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TABLE OF CONTENTS

1 INTRODUCTION AND EXECUTIVE SUMMARY ...... 1

1.1 Overview of Part 161 Study...... 2

1.2 NAA Land Use Compatibility Goal ...... 3

1.3 NAA Alternatives for Achieving Its Land Use Compatibility Goal...... 3

1.4 NAA Action to Meet Its Land Use Compatibility Goals...... 4

1.5 Noise-Related Benefits of the Recommended NAA Action...... 6

1.6 Estimated Costs of the Recommended NAA Action ...... 7

1.7 Summary Costs and Benefits of the Proposed NAA Action...... 7

1.8 Steps Taken by the NAA to Obtain Public Input on the Recommended Action ...... 9

2 BACKGROUND...... 11

2.1 Previous Noise Compatibility Planning...... 11

2.2 Current Noise Compatibility Program...... 13

3 STUDY OBJECTIVES AND ALTERNATIVES...... 15

3.1 NAA Land Use Compatibility Goal ...... 15

3.2 Current Noise Impacts and Land Use Compatibility Status ...... 16

3.3 Additional Noise Compatibility Alternatives ...... 28

4 BENEFIT-COST ANALYSIS METHODOLOGY...... 29

5 AIRPORT ACTIVITY WITH NO NEW RESTRICTIONS ...... 30

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6 OPERATIONAL IMPACTS OF PROPOSED RESTRICTIONS ...... 34

6.1 Stage 2 User Survey...... 34

6.2 Activity Forecasts Under Restriction Scenarios ...... 38

7 DEVELOPMENT OF COST ESTIMATES...... 48

7.1 Cost Assumptions ...... 48

7.2 Cost Categories...... 48

8 SUMMARY OF ESTIMATED COSTS UNDER ALTERNATIVE RESTRICTIONS ...... 62

8.1 Summary Estimated Cost of Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations ...... 62

8.2 Summary Estimated Cost of 24-Hour Restriction of Stage 2 Aircraft Operations...... 63

8.3 Summary Estimated Cost of Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 64

8.4 Comparative Summary of Estimated Costs ...... 68

9 ANALYSIS OF BENEFITS ...... 69

9.1 Cumulative Noise Exposure ...... 69

9.2 Other Noise Benefits...... 77

10 BENEFIT-COST SUMMARY AND CONCLUSIONS...... 78

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11 RECOMMENDATION ...... 81

11.1 Form of Restriction...... 81

11.2 Implementation Timing ...... 82

11.3 Recommended Waiver Provision ...... 82

12 OPPORTUNITY FOR PUBLIC COMMENT ...... 84

12.1 Definition of Notified Parties ...... 86

12.2 Notification of Proposed Rule ...... 87

12.3 Opportunity for Comment ...... 87

12.4 Adequate Time Period for Comment...... 90

13 ADDITIONAL PART 161 REQUIREMENTS ...... 91

APPENDIX A: TWO PROPOSED NAA RESOLUTIONS

APPENDIX B: METHODOLOGY FOR POPULATION COUNTS

APPENDIX C: METHODOLOGY FOR DEVELOPMENT OF CONTOURS

APPENDIX D: PORTIONS OF SECTIONS 5 AND 10 OF THE PROPOSED CHANGES TO THE EXISTING AIRPORT RULES AND REGULATIONS

APPENDIX E: STAGE 2 OPERATOR SURVEY

APPENDIX F: PUBLIC NOTICES

APPENDIX G: PART 161 NOTIFICATION LIST

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TABLE OF EXHIBITS

1-1 Overview of Part 161 Study ...... 2 1-2 Summary of Estimated Residential Population Within DNL 60 dB Contour – 2000 Existing and 2005 Forecast Conditions With and Without Potential Use Restrictions...... 6 1-3 Summary of Estimated Costs Related to Alternative Restrictions Studied ...... 7 1-4 Benefit-Cost Comparison of Alternative Restrictions in 2000 ...... 8 1-5 Benefit-Cost Comparison of Alternative Restrictions in 2005 ...... 8 2-1 Noise Compatibility Program Status ...... 14 3-1 Estimated Population within 2000 and 2005 Annual Average Day 60 DNL ...... 17 3-2 2000 Day-Night Average Sound Level (DNL) Contours ...... 18 3-3 2005 Day-Night Average Sound Level (DNL) Contours ...... 19 3-4 Estimated Residential Population within September 1998 and March 1999 Average Day 60 dB DNL Contours...... 20 3-5 September 1998 “Off-Peak Season” Day-Night Average Sound Level (DNL) Contours ...... 21 3-6 March 1999 “Peak Season” Day-Night Average Sound Level (DNL) Contours ...... 22 3-7 Composite Sound Exposure Level (SEL) Contours, 80 dB to 110 dB, for One Lear 25 Departure off of Each Runway End...... 25 3-8 Composite Sound Exposure Level (SEL) Contours, 80 dB to 110 dB, for One Lear 35 Departure off of Each Runway End...... 26 3-9 Summary of Calendar Year 1999 Noise Complaints...... 27 4-1 Benefit-Cost Analysis Methodology ...... 29 5-1 2000 Average Daily Operations With No New Restrictions ...... 31 5-2 2005 Average Daily Operations With No New Restrictions ...... 32 5-3 Annual Jet Operations by Noise Stage With No New Restrictions ...... 33 6-1 Stage 2 Operator Survey Base ...... 35 6-2 Operations Represented by Surveyed Stage 2 Operators at Naples...... 36 6-3 Comments Received on Stage 2 Operator Survey...... 38 6-4 Survey Responses to Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Jet Aircraft Operations...... 39 6-5 2000 Average Daily Operations Under Night (10 p.m.- 7 a.m.) Restriction of Stage 2 Aircraft Operations...... 40 6-6 2005 Average Daily Operations Under Night (10 p.m.- 7 a.m.) Restriction of Stage 2 Aircraft Operations...... 41

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6-7 Survey Responses to 24-Hour Restriction of Stage 2 Jet Aircraft Operations...... 42 6-8 2000 Average Daily Operations Under 24-Hour Restriction of Stage 2 Aircraft Operations...... 43 6-9 2005 Average Daily Operations Under 24-Hour Restriction of Stage 2 Aircraft Operations...... 44 6-10 Adjusted Survey Responses for Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 45 6-11 2000 Average Daily Operations Under Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 46 6-12 2005 Average Daily Operations Under Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 47 7-1 Estimated Annual Cost of Using Alternate Airports 2000 ...... 50 7-2 Estimated Annual Cost of Using Alternate Airports 2005 ...... 50 7-3 Estimated Annual Cost of Flight Cancellations 2000...... 52 7-4 Estimated Annual Cost of Flight Cancellations 2005...... 52 7-5 Hushkit Equipment Costs for General Aviation Jets ...... 53 7-6 Upper Bound Hushkit Installation Costs ...... 54 7-7 Total One-Time Costs of Aircraft Substitution ...... 56 7-8 Annual Estimated Cost of Rescheduled Flights 2000...... 57 7-9 Annual Estimated Cost of Rescheduled Flights 2005...... 57 7-10 Estimated FBO Revenue per Jet Operation ...... 58 7-11 Estimated Annual Cost of Lost FBO Revenue 2000 ...... 59 7-12 Estimated Annual Cost of Lost FBO Revenue 2005 ...... 59 7-13 Projected Daily Incremental Operations at Alternate Airports 2000...... 61 7-14 Projected Daily Incremental Operations at Alternate Airports 2005...... 61 8-1 Estimated Annual Costs of Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations 2000 and 2005...... 62 8-2 Estimated Annual Costs of 24-Hour Restriction of Stage 2 Aircraft Operations 2000 and 2005 ...... 63 8-3 Estimated Annual Jet-Related Costs of Night (10 p.m. – 7 a.m.) Restriction of All Operations 2000 and 2005...... 65 8-4 Estimated Revenue Associated With Air Carrier Cancellations Under Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 66 8-5 Estimated Revenue Generated by Flight Schools at APF in 1999...... 67 8-6 Comparative Estimated Annual Jet-Related Costs for Each Proposed Restriction in 2000 and 2005 ...... 68

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9-1 Estimated Residential Population Within DNL 60 dB Contour - 2000 Existing and 2005 Forecast Conditions With and Without Potential Use Restrictions ...... 70 9-2 2000 Day-Night Average Sound Level (DNL) Contours: Night (10 a.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations ...... 71 9-3 2005 Day-Night Average Sound Level (DNL) Contours: Night (10 a.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations ...... 72 9-4 2000 Day-Night Average Sound Level (DNL) Contours: 24-Hour Restriction of Stage 2 Aircraft Operations ...... 73 9-5 2005 Day-Night Average Sound Level (DNL) Contours: 24-Hour Restriction of Stage 2 Aircraft Operations ...... 74 9-6 2000 Day-Night Average Sound Level (DNL) Contours: Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 75 9-7 2005 Day-Night Average Sound Level (DNL) Contours: Night (10 p.m. – 7 a.m.) Restriction of All Operations...... 76 10-1 Comparison of Benefits of Potential Use Restrictions: Population Within DNL 60 dB Contour Compared to Status Quo – 2000 and 2005 Existing and Forecast Conditions...... 78 10-2 Estimated Total Costs of Proposed Use Restrictions in 2000 and 2005 Existing and Forecast Conditions ...... 79

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1 INTRODUCTION AND EXECUTIVE SUMMARY

aples Municipal Airport (APF) is located just 20 minutes from the center of one of the fastest growing communities in the nation. It provides the community with Nvaluable commercial and private air transportation services. The City of Naples Airport Authority (NAA) assigns a high priority to noise compatibility in its direction of airport development and operations. Since 1987, the NAA has pursued its noise compatibility objectives under the Federal Aviation Administration (FAA) Part 1501 program. The Part 150 process has led to FAA-approved actions by the NAA, City of Naples, and Collier County to implement a comprehensive package of noise abatement, compatible land use, and publicity measures. In 1997, in response to community concerns regarding operations of the noisiest general aviation jets, the NAA sought and received FAA approval of a restriction of non-emergency night Stage 1 jet operations.2 In 1998, the NAA sought FAA approval to extend that restriction to 24-hour application. The FAA approved that extension in 1999. Despite these ambitious noise compatibility actions, aircraft noise remains a major community concern. Operations by aircraft that are certificated pursuant to Part 36 of the FAA regulations as Stage 2 jets are the principal source of the noise impact that causes community concern.

1 Federal Aviation Regulation (“FAR”) Part 150 (14 CFR Part 150), “Airport Noise Compatibility Planning,” U. S. Department of Transportation, Federal Aviation Administration. 2 The FAA has established limits on allowable levels of aircraft noise emissions, under FAR Part 36 (14 CFR Part 36), "Noise Standards, Aircraft Type and Airworthiness Certification." Part 36 sets noise standards that airplanes must meet to receive "type" certificates. The permissible levels are weight-dependant; heavier aircraft are allowed to make more noise. The limits have become more stringent over time. Aircraft not certificated under Part 36 (those receiving type certificates prior to the dates specified in Part 36 and for which no later tests have demonstrated compliance) are termed "Stage 1" aircraft. Aircraft meeting the original noise limits are "Stage 2." Aircraft meeting the most recent, most stringent limits are "Stage 3." Another FAA regulation, FAR Part 91 (14 CFR Part 91, Subpart E, “Operating Noise Limits”), sets a phased schedule by which operators must eliminate Stage 2 jet aircraft, with maximum takeoff weights over 75,000 pounds, from their fleets by the end of 1999. Part 91 required the phase out of Stage 1 aircraft over 75,000 pounds before 1985. There is no phase-out requirement for Stage 1 or 2 jets under 75,000 pounds; that weight is roughly, but not absolutely, the dividing line between airline and general aviation jets.

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1.1 OVERVIEW OF PART 161 STUDY Exhibit 1-1 shows the steps the NAA has taken under the Part 161 process to address ongoing noise concerns in the community. Following the Introduction and Executive Summary, this report will describe each of the five principal steps in turn.

1-1 Overview of Part 161 Study

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1.2 NAA LAND USE COMPATIBILITY GOAL Part 150 requires airports to use the Day-Night Average Sound Level (DNL) metric to define areas of non-compatible land. A 1998 City of Naples ordinance established 60 dB DNL as the limit for land use compatibility within municipal limits. Within 60 dB DNL, the City Council must provide general development site plan (“GDSP”) approval. In addition, Collier County has notified the NAA of its intention to adopt 60 dB DNL as the limit for noise-land use compatibility and recently amended the County Land Development Code to require noise notices within that contour. In compliance with the FAA Part 150 guidance that airport proprietors must defer to local authorities in determining land use compatibility, the NAA is respecting the City of Naples and Collier County 60 dB DNL land use compatibility criterion and considers residential land within the 60 dB DNL contour to be incompatible with aircraft noise. Accordingly, the NAA has established the goal of minimizing residential land within the 60 dB DNL contour to the maximum feasible extent.

1.3 NAA ALTERNATIVES FOR ACHIEVING ITS LAND USE COMPATIBILITY GOAL The NAA has embarked upon an ambitious and aggressive program to improve land use compatibility in the vicinity of APF. To that end, the NAA has conducted three complete Part 150 studies for APF, with submissions to the FAA in 1987 (original Part 150 study), 1997 (first update), and 1998 (second update). These studies, and subsequent FAA Noise Compatibility Program (NCP) approvals, have led to the NAA’s establishment of a comprehensive program of noise abatement, compatible land use planning, monitoring, implementation, and public involvement focused on accomplishment of its land use compatibility goal. The 1997 NCP submission included a night restriction on Stage 1 operations. The 1998 submission extended this restriction to 24 hours. The FAA’s decision twice to approve operational restrictions on Stage 1 aircraft reveals that the FAA believes that operational restrictions are warranted at this airport and that the NAA has reasonably pursued all feasible non-restrictive alternatives for achieving its land use compatibility goals. The Stage 1 restriction and other noise compatibility program actions have limited, but not eliminated, the number of residences within the 60 dB DNL contour. In addition, continuing growth in aircraft operations is likely to increase that number, unless the NAA takes additional steps to restrict operations in an appropriate manner.

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To address this situation, in 1999 the NAA retained a team of consultants3 to conduct a two-phase investigation. The first phase included the preparation of updated Part 150 Noise Exposure Map (NEM) documentation for the years 2000 and 2005, and identification of three potential use restrictions that assist the NAA in accomplishing its goal of minimizing population within the 60 dB DNL contour:

Alternative 1: Night (10 p.m. - 7 a.m.) Restriction of Stage 2 Jet Aircraft Operations Alternative 2: 24-hour Restriction of Stage 2 Jet Aircraft Operations Alternative 3: Night (10 p.m. - 7 a.m.) Restriction of All Operations

The second study phase included analysis of the benefits and costs of these alternatives, and preparation of a recommended course of action for the NAA to follow. This report presents the results of that phase. The NAA and its consultants conducted this study according to the substantive and procedural requirements of Part 161.4 Those federal regulations address the process that airports must follow to analyze and implement restrictions on Stage 2 or 3 aircraft. Part 161 sets forth specific public notification processes. In preparing this document, the consultants exceeded the requirements in this important area. In addition, this report sets forth further notification steps that the consultants recommend that the NAA follow to implement the study recommendation. These planned steps also exceed applicable Part 161 requirements.

1.4 NAA ACTION TO MEET ITS LAND USE COMPATIBILITY GOAL This report concludes that the NAA has exhausted all reasonably feasible non- restrictive measures to achieve its land use compatibility goal and recommends that the NAA adopt a use restriction on operations at APF. This report finds that

3 The environmental noise and vibration consulting firm of Harris Miller Miller & Hanson Inc. (HMMH) is the prime contractor to the NAA on this study. The HMMH team includes the transportation economics and regulatory consulting firm of Simat, Helliesen & Eichner, Inc. (SH&E), and the aviation planning firm of Montgomery Consulting Group, Inc. (MCG). 4 FAR Part 161 (14 CFR Part 161), “Notice and Approval of Airport Noise and Access Restrictions.”

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a ban on operations by Stage 2 aircraft is the most reasonable, cost-effective, and feasible operational alternative available to meet the NAA’s noise compatibility goal. This report recommends implementation of a 24-hour restriction on operations by Stage 2 aircraft. Appendix A sets forth the text of two Authority resolutions. The NAA adopted the first Resolution, No. 2000-7, on June 22, 2000, setting forth the NAA’s intent to propose a ban on operations by Stage 2 aircraft. The proposal in that Resolution extends the existing 24-hour prohibition of Stage 1 aircraft operations to include Stage 2 aircraft operations but, like the Stage 1 restriction, exempts aircraft operated by the United States and State of Florida governments; law enforcement, emergency, fire, and rescue operations conducted by government agencies; and operations conducted for bona fide emergency purposes. The Resolution proposes that the restriction allow the NAA to grant temporary waivers from the prohibition on Stage 2 operations (for a maximum of six months and not beyond December 31, 2001), where an operator demonstrates commitment to either recertificating the aircraft as Stage 3 or to replacing the aircraft with a Stage 3 aircraft within the waiver period. The second Resolution in Appendix A, No. 2000-xx, sets forth the form of a resolution that the NAA would pass, following appropriate opportunity for public notice and comment, to adopt formally the proposed ban on Stage 2 operations. This report recommends that the NAA consider this resolution at its first regularly-scheduled meeting after the close of the public comment period. This report provides recommendations for ensuring that the NAA complies fully with federal regulations in the implementation of the proposed restriction. In addition to setting forth proposed public notice and comment procedures, this report provides the substantive analytical basis for action by the NAA to adopt the recommended restriction. At its meeting on June 22, 2000, the NAA received a formal public presentation of the consultant team’s analysis and conclusion. At that meeting, the public was given an opportunity to comment on the consultants’ work as well as the proposed implementation of a 24-hour ban on operations by Stage 2 aircraft. The NAA adopted Resolution 2000-7 following the presentations and public comment and directed staff to proceed with the public notice process described in this report.

