SUBJECT: NEW CASE LAW ON BANNING SIGHT-SEEING FLIGHTS!

To: Parties Interested in Airport Noise

From: Gerald A. Silver, Pres. Homeowners of Encino
      Stop the Noise! Coalition
      National Helicopter Noise Coalition
        email: gsilver@sprintmail.com

New case law has just come down that reaffirms an airport's right to ban
nuisance sight-seeing flights. The case, SeaAir v. New York City, is
described below. Residents of Juneau, Alaska are seeking to place a similar
ban on sight-seeing flights in effect. This is a very significant case that
has changed the sight-seeing landscape considerably.

Below is a letter from Stop the Noise! Coalition to Los Angeles Councilwoman
Cindy Miscikowsky asking that Los Angeles World Airports initiate an
immediate ban on all tourist, flight-seeing and sight-seeing operations from
Van Nuys Airport (VNY).

The material below should be read carefully by anyone experiencing noise
from sight-seeing flights.

Thank you,
Gerald A. Silver,
Pres. Homeowners of Encino

*****************************************************************

STOP THE NOISE! COALITION
PO BOX 260205, ENCINO, CA 91426
email:  gsilver@sprintmail.com
[List of 28 participating associations at bottom of letterhead]

July 16, 2001

Councilwoman Cindy Miscikowski
Los Angeles City Hall, Room 415
200 N. Spring St.
Los Angeles, CA 90012

RE: REPETITIVE SIGHT-SEEING FLIGHTS OVER ENCINO, SHERMAN OAKS

On November 13, 2000, I wrote to John Agoglia, BOAC President, bringing to
his attention troubling nuisance sight-seeing flights emanating from Van
Nuys Airport (VNY). Upon investigation, we determined that these were
repetitive sight-seeing flights conducted regularly during evening hours
from VNY. These flights involved noisy Cessna and other aircraft that fly
south out of VNY, then east down the Ventura Freeway and then to a number of
sight-seeing destinations, returning to VNY.

These flights often occur within a few minutes of each other, and thus
create a major annoyance to residents. In addition, several helicopter tour
companies offer sight-seeing flights from VNY. Collectively, these
helicopter and Cessna tourist and sight-seeing operations cause a
significant amount of unnecessary noise.

On November 28, 2000, I received a response from Mr. Agoglia in which he
stated that VNY has concluded that these tour flights "are deemed acceptable
operations." He went on to say that, "Tour flight operators are allowed to
fly for compensation and there are no Federal Aviation Regulations (FARs)
that can prohibit them from departing at a designated flight time . LAWA is
not in a position to deny access to any aircraft flying into and out of VNY
as long as they comply with all applicable rules and regulations governing
their operation."

In our view, sight-seeing flights out of VNY are not consistent with the
location of an airport in the heart of a residential community. We believe
that they should be terminated as soon as possible.

We believe in light of a new case decided less then a month ago by the
Second Circuit Court of Appeals of the Federal appellate courts, that VNY
can in fact regulate or flat out ban tourist and sight-seeing operations.

 In our opinion the case is the most significant yet that bears upon the
scope of the LAWA's legal authority to regulate sight-seeing from VNY to
reduce noise. The case is SeaAir NY, Inc. v. City of New York, decided May
22, 2001. A copy of the decision is attached to this letter. It affirms a
lower court decision (SeaAir, Inc. v. City of New York, 2000 WL 1201 379(2000)).

The importance of this case is that it deals specifically with sight-seeing.
In this case, the City of New York had a regulatory code which required that
a seaplane base on city-owned property be issued a permit. In July 1999 the
City issued a permit for the seaplane base that included the following
restriction:

To further minimize noise impacts on the general public, commercial air tour
operations shall not be permitted at any time. The term "commercial air
tour" means any flight conducted for compensation or hire in a powered
aircraft where a purpose of the flight is sightseeing.

In response, the operator filed an action claiming that this restriction
violated various clauses of the U.S. Constitution. However, as stated by
the Court," the primary point of SeaAir's complaint was that the City was
preempted by federal aviation statutes from restricting the operation of
seaplanes at the 23rd Street base. SeaAir also claimed that the City's
regulation was arbitrary and unreasonable since it was not based on factual
evidence of noise levels."

