IS AIREVAC MOVING?

AirEvac has asked for a permit from the City of Sullivan to construct a helicopter base next to the Hospital in Sullivan.

WHAT PLAN?

Now that we have heard from Concerned Critter and have gotten the “official” explanation of the MoDOT letter, I want to print my opinion of what it really means. 

It appears that MoDOT has been under some pressure to take a position on the closure.  I do not think that it came from the Feds, closure is off the table at this point.  It appears that outside political pressure has been introduced to get MoDOT to produce this letter. 

Take notice here that the letter simply states that they are not going to oppose.  What it does not state is that they are going to sign off on a closure plan.  What has happened here is that the city has not provided a plan; there is nothing to sign off on.   This does not mean that the city can shove any plan in front of MoDOT and the will sign off on it.  MoDOT is the same as any other governmental agency; they have to follow the law. 

I do know this; there is no support anywhere in the FAA organization for what St. Clair is trying to say is a plan, or what you would call the St. Clair concept of a plan.  It does not appear that the city has a clear understanding of what a plan is supposed to consist of, let alone have the resources to put a plan in front of the Feds.  

CONCERNED CRITTER'S EXPERT OPINION

According to Concerned Critter, the FAA is going to allow closure because MoDOT is telling them to.  That would almost make sense if the FAA wanted to close the airport.

From Concerned Critters comment, "If you want it in layman's terms, the FAA has found its scapegoat in MoDOT and now will say the airport can close on the recommendation from the state of Missouri."

5190.6b 22.3

The Administrator has delegated to ADOs and regional offices the authority to release, modify, or amend assurances of individual sponsor agreements under specific circumstances as prescribed in this chapter. ADOs and regional airports divisions do not have the authority to modify the list of assurances in a grant agreement. In addition, ADOs do not have the authority to effect a release permitting the abandonment, sale, or disposal of a complete airport. (See Order 1100.5, FAA Organization - Field, issued February 6, 1989.)

22.20. Release of Entire Airport.

a. Approval Authority. The FAA Associate Administrator for Airports (ARP-1) is the FAA approving official for a sponsor’s request to be released from its federal obligations for the purpose of abandoning or disposing of an entire airport before disposal can occur. That authority is not delegated. A copy of the sponsor's request, including related exhibits and documents, and a copy of the FAA Airports regional statement supporting and justifying the proposed action shall be provided to ARP-1.

If you want it in layman’s terms, the airport is not going anywhere until the ARP-1 says it is.  That means that closure is off the table until the ARP-1 says the airport is being operated the way the FAA says it will be operated.  The city if they want to continue with the closure will have to prove that they are following all the rules. 

This is one of the rules.

NOTE: Only benefits to the airport may be cited as justification for the release, whether tangible or intangible. The nonaviation interest of the sponsor or the local community – such as making land available for economic development – does not constitute an airport benefit that can be considered in justifying a release and disposal.

In layman’s terms, the airport property will never be turned into a strip mall. 

CANDIDATES DISSAGREE ON AIRPORT FUTURE

I find it difficult to digest this article in the Missourian. It almost made me throw up. Id be interested if this was a joint forum or if these guys were interviewed separately, I’m betting these were separate interviews. Someone please correct me if im wrong.

How appropriate that the great Mayor Blum gets to counteract every comment from the opponent “Ramon”. Its almost disgusting the favoritism Domke gives Blum in this article.

The citizens of St Clair deserve so much more than being force feed by Domke and the Missourian.

This airport isn’t going anywhere soon and if Childers is ready to send a letter saying all compliance issues are taken care of then so be it but he has no idea what compliance is about and he is about to find out from the Federal side. He and Domke are just a mirror puppet in Blum’s game.

3,4,5

April 10. MISSION 2.  Diest-Schaffen, Belgium

This was a lot easier than the first one, a six-hour flight We were only over enemy territory about two and one-half hours The overcast caused us to miss the primary target and we unloaded on the secondary, an aircraft assembly plant.

 Flak was light.

 We were briefed for 33 guns at the target but received no battle damage to “The Erie Ferry.”
We encountered no fighter opposition had very good fighter escort and saw no ships go down.

April 11. MISSION 3. Sietttn, Germany

Today we had it rough our primary target was Posen. Poland.  We missed it and hit the secondary, an aircraft assembly plant in Stettin, northeast Germany
The fighter support was inadequate, with no help from the Danish coast to the target and back to the Danish coast Jus before bombs away we were attacked by 12 ME, 110’s They made two frontal passes, sweeping under our formation T- did not knock down any of the ships in our group but a plane went down from the group directly behind us.
Flak was heavy over the target — 60 guns — but our ship received no battle damage. We were flying zero-one-three. One of the 332nd squadrons ships.
As we entered Germany one of our Forts aborted for Sweden with number one and number two engines knocked out by coastal flak
On the way out Vaughn’s ship went down He Just made e Danish coast, hot two of his boys bailed out over the Baltic Sea A fire was seen in the middle of the ship.
Donald Cash’s crew, that we trained with at Dalhart, went down on this one. We learned few days later.  They came across and started flying the same time we did, so it must have been one of their first five raids On that crew were Lt. John F. Harris pilot Lt Milton V. Wilson, co-pilot; Flight Officer John Marchetti, navigator; Lt Jim B Goodner, Jr bombardier; S ‘Sgt Thomas 0. Obechina, _engineer: S/Sgt. Clinton M. Gill, radio operator-gunner Sgt Edward A. Braun gunner, Sgt Jennings A. Ball, gunner; Sgt. Roger W. Fuller, gunner, and Sgt Donald L. Cash, gunner.
Some time later Fred received a clipping from his folks, taken from the Pekin Ill. Times, concerning this crew, this raid and this war.  The clipping carried a two-column picture of Cash’s crew, taken at Dalhart, and a sort of editorial which read:
“Sometimes I wonder if we appreciate the SIZE of the battle that is NOW going on over Europe.