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1.5 NOISE-RELATED BENEFITS OF THE RECOMMENDED NAA ACTION The recommended restriction provides a broad range of noise-related benefits. As shown in Exhibit 1-2, a 24-hour restriction of Stage 2 aircraft operations reduces population within the 60 dB DNL contour by approximately 91 percent in 2000 and approximately 76 percent in 2005. The other two potential restrictions result in less than a 40 percent reduction.

1-2 Summary of Estimated Residential Population Within DNL 60 dB Contour – 2000 Existing and 2005 Forecast Conditions With and Without Potential Use Restrictions

2000 2005 No New Restrictions 1,682 1,644

Night Restriction of Stage 2 Jet Aircraft Operations 1,312 1,318 24-hour Restriction of Stage 2 Jet Aircraft Operations 152 400 Night Restriction of All Operations 1,118 1,160

Sources: MCG analysis, HMMH contours

Analysis of the 1999 noise complaints reveals that Stage 2 jet operations were over 25 times more likely to cause noise complaints than Stage 3 jet operations and nearly 250 times more likely to cause noise complaints than propeller operations. Moreover, Stage 2 operations resulted in multiple noise complaints over 50 times more often than Stage 3 operations and over 800 times more often than propeller operations. Stage 2 operations result in single event noise exposure that affects extraordinary numbers of residents compared to Stage 3 aircraft operations. The combined area within the 85 dB Sound Exposure Level (SEL) single event noise contours for Stage 2 Lear 25 departures on the most common jet departure flight track off of each runway end encompasses over 70,000 residents, compared to approximately 16,000 residents for Stage 3 Lear 35 departures.5

5 SEL is the most complete measure of single event impacts, in that it takes into account the noise level and duration of an individual operation. SEL is the single event noise “dose” used in Part 150. The integrated

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1.6 ESTIMATED COSTS OF THE RECOMMENDED NAA ACTION Exhibit 1-3 shows a summary of estimated costs relating to the recommended Stage 2 restriction and the alternatives studied. Annual costs of the 24-hour Stage 2 restriction are estimated between $6.6 and $8.0 million in 2000, falling rapidly to a range of $800,000 to $1.6 million in 2005. The range primarily relates to the subjective value of time, with the lower bound following published FAA guidelines. Over 70 percent of these costs relate to the replacement or modification of an estimated 11 aircraft among the 191 Stage 2 aircraft that use APF. Analysis of the aircraft operations that might reasonably be expected to divert to other airports surrounding APF reveals that the effect on noise exposure at those airports will be negligible.

1-3 Summary of Estimated Costs Related to Alternative Restrictions Studied (in thousands of dollars)

2000 2005

Night Restriction of Stage 2 $4,353 - $4,911 $479 - $770 Jet Aircraft Operations 24-Hour Restriction of Stage 2 $6,618 - $8,009 $781 - $1,600 Jet Aircraft Operations Night Restriction of All Operations $11,403 - $18,355 $16,615 - $26,747

Source: SH&E

1.7 SUMMARY COSTS AND BENEFITS OF THE PROPOSED NAA ACTION Analysis of noise-related benefits and associated economic costs demonstrate that the recommended Stage 2 restriction accomplishes the NAA’s land use compatibility goal by reducing residential land use within the 60 dB DNL contour to the maximum feasible extent. Exhibits 1-4 and 1-5 show a benefit-cost comparison in 2000 and 2005 of alternative restrictions studied. In these exhibits, the benefits of reducing population within the 60 dB DNL contour are shown on

noise model calculates DNL at and around the airport by adding up the SEL values contributed by individual operations.

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the horizontal scale, compared to the costs associated with each alternative on the vertical scale.

1-4 Benefit-Cost Comparison of Alternative Restrictions in 2000

Cost ($ Million) $20

$15 All Night

$10

24-Hour Stage 2

$5 Stage 2 Night

$0 0 250 500 750 1000 1250 1500 1750

Source: HMMH, MCG,Reduction SH&E in Population Within 60 dB DNL Contour

1-5 Benefit-Cost Comparison of Alternative Restrictions in 2005

Cost ($ Million) $30

$25 All

$20 Night

$15

$10

$5 Stage 2 24-Hour Night Stage 2 $0 0 250 500 750 1000 1250 1500

Source: HMMH, MCG, SH&E

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1.8 STEPS TAKEN BY THE NAA TO OBTAIN PUBLIC INPUT ON THE RECOMMENDED ACTION To obtain public input on this proposed action, the NAA conducted a Public Forum on the proposal on June 13, 2000. This forum provided an opportunity for the public to hear a briefing from the consultants on the proposal, and to provide verbal comment prior to NAA consideration of the proposal. The NAA publicized this forum through the following mechanisms:6

T Direct mailings to at least the following parties: − all based jet operators − all fixed-base operators − the president of the Citizens for Control of Airport Noise (CAN) (a local airport noise activist group) − the National Business Aviation Association − the Aircraft Owners and Pilots Association − parties on the NAA Noise Compatibility Committee (NCC) distribution list − the FAA and the Florida Department for Transportation − any parties recorded as having filed a noise-related complaint within the past two years. − Naples Pilot Association members − known Stage 2 operators at Naples Airport − the president of Friends of Naples Municipal Airport

T Postings of notices at official notice locations in the General Aviation Terminal T Posting of notices on www.FlyNaples.com, the website of APF T Published notices in the Naples Daily News on Sunday, June 4, and Sunday, June 11 through Tuesday June 13

6 The Public Forum is not a Part 161 requirement. This step is one indication of the extraordinary measures that the NAA is taking to provide the highest possible level of publicity and opportunity for public input regarding the proposed action. In addition, the mechanisms used to announce the forum significantly exceed the notice standards of Part 161.

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T Published notice in the APF monthly safety newsletter preceding the forum

At the Public Forum, the consultants presented a summary of the goals of this Part 161 process, the alternatives studied and this report’s principal findings. Attendees were given the opportunity to ask the consultants questions to make comments. Prior to adoption of a restriction, the NAA is required to consider public comments on the proposal. A summary of those comments will be made available for public inspection and review prior to final Authority action.

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2 BACKGROUND

he City of Naples Airport Authority assigns a high priority to noise compatibility. Since 1987, the NAA has pursued its noise compatibility objectives under the TFAA Part 150 program.

2.1 PREVIOUS NOISE COMPATIBILITY PLANNING The Part 150 process has led to FAA-approved actions by the NAA, City of Naples, and Collier County to implement a comprehensive package of noise abatement, compatible land use, and publicity measures, including, but not limited to:

− restriction of noisiest operations − maintenance runup controls − preferential runway use − noise abatement flight paths − compatible land use planning and − portable noise monitoring zoning − noise abatement officer position − noise compatibility committee − noise compatibility program publicity − continuing program review

The focus of this study is the NAA’s objective of pursuing additional, appropriate use restrictions to minimize residential land use within the 60 dB DNL noise contour to the maximum feasible extent. This step is the most recent phase in an ongoing noise - land use compatibility process that has included four separate formal actions under Part 150: T In February 1987, the NAA completed its first Part 150 study for APF, and submitted the NEM and NCP documentation to the FAA. The FAA found the NEM in compliance in August 1988, and approved the NCP in February 1989. T In February 1997, the NAA submitted revised NEM and NCP documentation to the FAA, which reflected the current noise -

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land use compatibility situation at the airport.7 The FAA found the NEM in compliance in April 1997. In September 1997, the FAA approved all or part of 14 of the 15 recommendations in the updated NCP, including restriction of night (10 p.m. to 7 a.m.) Stage 1 operations, except for emergency and government operations. T In February 1998, the NAA submitted a second revision of the NEM and NCP documentation to the FAA.8 The revised NCP recommended extension of the Stage 1 restriction to 24 hours. In September 1998, the FAA determined that the NEM submission was in compliance. In March 1999, the FAA approved the extended Stage 1 restriction. T In August 1999, the NAA authorized HMMH, SH&E, and MCG to initiate a two-phase study. The first phase included the preparation of updated NEM documentation for the years 2000 and 2005, and identification of three potential use restrictions that would assist the NAA in accomplishing its goal of minimizing population within the 60 dB DNL contour:

Alternative 1: Night (10 p.m. - 7 a.m.) Restriction of Stage 2 Jet Aircraft Operations Alternative 2: 24-hour Restriction of Stage 2 Jet Aircraft Operations Alternative 3: Night (10 p.m. - 7 a.m.) Restriction of All Operations

The 2000/2005 NEM documentation presents detailed information related to airport operations, noise exposure, and land use in 2000 and 2005. The NEM documents baseline land-use compatibility in 2000 and 2005 in the absence of any new use restrictions. The 2000/2005 NEM documentation is incorporated by reference. It is available for public review at NAA offices. The consulting team presented the draft 2000/2005 NEM and potential restrictions to the NAA at its meeting on February 2, 2000 and to the NCC at its meeting on

7 “Revised Noise Exposure Map - 1996" and “Revised Noise Compatibility Program - 1996”, Naples Municipal Airport FAR Part 150 Study, prepared by Post, Buckley, Schuh & Jernigan, Inc. and Harris Miller Miller & Hanson Inc., February 1997. 8 “Naples Municipal Airport FAR Part 150 Update, Amendment of Noise Exposure Maps and Noise Compatibility Program to Extend Nighttime Stage 1 Use Restriction to 24 Hours,” prepared by Harris Miller Miller & Hanson Inc., February 1998.

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March 2, 2000. Based on comments received, the consultant team and APF staff revised the draft and submitted multiple copies to the FAA for review on May 30, 2000.9 Based on the results of the 2000/2005 NEM update, the NAA instructed staff and the consulting team to conduct a second project phase, including analysis of the benefits and costs of these alternatives, and preparation of a recommended course of action for the NAA to follow. This report presents the results of that phase.

2.2 CURRENT NOISE COMPATIBILITY PROGRAM The current APF NCP includes 15 measures that the FAA has approved, based on NAA Part 150 Update submissions in 1997 and 1998: T In the 1997 NCP update, the NAA requested FAA approval of 15 recommended measures. The FAA approved implementation of 13 of these measures in full, disapproved one10, and approved one in part.11 The 2000/2005 NEM Update presents a copy of the FAA Record of Approval for this update. T In the 1998 NCP update, the NAA requested FAA approval of one additional measure. The 1998 Update reviewed the implementation status of the 14 previously approved measures, but did not request any change to these measures, nor any FAA actions related to them. The 2000/2005 NEM Update presents a copy of the FAA Record of Approval for this update.

Exhibit 2-1 lists the 16 measures that the two updates recommended, including a description, the year of the applicable update, the FAA approval/disapproval action, and the implementation status of each. The table shows that the NAA has made significant progress in implementing the NCP. To date, the NAA has

9 “Naples Municipal Airport FAR Part 150 Noise Exposure Map Update,” prepared by Harris Miller Miller & Hanson Inc. in association with Simat, Helliesen & Eichner, Inc. and Montgomery Consulting Group, Inc., June 2000. 10 The disapproved measure requested that the FAA eliminate the existing practice that restricts initial departure climb clearances to 2,000 feet above mean sea level. The FAA disapproved this measure on the basis that there was insufficient noise benefit within the 65 dB DNL contour. See item 2 in Exhibit 2-1. 11 The partially approved measure related to use restrictions. The FAA approved a restriction on nighttime (10 p.m. - 7 a.m.) Stage 1 jet operations, but disapproved a voluntary curfew on nighttime Stage 2 and 3 jet operations, and a future restriction of nighttime Stage 2 operations. See item 6 in Exhibit 2-1.

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implemented all of the FAA-approved operational and continuing program measures, and one of the land use measures.

2-1 Noise Compatibility Program Status

Measure (Year of NCP update which Implementation recommended measure) Description FAA Action Status Operational Measures 1. Preferential Runway (1997) Maximize use of Runway 5 for departures. Approved Implemented 2. Flight Procedures (1997) Eliminate existing 2000 foot MSL initial Disapproved No further action departure restriction. (insufficient noise taken reduction) 3. Flight Paths (1997) Runway 5: straight Approved as Implemented Runway 23: right turn voluntary measure Runway 14: left turn Runway 32: right turn 4. Helicopters (1997) Centralized flight corridors, pilot education, Approved Implemented achieve altitude before departing airport 5. Ground Noise (1997) Ban night maintenance runups, designate runup Approved Implemented locations and orientations 6. Use Restrictions (1997) Restrict night Stage 1 jet operations Approved Implemented Voluntary Stage 2 and 3 night curfew Disapproved No further action Future elimination of night Stage 2 operations Disapproved No further action 7. Use Restriction (1998) 24 hour Stage 1 restriction Approved Implemented Land Use Measures 8. Land Acquisition (1997) Acquisition in Rock Creek Campground and Approved No action to date Naples Villas to develop buffer. 9. Easements (1997) Purchase of easements in Naples Villas and Approved No action to date Rock Creek Campground. 10. Zoning/Land Use Planning Adoption of DNL 60 dB for zoning and land use Approved Implemented (1997) planning. 11. Fair Disclosure (1997) Develop fair disclosure program to educate Approved No action to date potential home buyers. Continuing Program Measures 12. Noise Officer (1997) Establish Noise Abatement Officer position. Approved Implemented 13. Noise Committee (1997) Establish Noise Compatibility Committee. Approved Implemented 14. Noise Monitoring Program Establish noise monitoring program; acquire Approved Implemented (1997) portable noise monitor. 15. Public Information (1997) Implement public information program. Approved Implemented 16. NCP Review, Evaluation, and Regular or as needed NCP review and Approved Implemented Revision (1997) evaluation.

Sources: (1) APF Part 150 Update, 1997; (2) FAA Recommendation for Approval, 1997; (3) APF Part 150 Update, 1998; (4) FAA Recommendation for Approval, 1998; (5) NAA staff reports

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3 STUDY OBJECTIVES AND ALTERNATIVES

espite the City of Naples Airport Authority’s ambitious noise compatibility planning efforts, aircraft noise remains a major concern for residents near the Dairport.

3.1 NAA LAND USE COMPATIBILITY GOAL Part 150 guidelines suggest that airports use the Day-Night Average Sound Level (DNL) for operations on the average day (i.e., total annual operations divided by 365) to define areas of non-compatible land. Most federal agencies dealing with noise have formally adopted DNL. The Federal Interagency Committee on Noise (FICON) reaffirmed the appropriateness of DNL in 1992, by stating: “There are no new descriptors or metrics of sufficient scientific standing to substitute for the present DNL cumulative noise exposure metric.”12 In recognition of the widespread use of the DNL metric, the FAA’s Part 161 regulations require the use of the metric for analysis of noise impacts and benefits in a Part 161 study. This study adheres to that requirement. In simple terms, DNL is the average noise level over a 24-hour period, except that noises occurring at night (defined as 10:00 p.m. through 7:00 a.m.) are artificially increased by 10 dB. This weighting reflects the added intrusiveness of nighttime noise events attributable to the fact that community background noise levels decrease at night. The DNL can be measured or estimated. Measurements are practical only for obtaining DNL values for relatively limited numbers of points, and, in the absence of a permanently installed monitoring system, only for relatively short time periods. Most airport noise studies are based on computer-generated DNL estimates, depicted in terms of equal-exposure noise contours (much as topographic maps have contours of equal elevation).13 Part 150 guidelines consider 65 dB DNL to be the normal limit of land use compatibility. However, Part 150 recognizes that it is local authorities and not the

12 Federal interagency Committee on Noise (FICON), “Federal Agency Review of Selected Airport Noise Analysis Issues,” August 1992, page ES. FICON was an ad hoc committee made up of all federal agencies that deal with transportation noise. 13 HMMH prepared the contours presented in this study and the 2000/2005 NEM Update using the FAA’s own Integrated Noise Model (INM) Version 6.0, the most current version available at the time the work was initiated.

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FAA that set the standard of compatibility. Airports are instructed to adopt compatibility criteria established by local jurisdictions. A 1998 City of Naples ordinance established 60 dB DNL as the limit for land use compatibility within municipal limits. Within 60 dB DNL, the City Council must provide general development site plan (“GDSP”) approval. In addition, Collier County has adopted 60 dB DNL as the limit for noise-land use compatibility and has amended the County Land Development Code to require noise notices within that contour. In compliance with the FAA Part 150 guidance that airport proprietors defer to local authorities in determining land use compatibility criteria, the NAA respects the City of Naples and Collier County 60 dB DNL land use compatibility criteria and considers residential land within the 60 dB DNL contour to be incompatible with aircraft noise and has established the goal of minimizing residential land within 60 dB DNL to the maximum feasible extent. Consistent with this goal, the 2000/2005 NEM Update used the 60 dB DNL contour as the basis for identifying potentially non-compatible land use, and revealed the degree of improvement required for the NAA to meet its goal in full. The NEM Update includes supporting documentation regarding the City and County land use compatibility criteria.

