircraft based in Oldham County? Can’t
we create a “generic” Kentucky airport as a basis
for making a more informed decision?
3. Is it logical that forecast revenues from businesses
potentially moving into Oldham County are based on a study of
Oldham County businesses? Would you base the forecast revenue
potential of this proposed airport on only 5 positive responses
from a survey base of 415 respondents?
4. Would economic modeling be more
accurate if the airports used for analysis were sited in counties
more similar in size to Oldham County?
5. How do you determine whether or not the majority of
citizens in Oldham County support this airport initiative? What
will you do if you receive evidence that shows the majority do
not support it?
6. Before you conclude that an airport will aid in luring
businesses to Oldham County, wouldn’t it be logical to
survey businesses outside Oldham County to see what their priorities
are? Have them give you a prioritized list of what’s
important to them so that you know.
7. Shouldn’t you find out what the ongoing infrastructure
costs are for an airport? These are the costs that you’re
going to ask the residents of Oldham County to pay. Why
not ask the 14 counties that have airports similar to the size
you are planning?
8. What exactly will an FAA grant pay for? Runway,
navigation aids, hangars, FBO building, access to Oldham
County roads, grading, tree removal, etc. How will the
money be paid?
9. What is the effect of fractional ownership on corporate
aircraft purchases in the future? If a corporation can
purchase a share of an aircraft, yet get air support at any time,
why would it purchase an aircraft? Why would it spend money
on air crews, maintenance, and hangars?
10. What is the impact of teleconferencing on the need
for corporate travel? Can the “virtual meeting” reduce
the need for face-to-face business meetings?
11. Would it be prudent to have documentation
of who is providing funding for this airport, the amount of
money available each year of the project, and what the money
can be used for?
Final Thoughts. One common theme
that I have heard from many proponents of this airport—and
some of the magistrates--is this: “If we don’t
spend the federal & state grant money available for this
airport, someone else will”. If we don’t
need the funds, however, then we are not good stewards of the
taxpayer’s money if we take it. The lesson here is
one of needs versus wants. An airport for Oldham County
falls in the latter. You can attempt to dress it up any
way you want, but at the end of the day, an airport in Oldham
County will fulfill the “wants” of a very small minority,
while fulfilling the needs of no one. My analysis is only
intended to show you that the conclusions drawn from the feasibility
study are not solidly backed up by the data currently presented. To
build an airport, based on the feasibility study conclusions,
would be a serious mistake. The facts presented in this
paper provide the proof.
Disclaimer. I have
tried earnestly to provide you with factual, relevant data. I am only one
person, not a corporation who does this for a living. There
is no intent to deceive you or misrepresent the facts.
Other Sources:
- Report to the United States Congress,
AVIATION AND THE ENVIRONMENT,A National Vision Statement,
Framework for Goals and Recommended Actions. December
2004 Prepared by: Ian
Waitz, (Director of the Massachusetts Institute of Technology),Jessica
Townsend, Joel Cutcher-Gershenfeld, Edward Greitzer, and Jack
Kerrebrock
- PBT National Action Plan for Alkyl-Lead, U.S. EPA Persistent,
Bioaccumulative, and Toxic Pollutants (PBT) Program (June 2002)
[PBT Action Plan] at 13
- Petition to the U.S. Environmental Protection Agency, Seeking
Regulation of Lead Emission from General Aviation Aircraft,
Filed by Friends of the Earth, October 3, 2006
- Federal Aviation Administration, State & County
Inquiry, www.registry.faa.gov/aircraftinquiry/
- Airports in Kentucky, www.aircraft-charter-world.com/airports
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