The Court of Appeals for the Second Circuit held that sight-seeing
activities where the passengers are not transported from one place to
another, but rather where the destination is the same is the place of origin
does not involve interstate air transportation as that term is defined in
the federal statutes. Since the court concluded that such flights do not
involve interstate air transportation, SeaAir could not establish ". . .
that the City's regulation of sightseeing flights is preempted."

In rendering its decision, the court made it clear that the "City's
decisions to reduce the number of flights at the seaplane base and to
prioritize transportation over tourism were a reasonable means of achieving
noise reduction . therefore, that the City's actions comported with their
proprietary rights."

With respect to SeaAir's other arguments, the court held:

There is nothing in this record to convince us that the City's restriction
of sightseeing flights was unreasonable or arbitrary. The City made the
determination that in order to reduce the noise impact on the community, it
needed to cut the number of flights from the seaplane base, . . . SeaAir
acknowledges that noise reduction is a legitimate governmental objective but
claims that the City has no evidence that eliminating air tours will achieve
it. It is reasonable, however, to assume that a reduction in flights will
result in a corresponding reduction of noise. . . Accordingly, the City's
restriction did not violate SeaAir's due process rights.

Now that the Second Circuit has upheld the District Court's decision, it is
persuasive evidence that LAWA can no longer dismiss restrictions on
sight-seeing flights. Rather, and particularly since it is a pure
sight-seeing case, we believe it is the most important case in the area.
Other cases where a municipality has run afoul of the doctrine of federal
pre-emption have involved instances where the air traffic involved was
indisputably interstate commerce.

We believe that this case has reset the legal stage with regard to a
municipality's authority to regulate and control sight-seeing. The case
holds that a municipality is free to regulate sight-seeing activities
without colliding with federal jurisdiction. We believe this case stands for
the proposition that using the same definition employed by the City of
New York, LAWA can legally regulate and control sight-seeing activities in
sundry and reasonable ways in order to reduce the noise at VNY. This would
include regulating and controlling the hours of flights, the numbers of
flights, or even banning them outright.

On behalf of our member associations I ask that you request that LAWA
initiate an immediate ban on all tourist, flight-seeing and sight-seeing
operations from VNY.

Cordially yours,

Gerald A. Silver,
President, Homeowners of Encino
Stop the Noise! Coalition

Cc: LAWA Executive Director, Community organizations

*********************************************************************

SeaAir NY, Inc. v. City of New York

UNITED STATES COURT OF APPEALS

FOR THE SECOND CIRCUIT

______________________________

August Term, 2000

(Argued: March 2, 2001 Decided: May 22, 2001 )

Docket No. 00-9096

______________________________

SeaAir NY, Inc.,

Plaintiff-Appellant,

v.

City of New York, City of New York

Fire Department, City of New York

Department of Business Services and

Robert Grotell, Individually and as

the Director of the Mayor's Department

of Transportation,

Defendants-Appellees.

Before WALKER, Chief Judge, OAKES, and POOLER, Circuit

Judges.

Operator of a seaplane sightseeing operation sued the City

of New York on a variety of constitutional grounds for

prohibiting seaplane sightseeing flights from the East 23rd

Street seaplane base. The United States District Court for the

Southern District of New York, John S. Martin, Judge, granted

summary judgment to the City.

Affirmed.

Donald E. Creadore, Tunick,

Kupferman & Creadore, New York, NY

for Plaintiff-Appellant.

Ellen S. Ravitch, Office of

Corporation Counsel, City of New

York, New York, NY (Michael D.

Hess, Corporation Counsel, Stephen

J. McGrath and Deborah Rand, of

counsel), for Defendants-Appellees.

_____________________________

OAKES, Senior Circuit Judge:

SeaAir NY, Inc. ("SeaAir") sued the City of New York and

various other municipal defendants (collectively, the "City"),

charging that the City violated SeaAir's constitutional rights by

restricting the operation of seaplane sightseeing tours. The

United States District Court for the Southern District of New

York, John S. Martin, Judge, granted summary judgment to the

City, finding that the restriction did not violate the Supremacy

Clause, and that SeaAir did not have a valid due process or equal

protection claim. We agree with the district court that SeaAir

cannot demonstrate any constitutional violations and we

accordingly affirm the district court's decision.

