To: Parties Interested in Stage 2 GA jet restrictions

From: Gerald A. Silver
      Pres. Homeowners of Encino (HOME)
      National Helicopter Noise Coalition (NHNC)
      Stop the Noise! Coalition (STN)

Subject: UPDATE - NAPLES, FL. BAN ON STAGE 2 JETS, UNDER 75,000 LBS.

On August 8, 2001 the U.S. District Court, in Ft. Myers, FL dismissed a
lawsuit brought by the National Business AviationAssociation and the General
Aviation Manufacturers Association against the City of Naples [FL] Airport
Authority. The lawsuit sought to enjoin enforcement of a ban on the
operation of Stage 2 jet aircraft, under 75,000 lbs. at the Naples Municipal
Airport. The Naples ban was a 24 hour a day restriction aimed at all Stage 2
jet owners and operators.

In this key case, being watched closely by other airports seeking to ban
noisy Stage 2 GA jets, the judge ruled that the ban was constitutional.

This ruling opens the door to other communities that seek to use the Part
161 Study as a means of reducing noisy Stage 2 jets at other airports. While
the court's ruling supports the consitutionality of Stage 2 jet bans, it
does not foreclose the Federal Aviation Administration from hammering
airports, and threatening to withhold AIP and PFC funds.

The FAA claims that the Stage 2 ban would violate federal grant assurances
and other
federal regulations. This heavy handed, pro-aviation bias by the FAA should
not, however, stop other airports from banning Stage 2 jets, using the Part
161 Study. It should be noted that the FAA ordered a phaseout of all Stage 2
jets, OVER 75,000 lbs., by the year 2000. This is now complete, but DID NOT
apply to Stage 2 jets UNDER 75,000 lbs. Thus those airports such as in Van
Nuys, CA; Naples, FL; Centennial, CO and Flying Cloud, MN, still endure
extremely noisy jets, UNDER 75,000 lbs.

One of the best ways to gain an understanding of the pressure tactics used
by the FAA to hammer Naples is to review the news stories that appeared in
the local press, the Naples Daily News. You can read many excellent articles
by their writer, Larry Hannan. Their web site is:

     http://www.naplesnews.com/site_search.html

To give you a flavor for this excellent news coverage, reproduced below are
several excerpts from various Naples Daily News articles, and letters to the
editor:

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

March 25, 2001 (Naples Daily News)

How lucky? Not very

Editor, Naples Daily News:

How lucky are we in Naples to have a quiet municipal airport grow into a
noisy jetport in downtown Naples? How lucky are we to have a noisy jetport
in downtown Naples that encompasses 13 percent of our town? How lucky
are we to have a small minority of pilots, private jet owners and airport
management that can influence the FAA to stop the ban on Stage 2 noisy
jets?

I don't think we're so lucky! We have tried to compromise with this minority
and they have no regard for the voters of Naples.

We, the people of Naples, who do not like airport noise and air pollution
must stop these people who want to grow the jetport in Naples, increase the
jet fuel sales, and build more hangars. We must start a campaign to get rid of
the jetport. Naples is unique. How many small towns in the United States
have a jetport in the center of their city? Too bad if no other small cities
have
banned the Stage 2 jets. They don't have our problems. Think about it!

                                           - Jim McGurk/Naples

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

Jet ban issue will continue into late 2001

Monday, April 2, 2001 (Naples Daily News)

By LARRY HANNAN, ljhannan@naplesnews.com

Being first doesn't always mean being fast.

That's what Naples Municipal Airport is learning with its Stage 2 jet ban. The
airport is the first in the country to ban Stage 2 jets under 75,000 pounds.

The airport instituted the ban at the beginning of 2001 but later had to defer
enforcement of it when the Federal Aviation Administration raised objections
to the ban. The earliest the airport will be able to enforce the ban now is late
this year.

Airport Authority Chairman Eric West said the delays should not be surprising
to anyone who knows how the federal government works.

"Any time you do something that hasn't been done before, it make federal
regulators nervous," West said. "That is the situation we're facing now. We
have to expect delays and be prepared for questions and objections to issues
we think have already been answered."

West has previously spoken of an "echo effect," in which the FAA asks
questions, gets answers and then asks the same questions in a different way.

People have to view the correspondence with the FAA as a continual thing
and not expect the Airport Authority's responses to the FAA's letters to be
the final word because the FAA will more than likely write back with more
questions and comments, West said.