3.2 CURRENT NOISE IMPACTS AND LAND USE COMPATIBILITY STATUS The basis for community concern regarding noise impacts can be demonstrated in a number of ways, including: T cumulative noise exposure on an annual average day basis T cumulative noise exposure on a seasonal basis T single event noise exposure T noise complaints

Analysis of these data reveals that the basis for NAA action is supported by more than just the population within the NEM contours.

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3.2.1 Cumulative Noise Exposure on an Annual Average Day Basis Exhibit 3-1 presents the estimated residential population within the 2000 and 2005 60 dB DNL contours.14

3-1 Estimated Population within 2000 and 2005 Annual Average Day 60 DNL

Population Off Approach End of Each Runway

05 23 14 32 (City land (County land (County land (County land area to the area to the area to the area to the southwest) northeast) northwest) southeast) Total

2000 Existing Conditions 1,218 0 01/ 464 1,682

2005 Forecast Conditions 1,130 0 24 490 1,644

1/ The 2000 contour (Exhibit 3-2) shows a triangular area of residential land use off the end of Runway 14. However, this land area is in a portion of a residential development that does not include any dwelling units. It includes tennis courts and a club house for the development.

Source: MCG analysis based on HMMH contours

Exhibits 3-2 and 3-3 present the 60, 65, 70, and 75 dB DNL contours for APF, for 2000 and 2005, respectively. For both 2000 and 2005, the 60, 65, and 70 dB contours extend outside of airport property. The figures depict non-compatible land use within the 60 dB DNL contour, all of which is residential.15 There are residential areas between the 60 and 65 dB DNL contours off the approach ends of Runways 05, 14, and 32. The figures also show the border between the City of Naples and Collier County, the two land use planning and control jurisdictions. The airport boundary is shown with a dashed line, where it is not common with the City/County border.

14 Appendix B presents detailed information on the method that MCG used to develop these population estimates. The approach is the same as that which MCG used in developing population estimates for the 2000/2005 NEM. The method is significantly more precise than required by Part 150. 15 The 2000/2005 NEM documentation describes the modeling process, input data, and assumptions that these contours incorporate. It also discusses the process by which MCG identified and tabulated non- compatible land use. The NEM documentation is incorporated by this reference and is not repeated in this report.

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3-2 2000 Day-Night Average Sound Level (DNL) Contours

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3-3 2005 Day-Night Average Sound Level (DNL) Contours

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3.2.2 Cumulative Noise Exposure on a Seasonal Basis Operations at APF vary significantly on a seasonal basis, because Naples and the surrounding areas are a major winter destination. Airport activity peaks during the winter months (with March typically the busiest month) and drops off substantially during the summer (with September typically the slowest month). As a result of this seasonality, cumulative noise exposure, in terms of DNL, increases significantly during the winter, compared to annual average day conditions. Exhibit 3-4 presents the estimated residential population within the 60 dB DNL contour for offpeak (September) and peak (March) average days.16

3-4 Estimated Residential Population within September 1998 and March 1999 Average Day 60 dB DNL Contours

Population Off Approach End of Each Runway 05 23 14 32 (City land (County land (County land (County land area to the area to the area to the area to the Average Day southwest) northeast) northwest) southeast) Total September 1998 96 0 0 184 280 March 1999 1,310 28 24 904 2,266

Sources: MCG analysis, HMMH contours

As this exhibit shows, the noise contours expand to encompass a significantly larger number of residents during the peak season. Operations and noise complaints both typically reach their highest levels in March, and their lowest in July, August, or September. Exhibits 3-5 and 3-6 present DNL contours for average daily operations at APF in September 1998 and March 1999. These contours are based on actual operations and runway use during those two months, with the same flight track geometry and utilization rates as in the annual average day operations. Appendix C presents documentation related to the development of these contours.

16 MCG used the same methodology in preparing these population estimates as in preparing the population estimates for the 2000 and 2005 contours, as discussed in Appendix B.

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3-5 September 1998 “Off-Peak Season” Day-Night Average Sound Level (DNL) Contours

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3-6 March 1999 “Peak Season” Day-Night Average Sound Level (DNL) Contours

3.2.2

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3.2.3 Single Event Noise Exposure While the NAA is required to use DNL contours when considering the impacts and benefits of noise compatibility measures, many citizen concerns relate to the effects of unusually loud single events. Stage 2 operations result in single event noise exposure that affects extraordinary numbers of residents compared to Stage 3 aircraft operations. The INM includes noise and performance data for 10 corporate jet aircraft types; the FAA provides direction on how to assign actual jet operations to these representative types. The Lear 25 is one of two Stage 2 types in the database.17 The aircraft types it represents in modeling operations at APF comprise approximately 73 percent of the Stage 2 operations. The Lear 35 is one of eight Stage 3 types in the database. The aircraft types it represents in modeling operations at APF comprise approximately 47 percent of the Stage 3 operations at APF. Together, these two INM types represent approximately 50 percent of the jet operations at APF. Exhibit 3-7 presents composite single event noise contours, showing the total area affected by one Lear 25 departure, a Stage 2 aircraft, on the most common jet departure flight track off each runway end. Exhibit 3-8 presents the comparable composite contours for the Lear 35, a Stage 3 aircraft. The contours are in terms of the Sound Exposure Level (SEL). Appendix C summarizes the preparation of these contours. The FAA does not provide guidance regarding the SEL contour value to use in considering single event impacts. However, the NAA selected the 85 dB SEL as the contour to use in single event analyses in the 1997 Part 150 Update, based on public input. Exhibits 3-7 and 3-8 present the 80 to 110 dB SEL contours in five decibel increments. These figures clearly reveal the reduced noise impact of Stage 3 operations compared to Stage 2. The INM includes an automated method based on 1990 census data for calculating population within noise contours. We used this automated method, which is consistent with FAA Part 150 guidelines, to estimate the population within the large geographic areas of the SEL contours. Appendix C presents tables indicating the residential population within each of the SEL contour intervals shown in Exhibits 3-7 and 3-8, including cumulative subtotals.

17 Based on the FAA substitution list, the Lear 25 also represents the remaining Stage 1 aircraft operating at APF for emergency or other exempt purposes. There were approximately 15 such Stage 1 jet operations in 1999. The 2000/2005 NEM assumes that this minimal level of Stage 1 activity will continue over the forecast period.

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Using the NAA’s previously selected 85 dB SEL contour, the composite Lear 25 contour encompasses over 70,000 residents, compared to approximately 16,000 residents for the Stage 3 Lear 35 composite, clearly indicating the significantly greater impact associated with Stage 2 operations. While analysis of SEL contours was not the basis for any of the conclusions reached in this report, the analysis supports the study conclusions regarding the effects of alternate restrictions.

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3-7 Composite Sound Exposure Level (SEL) Contours, 80 dB to 110 dB, for One Lear 25 Departure off of Each Runway End

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3-8 Composite Sound Exposure Level (SEL) Contours, 80 dB to 110 dB, for One Lear 35 Departure off of Each Runway End

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3.2.4 Noise Complaints Noise complaint statistics support the significantly greater impact of Stage 2 operations, compared to Stage 3 operations or to propeller-driven aircraft operations. Analysis of the 1999 noise complaints reveals that Stage 2 jet operations were far more likely to cause noise complaints than either Stage 3 jet or propeller operations. Moreover, Stage 2 operations resulted in multiple noise complaints at a far greater rate than Stage 3 or propeller operations. While complaint analyses are not normally considered a scientific basis for evaluating noise impacts because of their highly subjective nature, they are a valid indication of annoyance. Multiple noise complaints associated with a single operation are an even stronger indication, since they indicate that the noise level was loud enough to incite more than one person to call the airport. Exhibit 3-9 presents a summary of 1999 single and multiple complaints by major aircraft type category, and time of day. As a basis for comparison, the table indicates the approximate number of complaints per operation, the approximate number of operations in 1999, and the percentages of complaints and operations associated with each aircraft type and time of day combination.

3-9 Summary of Calendar Year 1999 Noise Complaints

Number of Operations Causing: Time of Day (Day is 7 a.m. Approximate Approximate to 10 p.m., Three or Total Complaints Approximate Percent of Aircraft Night is 10 Single Two More Complaints Per 1999 Percent of 1999 Type p.m. to 7 a.m.) Complaint Complaints Complaints (Note) Operation Operations Complaints Operations Day 6 8 8 62 8.48 7 3.28% 0.01% Stage 1 Jet Night 2 0 3 17 2.32 7 0.90% 0.01% Day 309 55 49 663 0.80 832 35.16% 0.66% Stage 2 Jet Night 17 6 6 59 2.02 29 3.12% 0.02% Day 239 16 6 301 0.02 12,987 15.95% 10.30% Stage 3 Jet Night 67 13 5 118 0.23 504 6.25% 0.40% Day 230 9 2 258 0.00 109,690 13.67% 86.97% Non-Jet Night 85 9 3 118 0.06 2,073 6.25% 1.64% Other/General 291 0 0 291 n.a. n.a. 15.42% n.a. Number of complaints 1246 232 409 1887

Note: Assumes overall average of approximately five complaints per operation for "three or more complaints" category applies to every aircraft type.

Source: (1) NAA Records; (2) MCG and HMMH analyses

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Review of this table reveals the following major conclusions: T Stage 2 operations were the basis for approximately 38 percent of all noise complaints in 1999, yet they represented less than one percent of all activity. The percentage of noise complaints associated with Stage 2 operations was more than 50 times the percentage of operations conducted in Stage 2 aircraft. T The rate of complaints per Stage 2 operation was more than 25 times the rate per Stage 3 operation and approximately 250 times the rate per propeller-driven operation. T The Stage 2 operations were over 50 times more likely to cause multiple noise complaints than Stage 3 operations and over 800 times more likely than propeller operations. T Stage 2 operations were over 75 times more likely to cause three or more noise complaints than Stage 3 operations and over 1,400 times more likely than propeller operations.

These statistics provide clear evidence that Stage 2 operations are much more likely to annoy residents than Stage 3 operations.

3.3 ADDITIONAL NOISE COMPATIBILITY ALTERNATIVES The existing airport operations result in cumulative and single event noise exposure and complaints that demonstrate that the elements of the existing noise compatibility program do not achieve the NAA’s land use compatibility goal. Therefore, the NAA directed its staff and the consulting team to consider further use restrictions to address remaining noise impacts, including the following: Alternative 1: Night (10 p.m. - 7 a.m.) Restriction of Stage 2 Jet Aircraft Operations Alternative 2: 24-hour Restriction on Stage 2 Jet Aircraft Operations Alternative 3: Night (10 p.m. - 7 a.m.) Restriction of All Operations

Following sections discuss the analysis of the economic impact and noise benefits of these three alternatives.

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4 BENEFIT-COST ANALYSIS METHODOLOGY

xhibit 4-1 summarizes the key steps involved in benefit-cost analysis. The base case includes the noise abatement programs in effect at APF today, such as the EStage 1 restriction, the preferential runway program, the voluntary night curfew and education efforts targeted at the pilot community by the Noise Officer, but does not include any new use restrictions. Building on the base case, detailed operations forecasts reflect the three alternative restrictions. Each of these forecast scenarios holds all factors constant except the proposed restriction under study so as to highlight the incremental changes associated with each restriction. By estimating the differences between the base case and the alternatives, we have estimated the likely noise-related benefits and economic costs. Based on the benefit-cost analysis, we recommend the 24-hour restriction of Stage 2 jet aircraft operations. The methodology used in this study follows FAA published guidelines for benefit-cost analyses and standard industry practice as established in numerous studies as well as public finance reference texts.18

4-1 Benefit-Cost Analysis Methodology

EstimateEstimate BenefitsBenefits of of AlternativesAlternatives

Define Forecast BaseBase Define Forecast ResponsesResponses to to OperationsOperations CaseCase Alternative Under Forecast Alternative Under Forecast MeasuresMeasures AlternativesAlternatives

EstimateEstimate CostsCosts of of AlternativesAlternatives

18 The FAA set forth guidelines most recently in Office of Aviation Policy and Plans, FAA Airport Benefit-Cost Analysis Guidance (Washington, FAA, 1999) and FAA, Economic Analysis of Investment and Regulatory Decisions – Revised Guide (Washington, FAA-APO, 1998). Public finance reference books are in agreement on the fundamentals of benefit-cost analysis; this study referred to Rosen, Public Finance, Fourth Edition, (Boston, Irwin/McGraw-Hill, 1995), one example.

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5 AIRPORT ACTIVITY WITH NO NEW RESTRICTIONS

he base case scenario under this Part 161 study draws on activity forecasts that the City of Naples Airport Authority released for comment on December 2, 1999 as Tpart of the Naples Municipal Airport Part 150 NEM Update. In preparing this forecast, we examined in detail a number of factors that affect APF, including local and national trends in general aviation, real estate developments, and flight school activities. To reach detailed fleet mix and time-of-day figures, we examined a sample of air traffic control data and the APF night logs, the most detailed data available regarding the type of operations that take place at APF. Like other primarily general aviation airports, APF does not have published schedules of aircraft operations or other detailed records of aircraft arrival and departure times. By studying the air traffic control records and night logs, we were able to produce the most comprehensive understanding to date of the fleet mix at APF, along with precise estimates of daytime versus nighttime usage. Since the forecast was submitted for comment in December 1999, we do not believe there have been any material changes in the aviation climate in the Naples area that would affect its validity. The exhibits that follow show base forecasts of average daily operations at APF by aircraft type and time of day in 2000 and 2005. All operations forecasts in this report follow standard FAA practice: each arrival or departure is one operation; touch-and-gos are two. Night operations include all activity between 10 p.m. and 7 a.m. Aircraft types have been grouped together according to FAA-defined INM substitutes as discussed in Section 3.2.3. Exhibit 5-1 shows the base case operations forecast for APF in 2000. Exhibit 5-2 shows the base case forecast for 2005.

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5-1 2000 Average Daily Operations With No New Restrictions

Departures Arrivals

Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.84 0.03 0.84 0.03 1.73 GIIB Gulfstream II 0.30 0.01 0.30 0.01 0.63 Jet Stage 2 Total Stage 2 1.14 0.04 1.14 0.04 0.00 2.36

LEAR35 Gates Learjet 35 8.42 0.33 8.42 0.33 17.49 MU3001 Mitsubishi Diamond 300 3.48 0.13 3.48 0.13 7.24 CIT3 Cessna Citation III 1.61 0.06 1.61 0.06 3.34 CNA500 Cessna Citation 500 1.58 0.06 1.58 0.06 3.29 CL601 Canadair Challenger 601 0.78 0.03 0.78 0.03 1.62 CL600 Canadair Challenger 600 0.40 0.02 0.40 0.02 0.83 Stage 3 Jet IA1125 Israel Astra 1125 Westwind 0.76 0.03 0.76 0.03 1.58 GIV Gulfstream IV 0.75 0.03 0.75 0.03 1.57 Total Stage 3 17.79 0.69 17.79 0.69 0.00 36.95

Total Jets 18.94 0.74 18.94 0.74 0.00 39.35

Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 8.01 0.61 8.01 0.61 17.23 Twin Turboprop Intermediate Weight Saab 340 4.26 0.32 4.26 0.32 9.17 Small 2-Engine Turboprop Cessna Conquest 441 0.78 0.06 0.78 0.06 1.68 Total Turboprop 13.05 0.99 13.05 0.99 0.00 28.08

BEC58P Beech B58 48.09 0.92 48.09 0.92 20.42 138.88 Single Engine Piston GASEPF Propeller, Fixed Pitch 27.42 0.53 27.42 0.53 11.64 79.17 Single Engine Piston

PistonGASEPV Turboprop Propeller, Variable Pitch 19.91 0.38 19.91 0.38 8.45 57.50 DC-3 Douglas DC3 1.31 0.02 1.31 0.02 2.65 Total Piston 96.73 1.85 96.73 1.85 40.52 278.19

Total Nonjet 109.78 2.84 109.78 2.84 40.52 306.28

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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5-2 2005 Average Daily Operations With No New Restrictions

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.57 0.02 0.57 0.02 1.18 GIIB Gulfstream II 0.21 0.01 0.21 0.01 0.45 Jet

Stage 2 Total Stage 2 0.78 0.03 0.78 0.03 0.00 1.63

LEAR35 Gates Learjet 35 12.64 0.51 12.64 0.51 26.29 MU3001 Mitsubishi Diamond 300 5.13 0.21 5.13 0.21 10.66 CIT3 Cessna Citation III 2.62 0.11 2.62 0.11 5.46 CNA500 Cessna Citation 500 2.33 0.09 2.33 0.09 4.84

Stage 3 Jet CL601 Canadair Challenger 601 1.15 0.05 1.15 0.05 2.39 CL600 Canadair Challenger 600 0.71 0.03 0.71 0.03 1.48 IA1125 Israel Astra 1125 Westwind 1.12 0.05 1.12 0.05 2.33 GIV Gulfstream IV 1.11 0.04 1.11 0.04 2.31 Total Stage 3 26.80 1.08 26.80 1.08 0.00 55.77

Total Jets 27.59 1.12 27.59 1.12 0.00 57.44

Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 11.34 0.86 11.34 0.86 24.40 Twin Turboprop Intermediate Weight Saab 340 5.41 0.41 5.41 0.41 11.64 Small 2-Engine Turboprop Cessna Conquest 441 1.60 0.12 1.60 0.12 3.45 Total Turboprop 18.35 1.39 18.35 1.39 0.00 39.50

BEC58P Beech B58 58.93 1.14 58.93 1.14 26.10 172.35 Single Engine Piston GASEPF Propeller, Fixed Pitch 35.11 0.68 35.11 0.68 15.55 102.68 Single Engine Piston

PistonGASEPV Turboprop Propeller, Variable Pitch 24.85 0.48 24.85 0.48 11.00 72.67 DC-3 Douglas DC3 0.00 0.00 0.00 0.00 0.00 0.00 Total Piston 118.89 2.31 118.89 2.31 52.65 347.70

Total Nonjet 137.24 3.70 137.24 3.70 52.65 387.20

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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Under the base case, 14,363 jet operations will take place at APF in 2000, increasing to 20,963 in 2005. Of these jet operations, only six percent will be conducted by Stage 2 aircraft in 2000, falling to less than three percent in 2005. Exhibit 5-3 summarizes the annual jet operations expected under the base case in 2000 and 2005.

