Never mind carbon, lets talk decibel offsets

At the April 1st Airport Commission meeting, there were two main subjects up for discussion.  The first (Item 2-A) was a presentation by City staff on the proposal to increase landing fees at SMO and to apply them to all aircraft, including those based at SMO.  The second subject (Item 2-B) was a presentation of the results of the final Phase 3 in the much maligned City visioning process.  Here are some links to the backup documents presented:

Santa Monica Airport Visioning  Phase III Workshop Presentation
SMO Non-Aviation Land Enhancement Planning Project
Financial Projections–Proposed Landing Fee Calculation

I have little to offer on the Item 2-B presentation, other than to say that the complete lack of substance to the presentation was par for the course with the entire visioning process (see here and here).  Nothing concrete that substantively mitigates negative airport impacts on surrounding neighborhoods will be put before Council on the 30th as a result of the visioning process; a slap in the face for the 80% of people participating in it and two other community surveys that asked for real change (half directly asked for closure).  Even the trivial placebo changes suggested by pilots (which much to the annoyance of the community, were the only things that made it through Phase 1 and 2 of the visioning), were ultimately dismissed as unworkable or unjustified.  The City Council must direct staff at the April 30th meeting to stop playing ‘placebo-visioning’ and get serious about fixing the problems at SMO, the community will be watching in anticipation.

Turning to Item 2-A, as CASMAT detailed in an earlier post, because the current landing fees are too low, combined with the outrageous fact that fully two thirds of all takeoffs at SMO pay no landing fees whatsoever, city losses are in excess of $0.5 million each year, and is a major contributor to the fiscal woes at SMO.  CASMAT applauds City Staff for addressing this problem and, after all these years of losses, for proposing a fiscally responsible solution.  This landing fee change was first put forward in the Airport Commission recommendations (along with many other equally practical suggestions – thus far ignored).  A CASMAT petition in support of those recommendations garnered nearly 1,700 signatures.  We hope the Council will go ahead and authorize the landing fee changes. The fees don’t do much to help the community, but at least they will staunch the financial bleeding somewhat.  Ultimately, every taxpayer in Santa Monica has been paying for SMO losses for nearly 25 years now.  Enough is enough.

Not surprisingly, during Item 2-A public discussion, we were treated to a string of pilots and aviation business owners at the podium claiming the proposed fee increase was unjustified and unreasonable.  Some claimed it would put them out of business.  To put these claims into perspective, we should note that for a Cessna 172 (the most common type of aircraft used at SMO), the fee amount is approximately $12.  A Cessna 172 costs over a quarter million dollars to buy.  It is hard to see how anyone that can afford a quarter of a million dollars for an aircraft can claim poverty when asked to pay $12 in landing fees.  Lets face it, we Santa Monica residents must pay almost as much to park our cars at the beach; more in some places.  So it is hard to be sympathetic with an argument that says the City should loose money hand-over-fist in order to subsidize aviation businesses so they can avoid the equivalent of parking fees.  If you can’t run a business at a profit, it is not the job of Santa Monica taxpayers to bail you out.  Santa Monica residents certainly don’t get to park for free just because we live here, and we are fed up of paying for a free ride for aviation businesses that mainly serve those outside the City.

By the way, the other anti-fee-increase argument made at the podium was that “aviation businesses pay rents, and so shouldn’t pay landing fees”.  Firstly this argument clearly doesn’t hold for parking in this City, and secondly as we have shown elsewhere, the ridiculously sub-market-rate rents payed by aviation businesses are themselves responsible for additional revenue loss by the City.  Those subsidized aviation rents are costing Santa Monica taxpayers around $5 million/year that could be much better spent elsewhere.  Don’t use the rents argument as a justification, it just makes things worse.

It was telling that as soon as Item 2-A finished, the aviation advocates and pilots that filled the Council Chambers for Item 2-A, almost to a man, got up and left, thereby making abundantly clear their disinterest in ‘visioning’ a future for SMO that involved any kind of change whatsoever.  How do you compromise when when one side walks out of the debate?  Jay Elder, owner of the American Flyers flight school, perhaps unwittingly summed up the cognitive disconnect taking place when he twice told the commission that “adding mufflers to aircraft has nothing to do with reducing losses” and so should not be considered.  The very concept that the City might chose to do something to mitigate negative SMO impacts on the community, whether or not it reduces costs, apparently did not occur to him, even after all this time.

And that of course brings me to the thing I actually wanted to discuss is this post, which is staff’s comments during 2-A discussions regarding CASMAT’s proposal (in May 2012) to provide some form of financial incentives tied to landing fees in order to encourage the installation of mitigation technologies such as mufflers, quieter propellors, or the use of non-leaded fuel.  This proposal was made in response to the abandoned staff plan to pay flight schools to fly elsewhere.  Without such incentives, as illustrated by the Item 2-B walkout, the aviation community will clearly do nothing by themselves.