I mean the air war.
The world was shocked by Tarawa
Worst death toll in Marine history.
Even a book has been written about it
Say — a battle as costly as Tarawa is going on nearly every day in the air over Europe.
See that picture above”
Take a good look at the man standing on the right hand end of the line
He’s a Pekin boy, just 21
Sgt Roger Fuller.
Last week is parents. Mr. .and Mrs. Dwight C. Fuller. 1220 Charlotte Street, got word that he had
been “missing in action since April 11.”

We checked up in back copies of the Times and found that 64 bombers had been lost by the U.S Air Force alone that day.

April 12. MISSION 4. Augsburg, Germany

This was to be a tough one but the mission was abandoned just after we got over France, because of bad weather and low thick clouds.
We went to bed thinking we would get credit for the mission. When we went down to the operations shack the next morning, however, there was a notice on the bulletin board’ ‘No credit for mission of 4-12-44.” Third Division Headquarters had rescinded the credit.
But on April 16, four days later, another order came through giving us credit for the mission after all. We were very glad to hear this.

AprIl 13. A Close Call for Crew 69

The thirteenth was an unlucky, or in another sense, a very lucky day for Crew 69.   On the way to Augsburg again, we got hit by three 50-caliber machine gun bullets. Some guy in another 17 in the formation was a touch careless with his test firing We always test fire the guns soon after leaving England
One of the slugs came through the nose of 493, barely missing Counihan and ripping through Getz’ pant leg, grazing the skin.
Another bullet knocked out a quarter of the ship’s oxygen supply.
The third was a tracer bullet. It started a fire in the wing, which put itself out a little later. If the tracer had been the one which tore into the oxygen system we might have blown up, they said
We aborted from about half way across the Channel, therefore received no credit for the raid McMeekin’s crew, who shares Hut A with us, claims that Lt. Wertsch is bad luck for their ship, 493. He flew his first mission in it as Mac’s co-pilot with Mahathey flying left waist. They caught a lot of flak and lost the hydraulic system. It was in the hangar for a couple of weeks and then we happened to get it the day it came out We really fixed it up good this time Since the left wing cannot be replaced they have decided to junk the ship.  A lucky day for Getz and Crew 69.

The boys from the PRO — public relations office — took Getz’ picture with his pant leg ripped open to show what a close call he had. The picture appeared in lots of stateside newspapers, especially in sunny Cal. The caption they wrote for the picture was dramatic as hell, even if it didn’t pay a great deal of attention to humdrum facts The caption read:

A bullet from a German fighter plane cut the leg of his trousers 

MODOT LETTER

March 22, 2013
Mr. Jim Johnson
Airports Division Manager
FAA Central Region
901 Locust
Kansas City, MO 64106

Re: St. Clair Regional Airport

Dear Mr. Johnson:

For the past several years, the City of St. Clair has pursued closure of the St. Clair Regional Airport. During this time, MoDOT worked closely with the Federal Aviation Administration and the City to identify alternatives to closure, but these efforts have not impacted the City’s desire to close the airport.
Because the City has made its desire clear, MoDOT will not oppose the City’s request to close the airport. However, all federal airport closure requirements must be met by the City.
Sincerely,

MODOT letter

"https://skydrive.live.com/embed?cid=7E9617C9B830E108&resid=7E9617C9B830E108%21259&authkey=ANEq6Olh9DZj5SI"
If anyone would like to read the letter from MODOT to St Clair that seems to be confusing. These are the Compliance issues that need to be fixed first. Then the letter from MODOT

"https://skydrive.live.com/embed?cid=7E9617C9B830E108&resid=7E9617C9B830E108%21279&authkey=AGpFdm9KmtYAcLw"
Obviously the english major forgot to read the second line on the second paragraph.

Definition of COMPLIANCE

1

a : the act or process of complying to a desire, demand, proposal, or regimen or to coercion

b : conformity in fulfilling official requirements

Looks like more of I told you so than they are siding with the city to me.

The Thirty-Two Missions

Easter Sunday, April 9, 1944.

MISSION 1. Warnemunde, Germany.