5-3 Annual Jet Operations by Noise Stage With No New Restrictions

Average Annual 2000 2005 Growth

Stage 1 14 14 0.0% Stage 2 864 594 -7.2% Stage 3 13,485 20,355 8.6%

Total 14,363 20,963 7.9%

Source: SH&E

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6 OPERATIONAL IMPACTS OF PROPOSED RESTRICTIONS

ompared to the base case activity forecast, each of the proposed restrictions will lead some operators at the airport to change their usage patterns, generating a Cdifferent operational profile for the airport. Activity forecasts for APF take into account how operators would change their usage patterns under each restriction scenario.

6.1 STAGE 2 USER SURVEY We believe that the most reliable way to determine the impacts of the proposed restrictions on operator behavior is to survey the operators directly. City of Naples Airport Authority staff conducted an in-depth telephone survey of owners and operators of Stage 2 aircraft believed to have operated at Naples Municipal Airport in 1999. By asking airport users how they would respond to the proposed restrictions, we developed an understanding of how the restrictions affect overall activity levels at the airport. Our analysis of these survey responses underlies the detailed operations forecasts developed for each restriction scenario. Survey responses also established parameters of the costs that would be imposed on affected users under the three scenarios, allowing this Part 161 study to be carried out accurately and realistically.

6.1.1 Identifying and Contacting Affected Users To identify owners and operators of Stage 2 aircraft that have operated at APF, we purchased FAA Aircraft Situation Display (ASD) data from BridgeNet Consulting Services International. A stream of processed air traffic control messages, ASD contains the most accurate record available of instrument flight rule (IFR) operations at a given US airport. Although there is no detailed record of visual flight rule (VFR) operations at any airport, it would be highly unusual for a jet aircraft to operate under a VFR flight plan. From the ASD feed, BridgeNet captured substantially all IFR operations at APF from April 1999 through February 2000 and supplied a list of the unique registration numbers of aircraft believed to be Stage 2, most of which were listed as Lear 24, Lear 25, Gulfstream II and Gulfstream III. BridgeNet linked this data set with the National Aircraft Registry to provide aircraft owners’ names and addresses. The ASD data identified 174 likely Stage 2 aircraft that operated at APF in the study period. Among these aircraft, 33 were flown under blocked codes, meaning

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that the operators asked the FAA not to disclose their tail numbers in data released to the public. Since these operators excluded themselves from public records, we were not able to include them in our survey. We expect, however, that their patterns of behavior would be similar to those of other operators surveyed. An additional 13 operators were registered as lifeguard (medivac) operations. The remaining 128 operators were included in our survey base, as shown in Exhibit 6-1.

6-1 Stage 2 Operator Survey Base

Identified Stage 2 Non Medical Operators Confirmed Stage 2 Operators Flights Contacted Survey Participants

Confirmed 51 Stage 2 Operators Contacted 67 Did Not Confirm 51 128 Stage 2 141 Could Not Reach 67 After 3 Phone Attempts 128 Lifeguard Flights

141 Blocked Codes

174

Source: SH&E

Using airport and other public records, NAA staff located telephone numbers and contact information for the owners and operators of these aircraft. Over a period of two weeks, from March 13 through 24, 2000, NAA staff attempted to contact every owner or operator on the list, making at least three attempts for each record. Owners and operators of more than one Stage 2 aircraft were surveyed for all of their aircraft that had operated at APF during the preceding 12 months. Out of the 145 operators in the survey base, we made contact with 67, or 52 percent. Fifty-

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one of the operators confirmed that they had operated a Stage 2 jet at APF in the preceding 12 months and were willing to participate in the survey. The 51 operators contacted said they made 336 Stage 2 operations at Naples during the preceding 12 months, as shown in Exhibit 6-2. These operations make up 38.9 percent of the total yearly Stage 2 operations that take place at Naples, a high sample rate for survey methodology. Since our goal is to understand how operations at the airport would change under the proposed restrictions, we have weighted survey responses in proportion to the number of operations each operator made at Naples in the past year. That is, the responses of an operator who landed eight times at Naples last year have been given twice as much weight as the responses of an operator who landed only four times.

6-2 Operations Represented by Surveyed Stage 2 Operators at Naples

SurveSurveyyeded StaStaggee 2 2 OperatorsOperators RepresentRepresent 51 336 38.9% Operators Operations 38.9% ofof the the Sta Staggee 2 2 Operations Operations ConductedConducted at at NaplesNaples in in thethe PastPast Year. Year.

Surveyed Stage 2 Operators

Operations Conducted at Naples in 12 Months

Source: SH&E

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6.1.2 Survey Significance The unusually comprehensive nature of this survey allows conclusions to be drawn with confidence. Margins of error on the survey data averaged 3.18 percentage points and were in no instance higher than 4.10 percentage points. The availability of an estimate of the total number of operations conducted annually allows margins of error from the Stage 2 survey to be defined in a narrow band using a finite population correction factor. These margins of error define a 95 percent confidence interval bracketing the survey estimates, meaning that 95 out of 100 intervals drawn in this manner would include the true responses of the entire population.

6.1.3 Survey Contents The survey, attached as Appendix E, contained three parts totaling 26 questions and took approximately 12 minutes to answer over the phone. In the first part, operators were asked whether they had been correctly identified and what other aircraft they operated at Naples so that operators of more than one Stage 2 aircraft at Naples could be surveyed for all their aircraft in one phone call. In the second part, operators were asked about their usage patterns at Naples – how many operations they conducted at APF in the past twelve months, what airport they generally listed as an alternate, and how they would respond to each of the alternatives. Faced with a 24-hour ban on Stage 2 operations at APF, they were asked if they would substitute a Stage 3 jet, fly into another airport or cancel their flight to southwest Florida. Depending on the option they chose, they were then asked for additional details about how that course of action would affect them. Then operators were asked if they would take the same action faced with a nighttime only ban on Stage 2 operations at APF, or whether they would reschedule their flight into daytime. Operators were also asked questions about where and how long their passengers and crew stay in the Naples area. In the third section of the survey, respondents were given the opportunity to make comments and ask questions. Comments received on the survey indicate negative feeling among operators who would be affected by the proposed restrictions. Many respondents talked about inconvenience to themselves or their customers (“very inconvenient,” “a great deal of inconvenience”). Five respondents suggested they would file a lawsuit or contact their congressperson if a restriction were imposed. One respondent said he would sell his home in the Naples area. Exhibit 6-3 lists several of the sample comments received.

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6-3 Comments Received on Stage 2 Operator Survey

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■ ´5DLVH KHOO DQG FDOO P\ FRQJUHVVPDQµ ■ ´:K\ DUH \RX GRLQJ LW" >VLF@ $UH WKH KLJK PRQH\ SHRSOH QRW KDSS\ ZLWK WKH ■ ´&DOO P\ FRQJUHVVPDQ >ZKR@ RZQV WZR DLUFUDIW" 7KH SHRSOH VKRXOGQ·W KDYH SLHFHV RI SURSHUW\ LQ 1DSOHVµ ERXJKW KRXVHV VR FORVH WR WKH DLUSRUWµ

■ ´/LWLJDWLRQ RU PRYH >P\@ FRPSDQ\µ ■ ´,V WKH $LUSRUW $XWKRULW\ VR FORVHG PLQGHG WKDW WKH\ GRQ·W ZDQW QHZ EXVLQHVV LQ WKHUH"

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Source: Stage 2 Operator Survey Conducted March 13-24, 2000.

6.2 ACTIVITY FORECASTS UNDER RESTRICTION SCENARIOS To reach activity forecasts under the three restriction scenarios, we began with the base case forecast and used survey responses to estimate likely changes in usage patterns among user groups.

6.2.1 General Assumptions Certain assumptions are common to models of all three restriction scenarios: 1. Exemptions from the proposed restrictions will be permitted for the safety and welfare of the general public as they are under the existing ban on Stage 1 jet aircraft. Following detailed observations of exempt operations under the Stage 1 jet ban, we assume that the vast majority of these operations are lifeguard flights, which are forecasted according to their representation in the ASD data.

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A small number of exempt jet operations will take place for other reasons, and a small number of exempt lifeguard flights will take place in turboprop aircraft. Other exempt flights are conducted by the Collier Mosquito Control District, in DC-3 aircraft in 2000 and in small turboprop aircraft in 2005. 2. Substitution of Stage 2 aircraft into Stage 3 aircraft will take place with similar-sized models – Lear 35 (Stage 3) for Lear 25 (Stage 2) and GIV (Stage 3) for GIIB (Stage 2). Although it is possible that owners and operators choosing to substitute Stage 3 aircraft will take the opportunity to upgrade further, the economic impact of the restrictions is limited to that part of the upgrade that can be attributed directly to the new restriction. In fact, many substitutions are likely to take place within a single owner/operator’s existing fleet: 76.5 percent of respondents who said they would substitute a Stage 3 aircraft said that they already have Stage 3 aircraft in their fleet. 3. Survey responses have been analyzed in direct proportion to operations conducted, consistent with operations forecasts.

6.2.2 Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Jet Aircraft Operations Faced with a night restriction of Stage 2 aircraft operations, most (62 percent) of surveyed operators said they would reschedule their operations to daytime. Another five percent said they would substitute a Stage 3 aircraft. Exhibit 6-4 shows the survey responses used to forecast the night restriction of Stage 2 aircraft operations. In the activity forecasts, survey proportions are scaled down to account for exempt operations.

6-4 Survey Responses to Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Jet Aircraft Operations

Percent of Stage 2 Action Jet Operations Reschedule Operation 62% Cancel Flight 12% Use Alternate Airport 22% Substitute Stage 3 Aircraft 4% Total 100%

Source: SH&E

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Exhibits 6-5 and 6-6 show the 2000 and 2005 forecast daily aircraft operations by time of day and aircraft type under the proposed night restriction of Stage 2 jet aircraft operations. Because so many Stage 2 operations are rescheduled to daytime under this scenario, annual Stage 2 operations are only reduced to 850 in 2000 and 584 in 2005, less than a two percent reduction over the base case.

6-5 2000 Average Daily Operations Under Night (10 p.m.- 7 a.m.) Restriction of Stage 2 Aircraft Operations

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.85 0.00 0.85 0.00 1.71 GIIB Gulfstream II 0.31 0.00 0.31 0.00 0.62 Jet

Stage 2 Total Stage 2 1.16 0.00 1.16 0.00 0.00 2.33

LEAR35 Gates Learjet 35 8.42 0.33 8.42 0.33 17.49 MU3001 Mitsubishi Diamond 300 3.48 0.13 3.48 0.13 7.24 CIT3 Cessna Citation III 1.61 0.06 1.61 0.06 3.34 CNA500 Cessna Citation 500 1.58 0.06 1.58 0.06 3.29 CL601 Canadair Challenger 601 0.78 0.03 0.78 0.03 1.62 CL600 Canadair Challenger 600 0.40 0.02 0.40 0.02 0.83 Stage 3 Jet IA1125 Israel Astra 1125 Westwind 0.76 0.03 0.76 0.03 1.58 GIV Gulfstream IV 0.75 0.03 0.75 0.03 1.57 Total Stage 3 17.79 0.69 17.79 0.69 0.00 36.95

Total Jets 18.96 0.70 18.96 0.70 0.00 39.32 Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 8.01 0.61 8.01 0.61 17.23 Twin Turboprop Intermediate Weight Saab 340 4.26 0.32 4.26 0.32 9.17 Small 2-Engine Turboprop Cessna Conquest 441 0.78 0.06 0.78 0.06 1.68 Total Turboprop 13.05 0.99 13.05 0.99 0.00 28.08

BEC58P Beech B58 48.09 0.92 48.09 0.92 20.42 138.88 Single Engine Piston GASEPF Propeller, Fixed Pitch 27.42 0.53 27.42 0.53 11.64 79.17 Single Engine Piston

PistonGASEPV Turboprop Propeller, Variable Pitch 19.91 0.38 19.91 0.38 8.45 57.50 DC-3 Douglas DC3 1.31 0.02 1.31 0.02 2.65 Total Piston 96.73 1.85 96.73 1.85 40.52 278.19

Total Nonjet 109.78 2.84 109.78 2.84 40.52 306.28

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005. Source: SH&E

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6-6 2005 Average Daily Operations Under Night (10 p.m.- 7 a.m.) Restriction of Stage 2 Aircraft Operations

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.58 0.00 0.58 0.00 1.16 GIIB Gulfstream II 0.22 0.00 0.22 0.00 0.44 Jet

Stage 2 Total Stage 2 0.80 0.00 0.80 0.00 0.00 1.60

LEAR35 Gates Learjet 35 12.64 0.51 12.64 0.51 26.30 MU3001 Mitsubishi Diamond 300 5.13 0.21 5.13 0.21 10.66 CIT3 Cessna Citation III 2.62 0.11 2.62 0.11 5.46 CNA500 Cessna Citation 500 2.33 0.09 2.33 0.09 4.84 CL601 Canadair Challenger 601 1.15 0.05 1.15 0.05 2.39 Stage 3 Jet CL600 Canadair Challenger 600 0.71 0.03 0.71 0.03 1.48 IA1125 Israel Astra 1125 Westwind 1.12 0.05 1.12 0.05 2.33 GIV Gulfstream IV 1.11 0.05 1.11 0.05 2.31 Total Stage 3 26.80 1.08 26.80 1.08 0.00 55.77

Total Jets 27.61 1.10 27.61 1.10 0.00 57.42 Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 11.34 0.86 11.34 0.86 24.40 Twin Turboprop Intermediate Weight Saab 340 5.41 0.41 5.41 0.41 11.64 Small 2-Engine Turboprop Cessna Conquest 441 1.60 0.12 1.60 0.12 3.45 Total Turboprop 18.35 1.39 18.35 1.39 39.50

BEC58P Beech B58 58.93 1.14 58.93 1.14 26.10 172.35 Single Engine Piston GASEPF Propeller, Fixed Pitch 35.11 0.68 35.11 0.68 15.55 102.68 Single Engine Piston Piston Turboprop GASEPV Propeller, Variable Pitch 24.85 0.48 24.85 0.48 11.00 72.67 Total Piston 118.89 2.31 118.89 2.31 52.65 347.70

Total Nonjet 137.24 3.70 137.24 3.70 52.65 387.20

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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6.2.3 24-Hour Restriction of Stage 2 Aircraft Operations Under the proposed 24-hour restriction of Stage 2 aircraft operations, operators did not have the option of rescheduling to avoid the restriction. In this case, 66 percent of operators surveyed said they would use an alternate airport; 14 percent said they would cancel their trip. Exhibit 6-7 shows the survey responses used to forecast the proposed 24-hour restriction of Stage 2 aircraft operations.

6-7 Survey Responses to 24-Hour Restriction of Stage 2 Jet Aircraft Operations

Percent of Stage 2 Action Jet Operations

Cancel Flight 14% Use Alternate Airport 66% Substitute Stage 3 Aircraft 20% Total 100%

Source: SH&E

Under this scenario there is a significant decrease in overall Stage 2 operations at APF with a small increase in Stage 3 operations. The forecast shows 66 annual Stage 2 operations in 2000, down from 864 in the base case; and 44 annual operations in 2005, down from 594 in the base case. Exhibits 6-8 and 6-9 show complete activity forecasts for 2000 and 2005 under this scenario.

