HomeMy WebLinkAboutSS2 - Banner-Towing AircraftsCITY OF NEWPORT BEACH August 28, 2001
CITY ATTORNEY'S OFFICE Agenda Item SS 2
TO MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: ROBIN L. CLAUSON, ASSISTANT CITY ATTORNEY
DAVID KIFF, ASSISTANT CITY MANAGER
DAVID NIEDERHAUS, GENERAL SERVICES DIRECTOR
RE BANNER - TOWING AIRCRAFT
DATE : AUGUST 28, 2001 STUDY SESSION
BACKGROUND:
The City Council has asked staff how the City might respond to complaints from residents
regarding banner towing airplanes that advertise along the Orange County coastline
during the summer. Newport Beach residents as well as residents of our coastal city
neighbors, have complained about the loud drone of airplane noise throughout the day —
especially on the weekends —and have asked why the City does not regulate or prohibit
their operation:
FAA Preemption. The short answer is that all cities are preempted by the U.S.
Government from regulating aircraft flying within each city's airspace. Title 49 Section
40103 of the U.S. Code declares that the U.S. Government has exclusive sovereignty
over the airspace of the United States. The Federal Aviation Administration (FAA) is
granted the power to develop plans and policies for the use of airspace and to prescribe
traffic regulations on the flight of aircraft (including regulations on safe altitude) for:
(a) navigating, protecting and identifying aircraft;
(b) protecting individuals and property;
(y using the navigable airspace efficiently; and
(d) preventing collisions.
The FAA's right to exclusively regulate the airspace has been consistently upheld by the
courts. American Airlines Inc. vs. City of Audobon Park. Kentuckv (1969) 407 F.2d 1306;
City of Burbank vs. Lockheed Air Terminal (1978) 411 U.S. 624.
But No Flying Below 1,000 Feet. The relevant FAA regulation that currently addresses
the operations of airplanes is Federal Aviation Regulation (FAR) 91.119. FAR 91.119
prohibits aircraft from flying below an altitude of 1,000 feet above the highest obstacle
Mayor and Members of the City Council
August 28, 2001
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within a horizontal radius of 2,000 feet of the aircraft in a congested area. However, if the
plane flies over open water, outside the 2,000 feet radius, its altitude is limited to only 500
feet above any vessel on the ocean below.
As a point of reference, topographical maps show that the altitude of Signal Peak, the
highest point along the San Joaquin Transportation Corridor, is 1,180 feet above sea
level. Pacific Coast Highway along Crystal Cove State Park averages 250 feet above sea
level. Ocean Blvd. above Corona del Mar State Beach is approximately 150 feet in
height. Therefore, if a citizen is standing at Lookout Point viewing the ocean and a plane
flies by within 2,000 feet horizontally from Lookout Point, that pilot would be required to be
flying the plane at a minimum altitude of 1,150 feet above sea level.
Additional Regulations around Newport Beach /JWA. Newport Beach has additional
regulations within its airspace because of the flight patterns from John Wayne Airport.
The City's General Services Director, Dave Niederhaus, is an avid pilot and is very
familiar with FAA regulations. He has provided the attached aeronautical chart that
shows that most of the City's coastline is within a "Class C" controlled airspace. Class C
airspace is controlled from ground level to 4,400 feet by Southern California Approach
Control (SCAC). To enter the Class C control zone over Newport Beach an aircraft
operator must have two -way radio communications with SCAC and receive clearance into
the area. Aircraft must be equipped with a transponder and an altitude encoder. A
transponder is an avionics device that transmits a four digit code assigned to the pilot by
the radar controller and the altitude encoder is a device that transmits the aircraft's
altitude. Within the Class C Zone, banner - towing aircraft must be at least 1,000 feet but
no more than 1,500 feet in altitude. A pilot's altitude in the Class C airspace is therefore
easily determined by the SCAC since the radar operator can see the plane's position,
speed, direction of flight and altitude within the control zone at all times.