On April 9, 1944, the nation observed its third wartime Easter. For many U.S. servicemen, it was a day of war, rather than one devoted to the remembrance of Christ.
On Easter Sunday, 1944, we flew our first combat mission as Crew 69 of the 94th heavy bombardment group, U.S. Eighth Air Force,
from a base near Bury St. Edmunds in West Suffolk, southern England; we took off before dawn for a daylight raid on five targets in northern Germany and Poland. In one of the deepest penetrations made by the 8th Air Force up to that time, an estimated 500 to 750 American B-17 Flying Fortresses and B-24 Liberators with nearly 1,000 escorting fighter planes made a wide sweep over the Baltic Sea.
The Forts and Liberators bombed aircraft factories in Poseri, Poland and Four other cities north and northeast of Berlin. Pilots of the escorting Mustang, Lightning and Thunderbolt fighter planes reportedly shot down 20 Nazi planes in an air battle and destroyed others on the ground at
German airfields.
For Crew 69 it was a nine-hour mission, four hours on oxy gen at 25,000 feet, five hours over enemy territory. We got some close flak over the target — an aircraft factory at Warnemunde — but some of the more ‘experienced fliers termed it “just medium.”
We had good fighter escort all the way and saw no enemy fighter planes. Other bomb groups which made the deeper penetrations to Posen, Poland; Gdynia, the Polish port near Danzig; and Marienburg told of fierce, opposition in some instances and placed the number of enemy interceptors at about 600 planes.
Posen, about 150 miles east of Berlin, Was the site of large manufacturing plants for Focke-Wolf fighter airplanes relocated there from German cities to escape destruction. German military men had claimed the city was out of reach of allied bombers It had never been attacked.  
A communiqué issued by Lieut. Gen. Carl A. Spaatz’ Strategic Air Forces headquarters said- that Focke Wolf plants in all Five of the target cities were bombed in clear weather. The plants were described as interrelated factories that constituted a vital production complex for single-engine fighters of the Luftwaffe.
To reach their targets the American bombers crossed and re-crossed the most heavily defended parts of Germany and proved that hardly an acre of Hitler’s fortress was sate from daylight bombing raids.
After nine hours in the air, Crew 69 landed back at its base in England with one mission completed and 31 more to go.
The United States that day lost 31 heavy bombers and eight fighters. Some 318 American fliers were dead or missing in action. Many others were wounded.
We had no way of knowing how many Germans were dead or injured because of the bombings.
That was Easter Sunday, 1944. 

LEADING LADY PREFACE

Fred Arthur Muehler told me these stories in his own words; we went over them mission by mission. 

Part I

By Preston P. Clark. Jr.

PREFACE

These are pages from a gunner’s diary They were written at a U.S. Air Force base in England during the spring, summer and fall of 1944 The story actually began in November, 1943, when ten Americans in their teens and 20’s, trained in various specialties of aerial warfare as practiced on heavy bombers, were brought together as a combat crew for training at Dalhart Army Air Base, Dalhart. Texas.

Unfortunately the diary does not date back to those days at Dalhart. Let it suffice to say that it was snowing cats and dogs when we got there, we were snowbound on Christmas day, and we saw nothing but snow below all the way to Nebraska when we flew away in February.

At the Point of Embarkation, Kearney, Nebraska, they gave us a new crew number — 165 — another clothing check and several more health, security and survival lectures It was blowing up a snow storm when we taxied out and took off from the Kearney strip headed for New England We called at Grenier Field. N.H. and Presque isle, Maine, then hopped up to Goose Bay, Labrador, across to Iceland, and then over to Prestwick. Scotland. 

Fred often rode just behind the pilot and co-pilot seats, and told me that when they took off it was snowing so hard that they took off on instruments, because they could hardly see the runway.   After they got off the ground, air traffic control told them to come back and land, due to the weather, the pilot refused to do so, he would have never found the field, so they went on to Scotland.

We left our airplane at Prestwlck and rode an English train down to a U.S. Air Force staging base. “Somewhere in England ‘The whole crossing from Dalhart to England covered only about a week even with the time lost eating, sleeping and briefing at the various way stations.

The enlisted men were sent from the staging base to The Wash, over on the southeast coast, for a bit of brushing up on 50-caliber machine gun marksmanship. We never did find out what the officers were doing those two weeks, but general consensus was that they were holed up in some swank London boarding house, enjoying their last, fast-fading days as non-combatants.

We finally got a reprieve from The Wash and headed south again, arriving some five hours after at the typical little English town of Bury St Edmunds. The picturesque hamlet got its name from the boy King of East Anglia. Name of the town was switched from Beodericsworth (“full of happiness and prosperity”) to St. Edmund’s Bury where St. Ed was laid to rest there in 987A.D. –

The officers must have grown tired of London, or wherever they’d We found them awaiting our arrival at the base, some six miles or so gut of Bury, at a little wide place In the road called Rougham.

We found that we bad become Crew 69 of the 410th Bombardment Squadron, 94th Bombardment Group (Heavy). We were assigned bunk space In one of the Nissen huts, which looked like giant oil drums cut in half down the middle with the oval side up The 94th was scattered about over some eight or ten square miles of thickly wooded southern England We thought at first we’d landed in the middle of  Sherwood Forest. It was a beautiful place, at its freshest and greenest when we arrived.

We didn’t have much time to enjoy the scenery. They put us right to work. We got there in March, just when the cold days of English winter were fading into the good-flying- weather days of spring We arrived about the time they ‘started sending the heavies over in lots of 800 to 1,000, with an equal number of fighters to go along for protection. Every time the weather was clear enough they were sending out a maximum effort — all the ships they could put into the air.’ Idea was to destroy German resources and to weaken the enemy in every way possible so that the invasion of the Continent, which came four months after our crew reached England, would have the best possible chance for success.

We started out flying an old olive drab colored Fortress named “The Erie Ferry.” It was number 653 Then we flew a couple in number 180, “The Eagle’s Wrath,” before we were assigned an airplane of our own.  They gave us a shiny silver new B-17G. It was the pride of the U.S Air Force (notwithstanding opinions of the average 8-24 crew member to the contrary) and they called it the Flying Fortress because It fairly bristled with 50-caliber machine guns — 12 of them. The Fortress could carry 10 tons of bombs and had a range of better than 3.500 miles. Her wing span was 103 feet 9 inches her height, 19 feet 1 inch and she measured 74 feet 9 inches from nose to tail Loaded; she weighed 65.000 pounds, and empty, approximately 35,000. She got the tremendous power to carry all that weight from four 9- cylinder. 1,200 horsepower Wright Cyclone engines never let an airplane engine be called a motor).  Her top speed was 300 miles per hour; she cruised at about 225 most of the time.

