Flight School Relocation – The Missing Impact Study

Once again the plan to pay the flight schools to perform pattern flying elsewhere is on the City Council Agenda (Item 8-C on the July 10 agenda).  As before the Council vote will occur before the Airport Commission or the public have a chance to evaluate or comment on this plan and make recommendations (next Airport Commission meeting is scheduled for July 23).

In stark contrast to the kinds of mitigation (and/or elimination) actions that recent studies by CASMAT, OPA, and the City Visioning process have shown are favored by more than 80% of the community, City staff has put forward a plan to pay the flight schools $150 per trip to pattern fly at other airports.  This plan was originally conceived by the flight school operators themselves.
Rather than allow the plan to be reviewed by the Airport Commission and to receive public comment, staff has three times now placed the plan on the City Council agenda so as to avoid this review process.  No impact study or model has been done to evaluate the wisdom of meddling with SMO flight patterns and economics in this way.  By avoiding an impact study, staff is emulating the ill-fated 250 heading test performed by the FAA in a similarly imperious manner.  The community is still suffering from the unintended consequences on SMO flight patterns resulting from the 250 heading test.  By pushing ahead with the staff plan, the City is in grave danger of repeating and further aggravating this mistake.
While CASMAT does not have the resources to perform a full impact study in the time remaining, we have rapidly (in 3 days) put together this ‘missing’ impact report to try to ensure that City Council is made aware of the very deep issues that are being glossed over here, and of the potential negative impacts the proposed plan will likely have.
In brief we find the following potential negative impacts:
  • Stimulating flight schools to increase pattern flying activity to get the incentive money which they need to make up for what appears to be a declining flight school student enrollment. Much of historical flight school lesson plans and pattern flying behavior does not qualify for the plan.  Flight schools would thus be incentivized to perform additional pattern flying.
  • Stimulating additional students to take flying lessons at SMO rather than elsewhere in order to take advantage of the financial incentives.  When the plan is cancelled, all such students would revert to pattern flying at SMO itself for the rest of their training program.
  • Triggering pattern-flying counter-attacks from other cities with possible downsides including creating more traffic at SMO.  UPDATE: July 9 – It appears that this has already begun!  See here and here.  Also see this call to all pilots to deliberately buzz SMO.
  • Unintended changes in the flight patterns over SMO caused by this plan might actually increase traffic in some areas.
  • Staff assumptions on pattern flying and financial baselines appear to be incorrect.
  • Any measured ‘reduction’ in pattern flying loops will be hard to distinguish from increased activity actually stimulated by the program.  It is unclear how success or failure can be measured.
The bottom line is that it is ill advised to meddle with a complex adaptive system such as SMO flight traffic and flight school economics without a complete model and study of the potential consequences.  Staff appears to be determined to skip such review and press ahead immediately.
We strongly recommend that City Council exercise caution in such complex issues.

UPDATE: July 10 – The City Manager has indicated he will recommend to City Council this evening that the plan be tabled indefinitely.

Link: Full Report (PDF – 88 pages)