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6-8 2000 Average Daily Operations Under 24-Hour Restriction of Stage 2 Aircraft Operations

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.06 0.00 0.06 0.00 0.13 GIIB Gulfstream II 0.02 0.00 0.02 0.00 0.05 Jet

Stage 2 Total Stage 2 0.08 0.00 0.08 0.00 0.00 0.18

LEAR35 Gates Learjet 35 8.57 0.33 8.57 0.33 17.81 MU3001 Mitsubishi Diamond 300 3.48 0.13 3.48 0.13 7.24 CIT3 Cessna Citation III 1.61 0.06 1.61 0.06 3.34 CNA500 Cessna Citation 500 1.58 0.06 1.58 0.06 3.29 CL601 Canadair Challenger 601 0.78 0.03 0.78 0.03 1.62 CL600 Canadair Challenger 600 0.40 0.02 0.40 0.02 0.83 Stage 3 Jet IA1125 Israel Astra 1125 Westwind 0.76 0.03 0.76 0.03 1.58 GIV Gulfstream IV 0.81 0.03 0.81 0.03 1.68 Total Stage 3 18.00 0.70 18.00 0.70 0.00 37.39

Total Jets 18.10 0.71 18.10 0.71 0.00 37.61 Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 8.01 0.61 8.01 0.61 17.23 Twin Turboprop Intermediate Weight Saab 340 4.26 0.32 4.26 0.32 9.17 Small 2-Engine Turboprop Cessna Conquest 441 0.78 0.06 0.78 0.06 1.68 Total Turboprop 13.05 0.99 13.05 0.99 0.00 28.08

BEC58P Beech B58 48.09 0.92 48.09 0.92 20.42 138.88 Single Engine Piston GASEPF Propeller, Fixed Pitch 27.42 0.53 27.42 0.53 11.64 79.17 Single Engine Piston

PistonGASEPV Turboprop Propeller, Variable Pitch 19.91 0.38 19.91 0.38 8.45 57.50 DC-3 Douglas DC3 1.31 0.02 1.31 0.02 2.65 Total Piston 96.73 1.85 96.73 1.85 40.52 278.19

Total Nonjet 109.78 2.84 109.78 2.84 40.52 306.28

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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6-9 2005 Average Daily Operations Under 24-Hour Restriction of Stage 2 Aircraft Operations

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.04 0.00 0.04 0.00 0.09 GIIB Gulfstream II 0.02 0.00 0.02 0.00 0.03 Jet Stage 2 Total Stage 2 0.06 0.00 0.06 0.00 0.00 0.12

LEAR35 Gates Learjet 35 12.74 0.51 12.74 0.51 26.52 MU3001 Mitsubishi Diamond 300 5.13 0.21 5.13 0.21 10.66 CIT3 Cessna Citation III 2.62 0.11 2.62 0.11 5.46 CNA500 Cessna Citation 500 2.33 0.09 2.33 0.09 4.84 CL601 Canadair Challenger 601 1.15 0.05 1.15 0.05 2.39 Stage 3 Jet CL600 Canadair Challenger 600 0.71 0.03 0.71 0.03 1.48 IA1125 Israel Astra 1125 Westwind 1.12 0.05 1.12 0.05 2.33 GIV Gulfstream IV 1.15 0.05 1.15 0.05 2.39 Total Stage 3 26.95 1.09 26.95 1.09 0.00 56.07

Total Jets 27.02 1.10 27.02 1.10 0.00 56.23 Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 11.34 0.86 11.34 0.86 24.40 Twin Turboprop Intermediate Weight Saab 340 5.41 0.41 5.41 0.41 11.64 Small 2-Engine Turboprop Cessna Conquest 441 1.60 0.12 1.60 0.12 3.45 Total Turboprop 18.35 1.39 18.35 1.39 39.50

BEC58P Beech B58 58.93 1.14 58.93 1.14 26.10 172.35 Single Engine Piston GASEPF Propeller, Fixed Pitch 35.11 0.68 35.11 0.68 15.55 102.68 Single Engine Piston Piston Turboprop GASEPV Propeller, Variable Pitch 24.85 0.48 24.85 0.48 11.00 72.67 Total Piston 118.89 2.31 118.89 2.31 52.65 347.70

Total Nonjet 137.24 3.70 137.24 3.70 52.65 387.20

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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6.2.4 Night (10 p.m. – 7 a.m.) Restriction of All Operations The night restriction of all operations assumes that Stage 3 jet operators are similar to Stage 2 jet operators, and follow the same patterns as the former indicated in their survey when asked about a nighttime only ban. In addition, it assumes that Stage 2 operators do not substitute into Stage 3 aircraft under this ban, since the two are equally affected. Exhibit 6-10 shows the survey responses adjusted to account for no substitution.

6-10 Adjusted Survey Responses for Night (10 p.m. – 7 a.m.) Restriction of All Operations

Percent of Jet Operations Action Nighttime Only Reschedule Flight 62% Cancel Flight 13% Use Alternate Airport 25% Total 100%

Source: SH&E

Most turboprop flights at APF are scheduled commuter airlines. For the forecast, turboprop and piston operation are assumed to be cancelled – the turboprop airline flights because they are timed to meet connecting schedule banks; the piston flights because many nighttime piston operations are for training, which would need to take place elsewhere. Exhibits 6-11 and 6-12 show the complete activity forecasts at APF under the nighttime only ban on all aircraft. Although overall jet operations decline less than two percent under this scenario, the airport is effectively silenced at night.

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6-11 2000 Average Daily Operations Under Night (10 p.m. – 7 a.m.) Restriction of All Operations

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.85 0.00 0.85 0.00 1.71 GIIB Gulfstream II 0.31 0.00 0.31 0.00 0.62 Jet Stage 2 Total Stage 2 1.16 0.00 1.16 0.00 0.00 2.33

LEAR35 Gates Learjet 35 8.60 0.02 8.60 0.02 17.26 MU3001 Mitsubishi Diamond 300 3.56 0.01 3.56 0.01 7.14 CIT3 Cessna Citation III 1.64 0.00 1.64 0.00 3.30 CNA500 Cessna Citation 500 1.62 0.00 1.62 0.00 3.24 CL601 Canadair Challenger 601 0.80 0.00 0.80 0.00 1.60 CL600 Canadair Challenger 600 0.41 0.00 0.41 0.00 0.82 Stage 3 Jet IA1125 Israel Astra 1125 Westwind 0.78 0.00 0.78 0.00 1.56 GIV Gulfstream IV 0.77 0.00 0.77 0.00 1.55 Total Stage 3 18.18 0.05 18.18 0.05 0.00 36.46

Total Jets 19.35 0.06 19.35 0.06 0.00 38.84 Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 8.01 0.00 8.01 0.00 16.02 Twin Turboprop Intermediate Weight Saab 340 4.26 0.00 4.26 0.00 8.53 Small 2-Engine Turboprop Cessna Conquest 441 0.78 0.00 0.78 0.00 1.56 Total Turboprop 13.05 0.00 13.05 0.00 0.00 26.11

BEC58P Beech B58 48.09 0.00 48.09 0.00 20.42 137.03 Single Engine Piston GASEPF Propeller, Fixed Pitch 27.42 0.00 27.42 0.00 11.64 78.12 Single Engine Piston

PistonGASEPV Turboprop Propeller, Variable Pitch 19.91 0.00 19.91 0.00 8.45 56.73 DC-3 Douglas DC3 1.31 0.02 1.31 0.02 2.65 Total Piston 96.73 0.02 96.73 0.02 40.52 274.54

Total Nonjet 109.78 0.02 109.78 0.02 40.52 300.64

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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6-12 2005 Average Daily Operations Under Night (10 p.m. – 7 a.m.) Restriction of All Operations

Departures Arrivals Touch & Aircraft Category INM Type Example Aircraft Type Day Night Day Night Gos1/ Total

LEAR25-1 Gates Learjet 23 0.01 0.01 0.01 0.01 0.04 Jet

Stage 1 Total Stage 1 0.01 0.01 0.01 0.01 0.00 0.04

LEAR25 Gates Learjet 25 0.58 0.00 0.58 0.00 1.16 GIIB Gulfstream II 0.22 0.00 0.22 0.00 0.44 Jet

Stage 2 Total Stage 2 0.80 0.00 0.80 0.00 0.00 1.60

LEAR35 Gates Learjet 35 12.93 0.04 12.93 0.04 25.94 MU3001 Mitsubishi Diamond 300 5.24 0.02 5.24 0.02 10.52 CIT3 Cessna Citation III 2.68 0.01 2.68 0.01 5.38 CNA500 Cessna Citation 500 2.38 0.01 2.38 0.01 4.78 CL601 Canadair Challenger 601 1.17 0.00 1.17 0.00 2.36 Stage 3 Jet CL600 Canadair Challenger 600 0.73 0.00 0.73 0.00 1.46 IA1125 Israel Astra 1125 Westwind 1.15 0.00 1.15 0.00 2.30 GIV Gulfstream IV 1.13 0.00 1.13 0.00 2.28 Total Stage 3 27.42 0.08 27.42 0.08 0.00 55.01

Total Jets 28.23 0.09 28.23 0.09 0.00 56.65 Twin Turboprop Transport <15,000 pounds Dehavilland Twin Otter 11.34 0.00 11.34 0.00 22.69 Twin Turboprop Intermediate Weight Saab 340 5.41 0.00 5.41 0.00 10.82 Small 2-Engine Turboprop Cessna Conquest 441 1.60 0.06 1.60 0.06 3.33 Total Turboprop 18.35 0.06 18.35 0.06 36.83

BEC58P Beech B58 58.93 0.00 58.93 0.00 26.10 170.06 Single Engine Piston GASEPF Propeller, Fixed Pitch 35.11 0.00 35.11 0.00 15.55 101.32 Single Engine Piston Piston Turboprop GASEPV Propeller, Variable Pitch 24.85 0.00 24.85 0.00 11.00 71.70 Total Piston 118.89 0.00 118.89 0.00 52.65 343.08

Total Nonjet 137.24 0.06 137.24 0.06 52.65 379.92

1/ Each touch-and-go counts as two operations. Note: 0.00 includes non-zero figures less than 0.005.

Source: SH&E

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7 DEVELOPMENT OF COST ESTIMATES

he following cost estimates focus on local impacts and costs that are directly related with the proposed restrictions, consistent with the local focus of the Tbenefit estimates.

7.1 COST ASSUMPTIONS Certain assumptions apply to all three cost estimates. Macroeconomic Assumptions: All calculations are in current dollars. There is no inflation and no attempt to account for fluctuations in prices of key inputs, including jet fuel. Likewise, estimates of retail prices for aircraft modifications, airport services, ground services and other inputs are based on the most currently available data as of May 2000, or on averages over a recent period. Aircraft Modeling Conventions: Calculations are based on FAA-defined INM substitutes, as discussed in Section 3. Jet aircraft are assumed to have two pilots and passenger capacity consistent with common configurations. Aircraft operate with a passenger load factor of 50 percent, based on values recommended in Economic Values for Evaluation of Federal Aviation Administration Investment and Regulatory Program.19 Aircraft operating costs are based on member surveys conducted by the National Business Aviation Association (NBAA). Aircraft charter revenue is based on a survey conducted by SH&E in May 2000 of 69 US charter service providers located within 1,500 miles of Naples.

7.2 COST CATEGORIES Direct costs result from six principal categories: 1. Using another airport. 2. Canceling a trip to southwest Florida. 3. Substituting a Stage 3 aircraft. 4. Rescheduling a flight from nighttime to day. 5. Lost revenue to airport fixed base operators (FBOs). 6. Increased operations at alternate airports.

19 FAA, 1998.

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The following section will explain how we estimated the costs in each category.

7.2.1 Costs of Using Another Airport The cost of using another airport includes four elements: passenger time getting to and from another airport; passenger transport costs to and from another airport; the value of pilot overnight stays that would have been in Naples but are now in Fort Myers or elsewhere; the slight savings resulting from a shorter average air trip (since most APF users fly in from the north and the alternate airports they use are on the way for them, they land a few minutes sooner). Passenger Drive Time. We calculated passenger drive time based on driving distances as reported by Mapquest to the weighted average of the alternate airports indicated in the operator survey. As a lower bound figure, we used the FAA’s recommended value of time of $34 per hour.20 Since users of general aviation jets may value their time well above average figures, however, we calculated an upper bound at ten times the FAA recommended value. Cost of Passenger Transport. We calculated passenger transport based on April 2000 rates to hire a Lincoln Town Car or equivalent from local limousine services operating at APF and at the alternate airports indicated. We assumed that limousines hold three passengers and that the passengers would give a 20 percent tip. Lost Pilot Stay in the Naples Area. Based on survey data, we assumed that 52 percent of pilots stay overnight when flying into and out of APF. Of these, 93 percent stay in a hotel for an average of 1.1 days. If operators fly into an alternate airport as a result of the proposed restrictions, the pilots will stay near the alternate airport, costing the Naples area lost tourism revenue from pilot overnights. We assumed that pilots stay one-to-a-room at the regional average rate of $148, as calculated by the Naples Tourism Alliance. Based on research performed by Walter Klages, head of the Klages Group Research Data Service and an expert on tourism economics in Southwest Florida, we have assumed that for every dollar Naples visitors spend on hotels, they spend an additional $0.49 on food, entertainment and transportation. Savings From Reduced Airtime. We believe that for most operators at APF, using an alternate airport will result in a slightly shorter flight time. We calculated the average airtime savings based on the weighted average air distance from the alternate airports to APF and calculated the operating cost savings based on operating cost data provided by the NBAA. In addition, we have deducted the

20 FAA, Economic Values for Evaluation of Federal Aviation Administration Investment and Regulatory Program (FAA, 1998).

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airtime savings from the time passengers spend getting from alternate airports to APF, using the same values for time noted above. Exhibits 7-1 and 7-2 show the daily cost associated with using alternate airports under each of the proposed restrictions. For each scenario, we have shown lower- and upper- bound estimated costs in 2000 and in 2005.

7-1 Estimated Annual Cost of Using Alternate Airports 2000

(in thousands of dollars)

Psgr Lost Pilot Airtime Psgr Drive Time Transport Stay Savings Total Net Costs

Night Restriction of $47 - $466 $61 $41 ($16) - ($32) $132 - $536 Stage 2 Operations 24-Hour Restriction of $137 - $1,368 $178 $120 ($47) - ($93) $388 - $1,573 Stage 2 Operations Night Restriction of All ($397) - $769 - $7,695 $1,003 $710 $2,085 - $8,756 Operations ($653)

Source: SH&E

7-2 Estimated Annual Cost of Using Alternate Airports 2005

(in thousands of dollars)

Psgr Lost Pilot Airtime Psgr Drive Time Transport Stay Savings Total Net Costs

Night Restriction of $32 - $322 $42 $28 ($11) - ($22) $91 - $370 Stage 2 Operations

24-Hour Restriction of $95 - $945 $123 $82 ($32) - ($64) $268 - $1,087 Stage 2 Operations Night Restriction of All ($588) - $1,122 - $11,216 $1,463 $1,036 $3,032 - $12,755 Operations ($961)

Note: Totals may not sum due to rounding. Source: SH&E

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7.2.2 Cost of Canceling a Trip to Southwest Florida The costs related to trips that are cancelled because of the proposed restrictions relate to both passengers and pilots. For passengers, we have made a distinction between those passengers who stay at private homes and those passengers who stay at hotels. We have based the proportions on responses to the survey of Stage 2 operators. Although passengers might save on aircraft operation costs for a trip that they do not take, we have assumed that passengers who cancel their trip to the Naples area travel somewhere else instead. Passengers Who Stay in Hotels. Based on survey data, we believe that 16 percent of jet passengers flying into Naples stay in hotels. Since business jet passengers are at the very top of the income bracket, we have conservatively estimated that these passengers stay in a standard room at the Ritz, the only five-star hotel in Naples, at $425 per night in season, averaging 1.5 persons per room. Based on survey data, we have estimated an average stay of 6.3 days per passenger. In addition, we have assumed as above that for every dollar visitors spend on lodging, they spend an additional $0.49 in the local economy. Passengers Who Stay in Private Homes. The remaining passengers stay in private homes. We have assumed that none of the proposed restrictions would lead these passengers to sell their homes, but recognize that these passengers spend money in the local economy just as do visitors who stay in hotels – $139 per passenger per day staying in the Naples area. Cancelled Pilot Stays. We have calculated lost tourism revenue from the pilots on cancelled trips using the same methodology as in the alternate airport costs: $148 per pilot day on hotels and $73 per pilot day on other tourism expenditures. Exhibits 7-3 and 7-4 show a summary of the daily revenue lost from cancelled trips under each of the proposed restrictions. The tables show our best single point estimate; since this analysis did not include any strikingly subjective valuations, we have not included upper and lower bounds.

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7-3 Estimated Annual Cost of Flight Cancellations 2000

(in thousands of dollars)

Psgr Hotel Psgr Home Lost Pilot Stay Stay Stay Total

Night Restriction of Stage 2 $192 $325 $41 $558 Operations

24-Hour Restriction of Stage $220 $373 $47 $640 2 Operations

Night Restriction of All $3,171 $5,373 $711 $9,256 Operations

Note: Totals may not sum due to rounding.