When we started trying to choose a name for the new 17 it was about as big a problem as naming a new baby.  We surveyed the ships around us and noted these names Tuff Eddie. Idiot’s Delight. Airborn Spare. Mighty Warrior (Gagon’s crew), The Gimp (Stopulos’ crew in the 9lth). Dutchess, Frenese I and II, Gremlin, The Shady Lady. Fortress McHenry. Morgan ’s Raiders, My Asam Dragon. The Rebel Queen, Mission Mistress, Flak Buster. Rosie, Joker. St. Christopher’s Kids. Friday 13th, The Latest Rumor (Bavtos’ crew in the 100th), Nick’s Place, Shack Bunny (385th). Puddin, The Better Half and Old Hound Dog.

By the time we got a ship of our own, we had been shifted to another squadron as a Pathfinder (lead) crew.  That’s what really suggested the name we chose lot our new ship, number 668. We christened her the “Leading Lady,” and had the name painted on both sides of her nose in script two feet high. We flew her on a lot of rugged raids and she took a lot of battle damage, but she was still operational when we left England. Last we heard of her they said she’d gotten too old to lead the way so they took the Mickey (radar) equipment out of her and made her a wing ship in the 385th Bomb Group. After the Lady had given up the best flying hours of her life and sustained terrific battle damage, they had to stick her back in the rear end of a strange squadron in a strange group. With “Leading Lady” painted on her nose in letters two feet high.

One more paragraph of preface, and then the diary.  

The members of the crew about which the material was written were:

V. Allan Wertsch, pilot. Delevan, Illinois.

Ralph S. Taylor, co-pilot. Grande Lodge, Michigan.
Richard P. Getz, navigator, San Diego.
Mark J. Counihan, bombardier, Iron River, Michigan.
John S. Stepanski, Jr., Mickey navigator, Detroit.
Fred Arthur Muehler, engineer and top turret gunner, Pacific, Missouri
Cecil R. Mahathey, assistant engineer and left waist gunner, Winston-Salem, NC.
Lloyd Elliott, radio operator-gunner, Bakersfield, California,

 Preston P. Clark. Jr.  Gunner. Abilene, Texas.
In addition to these there was a lad named Alfred Beacon a Bostonian, who was a member of the original crew, from Dalhart until about the time we reached England. He was replaced by a Polish boy named Ted Kosinski. who was with us from Wash days until we became a lead crew Then there was a kid from Staten Island on the original crew whose r.ame was Lawrence Dunn We never called him anything Larry He was the ball turret gunner and stayed with us we became a lead crew arid got the radar hat in place of e bail turret  The diary is reproduced on the following pages,  just as it was first written It is the mission-by-mission account of the  Operational Tour of the “Leading Lady,” a great airplane, and of the crew who flew her, a great bunch of guys. 

NEW HANGARS AT WASHINGTON

$180,000 investment by the city of Washington, and will pay off in 4 years.  That is how an airport is supposed to be operated.  One of the most profitable public projects by the city.  WOW!!  The best part is that they are less expensive than hangars at St. Clair which has no fuel, courtesy car, mechanics, terminal, or indoor plumbing.

Notice the name Muehler.  That was Art Muehler from Pacific Missouri.  He was the top turent gunner and crew chief.  They did not have a belly turent, but was outfitted with a radar pod in the place of the belly turent.   They were the backup b-17 for the entire 8^th air force over Europe.   There is a diary of all 33 missions that his crew flew, and I will try to get a copy and put some of the missions on the blog.  The plaque is at the tower memorial in Rougham England.

Concerned Critter

After reading the comments to the previous post, I have to respond to Concerned Critter.  I don’t understand where you get the idea that the tenants are trying to handcuff the city, or trying to hold the city hostage.  The tenants have no voice in the Federal laws and FAA rules.  The airport was handcuffed to these rules when they accepted Federal Grants, many years ago.  Blaming he tenants is ridiculous.   

The tenants did not start this “discourse” or whatever you want to call it. What is obvious also is that the anti airport people think the tenants are “bad people” because we won’t just walk away and give the airport up to the city.  Again it will make no difference to the FAA if there are fifty tenants on the airport, or no tenants at all.  What they will figure out, is that if there are no tenants on the airport, something is wrong at the airport.  If there are empty hangars, something is wrong at the airport.  If the city is not pursuing aviation development, there is something wrong at the airport.   There is no plus side for the city to try and force tenants off of the airport. 

It understandable that the city is trying to prove that the airport is not needed, But that only makes sense to someone outside of aviation, and inside St. Clair.  To anyone else, and that includes the FAA, MoDOT, AOPA,NBAA, EAA, The OIG, and the United States Congress, and many, many people that just think aviation is great, AND to anyone who has read the rules, it make absolutely no sense at all.  

The argument by the city, that the airport should be allowed to close under the present circumstances implemented by the city, actually proves that the city is not following the rules laid out for them by the FAA.  But, you would have to have an understanding of those rules in order to understand why.   Do not comment to this and claim that the city is following everything that the FAA has told them without reading the rules for yourself, and doing so, will only prove that you do not know the rules.   