Five Local Towing Companies. In addition to altitude restrictions, FAR 91.311 prohibits
pilots from towing basic banners except in accordance with a "Certificate of Waiver'
issued to the operator by the FAA Administrator. A list of the five businesses that tow
advertising banners from planes flying out of the Long Beach Airport is attached.
Representatives from two of the companies, Aviad Corporation and Aerial Promotions,
Inc., met with Dave Niederhaus on August 9, 2001, and expressed their desire to
cooperate to address citizens concerns on safety, noise and congestion.
What Cities and Residents Can Do. Even though local government cannot regulate or
prohibit aircraft from towing banners along the coast, cities can work with the operators
and the FAA to obtain the operators voluntary agreement to address concerns and to
request additional conditions upon the "Certificate of Waiver." We can also educate
citizens on existing regulations and provide FAA phone numbers to report pilots flying at
less than 1,000 feet and other unsafe practices, or violations.
While it may be difficult for a person on the ground to distinguish between a 950 feet flight
path and a 1,000 -foot path, elevations of local geographical points may be helpful as a
a
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August 28, 2001
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point of comparison. A person standing at Lookout Point can compare his or her view at
approximately 150 feet of altitude to that of a plane flying by and determine if the plane is
level with, above or below this altitude. Given that Signal Peak is at 1,180 feet, a plane
flying along our beaches next to 150 feet tall bluffs should be almost as high as Signal
Peak. Attached is a copy of an information bulletin produced by the FAA that provides
directions on the information citizens need to provide to the FAA to assist in enforcing the
regulations for banner operations.
The FAA regulates operations under a Certificate of Waiver by the inspection of all tow
banner aircraft and pilot's flight histories. Because many pilots that fly for the advertising
companies do so to obtain additional hours of flying time to qualify for employment in the
airline industry, a clear record of compliance with the FAA regulations is important to their
record for future employment opportunities and to the operator to renew the Certificate of
Waiver.
The City has invited representatives from the Cities of San Clemente, Dana Point,
Laguna Beach, Huntington Beach, and Seal Beach to this afternoon's Study Session.
Also invited are the two industry representatives from the banner towing companies that
met with Dave Niederhaus earlier this month. They will be available to answer questions
or provide additional information.
RECOMMENDATION:
We recommend that the City Council direct staff to:
1. Work with Newport Beach residents and with other cities to educate residents as to
how to appropriately determine, photograph, and report potential violations of the
FAA's regulations; and
2. Work with towing company operators and the FAA to try to reach a voluntary
agreement for noise abatement procedures such as having the planes make turns
out over the water.
RLC:da
Attachments: Aeronautical Chart
List of Five Banner Towing Businesses
Information bulletin produced by the FAA
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Aerial Promotions. Inc.
/ Bob Dobry, Owner
2870 E. Wardlow Road
Long Beach, CA 90807 (562) 492 -1018
Aerial Sign Company
Mr. David Collette,
Director of Flight Operations
7501 Pembroke Road
Hollywood, FL 33023 (954) 989 -2056
Aviad Corporation
Wayne Mansfield, President
250 Clark Street
North Andover, MA 01845 (978) 420.6250
Paradise Aerial Advertising
Wayne Fulton, Manager
903 Airport Drive #2
San Luis Obispo, CA 93401 (805) 785 -0144
Sky Ads
Robert Scott. Manager
21213 -8 Hawthorne Boulevard
Torrance, CA 90509 (310) 638-8000
Low Flying Aircraft Complaints
......Low Flying Aircraft Complaint
The Federal Aviation Administration (FAA) is the government
agency responsible for aviation safety. We welcome
information from citizens that will enable us to take corrective
measures including legal enforcement action against
individuals violating Federal Aviation Regulations (FAR). It is
FAA policy to investigate citizen complaints of low -flying
aircraft operated in violation of the FAR, and that might
endanger persons or property.
To 91om Should You Complain?
Within FAA, the Office of Flight Standards monitors aircraft operations.
Locally, Flight Standards inspectors work in a Flight Standards District
Office (FSDO). See below for the office nearest you.
If no FSDO is listed, call any FAA facility: they can give you this
information.