Source: SH&E

7-4 Estimated Annual Cost of Flight Cancellations 2005

(in thousands of dollars)

Psgr Hotel Psgr Home Lost Pilot Stay Stay Stay Total

Night Restriction of Stage 2 $133 $225 $28 $386 Operations

24-Hour Restriction of Stage $152 $258 $32 $442 2 Operations

Night Restriction of All $4,622 $7,832 $1,038 $13,492 Operations

Source: SH&E

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7.2.3 Cost of Substituting a Stage 3 Aircraft Under the proposed restrictions on Stage 2 jets, users have the option of substituting Stage 3 equipment to comply with the proposed regulation. Users who would choose to do so fall under three categories: those who substitute aircraft within their existing fleet, those who modify and recertificate their Stage 2 aircraft as Stage 3, and those who replace their Stage 2 aircraft with a Stage 3 aircraft. Substitution Within Fleet. Over three-quarters of the operators who said they would substitute a Stage 3 jet already operate Stage 3 jets in their fleets. We have assumed that for them substitution involves allocation of aircraft within their fleet and does not impose any costs beyond a minor loss of flexibility. We have not calculated any costs for these users. Aircraft Modification. Hushkits are currently available for most Stage 2 general aviation jets with the notable exception of the Gulfstream aircraft. A successful hushkit designer, George Ottendorf, reported to us that he expects to certificate and market a hushkit for Gulfstream aircraft beginning in summer 2000. We have assumed that this and other hushkits on the market remain available at current prices during the implementation of any Stage 2 jet restriction. Hushkit costs including installation are shown in Exhibit 7-5. We have further assumed that the hushkits do not impose any significant operating penalty.21

7-5 Hushkit Equipment Costs for General Aviation Jets

(in thousands of dollars)

Approximate Installed Aircraft Hushkit Supplier Hushkit Cost Availability Dassault Falcon 20 Noise Reduction Engineering $200 Current Dassault Falcon 20 (re-engining) Allied Signal $3,780 Current Gulfstream GII, GIIB, GIII Really Quiet LLC $1,800 Summer 2000 Learjet 20-Series Ottendorf Aviation $130 Current Sabreliner 75A, -80 Noise Reduction Engineering $200 Current

Source: Armando Tovar, phone interviews with hushkit suppliers.

21 Since most hushkits for general aviation jets remove or replace the thrust reverser, there is reason to believe that they may even offer modest savings in maintenance. We have not attempted to quantify this benefit.

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According to the manufacturers, modifications can be installed on most general aviation jets in approximately seven days; installation for the Gulfstream hushkits is expected to take 28 days. Since these installations are likely to take place during scheduled heavy maintenance, it is reasonable to assume that there is no cost associated with aircraft downtime during installation, an assumption we have made in our lower bound scenario. Should the installation be completed outside the regular maintenance schedule, it would remove the aircraft from service for seven or 28 days, depending on the aircraft. In our upper bound scenario, we have modeled the cost of this time as the net operating revenue that would ordinarily accrue if the aircraft were operated in charter service. According to member survey data provided by the NBAA, we have assumed that Lear 25 models are operated an average of 0.64 hours per day and that Gulfstreams are operated an average of 1.30 hours per day. Exhibit 7-6 shows estimated upper bound costs for installing a hushkit on Lear 25 and GIIB aircraft.

7-6 Upper Bound Hushkit Installation Costs

Daily Hourly Daily Cost of Upper Hushkit Install Util- Hourly Operat- Net Aircraft Bound Cost Time ization Chart- ing Rev- Down Hushkit Aircraft Installed (Days) (Hrs) er Rate Costs enue Time Cost

LEAR 25 $130,000 7 0.64 $1,464 ($913) $354 $2,477 $132,477 GIIB $1,800,000 28 1.30 $3,900 ($1,807) $2,725 $76,313 $1,876,313

Source: Hushkit manufacturers, NBAA, SH&E survey of 69 US charter operators within 1,500 miles of APF.

We have assumed that the full cost of a hushkit installation can be attributed to the proposed APF restriction, even though operators with hushkits will derive other benefits from the modifications, notably when flying to other restricted airports in Europe or elsewhere. Following FAA benefit-cost methodology, we have allocated the full cost of modifications to the first year of the restriction scenario, even though the benefits, and hence the capital expense, would be spread across the life of the equipment for accounting purposes.22 Likewise, we

22 “BCA analysis is concerned with when resources are actually consumed….” FAA Airport Benefit-Cost Analysis Guidance, Office of Aviation Policy and Plans, FAA, December 15, 1999, p. 66.

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have calculated hushkit costs per aircraft affected, without accounting for the number of operations each operator conducts at APF. Aircraft Replacement Costs. A certain number of operators said they would replace their Stage 2 aircraft with Stage 3 aircraft, a potentially costly response to the proposed regulation. When calculating the costs associated with aircraft replacement, it is necessary to deduct the additional benefits that operators would derive from operating a newer Stage 3 aircraft that are not related to complying with the proposed noise restriction. To model that part of aircraft replacement that relates only to noise abatement, we have used hushkit installation costs as a proxy. If it were possible to identify two aircraft that are alike in all respects except that one were Stage 2 and the other Stage 3, the purchase price difference between them would be exactly the cost of purchasing and installing a hushkit. If the cost of the similar Stage 3 aircraft were any higher, rational consumers would instead purchase the Stage 2 aircraft and install a hushkit. We have assumed that any cost differential between Stage 2 and Stage 3 aircraft beyond the cost of hushkit installation relates to additional utility operators expect to gain from purchasing a Stage 3 aircraft. To make this proxy accurate, we have included in our upper bound scenario the costs associated with aircraft downtime of installation. In response to a 24-hour restriction of Stage 2 jet aircraft operations, some operators said they would install hushkits and some said they would replace their Stage 2 aircraft with Stage 3 aircraft. In response to the night restriction of Stage 2 aircraft operations, however, when operators have the less burdensome option of rescheduling flights, no operators said they would install hushkits. In both Stage 2 restriction scenarios, some operators indicated that they would replace their aircraft.23 In the case of a nighttime only ban on all aircraft, we have assumed that no Stage 2 operators would be induced to substitute aircraft, since there is no direct benefit. Exhibit 7-7 shows our estimates of the daily costs involved in aircraft substitution under each of the three restrictive scenarios in 2000. There are no costs associated with aircraft substitution in 2005, as modifications and replacements have already taken place by then.

23 All operators who said they would replace or modify their aircraft had also indicated that they have “current plans” to replace or modify their aircraft. Although this finding could imply that there is no substitution cost associated directly with the proposed restriction (since operators had plans to replace or modify aircraft even before the restriction was implemented), we have modeled this scenario conservatively, understanding that “current plans” to replace or modify Stage 2 aircraft may represent the operators’ expectations that restrictions are likely to be imposed in the near future.

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7-7 Total One-Time Costs of Aircraft Substitution

(in thousands of dollars)

Hushkit Aircraft Costs Downtime Total Costs Night Restriction of Stage 2 Operations $3,658 $0 - $137 $3,659 - $3,796 24-Hour Restriction of Stage 2 Operations $5,488 $0 - $206 $5,488 - $5,694 Night Restriction of All $0 $0 $0 Operations

Note: Totals may not sum due to rounding.

Source: SH&E

7.2.4 Cost of Rescheduling Flights Faced with a restriction at night only, over half of all operators said they would reschedule their flights to daytime to comply. The cost associated with this response is the value of passengers’ time (pilots are assumed to be employees who are compensated for their time). We studied a two-week sample of detailed air traffic control data and APF night logs to determine when night flights arrive and depart. Most take place between 10 p.m. and midnight, and between 6 and 7 a.m. The average amount of time required to move night flights to daytime hours was 42 minutes. Using the same aircraft occupancy rates as those assumed in the analysis of the cost of using an alternate airport, we calculated the total passenger time displaced. As above, we valued passenger time at the FAA recommended $34 per hour in our lower bound scenario, and at ten times that rate in the upper bound. Exhibit 7-8 shows estimates of the annual cost incurred due to rescheduling flights under the two nighttime ban scenarios in 2000. Exhibit 7-9 shows similar estimates for 2005.

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7-8 Annual Estimated Cost of Rescheduled Flights 2000

(annual costs in thousands of dollars)

Annual Psgr Hourly Hours Value of Annual Cost of Displaced Time Rescheduling

Night Restriction of 56 $34 - $340 $2 - $19 Stage 2 Operations 24-Hour Restriction of 0.0 $34 - $340 $0 Stage 2 Operations Night Restriction of All 919 $34 - $340 $31 - $312 Operations

Source: SH&E

7-9 Annual Estimated Cost of Rescheduled Flights 2005

(annual costs in thousands of dollars)

Annual Psgr Hourly Hours Value of Annual Cost of Displaced Time Rescheduling

Night Restriction of 39 $34 - $340 $1 - $13 Stage 2 Operations 24-Hour Restriction of 0.0 $34 - $340 $0 Stage 2 Operations Night Restriction of All 1,340 $34 - $340 $46 - $455 Operations

Source: SH&E

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7.2.5 Costs to FBOs at APF A partial or complete restriction at APF would result in lost net revenue for the City of Naples Airport Authority and APF’s privately operated FBO, Jet 1. As an airport operator, the NAA also functions as a fixed base operator, providing services – notably fuel sales – to aircraft that use the facility. In lieu of the landing fees that air carriers pay, general aviation users at APF pay a premium on fuel purchases as their effective payment to use the airport. In addition, the NAA generates modest revenue from concession fees on the rental car operation located in the general aviation terminal, catering services provided by local restaurants and sundry services. Jet 1 charges for each service it provides to its customers except fuel sales, which are provided for customers’ convenience at purchase cost from the NAA. Based on NAA financial records and data provided by Jet 1, we have calculated a per-operation revenue figure for the NAA and Jet 1, shown in Exhibit 7-10.

7-10 Estimated FBO Revenue per Jet Operation

NAA Jet 1 Item Revenue Revenue Net Fuel Revenue $134 Catering Concession Revenue $1 Car Rental Concession $6 Lavatory and GPU Service $1 Miscellaneous Services $125

Total Estimated Revenue per Operation $142 $125

Source: SH&E estimates based on NAA financial data and information provided by Jet 1

We have assumed that the number of operations affected is not enough to alter fundamentally the employment base and cost structure of either the NAA or Jet 1, meaning that the net revenue shown in Exhibit 7-10 is directly related to profit for both FBOs. Exhibits 7-11 and 7-12 show estimates of the total cost of lost revenue to the NAA and to Jet 1 under each of the three scenarios. Since our analysis does not involve subjective values, we have calculated a point estimate without upper or lower bounds.

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7-11 Estimated Annual Cost of Lost FBO Revenue 2000

(in thousands of dollars)

Net Cost to Cost to Cost to NAA Jet 1 FBOs Night Restriction of Stage 2 $2 $0 $2 Operations

24-Hour Restriction of Stage 2 $91 $12 $102 Operations $27 $4 $31 Night Restriction of All Operations

Note: Totals may not sum due to rounding

Source: SH&E

7-12 Estimated Annual Cost of Lost FBO Revenue 2005

(in thousands of dollars)

Net Cost to Cost to Cost to NAA Jet 1 FBOs Night Restriction of Stage 2 $1 $0 $1 Operations

24-Hour Restriction of Stage 2 $62 $8 $71 Operations $40 $5 $45 Night Restriction of All Operations

Note: Totals may not sum due to rounding.

Source: SH&E

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7.2.6 Increased Activity at Alternate Airports As discussed in the preceding sections, one potential effect of the alternative restrictions under consideration will likely be to cause some operations to divert to other airports, including Southwest Florida International (RSW), Page Field (FMY), Marco Island (MKY), Palm Beach International (PBI), and Sarasota- Bradenton International (SRQ). These diversions will increase noise exposure at those airports. However, that increase in exposure will be negligible, given the extremely limited number of diversions. Exhibits 7-13 and 7-14 summarize the estimated numbers of diverted operations, on an average day basis, that SH&E forecasts under each of the alternatives in 2000 and in 2005. As these tables indicate, the number of diverted operations is extremely small, on the order of hundredths of an operation per day in most cases. In the most extreme case, fewer than two daily operations would be diverted to RSW. The FAA Form 5010 Airport Master Record for RSW, effective September 9, 1999, indicated a total of approximately 67,000 annual operations, of which approximately 38,500 were air carrier jets. This translates into approximately 184 average daily operations overall and approximately 105 average daily air carrier operations alone. Using very conservative assumptions (considering only the air carrier operations at RSW and assuming that the diverted APF operations were ten decibels louder than those existing operations on average), the diverted activity would only increase DNL at RSW by approximately 0.6 dB. Even this exaggerated estimate of the potential increase is significantly less than the FAA’s 1.5 dB threshold for a significant change in DNL, which is the trigger for detailed noise analysis.24

24 “Airport Environmental Handbook,” FAA Order 5050.4A, October 8, 1985, Chapter 5, paragraph 47.e.(1)(d)2, page 30.

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7-13 Projected Daily Incremental Operations at Alternate Airports 2000

Day Night RSW FMY Other RSW FMY Other

Night Restriction of Stage 2 Operations 0.00 0.00 0.00 0.02 0.00 0.00 24-Hour Restriction of Stage 2 Operations 1.15 0.14 0.08 0.04 0.00 0.00 Night Restriction of All 0.00 0.00 0.00 0.26 0.03 0.01 Operations

Source: SH&E

7-14 Projected Daily Incremental Operations at Alternate Airports 2005

Day Night

2005 RSW FMY Other RSW FMY Other

Night Restriction of Stage 2 Operations 0.00 0.00 0.00 0.01 0.00 0.00 24-Hour Restriction of Stage 2 Operations 0.79 0.09 0.05 0.03 0.00 0.00 Night Restriction of All Operations 0.00 0.00 0.00 0.38 0.05 0.02

Source: SH&E

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8 SUMMARY OF ESTIMATED COSTS UNDER ALTERNATIVE RESTRICTIONS

8.1 SUMMARY ESTIMATED COST OF NIGHT (10 P.M. – 7 A.M.) RESTRICTION OF STAGE 2 AIRCRAFT OPERATIONS The proposed night restriction of Stage 2 aircraft operations would impose costs in all six categories described in Section 7, as shown in Exhibit 8-1. Under this scenario, close to 60 percent of affected operations reschedule to daytime, a comparatively low-cost alternative. The likely decision of just a few operators to replace their aircraft drives the cost of this scenario. Since aircraft replacement costs are borne fully during the first year the proposed regulation is implemented, costs drop significantly in the later years. We estimate that the proposed night restriction of Stage 2 aircraft operations would impose a cost of $4.4 to $4.9 million in 2000, and $480,000 to $770,000 in 2005.

8-1 Estimated Annual Costs of Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations 2000 and 2005

(in thousands of dollars)

2000 2005

Use of Alternate Airport $132 - $536 $91 - $370 Cancellations $558 $386 Replacement and Modification of Aircraft $3,659 - $3,796 $0 Rescheduling of Flights $2 - $19 $1 - $13 FBO Revenue Impact $2 $1

Total $4,353 - $4,911 $479 - $770

Source: SH&E

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8.2 SUMMARY ESTIMATED COST OF 24-HOUR RESTRICTION OF STAGE 2 AIRCRAFT OPERATIONS The proposed 24-hour restriction of Stage 2 aircraft operations would impose approximately 60 percent higher costs than a night restriction of Stage 2 aircraft operations. Under this scenario, some operators who would simply reschedule their flights to comply with a night ban install hushkits. The greater number of operations affected also means that the costs of using alternate airports and the lost revenue to airport FBOs are higher. Exhibit 8-2 shows our estimate of the total costs imposed by a 24-hour restriction of Stage 2 aircraft operations.

8-2 Estimated Annual Costs of 24-Hour Restriction of Stage 2 Aircraft Operations 2000 and 2005

(in thousands of dollars)

2000 2005

Use of Alternate Airport $388 - $1,573 $268 - $1,087 Cancellations $640 $442 Replacement and Modification of Aircraft $5,488 - $5,694 $0 FBO Revenue Impact $102 $71 Total $6,618 - $8,009 $781 - $1,600

Source: SH&E

These figures probably overstate the cost of the Stage 2 restriction. Over 70 percent of the costs under the proposed 24-hour restriction of Stage 2 aircraft operations relate to the replacement and modification of approximately 11 aircraft. Although these costs are real, they are in some sense voluntary: Stage 2 operators would all have the option of complying with the restriction by using an alternate airport. If the operators of these 11 aircraft choose instead to comply by investing in new equipment then they both drive and bear a significant part of the costs of the proposed regulation. In our survey of Stage 2 users, we found that respondents who said they would respond to a restriction of Stage 2 operations by hushkitting or replacing their aircraft were often already contemplating such an upgrade, perhaps in anticipation of impending use restrictions at APF or elsewhere, or perhaps for other reasons.

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8.3 SUMMARY ESTIMATED COST OF NIGHT (10 P.M. – 7 A.M.) RESTRICTION OF ALL OPERATIONS We have grouped the costs of the proposed night (10 p.m. – 7 a.m.) restriction of all operations into two categories – costs that relate strictly to general aviation jets, as under the proposed restrictions on Stage 2 operations, and costs related to other aircraft operations. We have quantified the impacts on general aviation jets using the same methodology as in our analysis of the proposed Stage 2 restrictions, extending findings from the survey of Stage 2 operators to forecast the behavior of Stage 3 jet operators. (Stage 2 and Stage 3 general aviation jet operators tend to use their aircraft in similar ways and are likely to make similar choices.) In addition, the proposed night restriction on all operations would impose unique cost on air carriers, which operate turbojet equipment at APF, and flight schools, which operate piston aircraft, as well as recreational pilots and other non-jet operators.

8.3.1 Costs Related to General Aviation Jets Costs related to general aviation jets under the proposed night restriction on all operations fall into the same categories as costs under the proposed night restriction on Stage 2 aircraft operations. As in that scenario, we have assumed that the proposed regulation does not induce any operators to modify or upgrade their aircraft; most simply reschedule. As shown in Exhibit 8-3, we estimate that the costs related to jet aircraft of the proposed night restriction on all operations ranges from $11.4 to $18.4 million in 2000, and between $16.6 and $26.7 million in 2005. Unlike the proposed Stage 2 restrictions, a restriction on all operations would impose rising costs over time. The number of operations by Stage 2 aircraft at APF and elsewhere is steadily declining, meaning that the cost of restricting these operations is also likely to decline. Operations by Stage 3 aircraft, on the other hand, are rising, as will the cost of restrictions imposed on them.