BACKGROUND

The facts in this case were undisputed and are readily

summarized here. The East 23rd Street Seaplane Base, which is

operated by a lessee called New York Skyports, Inc., is on city-

owned waterfront property. Beginning in March 1999, SeaAir

provided seaplane air tours which left from the seaplane base,

flew around the metropolitan area for approximately 30 minutes,

and landed again at the seaplane base. During the flight, the

planes crossed into New Jersey airspace.

The City's regulatory code requires that a seaplane base on

city-owned property be issued a permit, which "may be limited by

appropriate conditions . . . as may be necessary or desirable to

insure the public safety and interest[.]" 66 RCNY   3-04(f)

(2000); see also 66 RCNY   3-02. In July 1999, the City issued a

permit for the seaplane base that contained the following

restriction:

5. To further minimize noise impacts on the general

public, commercial air tour operations shall not be

permitted at any time. The term "commercial air tour"

means any flight conducted for compensation or hire in

a powered aircraft where a purpose of the flight is

sightseeing.

In response, SeaAir filed suit on July 29, 1999, alleging that

the restriction violated the Supremacy, Due Process, and Equal

Protection Clauses of the Constitution as well as various federal

statutes. The primary point of SeaAir's complaint was that the

City was preempted by federal aviation statutes from restricting

the operation of seaplanes at the East 23rd Street base. SeaAir

also claimed that the City's regulation was arbitrary and

unreasonable because it was not based on factual evidence of

noise levels.

On August 12, 1999, the district court ordered a preliminary

injunction for the duration of litigation against enforcement of

the regulation. On August 21, 2000, the district court granted

the City's motion for summary judgment. Finding that SeaAir did

not engage in interstate air transportation by virtue of its

travel into New Jersey airspace during its tours, the district

court concluded that there was no federal preemption of the

City's regulations. The district court further found that the

City's decision not to permit seaplane sightseeing tours did not

violate SeaAir's due process or equal protection rights because

it was supported by the rational objectives of reducing noise and

prioritizing transportation over sightseeing. The district court

also ruled against SeaAir on its remaining statutory and Commerce

Clause claims, none of which are appealed here.

DISCUSSION

We review the district court's award of summary judgment to

the City de novo. See Greater New York Metro. Food Council, Inc.

v. Giuliani, 195 F.3d 100, 104 (2d Cir. 1999). Because the

parties agree that there are no material facts in dispute, we

need only determine whether the City was entitled to such a

judgment as a matter of law. See id.

As the district court recognized, SeaAir's preemption

argument under the Supremacy Clause relies entirely on the

conclusion that SeaAir engages in interstate air transportation

as defined in 49 U.S.C.   40102(a)(25) (2000). This is so

because if SeaAir does not engage in such transportation, it does

not fall under the provision of the Airline Deregulation Act of

1994 that expressly preempts state and local aviation

regulations. Section 40102(a)(25) defines "interstate air

transportation" as:

the transportation of passengers or property by

aircraft as a common carrier for compensation . . . (A)

between a place in -- (i) a State, territory, or

possession of the United States and a place in the

District of Columbia or another State, territory, or

possession of the United States[.]

SeaAir principally argues that because its planes fly into New

Jersey airspace during the course of their flights, they have

traveled "between" two states in satisfaction of this statute.

The merit of SeaAir's position boils down to the proper

definitions of "transportation" and "between." The district

court quoted Webster's definition of "transport" as "to carry . .

. from one place to another." SeaAir NY, Inc. v. City of New

York, No. 99 CIV 6055 JSM, 2000 WL 1201379, at *2 (S.D.N.Y. Aug.

23, 2000). Because SeaAir does not carry its passengers from New

York to New Jersey, but instead brings them back to where they

started at the seaplane base, the district court concluded, and

we agree, that SeaAir does not "transport" them to another state.

Similarly, SeaAir does not take its passengers "between" two

states, as that term is commonly understood, simply by flying

into the airspace of New Jersey. Despite SeaAir's urgings to the

contrary, we do not live in a world in which a piece of air can

serve as a place for the purposes of creating a "between."

Indeed, as the government points out, accepting such a definition

of "between" would render the statute nonsensical because a plane

would travel through an infinite number of places in both states

-- not simply between two places -- during a flight such as the

one at bar.

Moreover, SeaAir's proffered meaning of "place" conflicts

with the use of the word in another part of   40102(a)(25).