This post is to reply to St. Clair All the Way.

In the first two comments, St. Clair All the Way refers to MIRMA.  “The man there said that since the city does direct personnel to work at the airport for maintenance, it's fair and reasonable that the city charge back a percentage to the airport. The man said if the city did not have an airport, its rate would decrease.”

“MIRMA has said since St. Clair has no payroll specifically directed to the airport, it can be difficult to determine what percentage directly would go toward the airport, but 5 percent is a reasonable amount. That is from MIRMA, not the city.”

In the next two comments St. Clair All the Way adds this.

“Since the city is now following the recommendations of MoDOT and the FAA, there's no beef anymore with the city there either. Your beef is with MoDOT and the FAA.” And later states “since the city is following the advice of MIRMA, MoDOT and the FAA, your beef now is with MIRMA, MoDOT and the FAA.”

It appears that St. Clair All the Way has information from the Feds on this issue. 

The following is from Joe Pestka at MoDOT

September 23, 2010

The Honorable Ron Blum. Mayor

City of St. Clair

#1 Paul Parks Drive

St. Clair, MO 63077

Dear Mayor Blum:

Re: St. Clair Regional Airport

Informal Complaint Review

In late 2009 and early 2010, our office received an informal complaint from a tenant at the St. Clair Regional Airport. The informal complaint concentrated on four areas. These areas included:

• Insurance costs for the airport

• Potential revenue diversion from the airport

• Potential revenue collection for a sewer lift station located at the airport

• Land use compatibility around the airport

In early 2010, our office requested information from the complainant and the City of St. Clair concerning these four issues. Our office has reviewed the information that was provided and is offering the following assessment.

Insurance costs for the airport.

Based on a review of information provided by the City and the complainant, insurance for the airport is provided through the Missouri intergovernmental Risk Management Association (MIRMA). MIRMA provides a listing of municipalities that own airports and have separated those into airports that sell fuel and those that do not sell fuel. MIRMA also publishes an “Airport Premises Renewal Hinder” that provides information on those municipalities with airports.

In reviewing information provided by the complainant, the City has presumably charged for insurance for some years and sonic years has not. Our office would recommend that the City of St. Clair have further discussions with other municipalities that have airports that do not sell fuel and determine how those municipalities establish their insurance costs for the airport. This will allow the City to develop an annual reasonable cost for airport insurance that is consistent in terms of actual cost compared to value received. This will also enhance the airport budget planning process.

Potential revenue diversion from the airport

On March 27. 2008, the City of St. Clair submitted a Sponsor Questionnaire — Airport Compliance Status to our office that stated all revenue produced on the airport was not applied toward the operation, maintenance, and development of the airport. If this is the case, this may result in a violation of the Revenue Use Policy and grant assurance 25, Airport Revenues. The City should identify any funds that may have been used for purposes other than the operation, maintenance and development of the airport. Please submit detailed information to our office and include an itemized listing of all revenues and expenses, with all applicable documentation to support your conclusions. As you are aware, per Federal Aviation Administration (FAA) grunt requirements, the City, under contract with the Federal government, has agreed to use airport generated funding for the operation, maintenance and development of the airport.

Potential Revenue Collection for the Sewer Lift Station

The airport must receive fair market value for non-aeronautical facilities located at an airport. In reviewing the information provided by the City, I could not find or determine the rental amount for the sewer lift station. If this area is not collecting rent for the airport, the City must do so by establishing an annual fair market value rental charge for the sewer lift station and deposit those funds into the airport’s operating account. The determination of fair market value can be accomplished through a professional assessment.

Airport Sustainability

The MoDOT Aviation Section is participating with other aviation industry representatives in the preparation of a guidebook to assist political subdivisions in the development of a General Aviation Airport Business Plan. A business plan can assist airport owners in the short and long term sustainability of the airport and can allow the airport to respond accordingly in financially challenging times. Once the study is completed, our office will forward you a copy.

Based on information provided by the City for their 2009 revenue and expenses for the airport, it is possible for the airport to sustain itself if management and operational practices were executed in accordance with Federal Aviation Administration guidelines and circulars and in compliance with federal grant obligations. Our office is available to assist the City with any questions related to the airport and can provide FAA documents related to compliance with Federal grant ass assurances.

Our office will await the submittal of the requested information in this Letter. Please feel free to contact our office if you should have any questions.

Here you have MoDOT telling the city that the airport would be selfsustaining if the city was following the rules. 

The city’s response to the MIRMA issue is as follows, “FAA is fully aware of what we charge them and we have not received any complaints from them.”  This statement was made more than a year after the MoDOT letter. 

This really does not sound like MoDOT and the FAA signed off on the insurance plan.   Just because they have not heard from the FAA does not make it legal.

What to do in St Clair ???

If I were looking for a $150 dollar hamburger, used to be a $100 where would I go?
K39 St Clair Airport. click the link to see what pilots see when they are looking for a place to go.
http://www.aopa.org/airports/K39
Are these the only thing so see near St Clair Airport? It's FREE to list your business, you can't beat FREE!
This data is provided by the city and businesses. Is the administration not proud of what the city and and surrounding area has to offer, what about the chamber ??? There should be 50 listings here. Is there nothing to eat, shop, golf, B&B, recreational activities or places to stay in St Clair. Why not promote the local already established businesses in St Clair, instead of selling them out for Big Box store who they can't even name. In my opinion St Clair is not about Big Box store, it's about people. Dumke and the Misserian always end their articles with "none of the pilots live in St Clair" who cares, we like St Clair and the people there, otherwise we would just leave. Don't you think others would too??? Do you want St Clair to look like north county with abandoned businesses and shopping centers??? Small town friendliness and hospitality are the assets. They are The Crown Jewel of St Clair, not Big Box store.