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8-3 Estimated Annual Jet-Related Costs of Night (10 p.m. – 7 a.m.) Restriction of All Operations 2000 and 2005

(in thousands of dollars)

2000 2005

Use of Alternate Airport $2,085 - $8,756 $3,032 - $12,755 Cancellations $9,256 $13,492 Rescheduling of Flights $31 - $312 $46 - $455 FBO Revenue Impact $31 $45 Total $11,403 - $18,355 $16,615 - $26,747

Source: SH&E

8.3.2 Costs Related to Turboprop and Piston Aircraft Turboprop. Approximately one half of all turboprop operations at APF are conducted by air carriers. American Eagle, US Airways Express and Cape Air all regularly operate flights that arrive and depart at night, in some cases only during peak season. Although the US Airways and Cape Air flights could probably be rescheduled without severely disrupting connecting opportunities, the American Eagle flight that operated daily until recently was scheduled to meet connecting banks at American’s Miami hub. In March 2000, American Eagle’s flight was scheduled to depart Miami at 11:15 p.m. and arrive at Naples at 12:05 a.m. If American were to reschedule that flight to arrive at Naples by 10:00 p.m., it would miss 15 connecting flights at Miami. We believe American Eagle would choose to cancel this flight under the proposed night restriction of all operations. We have made estimates of the magnitude of economic impact associated with canceling one nighttime air carrier flight. As shown in Exhibit 8-4, we estimate that American Eagle’s one night flight at Naples in 1999 generated close to $500,000 in revenue. To reach this estimate, we multiplied the number of scheduled night flights by American’s average load factor and average fares on this route. We gathered schedule data from the Official Airline Guide schedule tapes (OAG), load factor from the DOT’s T100 database, and average fares from the DOT’s DB1A database. Although we believe many of the passengers on this flight are transferring at Miami, and hence paying a higher fare than the fare for

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Naples-Miami, this local fare is a good proxy for the prorated portion of the total fare paid. In addition to lost revenue on cancelled night air carrier flights, passengers on flights that are rescheduled would be inconvenienced.

8-4 Estimated Revenue Associated With Air Carrier Cancellations Under Night (10 p.m. – 7 a.m.) Restriction of All Operations

(in thousands of dollars)

Able to Flights Estimated Resched- Scheduled Revenue Affected Airline Destination ule? 19991/ by Cancellation

American Eagle Miami No 271 $482 Air Midwest (US Airways Express) Orlando Probably 151 NA Air Midwest (US Airways Express)2/ Tampa Probably 284 NA Cape Air Key West Probably 52 NA

Total 758 $482

1/ 12 months ended 3rd quarter 1999. 2/ Operated by Florida Gulf in November 1998. Source: OAG Schedule Tapes, T100, DB1A

Piston. Most piston operations at APF take place during daytime hours. Absent restrictions, approximately 2,000 of the 110,000 annual piston operations at APF take place at night. Although a small percentage of the total, these operations play an important role for flight schools based at APF. The Private Pilot’s License (PPL), the central course offered by Naples flight schools, requires students to complete 20 night operations. Other courses also require night training. To comply with voluntary noise abatement procedures, flight schools based at APF currently conduct most of their nighttime training away from APF, at nearby airports. Still, even if a student conducts 20 night operations at Marco Island or Immokalee, he or she must still take off and land at APF once to begin and once to end each training session. Managers at Naples Air Center, which generates approximately 65 percent of the flight training hours at APF, have said that their business would be untenable without the opportunity to conduct night training; they would be forced to shut down.25 In fact the definitions of night for

25 Flight hours of four flight schools based at Naples were estimated by Naples Air Center based on Naples Airport fuel records assuming training aircraft average eight gallons per hour.

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pilot training and for the proposed restriction are different, meaning that there is a window in which flight schools would be able to conduct “night” training during the day (before 10 p.m.).26 Still, the proposed restriction would limit the flight schools’ ability to conduct night training and could indeed cause them to close. As shown in Exhibit 8-5, flight schools based at APF were responsible for approximately $2.3 million of activity in 1999, not counting the maintenance and charter businesses operated by the flight schools. Combined flight training revenues were approximately $1.8 million. Moreover, since most of the students come from overseas, they stay in Naples hotels for extended periods. Based on information provided by Naples Air Center, Naples flight school students spent approximately $313,000 on hotels, and an additional $153,000 on food, entertainment and transportation. For these estimates, we have assumed that 90 percent of flight students are non-local, that they stay an average of 12 nights at a special flight student rate of $51 in season, and that they spend $25 a day on other tourism. Although we are not convinced that the proposed restriction would force the flight schools at APF to shut their doors, the economic activity these businesses generate is significant enough that even some chance the restriction would cause them to close is still a costly prospect. In addition to flight schools, other airport users conduct piston operations at night. Under a night restriction of all aircraft operations, there will be a non-zero cost to these users, although it is not possible to establish a dollar value for that cost.

8-5 Estimated Revenue Generated by Flight Schools at APF in 1999

(in thousands of dollars)

Other Flight School Hotel Tourism Total Revenue Revenue Revenue Activity1/

All Flight Schools $1,876 $313 $153 $2,342

1/ Revenue represents an upper bound of costs.

Source: SH&E estimates based on data provided by Naples Air Center

26 For pilot training, “night” is one hour after sunset to one hour before sunrise.

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8.4 COMPARATIVE SUMMARY OF ESTIMATED COSTS Exhibit 8-6 shows a summary of the estimated annual costs associated with each of the restrictions studied. As in the detailed cost estimates, ranges relate primarily to subjective valuations of time: lower values assume the FAA’s recommended hourly value of time of $34 per hour; upper values assume ten times that figure.

8-6 Comparative Estimated Annual Jet-Related Costs for Each Proposed Restriction in 2000 and 2005

(in thousands of dollars)

Night Restriction of Stage 2 24-Hour Restriction of Stage 2 Night Restriction of All Aircraft Aircraft Operations Aircraft Operations Operation 1/ 2000 2005 2000 2005 2000 2005 Use of Alternate Airport: Passenger Drive Time $47 - $466 $32 - $322 $137 - $1,368 $95 - $945 $769 - $7,695 $1,122 - $11,216 Passenger Transport $61 $42 $178 $123 $1,003 $1,463 Lost Pilot Stay $41 $28 $120 $82 $710 $1,036 Airtime Savings ($16) - ($32) ($11) - ($22) ($47) - ($93) ($32) - ($64) ($397) - ($653) ($588) - ($961) Total Use of Alternate Airport $132 - $536 $91 - $370 $388 - $1,573 $268 - $1,087 $2,085 - $8,756 $3,032 - $12,755

Cancelled Flights: Passenger Hotel Stay $192 $133 $220 $152 $3,171 $4,622 Passenger Home Stay $325 $225 $373 $258 $5,373 $7,832 Pilot Stay $41 $28 $47 $32 $711 $1,038 Total Cancelled Flights $558 $386 $640 $442 $9,256 $13,492

Aircraft Substitution: Hushkit Costs $3,658 $0 $5,488 $0 $0 $0 Aircraft Downtime $0 - $137 $0 $0 - $206 $0 $0 $0 Total Aircraft Substitution $3,659 - $3,796 $0 $5,488 - $5,694 $0 $0 $0

Rescheduling Flights: Passenger Time $2 - $19 $1 - $13 $0 $0 $31 - $312 $46 - $455 Total Rescheduling Flights $2 - $19 $1 - $13 $0 $0 $31 - $312 $46 - $455

Foregone FBO Revenue: NAA Revenue $2 $1 $91 $62 $27 $40 Jet 1 Revenue $0 $0 $12 $8 $4 $5 Total Foregone FBO Revenue $2 $1 $102 $71 $31 $45

Summary: Total Use of Alternate Airport $132 - $536 $91 – 370 $388 - $1,573 $268 - $1,087 $2,085 - $8,756 $3,032 - $12,755 Total Cancelled Flights $558 $386 $640 $442 $9,256 $13,492 Total Aircraft Substitution $3,659 - $3,796 $0 $5,488 - $5,694 $0 $0 $0 Total Rescheduling Flights $2 - $19 $1 - $13 $0 $0 $31 - $312 $46 - $455 Total Foregone FBO Revenue $2 $1 $102 $71 $31 $45 Total $4,353 - $4,911 $479 - $770 $6,618 - $8,009 $781 - $1,600 $11,403 - $18,355 $16,615 - $26,747

1/Jet-related costs only – does not include costs related to air carrier, training and other non-jet aircraft. Note: Totals may not sum due to rounding. Source: SH&E

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9 ANALYSIS OF BENEFITS

onsistent with land use compatibility criteria established by local land use jurisdictions, which the City of Naples Airport Authority has respected in its land Cuse compatibility goal, the 60 dB annual average day DNL contour is the fundamental measure of effectiveness used in evaluating alternatives. Other measures discussed in Section 3.2 also provide comparative supplemental bases for evaluating the alternatives.

9.2 CUMULATIVE NOISE EXPOSURE Exhibit 9-1 presents the estimated residential population within the 60 dB DNL contour, for the 2000 existing and 2005 forecast conditions with and without the potential use restrictions.27 The table clearly reveals that the 24-hour restriction of Stage 2 operations provides the greatest reduction in population within the 60 dB DNL contour, the NAA’s land use compatibility goal.

27 Under existing 2000 and forecast 2005 conditions, no residential population is believed to be within the 65 dB DNL contours.

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9-1 Estimated Residential Population Within DNL 60 dB Contour - 2000 Existing and 2005 Forecast Conditions With and Without Potential Use Restrictions

Population Off Approach End of Each Runway 05 23 14 32 (City land (County land (County land (County land area to the area to the area to the area to the southwest) northeast) northwest) southeast) Total 2000 Existing Conditions 1,218 0 01/ 464 1,682 2000 Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations 1,002 0 0 310 1,312 2000 24-Hour Restriction of Stage 2 Aircraft Operations 152 0 0 0 152 2000 Night (10 p.m. – 7 a.m.) Restriction of All Operations 858 0 0 260 1,118

2005 Forecast Conditions 1,130 0 24 490 1,644 2005 Night (10 p.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations 850 0 24 444 1,318 2005 24-Hour Restriction of Stage 2 Aircraft Operations 368 0 0 32 400 2005 Night (10 p.m. – 7 a.m.) Restriction of All Operations 850 0 0 310 1,160

1/ The 2000 existing conditions contours (Exhibit 3-2) shows a triangular area of residential land use off the end of Runway 14. However, this land area is in a portion of a residential development that does not include any dwelling units. It includes tennis courts and a club house for the development.

Sources: MCG analysis, HMMH contours

Exhibits 9-2 through 9-7 present DNL contours for forecast 2000 and 2005 operations under each of the three alternatives, based on the SH&E activity forecasts presented in Section 6.2.

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9-2 2000 Day-Night Average Sound Level (DNL) Contours: Night (10 a.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations

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9-3 2005 Day-Night Average Sound Level (DNL) Contours: Night (10 a.m. – 7 a.m.) Restriction of Stage 2 Aircraft Operations

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9-4 2000 Day-Night Average Sound Level (DNL) Contours: 24-Hour Restriction of Stage 2 Aircraft Operations

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9-5 2005 Day-Night Average Sound Level (DNL) Contours: 24-Hour Restriction of Stage 2 Aircraft Operations

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9-6 2000 Day-Night Average Sound Level (DNL) Contours: Night (10 p.m. – 7 a.m.) Restriction of All Operations

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9-7 2005 Day-Night Average Sound Level (DNL) Contours: Night (10 p.m. – 7 a.m.) Restriction of All Operations

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9.3 OTHER NOISE BENEFITS Section 3.2 provided single event contours and related population counts, and noise complaint statistics which demonstrated the single event related noise impacts of Stage 2 operations. Those data clearly support the analyses of DNL contours that shows that Stage 2 operations generate significantly greater impacts and annoyance than Stage 3 operations. On a single-event basis, Stage 2 operations affect approximately four times as many residents as Stage 3 operations. Clearly, the reduction of Stage 2 operations would significantly reduce single event impacts. The complaint analysis indicates that switching operations from typical Stage 2 to Stage 3 types would cause complaints to drop approximately 27 times faster than the substitution rate. Given that noise complaints generally relate to the most annoying operations, the benefit of substitution would be dramatic.

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10 BENEFIT-COST SUMMARY AND CONCLUSIONS

he City of Naples Airport Authority has established the goal of minimizing residential land within the 60 dB DNL, consistent with the City and County land- Tuse policies. Only one of the three studied alternatives clearly meets this objective. Absent new restrictions, we estimate that there are 1,682 persons within the 60 dB DNL contour under existing conditions, and forecast that there will be 1,644 persons within the 60 dB DNL contour in 2005. The proposed 24-hour restriction on Stage 2 aircraft operations reduces those numbers to 152 in 2000 and 400 in 2005. Exhibit 10-1 shows that this restriction is significantly more effective at meeting the NAA’s goals than the next best alternative, a night restriction on all operations.

10-1 Comparison of Benefits of Potential Use Restrictions: Population Within DNL 60 dB Contour Compared to Status Quo – 2000 and 2005 Existing and Forecast Conditions

1,800

1,600

1,400 2000 1,200 2001 1,000

800

600

400

200

0 Baseline Night Restriction 24-Hour Night Restriction Conditions of Stage 2 Restriction of of All Operations Operations Stage 2 Operations

Source: MCG analysis, HMMH contours, SH&E forecasts

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In addition to effectively reducing population inside the 60 dB DNL contour, the proposed 24-Hour Restriction on Stage 2 Aircraft Operations is cost-effective. It is likely to impose costs of approximately $6.6 to $8.0 million in the first year, falling rapidly to $800,000 to $1.6 million in 2005. These ranges represent lower and upper bounds that represent a range of estimates for the value of time. The next best alternative in terms of benefits, the proposed night restriction of all operations, would impose costs relating to a broader range of users: the costs relating to general aviation jets alone under this scenario are more than twice as high as under the Stage 2 restriction, in addition to significant potential costs related to air carrier and flight school operations. Exhibit 10-2 compares the total costs under the three proposed restrictions.

10-2 Estimated Total Costs of Proposed Use Restrictions in 2000 and 2005 Existing and Forecast Conditions

(in thousands of dollars)

2000 2005

Night Restriction of Stage 2 Operations $4,353 - $4,911 $479 - $770 24-Hour Restriction of Stage 2 Operations $6,618 - $8,009 $781 - $1,600 Night Restriction of All Operations1/ $11,403 - $18,355 $16,615 - $26,747

1/ Costs relating to jets only; does not include costs relating to air carrier, flight school or other non- jet operations.

Source: SH&E

The 24-hour restriction of Stage 2 aircraft operations is an effective way to reach the NAA’s goal of minimizing population within the 60 dB DNL contour with balanced and reasonable costs that decrease over time. Moreover, over 70 percent of these costs relate to one-time aircraft upgrades of approximately 11 Stage 2 aircraft. There is reason to believe that the operators of these aircraft have a unique willingness to bear higher compliance costs that explains why they would not elect a cheaper response. After these initial conversions, annual costs of compliance with the 24-hour restriction of Stage 2 aircraft operations fall every year, to well under $1 million in 2005.

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To put these costs in perspective, MCG has estimated the value of all non- compatible land (including houses and other improvements) inside the 60 dB DNL contour today and under the proposed 24-hour restriction of Stage 2 aircraft operations. The property that would be shifted out of the 60 dB DNL contour is worth approximately $67.5 million according to current Collier County tax appraisals, almost ten times the first-year cost of the restriction, and over 40 times the cost of the restriction in later years. Although the property valuation methodology was not the basis for conclusions, it supports an understanding of the balance between the costs and benefits of the recommended restriction.

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11 RECOMMENDATION

ased on the preceding analysis, the consulting team recommends that the City of Naples Airport Authority adopt a 24-hour restriction on Stage 2 jet operations. BAppendix A presents the text of a proposed resolution that would implement the restriction. The resolution incorporates the following elements for the restriction.

11.1 FORM OF RESTRICTION The proposed restriction would amend existing Airport Rules and Regulations. Appendix D sets forth the existing Airport Rules and Regulations as they have been recently amended: T Section 5 (“Aeronautical Activities”) as amended March 15, 1999; and T Section 10 (“Penalties”) as amended March 5, 1998

The existing Rules and Regulations include the existing Stage 1 restriction: T Section 5.06 B.1. prohibits Stage 1 aircraft operations, subject to exceptions set forth in Section 10.4. T Section 10.3 establishes that violations of Section 5.06 B.1. are punishable by a fine not to exceed $500 per offense. T Section 10.4 exempts aircraft operated by the United States and State of Florida governments; law enforcement, emergency, fire, and rescue aircraft operated by government agencies; and aircraft operated for bona fide emergency purposes.

The most effective means of implementing the proposed restriction would be to add language to Section 5.06 B.3. that prohibits Stage 2 operations at APF: “All aircraft certificated as meeting Stage 2 noise limits identified in 14 C.F.R. Part 36, App. C § 36.5, as the same may be amended in the future, are prohibited.” Language in Section 5.06 C.2 referencing the voluntary cessation of Stage 2 operations would be deleted. Existing exemption and penalty provisions do not merit revision.