Staff stated that they had talked with the FAA about the idea and had been told that because mufflers cannot be installed on all aircraft, this idea could be seen as ‘discriminating’ against other kinds of aircraft (e.g., jets) and so was not tenable.  First of all, lets be clear, the new City landing fee schedules apply exactly the same to everyone now, thereby eliminating the discrimination that actually existed before.  End of story, the fees are increasing for all and apply to everyone, and there is nothing the FAA can say about it.  Now as a separate matter, the City, as the proprietor has the perfect right to operate some kind of incentive program to encourage desirable behavior or mitigate impacts within its borders.  One example of such a program was staff’s own idea to pay the flight schools to fly elsewhere.  Apparently that was an ok thing to do.  But wasn’t that just discriminating against everyone except the flight schools?  You can’t make the discrimination argument when it suits you and not when it doesn’t.  So in summary, CASMAT does not believe the FAA has any rights whatsoever over a voluntary City incentive program and we should simply go ahead with the incentives.  Practically speaking, at the current rate of progress this may be the only thing that will make any appreciable difference to the community prior to 2015 and we must move forward with it.

However, lets take the ‘discrimination’ argument at face value and see if we can’t come up with an incentive program that avoids any FAA (or aviation advocate) perception of discrimination.  Never one to give up easily, CASMAT has just such a scheme to propose.

What we propose is for the City of Santa Monica to enact a ‘decibel offset program’, much like the carbon offsets that are becoming commonplace in this country and worldwide.  In a carbon offset program, anyone that can demonstrate appreciable reductions in carbon emissions can sell those reductions to others who are are over their emission quota and would otherwise be subject to penalties.  In this way, carbon offsets create a viable economy wherein all involved are financially motivated to participate and to reduce emissions.  The great thing about such programs is that those that are unwilling to reduce emissions are nonetheless incentivized to pay those that are, thereby reducing their own costs even more due to the offsets they acquire.  In the end, even the worst polluters start to look at their own behavior in such a system.

The Santa Monica decibel offset program would operate much the same way.  It might even be applied outside of an airport context for other forms of ‘green encouragement’, but we’ll focus on just the airport here.  The way it works is that the city offers a percentage reduction in landing fees for any aircraft operator that can demonstrate a reduction in the total number of decibels recorded by the City’s noise monitors (i.e., the SENEL recorded for each aircraft).

To illustrate, lets say aircraft N1234 (a Cessna 172) takes off a total 300 times during the year (as we can tell from the Vector System tail number data).  We know from the earlier muffler test results that this will confer a reduction in noise pollution of around 6dBA per takeoff if the plane were fitted with the Gomolzig muffler.  That means that over the year, installing the muffler on this plane has reduced community noise impact by 1,800 dBA.  For the sake of argument lets say that for any plane that demonstrates an annual reduction of over 1,000 dBA for the same plane and number of takeoffs as the prior year, the City awards one ‘Decibel Offset’ token, good for a 25% reduction in landing fees for ONE plane (and two years if applied to the same plane, one if a purchased ‘offset’ – see below).  This ‘token’ is awarded regardless of how the noise reduction was achieved – muffler, prop, or otherwise.

Now for a flight school aircraft, 300 takeoffs a year is nothing, and a 25% reduction in that plane’s fees would be 300 x $4 = $1,200.  Since mufflers must be replaced regularly (standard exhaust is approximately $1,500 and a muffler is say $4,500), this means the flight school would recover their investment in the muffler for that plane in just two years, likely far quicker, since most flight school planes take off many times per day.  Maybe this is enough motivation, maybe it is not.

But lets think about a business jet that takes off from SMO 300 times a year (also common).  Fees for a business jet may be anything from $100 to $300 per takeoff (depending on size) which means that over the year the fees would be at least $30,000.  25% off that would be $7,500 – way more than the cost of installing a muffler on a Cessna 172.  But of course, you can’t install a muffler on a business jet.

This is where the ‘decibel offset’ idea comes in because it is now worth it for the jet operator to pay to install a muffler on a flight school plane in exchange for getting the resulting decibel offset.  The jet operator saves money, and the flight school operator gets a quieter more valuable plane and doesn’t have to pay to install a muffler.  He also gets the second year’s 25% reduction for free (given enough takeoffs that year) since a purchased offset can only be applied by the purchaser for the first year.  Maybe the jet operator might even kick in a cash incentive to purchase the offset.

Most importantly of all, the City doesn’t need to put in any money!  All it has to do is keep track of how many decibels can be attributed to each plane out of SMO and publish those results in it’s ‘decibel offset table’ for all to see.  Market economics will take care of the rest, as those with big landing fee bills will pay to acquire offsets first from the flight schools, and then from other active planes.   Maybe when those wells dry up, jet operators might seriously look at quieter planes, or other noise mitigation strategies of their own.  In short order, the noise problem caused by pattern flying at SMO could be effectively solved, the City of Santa Monica could set a precedent for aviation mitigation in this country, and best of all, it would require no investment by the City, and is completely non-discriminatory and thus immune to FAA criticism.

Staff stated at the meeting that they would consider other ways of incentivizing mitigation technology, however, without tying the incentives to real financial benefits (e.g., saved landing fees) that outweigh the costs, it is hard to see why the people that walked out of agenda item 2-B would be motivated by such an incentive.  Incentive schemes like paying half the cost of installation and other simple equivalents would likely fail to make any real difference for exactly this reason.

Therefore CASMAT is asking that staff give serious consideration to a decibel offset incentive program as a means to bring about real change in the short term (i.e., before 2015) while skirting any potential for argument by the FAA.  Clearly there are many details that need to be resolved in such a program, but the basic idea has already been demonstrated sound by the emergent global carbon offset economy.  Remember also that with a bit of creativity, offset style programs could be applied to other negative SMO impacts such as leaded fuel use and pollution in general.

Just an idea.  Please think about it for the community’s sake.