AIRPORT INSURANCE COST

The following is from the city minutes concerning airport insurance cost.

Administrator Childers answered 2012 was $7,904 and we are anticipating $9,000 in 2013.

“The budgeted number is $6,900, and in 2011 it is $6,736 to date which is a split of 50% of the

general fund, which is 45% Administration, 5% Airport, 10% Parks, 20% Water and 20% Sewer.

How does that break down?  Total insurance cost   would be   $158,080.00

Administration          $71,136.00

Airport                      $7,904.00

Parks                      $15,808.00

Water dept.             $31,616.00

Sewer dept.             $31,616.00

MIRMA airport cost for St. Clair in the 09-10 year was $1515.  Airports like Down Town Parks have experienced a decrease in insurance cost for the past three years.   

MORE FROM THE FAA ON HANGAR RENT

This is from the previous post, “THE FAA ON HANGAR RENT”.

In order to demonstrate compliance with federal grant obligations, a corrective action plan is required which documents that the City’s current lease agreement with AirEvac is consistent with the City’s rental structure for businesses operating at the Airport. An acceptable corrective action plan would also include a City commitment to modifying its lease with AirEvac at the next available opportunity to include an escalation provision which would increase AirEvac’s rent at the same rate as the other airport tenants in order to work towards achieving airport self-sufficiency.

After reading AirEvac’s lease I do not think the city can raise their rental rate.   I have read decisions in the part 16 database where the FAA could not enforce a change in a signed lease.  The Airevac lease might have an automatic renewal, and an increase apparently must be mutually agreeable between the two parties.   So if Airevac does not agree to an increase, it looks like the city cannot push the issue.  Who knows?

 So as it stands now, if the city can raise the Airevac rate, Airevac and the city must mutually agree on a lease rate, but the fixed wing tenants do not have that option.  The mayor stated in the last meeting that the city sets the hangar rates, not the tenants, but that does not apear to be true for Airevac. 

For your reading pleasure

Just in case you were wondering where all of our information comes from you have to do a little reading. Below are links to the FAA and a skydrive which the city should have read before wasting sooo much money and all of the letters the city has recieved from MODOT and the FAA.

First, all the rules
http://www.faa.gov/airports/resources/publications/orders/compliance_5190_6/

Research

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ALP Airport Layout Plan

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Letters

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THE FAA ON HANGAR RENT

December 21, 2012

Mr. Rick Childers

City Administrator

City of St. Clair

# I Paul Parks Drive

St. Clair, MO 63077

Re: St. Clair Regional Airport

Informal Complaint Regarding Hangar Rates

Dear Mr. Childers:

I have received your December 10, 20 1 2 response to the informal complaint regarding the City’s 2013 hangar rental rates. MoDOT and the Federal Aviation Administration (FAA) have reviewed the City’s response to the informal complaint and have determined that the information provided in the City’s December 0, 2012 letter is not sufficient to ensure the City’s compliance with federal grant assurances. The purpose of this letter is to provide the City with guidance to ensure compliance with federal grant assurances and to set forth a timeline for the City to achieve voluntary compliance.

Informal Complaint

The informal complaint asserted that the 201 3 hangar rental rate ($300/month) is unjustly discriminatory and unreasonable, and that the City has discriminated against fixed wing tenants at the airport by raising the rent for hangars, while not raising rent for AirEvac Life Team during this same time period. The informal complaint also asserted that the City’s hangar rent for 2012 was higher than hangar rent at comparable nearby airports.

City Response

In its response, the City indicated that the Board of Aldermen directed City administration to “secure user funds sufficient to cover the full cost of operation, maintenance, insurance and management of the St. Clair Regional Airport” and as a result, 2013 hangar rental rates were set at $300/month. The City’s response confirmed that AirEvac’s rent will not increase in 201 3, because AirEvac’s lease is structured as a five year lease and is not due for renewal until 2015. The City also noted “there is no basis for comparison between fixed wing and  

Mr. Rick Childers

Page 2

December21, 2012

rotary wing aircraft operations or field requirements”, nor is there any requirement that the City’s “rental rates and other charges be ‘competitive’ with other airports, only that they be justified to enable the airport to operate on a self-sustaining basis.”

Overview of Lease Review Process

In its response, the City also noted that it could find “no reference to responsibility or authority for the establishment of rental rates by any entity which supersedes or takes precedence over the local governing authority.” The City is correct that MoDOT and the FAA do not have the authority to establish hangar rental rates at the Airport; see FAA Order 5 1 90.6B ¶1 2.4, which states “The FAA does not approve leases, nor does it endorse or become a party to tenant lease agreements.” However, ¶12.3.a. states that when a lease is reviewed, the FAA must determine if a lease has the effect of granting or denying rights that are contrary to federal statute, sponsor federal obligations or FAA policy and identify terms and conditions that could prevent the airport from realizing the full benefits for which it was developed.