It is also possible that the FAA will ask the exact same questions as before
even though the authority answered those questions in previous
correspondence, West said.

Stage 2 jets were made primarily between 1975 and 1983 and are noisier
than jets made after that time.

The FAA claims that the airport is being discriminatory by banning Stage 2
jets and will lose its ability to get grants if it goes forward. The federal
agency
also claims the airport didn't follow the proper procedures in the $3500,000
noise study the Naples Airport Authority commissioned that recommended
banning Stage 2 jets.

The airport is now moving forward with plans to add some supplemental
information to the noise study. That information is expected to correct the
procedural failures that the FAA claims occurred in the original noise study.

Airport Authority members recently approved a $102,500 scope-of-services
agreement with airport consultants that will go back and deal with issues the
FAA claims weren't looked at in the airport's original noise study.

Those issues include examining non-restrictive measures to reduce noise at the
airport and an examination of the use of noise buffers in the area.

The scope-of-services agreement is expected to correct all the problems with
the noise study. FAA officials have promised to look at the agreement and let
the airport know if the work meets the requirements for banning Stage 2 jets
under federal law before the Airport Authority approves it.

It is expected to take about two months to complete the work under the
agreement. The airport must then go through a 45-day comment period and a
180-day notification period before the ban can be enforced.

The airport's plan is to deal with all issues involving the noise study and get
that out of the way before tackling the issue of grant compliance, said Airport
Authority Executive Director Ted Soliday.

"We want to move forward with the supplemental information (on the noise
study) and get an acknowledgment from the FAA before we deal with the
other issues," Soliday said.

The FAA has told Naples Airport that even if it fixes the noise study, the
federal agency might still rule that the ban cannot be enforced because it
discriminates against a certain type of aircraft.

If the FAA decides the ban is discriminatory and the airport goes ahead with
the ban anyway, the agency could revoke federal grants the airport has
received and prohibit the county from getting any new grants.

The Airport Authority has directed the administration to work with the FAA
in reaching an agreement on the grant-compliance issue.

"So far, every time we bring up the issue of grant compliance with the FAA
they tell us that they don't think we can do it because the ban is
discriminatory," Soliday said. "But then they say it's just their opinion
and not
a final answer."

Naples Airport attorney Frank Kowalski said in situations like this grant
compliance is usually negotiated with the FAA.

"In most cases involving grant compliance, airports and the FAA are able to
negotiate some kind of agreement," Kowalski said. "Hopefully, we can do
that here."

Soliday said he believes the airport has followed the rules set forth by
Congress in banning Stage 2 jets.

"We believe we have followed the laws that have been set up for a situation
like this," Soliday said. "We don't think the FAA has a right to block us."

If the FAA is unwilling to give ground on this issue, the airport will seek
assistance from Congress, Soliday said.

In a worst case scenario, the airport could go forward without receiving any
grants. But airport officials say that will not happen.

"I don't think that's a valid option," West said.

Soliday said it could be done, but the airport would have to cut out a lot of
operations it now provides and would also have to cancel plans to upgrade
the airport in the future.

"It would make my job very difficult and I don't think the current Airport
Authority board has any interest in doing that," Soliday said.

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

Naples Airport Authority gets ready for FAA meeting about Stage 2 jet ban

Monday, July 30, 2001 (Naples Daily News)

By LARRY HANNAN, ljhannan@naplesnews.com

It is the calm before the summer storm at Naples Municipal Airport.

An uneventful summer for airport officials could come crashing to a halt during
the next few weeks when the Naples Airport Authority meets with the
Federal Aviation Administration over the Stage 2 jet ban the authority enacted
at the beginning of 2001. In addition, the authority is scheduled to defend the
ban in federal court next month.

Naples Airport Authority Executive Director Ted Soliday went to
Washington, D.C., Saturday and said he hopes to meet with FAA officials
today or Tuesday.

Soliday is in the capital on other business but is trying to schedule a time to
meet with the FAA while there.

The authority's ban on Stage 2 jets - noisy jets made primarily between
1975 and 1983 - took effect in January. But the ban was later deferred after
the FAA raised objections to the original $350,000 noise study.

Federal officials have criticized the ban because the noise study that
recommended it used a 60-decibel noise level. The FAA uses a 65-decibel
level and would have preferred the authority follow its lead.

The authority is free to use 60 decibels but has to provide evidence and an
explanation of why it used the lower level. The authority didn't do that, said
Lynne Pickard, manager of the FAA's community and environmental needs
division.