Section 40102(a)(25)(A)(ii) includes in the definition of

"interstate air transportation" transportation between a place in

"Hawaii and another place in Hawaii through the airspace over a

place outside Hawaii." (Emphasis added). If a place could be

airspace itself, this provision would make no sense. That fact

suggests that the "places" to which the statute refers are on the

ground.

While it is perhaps a "down-to-earth" notion, we believe

that Congress, in devising the language of   40102(a)(25), used

the words "transportation" and "between" in their traditional

sense of movement from one place to another, and intended that

the movement be from the earth of one state to the earth, not the

airspace, of another. We agree with the district court that

SeaAir's air tours do not meet these requirements, and that

SeaAir therefore cannot establish that the City's regulation of

sightseeing flights is preempted.

Even if SeaAir's air tours did qualify for protection from

local regulation under the Airline Deregulation Act's preemption

provision, the City's regulation might still escape preemption

under the exception established in 49 U.S.C.  41713(b)(3) (2000),

which states that a "political subdivision of a State . . . that

owns or operates an airport" is not limited "from carrying out

its proprietary powers and rights." The proprietor exception to

federal preemption was the subject of our decision in Nat'l

Helicopter Corp. v. City of New York, 137 F.3d 81 (2d Cir. 1998),

where we found that the City had the proprietary right to

"promulgate 'reasonable, nonarbitrary and non-discriminatory'

regulations of noise and other environmental concerns" for a

heliport it owned and leased out at East 34th Street. Id. at 88

(quoting British Airways Bd. v. Port Auth., 558 F.2d 75, 84 (2d

Cir. 1977)). We noted in Nat'l Helicopter that the proprietor

exception "allow[s] reasonable regulations to fix noise levels at

and around an airport at an acceptable amount," id. at 92, and

upheld evening curfews, weekend bans, and an overall reduction in

helicopter operations at the heliport. See id. at 88-92.

Although we do not rely upon it today, our holding in Nat'l

Helicopter indicates that the City's noise-related regulation of

sightseeing flights from the seaplane base would fall comfortably

within the proprietor exception. As discussed below, the City's

decisions to reduce the number of flights at the seaplane base

and to prioritize transportation over tourism were a reasonable

means of achieving noise reduction. It seems evident, therefore,

that the City's actions comported with their proprietary rights

under   41713(b)(3).

Turning to the due process and equal protection claims

before us, we find SeaAir's arguments in support of them to be

unavailing. In order to state a valid claim for violation of

substantive due process, SeaAir must show that the City's

regulation was an "exercise of power without any reasonable

justification in the service of a legitimate governmental

objective[.]" County of Sacramento v. Lewis, 523 U.S. 833, 846

(1998). As the district court stated, we have held that to meet

that standard, the City's action must be "arbitrary, conscience-

shocking, or oppressive in a constitutional sense[.]" Kaluczky

v. City of White Plains, 57 F.3d 202, 211 (2d Cir. 1995).

There is nothing in this record to convince us that the

City's restriction of sightseeing flights was unreasonable or

arbitrary. The City made the determination that in order to

reduce the noise impact on the community, it needed to cut the

number of flights from the seaplane base, and of those flights,

sightseeing tours were not as beneficial to the City as

commercial flights. SeaAir acknowledges that noise reduction is

a legitimate governmental objective, but claims that the City has

no evidence that eliminating air tours will achieve it. It is

reasonable, however, to assume that a reduction in flights will

result in a corresponding reduction of noise. See Nat'l

Helicopter, 137 F.3d at 90 (holding that eliminating a portion of

helicopter operations was a reasonable response to excessive

noise). Accordingly, the City's restriction did not violate

SeaAir's due process rights.

SeaAir's equal protection argument, although never clearly

set forth on appeal, seems to rely on the noise differences

between seaplanes and helicopters to claim that the City's

restriction unfairly discriminates against seaplanes. SeaAir

makes much of the fact that the district court mistakenly stated

that seaplanes add more to ambient noise levels than do

helicopters. However, given that helicopters do not even operate

from the seaplane base and that, as discussed in Nat'l

Helicopter, the City has restricted helicopter sightseeing tours

as well as seaplane tours in pursuit of a general policy against

air tourism, we fail to see how the district court's mistake

impacts the inevitable conclusion that there has been no equal

protection violation here.

CONCLUSION

In light of the foregoing, the district court's grant of

summary judgment to the City is affirmed.

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