"The facts, Ma am, the factsl"
Before contacting the FSDO /GADO, remember that the FAA is a safety
organization with legal enforcement responsibilities. So we will need
facts before we conduct an investigation. To save time, please have this
information ready when you call. And do keep your notes: we may
request a written statement. Here is the type of information we need:
• Identification - Can you identify the aircraft? Was it military or
civil? Was it a high -or low -wing aircraft? Did you record the
registration number which appears on the fuselage? (On U.S.
registered aircraft, that number will be preceded with a capital
"N.")
• Time and place - Exactly when did the incident(s) occur? Where
did this happen? What direction was the aircraft flying? What was
the color?
• Altitude - How high (low) was the aircraft flying? On what do you
base your estimate? Was the aircraft level with or below the
elevation of a prominent object such as a tower or building? Did
you obtain photographs? Are there any witnesses who could
confirm your estimate - do you have their names, addresses,
telephone numbers?
• Supporting Evidence:
• Witnesses, Police,
• Photographs
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httD:// www.faa.eov /fsdo/hln/lowflv.htm 08/17/2001 /c
Low Flying Aircraft Complaints
Do you know of any other witnesses? The more the better. Do you
have their names, addresses? They may be contacted.
Are local police aware of the problem? While they have limited authority
in aviation matters, police officers are considered "trained observers" by
the courts and their written statements or reports make excellent
evidence should our enforcement action go to trial.
If you took photographs, we need to know the lens used, and the height
of any identifiable landmarks that appear.
What FAA Will Do
Once we have the appropriate facts, an FAA aviation safety inspector
from the local FSDO /GADO will attempt to identify the offending aircraft
operator. We can do this in several ways. For example, we can check
aircraft flight records with our air traffic control information and/or
sightings from other observers, such as local law enforcement officers.
We may need to trace and contact the registered aircraft owner, since
the owner and operator may be two different people.
Do you want feedback?
FAA welcomes assistance in identifying and prosecuting all violations
of the Federal Aviation Regulations. Citizens complaining about low -
flying aircraft will, upon request, be advised of the final results of the FAA
investigation: be sure to give the FSDO /GADO your name, address and
telephone numbers where you can be reached at home and at work.
If further information is required, please write: Community and
Consumer Liaison Division, APA -200, Federal Aviation Administration,
Washington, D.C. 20591. During regular duty hours (7:30 a.m. - 4:00
p.m., Eastern Time, Monday through Friday), telephone (202) 267 -3481.
• This is the FAR
• If you're interested, shown below is Title 14, Code of Federal
Regulations, Section 91.119 of the General Operating and Flight
Rules which specifically prohibits low -flying aircraft.
91.119 Minimum safe altitudes; general
• Except when necessary for takeoff or landing, no person may
operate an aircraft below the following altitudes;
• (a) Anywhere. An altitude allowing, if a power unit fails, an
emergency landing without undue hazard to persons or property
on the surface.
• (b) Over congested areas. Over any congested area of a city,
town, or settlement, or over any open air assembly of persons, an
altitude of 1,000 feet above the highest obstacle within a
horizontal radius of 2.000 feet of the aircraft.
• (c) Over other than congested areas.
• An altitude of 500 feet above the surface except over open water
or sparsely populated areas. In that case, the aircraft may not be
operated closer than 500 feet to any person, vessel, vehicle, or
structure.
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Low Flying Aircraft Complaints
• (d) Helicopters. Helicopters may be operated at less than the
minimums prescribed In paragraph (b) or (c) of this section if the
operation is conducted without hazard to persons or property on
the surface. In addition, each person operating a helicopter shall
comply with routes or altitudes specifically prescribed for
helicopters by the Administrator.
Helicopter operations may be conducted below the minimum altitudes
set for fixed -wing aircraft. The reason? The helicopter's unique operating
characteristics, the most important of which is its ability to execute
pinpoint emergency landings during power failure. Further, the
helicopter's increased use by law enforcement and emergency medical
service agencies requires added flexibility in the application of many FAA
provisions.
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