As part of the lease review process, the FAA must ensure that “(a) the sponsor maintains a fee and rental structure in the lease agreements with its tenants that will make the airport as self- sustaining as possible and that (b) the facilities of the airport are made available to the public on reasonable terms without unjust discrimination” (see FAA Order 5190.6B ¶12.5). This letter will evaluate each of those components.

Self-Sustainability

In its December 10 response, the City indicated that it set its 2013 hangar rental rate at $300/month in order to cover the full cost of operation, maintenance, insurance and management of the Airport, but the City did not provide any additional information or documentation on those costs. While the City provided some documentation regarding Airport expenses as part of the Office of Inspector General hotline complaint investigation, the information provided was not comprehensive. Without current information on the City’s costs to operate, maintain, insure and manage the Airport, MoDOT and the FAA cannot determine whether a rental rate of $300/month would cover Airport expenses without creating a revenue surplus. FAA Order 51 90.6B ¶17.10 notes that “fees for the use of the airfield generally may not exceed the airport’s capital and operating costs of providing the airfield.” Please provide current documentation of the City’s costs to operate, maintain, insure and manage the Airport so MoDOT and the FAA can confirm that no revenue surplus will be created based upon the 2013 hangar rental rate.

Other factors relating to self-sufficiency must also be considered when establishing rental rates, Airport sponsors “must maintain a fee and rental structure that in the circumstances of the airport makes the airport as financially self-sustaining as possible” (see FAA Order 51 90.6B ¶1 8.22.a). This requirement “recognizes that individual airports will differ in their ability to be fully self-sustaining, given differences in conditions at each airport” (FAA Order 5190.6B ¶17.5).

Mr. Rick Childers

Page 3

December21, 2012

The informal complaint asserted that comparable hangar rental rate at neighboring airports ranged from $125/month to $140/month. As part of the investigation of the informal complaint, MoDOT verified that the Washington Regional Airport rents single t-hangars for $ 140/month and that the Washington County Airport, the Sullivan Regional Airport and the Cuba Municipal Airport all rent hangars for $125/month.

The City is correct that there is no federal requirement that hangar rental rates remain “competitive” with those at other airports, but if hangar rental rates are set at a rate that causes current tenants to terminate their leases for less costly options at surrounding airports, such actions would essentially price the airport out of the market and would hinder the sponsor’s ability to become as self-sustaining as possible.

As part of the investigation of the Office of the Inspector General hotline complaint, copies of leases at the Airport were provided. Since 2005, monthly fee for hangar rental in the City Hangar has increased by over 45% (from $120/month in 2005 to $175/month in 2012), and will have increased by 150% when the 2013 hangar rental rates go into effect. During that same time period, AirEvac’s rent has remained unchanged at $300/month, which will be discussed in further detail below.

In order to demonstrate compliance with federal grant obligations, a corrective action plan is required which documents how the 2013 hangar rental rate will allow the airport to become as self-sustaining as possible under the circumstances. An acceptable corrective action plan would include documentation identifying the City’s expenses for airport operation, maintenance, insurance and management, as well as documentation confirming that the proposed hangar rental rate will not ultimately hinder the Airport’s ability to become self- sustaining by pricing its hangars out of the market.

Facilities Available on Reasonable Terms Without Unjust Discrimination

When reviewing leases, FAA Order 5190.6B requires the FAA to also evaluate whether airport facilities are made available to the public on reasonable terms without unjust discrimination.

FAA Order 51 90.6 B ¶[9.2.a states that

For facilities that are directly and substantially related to air transportation, regardless of whether an air carrier or user is a tenant, subtenant, or nontenant, the sponsor must impose nondiscriminatory and substantially comparable rates, fees, rentals, and charges on all air carriers and users that assume similar obligations, use similar facilities, and make similar use of the airport. Aside from rates, fees, and rentals, the sponsor must also impose comparable rules, regulations, and conditions on the use of the airport by its air carriers and users, regardless of whether they are tenants, subtenants, or nontenants.

Mr. Rick Childers

Page 4

December 21, 2012

In its response, the City stated that there was no basis for comparison” between the fixed wing tenants and AirEvac Life Team. The City stated that AirEvac requires no runway access (although it is MoDOT and the FAA’s understanding that AirEvac uses the runway for its approach), provides its own landing lights, and requires no City maintenance activities, while the fixed wing tenants “have required and been the recipient of nearly all upgrades and expenses the City has ever undertaken at the airport.” The City stated that AirEvac provides a critical service which serves a community benefit, while the fixed wing tenants “provide no benefit to the community in any form”. The City noted that AirEvac was a business actively recruited by the City, while the fixed wing tenants do not conduct business, that AirEvac has a constant presence at the airport, which provides additional security, while the other tenants are only at the airport infrequently, and that fixed wing tenants’ leases are annual, while AirEvac has a five year lease, next due for renewal in 2015.

The differences between AirEvac and the fixed wing tenants at the Airport are apparent, and these differences could substantiate different rental structures for businesses operating at the airport and for other fixed wing tenants. However, the City has not provided any documentation outlining its rental structure for businesses operating at the airport, and without such documentation, MoDOT and the FAA cannot determine whether AirEvac’s current lease agreement is consistent with such rental structure.

While different rental schedules can be utilized for differently situated tenants, having no increase in rent for a tenant since 2005, regardless of whether that entity is receiving some sort of business entity consideration, raises additional compliance issues.