The study also didn't include an examination of nonrestrictive ways to reduce
airport noise, such as noise barriers, land purchases and voluntary curfews,
FAA officials said.

The FAA doesn't have to approve the Stage 2 jet ban but it does have to rule
that the Naples Airport Authority followed proper procedures in instituting the
ban. The FAA has said the authority didn't follow proper procedures.

In June, the authority completed a $102,500 scope of services study that it
believes takes care of all the issues cited by the FAA. But the federal agency
hasn't yet said whether it believes the scope of services study addressed all of
its concerns.

Pickard promised the Naples Airport Authority at a meeting earlier this year
that the FAA would take an unofficial look at the scope of services agreement
once it is completed and let the authority know if the work dealt with all
of the
objections the federal agency had with the original noise study.

"We don't want to go forward and approve the study until the FAA has given
its approval," Soliday said.

FAA spokeswoman Holly Baker said the FAA is reviewing the study and
expects to respond to the authority in the next couple of weeks.

Meanwhile, the authority will defend itself next month in a lawsuit filed by a
national trade group that is challenging the jet ban. The suit was filed against
the authority by the National Business Aviation Association in federal district
court in Fort Myers.

The association, a Washington, D.C.,-based trade group that represents
about 6,400 corporate members who fly in connection with their primary
business, has sued the authority because of the Stage 2 ban enacted at the
beginning of 2001.

The trade association, which contends the ban is unconstitutional, is seeking a
permanent injunction that would prohibit Naples airport from enforcing the
Stage 2 jet ban.

The case will be heard starting Monday, Aug. 20, before U.S. District Judge
Gregory Presnell and is expected to take about a week.

At a hearing earlier this month, Presnell denied the trade association's request
for a preliminary injunction and granted an authority motion that excluded
letters from the FAA criticizing the Stage 2 jet ban.

The association had hoped to introduce the letters as evidence that the ban is
unconstitutional.

"We're excited that they've ruled for us in all the preliminary motions,"
Soliday
said. "It may not mean that much, but we're happy it's gone our way so far."

Soliday said there is no chance of a settlement before the trial.

Airport Authority Chairman Eric West said the authority won't comment on
matters related to the lawsuit until after the trial.

"I really can't talk about it, which is a shame because I have a lot to say,"
West said.

Soliday said the authority is confident it has followed the law in
instituting the
ban and will be vindicated in court.

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

Editorial: Federal court ruling moves Naples nearer Stage II ban

Friday, August 10, 2001 (Naples Daily News)

The Naples Daily News

Airport noise
Federal court ruling moves Naples nearer Stage II ban

Good news.

The Naples Airport Authority has cleared a hurdle en route to banning the
oldest and loudest jets.

A federal court in Fort Myers has ruled that aviation industry interests that
challenged efforts to ban so-called Stage II jets have failed to prove that such
a move would be discriminatory.

For the layman, that means Naples Municipal Airport is not picking only on
Stage IIs; it is picking on all planes that shatter the community's peace and
quiet, and abuse its welcome.

There are lots of quiet, state-of-the-art jets available to those who find
service
at Southwest Florida International Airport too slow or too humble.

The community will have more to say about this seeming anti-noise
development as more information becomes available.

The proposed ban still has to pass muster with the Federal Aviation
Administration, which is pro-industry.

At the earliest, a ban is six months away, assuring at least one more peak
winter season of maximum jet traffic for conventions and golf.

Still, progress is progress, and this court ruling is a step in the right
direction. It
vindicates public advocates who say go ahead and try something bold rather
than cower at the prospect of irritating big business.

Further successful work to oust Stage IIs will make the Naples airport's
motto come true: "The best little airport in the country."

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

Saturday, August 11, 2001

Naples Daily News (Naples Daily News)

Letters to the editor

The charade continues

Editor, Naples Daily News:

Re: an article by Larry Hannan that the financial reserves of the Naples
Airport Authority are dangerously low.

All of this while the members shelled out $500,000 plus an additional
$105,000 for a flawed study on the Stage II Jets which we all know will
never receive FAA approval.

Rather we should have unilaterally instituted the ban and let the chips fall
where they may.

We would have had 18 months of quiet and no more legal problems than we
have now.

The FAA advised me they never sue anyone and the NBAA (National
Business Aircraft Association) has already sued us.

Should they play games with grant assurance, we could sue them or seek
legislative assistance.

                                  - Tom Ryan/Naples and Minnesota

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