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11.2 IMPLEMENTATION TIMING The process for implementation of the restriction is largely driven by the requirements of the Part 161 regulations. Based upon the NAA’s adoption of Resolution No 2000-7 on June 22, 2000, it should be possible to publish notice of the proposed restriction on or prior to June 30, 2000. The notice and comment process is explained in section 12 of this report. This notice date will trigger a 180-day notice period required by Part 161, §161.203(a), permitting an effective date of January 1, 2001 for the restriction, should the NAA decide, following review of public comments, that it wishes to implement the proposed restriction.

11.3 RECOMMENDED WAIVER PROVISION It would be appropriate for the Stage 2 restriction to include language authorizing NAA staff to issue temporary exemptions under narrowly defined circumstances to accommodate Stage 2 owners in the process of modifying or replacing their aircraft to comply with the regulation. The following language is recommended for inclusion as Section 10.7:

10.7 Waivers from Stage 2 Restriction An aircraft operator may apply to the NAA for a temporary waiver from the paragraph 5.06 B.3 prohibition on Stage 2 aircraft operations, subject to the following provisions:

A. No waiver for Stage 2 operations shall apply for a period exceeding six months.

B. No waiver for Stage 2 operations shall extend beyond December 31, 2001.

C. An operator must file an application for a temporary waiver and receive NAA’s approval in advance of the operation of a Stage 2 aircraft at the airport.

D. An application for a temporary waiver must provide documentation demonstrating that the operator has committed to either:

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1. retrofitting the aircraft to be recertificated as FAR Part 36 Stage 3 within the waiver period; or

2. replacing the aircraft with a Stage 3 aircraft within the waiver period.

E. Potentially acceptable documentation includes, but is not limited to, materials such as executed contracts, letters of intent, evidence of deposits, or other similar items or combinations of items demonstrating commitments to obtain FAA- certified aircraft modifications or purchase of replacement aircraft or otherwise showing the applicant’s good faith attempt to comply with section 5.06B and inability to comply in a timely manner with such paragraph because of circumstances over which the applicant does not exercise control.

F. The Board will act on the recommendations from the Executive Director considering approval for a temporary waiver upon finding that (1) the applicant has in good faith attempted to comply with section 5.06B, or (2) that enforcement of section 5.06B as to the applicant and the applicable aircraft would be an undue hardship on the applicant or (3) enforcement of section 5.06B as to the applicant and the applicable aircraft would unduly burden interstate commerce. The Board’s findings shall be final and binding. The Executive Director or the Board may request such additional documentation as the Executive Director or Board deem necessary to review an application fully. The Executive Director shall provide the applicant with the Board’s written approval or disapproval of the waiver application.

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12 OPPORTUNITY FOR PUBLIC COMMENT

f the City of Naples Airport Authority decides to implement the restriction recommended in this study, it would be required to comply with the procedural Irequirements imposed by the Part 161 regulations. The Part 161 regulations, implemented pursuant to the Airport Noise and Capacity Act of 1990, set forth detailed requirements for public comment and public notice before an airport proprietor can implement an operational restriction that affects Stage 2 aircraft. (The required process is dependent upon which alternative the NAA chooses to pursue. If the NAA decides to implement the night restriction of all operations, the process for notice and comment would be substantially different. Since this study does not recommend that alternative, the process for approval of that restriction is not discussed here.) This report was prepared in a manner that will allow the NAA to implement the recommendation in compliance with Part 161 if it so decides. In addition to procedures already followed, the NAA will be required to comply with additional steps to ensure adequate opportunity for public comment. The following schedule summarizes the actions taken to date and the recommended sequence for further public notification and opportunity for public comment. Early June 2000– The NAA published notice in the Naples Daily News of the Public Forum that was held on June 13. Staff also provided notice of the Public Forum to the following parties: All locally based jet operators; all fixed base operators; all Stage 2 operators contacted in the survey; Naples Pilots Association members; all airport tenants; Citizens for Control of Airport Noise (CAN) president; NBAA and Aircraft Owners and Pilots Association (AOPA) representatives; the NCC distribution list; FAA and U.S. Department of Transportation; and any party that has been recorded as having filed a noise- related complaint to the NAA within the last two years. Authority staff placed a copy of the notice concerning the Public Forum in the official notice locations at the General Aviation Terminal and posted the notice on the NAA’s web page. Staff published notice concerning the Public Forum in the monthly safety newsletter in June. June 13, 2000 – The consultant team hosted a Public Forum to discuss the draft study results. June 22, 2000 – The NAA convened a Special Meeting to consider the study report and proposed restriction. The NAA adopted Resolution No. 2000-7 accepting the study recommendations, declared its intent to adopt the proposed restriction after the requisite public comment period, and directed staff to initiate

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the formal notice and public comment process. The NAA did not formally adopt the rule by adoption of Resolution No. 2000-7. That Resolution merely declares its intent to do so. On or Prior to June 30, 2000 – Under the provisions of Part 161 of the FAA regulations, the NAA cannot implement the proposed rule until at least 180 days after notice has been given to interested or potentially affected parties. The NAA staff should send notice of the completion of the final report, thereby triggering the 180-day notice period. Notice should begin to run on this date in area-wide, daily newspapers. The NAA staff should provide notice or take out a paid advertisement in the three most common pilot magazines. The NAA should post notice in the official notice locations in the General Aviation Terminal and other facilities on this date. In order to comply with the requirement of Part 161, the NAA must send direct written notice to the following parties: aircraft operators providing scheduled passenger or cargo service at APF; aircraft operators based at APF; all commercial air carriers providing scheduled commuter service to airports within the South Florida region; aircraft operators known to routinely provide scheduled service at APF; the Federal Aviation Administration (Airports District Office, Regional Office, Washington DC headquarters); each federal, state, and local agency with land use control jurisdiction within the airport noise study area; all fixed base operators and other tenants at APF; community groups and business organizations known to be interested in the restriction; all federal, state and local elected officials representing communities within the noise study area; all parties that commented on the most recent Part 150 NEM; and all directors of nearby airports in South Florida. The NAA also should provide written notice to the following parties likely to have an interest in the proposed restriction: the National Oceanic and Atmospheric Administration for inclusion in the Airport Facility Directory; Jeppeson Publications; all Stage 2 jet aircraft operators who are known to have operated at APF within the last year; all APF tenants via the monthly safety newsletter; CAN members via notification to CAN President; NBAA and AOPA representatives; and the NCC distribution list. (See Appendix A, Draft Resolution, Attachment 1.) The NAA should publish notice on the Airport web page. Mid-July 2000 – The FAA will publish an announcement of the proposed restriction in the Federal Register. The precise date of this announcement is subject to FAA discretion.

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August 21, 2000 – Last day of public comment period. This date should be announced in all notices of the proposed restriction. First NAA Regular Meeting After August 21, 2000 – After reviewing and considering public comments, the NAA may consider adopting by resolution the proposed restriction, if deemed appropriate at that time. If the NAA decides to make any changes to the proposed restriction based upon public comment, staff should provide direct written notice of the proposed change to each of the previous recipients of direct written notice identified above. Minor changes to the proposed restriction would not affect the public comment period or the effective date of the restriction. Major changes would require reinitiating the 180-day notice period and 45-day comment period. January 1, 2001 – If the NAA has initiated notice as recommended in this report on June 30, 2000 and has adopted the proposed restriction in September of 2000, the NAA can begin implementation of the restriction.

12.1 DEFINITION OF NOTIFIED PARTIES Part 161 of the FAA regulations define several parties whom the FAA believes should be notified of any proposal to impose operational restrictions on Stage 2 aircraft at an airport. The FAA has concluded that these parties are: T Aircraft operators providing scheduled passenger or cargo service at APF; T Aircraft operators based at APF; T All commercial air carriers providing scheduled commuter service to airports within the South Florida region; T Aircraft operators known to routinely provide scheduled service at APF; T The Federal Aviation Administration (Airports District Office, Regional Office, Washington DC headquarters); T Each federal, state, and local agency with land use control jurisdiction within the airport noise study area; T All fixed base operators and other tenants at APF; T Community groups and business organizations know to be interested in the restriction;

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T All federal, state and local elected officials representing communities within the noise study area; T All parties that commented on the most recent Part 150 NEM; and T All directors of nearby airports in South Florida.

In addition to those parties, the consultant team believes that the following groups are sufficiently interested that they should also be notified of the proposed restriction: T National Oceanic and Atmospheric Administration for inclusion in the Airport Facility Directory; T Jeppeson Publications; T All Stage 2 jet aircraft operators who are known to have operated at APF within the last year; T All tenants via monthly safety newsletter; T CAN members via notification to CAN President; T NBAA and AOPA representatives; and T NCC distribution list.

12.2 NOTIFICATION OF PROPOSED RULE It is recommended that the NAA provide notice using two mechanisms: a written notice that is mailed to interested and affected parties and an advertisement that appears in appropriate publications. The text of a proposed written notice and advertisement is included in Appendix F.

12.3 OPPORTUNITY FOR COMMENT Part 161 of the FAA regulations requires that the NAA seek public comment for 45 days before implementing any operational restriction that affects Stage 2 aircraft. The principal purpose of the extended comment period required by the FAA regulations is to afford interested and potentially affected parties a reasonable opportunity to submit comments on the proposed restriction and for

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the NAA to consider those comments prior to taking any final action to approve the restriction. For that reason, the NAA already has embarked upon an aggressive program to solicit input from all potentially interested or affected parties. This study recommends that the NAA continue to pursue public comment and to afford opportunities for comment beyond the minimum required by FAA regulations.

12.3.1 Public Presentations The consultant team presented the findings and conclusions of this study at a public forum on June 13, 2000. At that meeting, the public was given the opportunity to present oral comments and was notified of its opportunity to submit written comments that would become part of the public record. A second presentation was made at the NAA meeting on June 22, 2000, at which time public comments were once again received. Both prior to and following those two presentations, NAA staff has responded to numerous informal public inquiries about the conclusions of this study, the analysis, the underlying data, and the consultants’ recommendations.

12.3.2 Docket One of the most important requirements of the Part 161 process is the maintenance of a formal record-keeping and docketing system. The Part 161 requirements are largely procedural and are designed to achieve two objectives: to ensure (1) that an airport proprietor does not adopt a noise restriction without an exhaustive opportunity for public comment, and (2) that the final decision to implement a noise restriction is based upon a thorough factual record that supports and justifies the decision.

Section 161.207 of the FAA regulations sets forth the requirement that an airport proprietor establish a formal docketing system for the recordation of comments on a proposed noise rule prior to its adoption. Section 161.207 mandates three particular actions:

1. The airport operator must “establish a public docket or similar method for receiving and considering comments,”

2. The airport operator must “make comments available for inspection by interested parties upon request,” and

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3. The comments “must be retained as long as the restriction is in effect.”

While the FAA regulations provide little guidance on the particular steps that should be taken to satisfy these requirements, this report recommends that the NAA implement the following procedures to ensure that both the strict letter and overall spirit of the Part 161 requirements are satisfied.

1. The public docket should have two principal components: (a) a compilation of all written comments and a corresponding log or index of all comments, and (b) copies of all notices and other communications initiated by the NAA regarding the proposed restriction and a corresponding log or index of all notices. 2. The NAA should identify a central repository at the NAA’s offices and allow access to the repository for inspection purposes during ordinary business hours. 3. The NAA should compile all written comments concerning the proposed restriction. 4. While there should be a log of the names of people who offer oral comments, the substance of such comments need not be recorded. 5. The NAA should maintain a log or similar means of recording every comment received with regard to the proposed restriction. 6. The NAA should compile each notice initiated by the NAA concerning the proposed restriction, including notice of the proposed restriction and notice of any public meeting at which the proposed restriction will be discussed or acted upon. 7. The NAA should maintain a log or similar means of recording every notice initiated by the NAA concerning the proposed restriction. 8. Each component of the public docket should be retained by the NAA so long as the restriction is in effect.

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12.4 ADEQUATE TIME PERIOD FOR COMMENT As explained in section 12.3, Part 161 of the FAA regulations requires that the NAA give the public 45 days to comment on any proposed noise restriction prior to approval. The timetable set forth in section 12 provides for in excess of 45 days for public comment prior to formal approval. In addition, the NAA already has sought public comment through informal mechanisms including especially the June 13, 2000 Public Forum. If the NAA adheres to the schedule and public outreach recommendations set forth in section 12, it will have complied fully not only with the strict requirements, but also with the intent and spirit of the FAA regulations. The NAA should be able to implement on or after January 1, 2001.

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13 ADDITIONAL PART 161 REQUIREMENTS

he FAA’s Part 161 regulations set forth specific requirements that airport proprietors must meet before implementing restrictions on jet operations. If the TCity of Naples Airport Authority were proposing to implement a restriction that would affect Stage 3 jet aircraft, formal FAA review and approval would be required. FAA approval is not required, however, for a restriction that would only affect Stage 2 aircraft operations. The FAA's role for Stage 2 restrictions is to provide comments on the proposal. The purpose of the comments is two-fold. The FAA's primary role under Part 161, section 161.205, is oversight of the regulation, which includes ensuring that procedural requirements for the proposed airport noise and access restriction fully complies with the regulatory requirements. The agency’s secondary role is as a commenting party to provide a detailed review of the substance of the proposal for compliance with other federal requirements. While Part 161 does not impose substantive standards that must be met, the FAA has recommended that airports use the six standards applicable to Stage 3 restrictions as a guideline for determining whether a Stage 2 restriction would be legally valid. (These standards are set forth in section 161.305 of the FAA regulations.) The proposed restriction of Stage 2 aircraft operations at APF satisfies these standards. 1. The restriction is reasonable, non-arbitrary, and nondiscriminatory. This report documents that a current or projected noise problem exists at APF and that the proposed ban on Stage 2 operations would fulfill the City of Naples Airport Authority’s land use compatibility goals. The NAA maintains a comprehensive noise abatement program that takes full advantage of a full range of non-restrictive measures. Before proposing restrictions, the NAA exhausted available non-restrictive measures. For this study, the NAA designed the three narrowest use restrictions that showed promise of bringing the airport into compliance with local land-use policies. This report sets forth a detailed description of the noise problem that precipitated the study and the proposed restriction, and includes background information on factors that contributed to the NAA’s decision to initiate this study and decision to propose the restriction of Stage 2 aircraft operations. The recommended restriction is not arbitrary: although Stage 2 aircraft operations represented less than one percent of all activity at APF in 1999, they generated 38 percent of all noise complaints; this study has demonstrated that restricting this small fraction of operations at APF will reduce the population inside the 60 dB DNL contour from 1,682 to 152

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under existing conditions. Since the FAA used FAR Part 36 to differentiate between Stage 2 and Stage 3 aircraft as part of the national noise policy, we believe the recommended restriction is also nondiscriminatory. This report further concludes that implementation of the proposed restriction would be consistent with plans of those government agencies that are authorized to plan for the development of the area around APF and that other local governments already have taken appropriate and reasonable actions to restrict land uses in the vicinity of the airport to uses that are compatible with the airport. 2. The restriction does not create an undue burden on interstate or foreign commerce. This study includes an exhaustive benefit-cost analysis of the potential impacts of the proposed restriction and concludes that the benefits have a reasonable chance to exceed the estimated potential cost of the adverse effects on interstate and foreign commerce. The analysis was prepared using accepted economic methodology. The estimated total annual cost burden of the recommended restriction is between $6.6 and $8.0 million in 2000, falling rapidly to $800,000 to $1.5 million in 2005. These costs primarily arise on the local level and do not represent significant disruptions to interstate or foreign commerce. 3. The restriction maintains safe and efficient use of the navigable airspace. The recommended restriction affords the same exemptions for health and welfare of the general public as apply to restrictions in effect on Stage 1 aircraft operations at APF. The proposal does not in any manner affect use of airspace in the vicinity of APF. 4. The restriction does not conflict with any existing Federal statute or regulation. The proposed restriction does not conflict in any manner with any existing federal statute or regulation, including but not limited to those governing exclusive rights to use APF, existing federal grant assurances, and federal statutes and regulations governing control of aircraft operations. This report and the process for review, implementation and approval of the proposed restriction is intended to comply fully with the Airport Noise and Capacity Act of 1990 and Part 161 of the Regulations of the FAA. 5. The applicant has provided adequate opportunity for public comment. The procedures described in section 12.3 and 12.4 meet and exceed the notice and comment requirements of Part 161. 6. The restriction does not create an undue burden on the national aviation system. APF is one of five airports within a 45-minute drive of the City of Naples. One of these airports, Marco Island, is only 12.4 miles away. Stage 2 aircraft operations are not restricted at Marco Island or the other area

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airports. The analysis in this report shows that the proposed restriction does not have an adverse effect on existing or planned airport system capacity, on observed or forecast airport system congestion and aircraft delay, or on airspace system capacity or workload. It further shows that non-aircraft alternative measures to achieve the NAA’s objectives have already been implemented or otherwise are inappropriate or ineffective at achieving the NAA’s objectives.

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Appendix A: Two Proposed NAA Resolutions

Appendix B: Methodology for Population Counts

Appendix C: Methodology for Development of Contours

Appendix D: Portions of Sections 5 and 10 of the Proposed Changes to Existing Airport Rules and Regulations

Appendix E: Stage 2 Operator Survey

Appendix F: Public Notices

Appendix G: Part 161 Notification List $SSHQGL[$

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