WAAM objects in the strongest possible manner to initiating any part of the FAR Part 161 Study, including defining the scope of the FAR 161, prior to doing an Airport Exploratory Study (AES) which in itself will help define the need and scope of an FAR 161 study at Martin County Airport.

We should move forward to define the scope of the AES only at this time, the scope being defined and limited by the "Strategic Plan" that was adopted by the Board of County Commissioners on November 26th, 2002, which stated "Operate the airport in a manner that minimizes impacts on the community / stop growth at the airport".

It would be premature to begin any part of the FAR 161 study process while considering other options. We need an unbiased and credible AES. This would not be possible with a parallel effort toward only one option (FAR 161). If the AES it is not fair and impartial, it will be a waste of time and taxpayer money and will result in a significant loss of credibility by Martin County government. We must be sure that this does not happen. It is imperative that our representatives have the confidence of the voters.

Beginning any portion of the FAR 161 study before an Airport Exploratory Study (AES) is completed, would bias the AES and cloud any conclusions and recommendations that the AES would produce.

Consultants should not be asked to invest their time, effort and money on bid proposals when it has not been determined that an FAR 161 study will be required at the Martin County Airport. WAAM considers it unethical to request consultant bids when there is no clear intent to proceed.

The minimum options to be examined by the Airport Exploratory Study (AES) are:

(1) the viability of airport downsizing
(2) the viability of airport relocation
(3) the viability of airport closure
(4) Explore the steps that can be taken to implement the strategic planning goals of this commission which is "to stop the growth of this airport." This includes, among other objectives, exploring the background, history, and legality of the laws and rules promulgated by Congress and the FAA that give the FAA power over a small, locally owned airport for a period of twenty years following a grant of funds, however small, without any exit options.

Each of these options should include an examination of the economic impact on runway-dependent businesses at the airport, and the economic value of non-aviation uses of the airport property.

The one absolute criterion for consultant selection for the Airport Exploratory Study (AES) described above must be evidence of credibility and absence of bias toward any one option. It must be repeated the study shall follow the "Strategic Plan" that was adopted by the Board of County Commissioners on November 26th, 2002, which stated  "Operate the Airport in a manner that minimizes impacts on the community / stop growth at the airport".

It is WAAM's position that the FAR Part 161 Study is of limited value and should be considered the avenue of last resort for the reasons stated in the next paragraph. It should be ordered and completed only after the determination that downsizing, moving, or closing the Martin County Airport are not viable options for the people of Martin County.

The FAR 161 study addresses issues that WAAM feels are of limited value to the community.
For example;

(1) Stage I jet operations are almost extinct (approx. 2 operations in the entire year of 2002). It is therefore clear that banning Stage I jets will have almost no impact on noise and pollution.

(2) Stage II jet operations comprise less than 20% of the total jet operations (not total aircraft operations) at Martin County Airport and through attrition, Stage II jets are currently being phased out. Again, limited relief from noise and pollution will result as the number of Stage III jets will take the place of retiring Stage II jets with the total number of jet operations at Martin County Airport continuing to increase each year.

(3) The vast majority of jet operations at Martin County Airport are Stage III jets. They cannot be banned, curfews are voluntary and their numbers continue to proliferate as Stage II jets are eliminated by attrition.

(An example of one Stage III jet that the community has found considerably objectionable is Attorney Gary's 737 whose operation in and out of the Martin County Airport would not be affected in any way by the outcome of a successful FAR 161 study. How many more of these behemoths must we endure as the jet operations at MCA continue to grow?)

(4) The FAR Part 161, a study that is estimated to cost in the neighborhood of one (1) million dollars will have to be paid for by Martin County taxpayers, as Federal funds are specifically excluded for the purpose of doing the FAR 161 study.

If Naples airport, the only airport to successfully complete an FAR 161 study can be used as an example, the initial cost of the FAR 161, estimated to be one (1) million dollars, is only the beginning.

Successful completion of the FAR 161 by Martin County could also lead to expensive and lengthy litigation as happened in Naples. One has to look at the limited results and cost of the 161 in Naples, our only example of the 161 in action, to determine the usefulness of the FAR 161 to Martin County.

County government and citizens groups such as WAAM with the goal of stopping airport growth must work hand in hand with to resolve the complex issues facing the Martin County Airport.

Signed for Board,
/ s /
Lynne Pine, President WAAM