FAA Order 51 90.6B ¶J9.5.e. states that

Ground leases with terms of five (5) or more years should contain an escalation provision for periodic adjustments based on a recognized economic index. This will facilitate parity between new and established lessees. An escalation provision also helps the sponsor comply with Grant Assurance 24, Fee and Rental Structure, which requires the sponsor to make the airport as self-sustaining as possible under the circumstances.

Entering into business entity leases with a five year term and no escalation provision while increasing hangar rental rates for other airport tenants 150% over the same time period raises questions regarding unjust discrimination against fixed wing tenants, as well as self- sufficiency issues. While MoDOT and the FAA understand that the City’s current lease with AirEvac is not subject to renegotiation until 2015, the City has not indicated that it intends to increase AirEvac’s rent at that time as part of its effort to become self-sufficient.

In order to demonstrate compliance with federal grant obligations, a corrective action plan is required which documents that the City’s current lease agreement with AirEvac is consistent with the City’s rental structure for businesses operating at the Airport. An acceptable corrective action plan would also include a City commitment to modifying its lease with AirEvac at the next available opportunity to include an escalation provision which would 

Mr. Rick Childers

Page 5

December 21, 2012

increase AirEvac’s rent at the same rate as the other airport tenants in order to work towards achieving airport self-sufficiency.

Please provide a final and comprehensive corrective action plan addressing the items herein within 60 days of the date of this letter in order to ensure that the City is not found to be in informal noncompliance status. It may also be beneficial for the City to meet with the current airport tenants to discuss the 2013 hangar rental rates in an effort to resolve this informal complaint.

MoDOT would be happy to work with the City in its pursuit of an acceptable corrective action plan. We are available to meet with the City at any time to discuss these issues in further detail and to identify steps the City can take to ensure future compliance. If you have any questions, please do not hesitate to contact me.

Sincerely,

Amy Ludwig

Administrator of Aviation

cc: Mr. Jim Johnson, Federal Aviation Administration

Ms. Lynn Martin, Federal Aviation Administration

Mr. Ed Hassinger, Missouri Department of Transportation

In 2006 or there abouts the city signed a grant agreement with the FAA to resurface the runway.  This was a 5/95 program.  5% of the money had to come from the sponsor.    This was started back in the late 90’s and according to MoDOT the runway overlay was going to happen even if St. Clair applied for the grant or not.   The ALP was expensive we don’t know how much was spent on it, but it was a requirement for the AIP grant, program.   

If this airport had been operated by a sponsor that understood the obligations, and the opportunities, St. Clair would have 100 aircraft on the field at the present time.  The city cannot prove that they understand their obligations, have a plan in place, and are carrying out the obligations, which basically makes them in violation of everything.  This is going to be a hard lesson for the city to learn, but they will learn it.  MoDOT also told the city that if St. Clair would come up with a project, it would be funded.   That leaves out the uncertainty of obtaining grants.  

Over the years land was purchased with Federal grant money, which means that the land and all its appurtenances, that means everything attached to it, are under the grant obligations forever.   Also the city signed special grant assurances for the operation of the lighting, and for the land.  I have not seen these, but they are referenced in the grant documents. 

This is page 2 of the ALP.  When St. Clair was told  by the FAA to come up with a plan, it would be understandable to think that something similar to this is what the FAA is expecting from the city for the Washington and Sullivan airports.  You do not spend the feds money with out a plan  ON PAPER. 

This is similar to what the city sent the Feds ion their closure dcumentation, and then stated that their was no room for expamsion of the airport. 

ARTICLE ON THE TENATS LEASE

Ron Blum stated that the city was trying to follow the law as best we can here. 

In past determinations, the Director has consistently applied a general standard of compliance to the airport specific circumstances in all compliance cases. This standard is found in the Order:

The judgment to be made in all cases is whether the airport owner is reasonably meeting the Federal commitments. It is the FAA’s position that the airport owner meets commitments when: (a) the obligations are fully understood, (b) a program (preventive maintenance, leasing policies, operating regulations, etc.) is in place which in the FAA’s judgment is adequate to reasonably carry out these commitments, and (c) the owner satisfactorily demonstrates that such a program is being carried out.

What is not included in the article is that the city attorney offered to present the tenant’s revisions to the city. 

This article shows that the city is making a point to prove that it is a benefit to aviation to have fewer tenants on the field that pay a higher hangar rate than more tenants on the field that pay a lower rate.   It sounds more like an attempt to justify higher rates in order to get tenants to move off of the airport.   

CITY AGENDA MONDAY NIGHT.

The agenda for Monday night includes some airport business, it does not say what, but Gib said the City tabled the tenant proposed lease to lower the rent to $125/month, so this could be what it is about.  Gib also said that the alderman not only SMIRKED at the $125 idea, they thought it was laughable, and that is what they did, laugh, out loud.  But of course that was not in the paper either.   

WHAT IS THE REAL COST?

Counting the redevelopment plan, best guess to date, the city has probably spent over $122,000 trying to close the airport.  That number could climb higher since the OIG has not finalized its investigation.   This does not include what the corrective action plan which could cost well over another $150,000.  Six year so far, and the city is apparently is losing ground in the battle with the FAA to close the airport on the north end of town.   The city is projecting $4,950,000 in annual sales and personal property tax revenues from the development of a Chesterfield Mall like development on the airport, which lies partially in the Union School district.  If it takes another six years, the city will have lost $59,400,000.00 in tax revenues by wasting time trying to close the airport as opposed to selecting another location.   The cash registers could have been ringing for at least a couple of year already.