Presented below, in its entirety, is the email Ms. Lang sent to the Acting Venice City Manager in which she lays out her plan for the Venice Municipal Airport.

The Venice Airport Business Association (“VABA”) comments to the “Lang Plan” are also presented in italics and the color red throughout the document.

Thank you Nancy!  Following are some quick and rough suggestions for the scope of work for the DY contract.  (DY is the firm City Council selected to take the place of MEA/Hanson) I also urge you to consider suggestions from other members of the community, especially persons with considerable knowledge on this subject such as members of the Airport Pilots Tenants Union and other residents with engineering and airport experience, as well as residents who are directly impacted by the airport.

Since we are paying for this work, deliverables would come to the City of Venice, not FAA or FDOT.  One of the deliverables would be to assist Venice in making its case for the revised MPU/ALP to FAA.  Note:  FAA does not approve the MPU, only the ALP). (FAA also approves all forecasts of the critical design aircraft and flight activity.)

All forecasts throughout the MPU need to be revised to reflect accurate data on operations, desiign aircraft, and actual economic impact from aviation/aviation businesses using approved methodology.

Operations Count:  3-4 months is sufficient given the recent counts documented by the Airport Pilots Tenants Union and the data available on flightaware.com. (The VABA does not agree that any count supplied by a community group or that does not constitute a full year count is acceptable. Further, the FAA has already approved the MEA count methodology.)

Classification of Airport/ALP:  Rwy 22 departing to the southwest is our noise abatement runway and this needs to be stressed in the plan.  Neither Runway meets all criteria for "C" class and it would not be acceptable to utilize waivers, extensions, etc. in order to classify 13-31 as a "C" when we need to stress departures on Rwy 22, our only noise abatement runway.  Any extension added to Rwy 13-31 in order to have this Runway classified as a "C" would be especially objectionable as this would encourage larger jet and plane traffic here, and, increase flying over homes in Gulf Shores, Golden Beach, Sunset Beach, etc.  RSA's, RPZ's, etc. need to be contained on the existing airfield with the exception, if neces sary, of very minor deviations for RWy 22 so that the Golf Course is not impacted. (The Runway Safety Area – “RSA” at the departure end of Runway 31 is already generally in compliance with FAA requirements. A Runway Protection Zone like designated airspace, referred to as a “Clear Zone”, has existed over the Gulf Shores section since at least 1965.  The City should enter into good faith negotiations with the owners of the Golf Course immediately to work out reconfiguring the driving range to accommodate the Runway 22 Runway Safety Area.)   Maintaining the airport for pre-dominantly privately owned single engine aircraft should be the primary objective.  Charlotte Regional Airport and SRQ, both of which are, for all intents and purposes within the same region as Venice, and very close by, serve the needs of larger aircraft owners and businesses.  The MPU should show how each of the three airports along with Buchan Field in Englewood, complement rather than duplicate each other.  Venice should not be identified as a "reliever" for SRQ.  Charlotte Regional which has longer runways is the appropriate reliever except for small aircraft.  Commercial flight training, heliocopter training, jet sales, hangars and service, "Net jets," "DayJet," etc. should be encouraged at Charlotte Regional instead of Venice. (This suggestion is clearly egregious because the City agreed in the Quit Claim Deeds by which the Airport property was transferred that it would not discriminate against any type of user of the Airport.  Should the City pursue this discrimination the FAA would surely intervene and expensive litigation would be the result.)  Recommendations for limiting these activities through lease agreements and by not adding new hangars or tie downs or control towers or instrument landing systems, etc. need to be included.  (Attempts to discriminate against any class of aircraft through lease agreements is clearly against FAA rules.) (Denying aircraft that visit our Airport the enhanced safety brought by the use of up to date services of air traffic control, instrument approaches or shelter from weather and the elements is not appropriate.)  

Recommendations for improvement of RWy 4-22 including consideration of the Airport Pilots Tenants Union suggestion for repairing the runway instead of complete re-construction should be included. (This Runway is clearly in very poor condition. If the City expects heavier aircraft to use it for noise abatement the runway needs to be in the best condition possible.)

Recommendations for mitigating and controlling soot and fumes need to be included.

Recommendations for a Comprehensive Noise Abatement Program need to be included.  Staff and the AABoard have failed to produce and implement such a program which most other airports have.  We do not need recommendations for studies such as doing another Part 150 Noise Study.  One was done 15 years ago and most of the recommendations were not followed including never establishing a Citizens Noise Committee, limiting hours for touch and goes, voluntary agreements on limits of night take offs and landings, etc.  (Our conclusion is that Ms. Lang realizes that an FAA Part 150 Noise Study must be conducted in an impartial, unbiased basis and more importantly would likely once again demonstrate that there is no noise problem at the Venice Airport that would allow mandatory noise abatement rules to be enated.  Additionaly, Ms. Lang seems to ignore the fact that, without a Part 150 Noise Study in place, any noise abatement policies or procedures developed by the City must be strictly voluntary.  To attempt to otherwise enforce such noise abatement procedures would clearly put the City at odds with the FAA.)  Assistance is needed with implementing a right turn for departures on Rw y 4 similar to Rwy 13.  This would alleviate much of the noise from Bellagio, Venice Isles, etc. without negatively impacting others because the right turn is over an industrial commercial area.  Assistance is also needed with implementing the suggested "sidestep" for departures on 31 in order to reduce impact on Gulf Shores, Golden Beach, Sunset Beach, etc.

An analysis of opportunities for new revenue for the City's General Fund by declining future FAA and FDOT grants and de-designating more of the non-aviation areas of the airport such as the Mobile Home Park and Holiday Apts, the Circus Arena property, the Golf Course, that part of Sharky's parking lot, etc. that is still airport property, should be included.  The FAA would be paid to release its liens just as was done with the Wastewater Treatment Plant/Tramonto Vista Park and other former airport deeded property.  It would appear that a reasonable price could be negotiated with the FAA and over the l ong term, the revenue from these properties would greatly surpass the cost of paying off the FAA and assuming full maintenance of the airport. (This suggestion amounts to nothing more than “Revenue Diversion”.  In order for something like this to occur, the properties would need to be appraised to determine their fair market value.  The primary indicia of their value would be the net revenues they produce as capitalized by a fair rate of return.  Accordingly, the City would need to pay the fair market value for these properties which would be invested at a similar rate of return.  This could amount to millions of dollars the City would need to raise to buy these properties from ourselves.  Does this make any sense at all???)   Revenue from aviation leases and other fees, etc. can and should pay to maintain the airport. (There is often talk that leases at the Airport must be at “Fair Market Value” to comply with FAA requirements.  While this is true, it should also be understood that FAA non-discrimination rules require that Airport lease rents cannot otherwise exceed the fair market value.)   Selling aviation fuel directly instead of receiving only 5 cents per gallon from the Jet Center would also provide revenue for the maintenance of the airport and should be considered.  (One has to wonder what Ms. Lang intends to do about the long term lease interests of the current FBO fuel sellers.  Are these folks simply to go away quietly… Or does she suggest that they should otherwise be driven away and their agreements with the City be abrogated.)

Recommendations for attracting and locating small, clean and quiet businesses which do not increase air traffic or negatively impact sensitive habitat or nearby residents, would be desirable.

Environmental recommendations that recognize and protect sensitive habitat located on airport property, and, preserve the quality of life of residents near the airport should also be included in the MPU.