TRACTOR PULL FILES A MISSED APPROACH

From the city agenda.

3. Ozark Tractor Pullers: The Board of Aldermen had previously approved a request by this organization to hold their event at St. Clair Regional Airport, as has been done for many years in the past. Per the attached email from MoDOT Aviation, the requirements for doing so are now too onerous to allow the event.  Staff requests with regret that the Board of Aldermen rescind the approval for use of the airport by the Ozark Tractor Pullers. Staff has assisted the organization in securing adjacent private land for the event scheduled for June 8th. An approved motion is required to rescind the approval.

Why did the tractor pull move to the airport in the first place?  Why did the tractor pullers move from the city property next to the treatment plant, which was ideal for pulling, it was a much larger area.  What specifically happened to the property to make it unsuitable for a tractor pull?

A CORRECTIVE ACTION PLAN

The city has a hard time grasping the meaning of the words “corrective action plan”.  What it is going to come down to is that St. Clair is going to have to be run just like any other airport in the system.  What this also means that everything that the city has done to destroy the airport, will have to be redone at the city’s expense, since they gave all the grant money back.  What the local news publication did not report, is that the airport still has $450,000 in entitlement grants waiting to be used.  The word entitlement, means that it is money already approved for the St. Clair airport, all the city needs to do to get it is apply.  It is not a competitive process.   

An acceptable corrective action plan will include a commitment from the City to ongoing routine maintenance of grass and weeds in cracks on pavement surfaces. 

What does the FAA have to say about this? 

b. Airport Facilities to be Maintained.

This section applies to all airport facilities shown on the Airport Layout Plan (ALP) as initially dedicated to aviation use by an instrument of transfer or federal grant agreement. Essentially this

From a compliance standpoint, airport operations also encompasssafety issues. For example, airport sponsors are required to inspect runways, taxiways, and other common-use paved areas at regular intervals to ensure compliance with operational and maintenance standards. Sponsors must make routine repairs, such as filling, sealing cracks, and repainting markings (as shown here)to prevent progressive pavement deterioration. (Photo: FAA)

09/30/2009 5190.6B

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means that the sponsor cannot discontinue maintenance of a runway or taxiway or any other part

of the airport used by aircraft until the FAA formally relieves the sponsor of the federal

maintenance obligation. The federal obligations of the sponsor remain in force throughout the

useful life of the facility, but no longer than 20 years – except for land that specifically obligates

the airport in perpetuity.

7.3. Grant Assurance 19, Operation and Maintenance. Grant Assurance 19, Operation and

Maintenance, is the most encompassing federal grant assurance related to airport maintenance.

It requires the sponsor to operate and maintain the airport’s aeronautical facilities – including

pavement – in a safe and serviceable condition in accordance with the standards set by applicable

federal, state, and local agencies. FAA pavement guidance applies.

7.4. Maintenance Procedures. Generally, airport agreements require the sponsor to carry out a

continuing program of preventive and remedial maintenance. The maintenance program is

intended to ensure that the airport facilities are at all times in good and serviceable condition to

use in the way they were designed. Advisory Circular (AC) 150/5380-7A, Airport Pavement

Management Program, discusses the Airport Pavement Management System (APMS) concept,

its essential components, and how it can be used to make cost-effective decisions about

pavement maintenance and rehabilitation. The airport agreement may express or imply such

maintenance requirements and include specific federal obligations such as:

a. Frequently check all structures for deterioration and repair.

b. Inspect runways, taxiways, and other common-use paved areas at regular intervals to ensure

compliance with operational and maintenance standards, to prevent progressive pavement

deterioration, and to make routine repairs such as filling and sealing cracks.c. Inspect gravel runways, taxiways, and common-use paved areas at regular intervals to ensurecompliance with operational and maintenance standards, to prevent progressive deterioration ofoperation areas, and to make routine repairs including filling holes and grading.

d. Inspect turf airfields at regular intervals to ensure there are no holes or depressions, andotherwise to ensure that all turf areas are preserved through clearing, seeding, fertilizing, and

mowing.

e. Maintain field lighting and Visual Approach Slope Indicators (VASIs) in a safe and operable

condition at all times. When conditions dictate, realign VASIs on a regular basis.

f. Maintain airfield signage in a safe and operable condition at all times.

g. Frequently inspect segmented circles and wind cones to ensure accurate readings and proper

functioning.

h. Frequently inspect all drainage structures including subdrain outlets to ensure unobstructed

drainage.

i. Frequently check all approaches to ensure conformance with federal obligations.

FAA REPLY TO CORRECTIVE ACTION PLAN

May 21, 2013

Mr. Rick Childers
City Administrator
City of St. Clair
#1 Paul Parks Drive
St. Clair, MO 63077

Re: St. Clair Regional Airport

March 26, 2013 Correspondence

Dear Mr. Childers:

Thank you for your March 26, 2013 letter. The corrective actions described in your letter demonstrate that the City has made significant progress in addressing the action items contained in my December 21, 2012 letters and Jim Johnson’s December 28, 2012 letter.
However, there are still a few items that must be addressed in order for the City’s corrective action plan to be accepted by MoDOT and the Federal Aviation Administration (FAA). The purpose of this letter is to outline the items which require additional action and to provide the City with guidance to ensure that its corrective action plan is accepted. 

Routine Maintenance items 

For item 1, “Grass and Weeds in Cracks on Runway and Apron”, the City’s response suggests that pavement cracks are only sprayed once a year. However, if weeds begin to grow out of pavement cracks after the annual spraying has occurred, these weeds should be sprayed as needed. An acceptable corrective action plan will include a commitment from the City to ongoing routine maintenance of grass and weeds in cracks on pavement surfaces. 

For Item 4, “Rotating Beacon Inoperative”, and Item 7, “Runway Lights Broken and Mounted Improperly”, ongoing routine maintenance must continue regardless of the status of negotiations on the City s closure request. An acceptable corrective action plan will include a commitment from the City to ongoing routine maintenance of the rotating beacon and the runway lighting system and will not condition that commitment on the outcome of closure discussions. 

Compliance Plan Correspondence 

For Item 3, which relates to main hangar storage, the actions proposed are acceptable and address the compliance issues raised, but additional information is needed for MoDOT and the FAA to accept the City’s corrective action plan for this item. Please provide me with documentation demonstrating that the $ 11,700 transfer to the new airport account has occurred. Please also provide documentation of the public auction to sell any items remaining in the hangar and documentation demonstrating that the auction proceeds were transferred to the new airport account. 

For Item 4, which relates to Air Evac’s lease, MoDOT and the FAA agree that inclusion of a CPI indexing clause in the next Air Evac lease will help to ensure that Air Evac’s monthly rental rate reflects current economic conditions. MoDOT and the FAA also agree that different categories of tenants can have different rental rates, so long as a consistent methodology is utilized to establish fees for comparable aeronautical users of the airport. 

Although the City’s letter indicates it will include a CPI indexing clause in its next lease agreement with Air Evac, the letter does not state whether the base monthly rental rate for Air Evac will increase from $300/month when the Air Evac lease is next negotiated. Without this information, MoDOT and the FAA cannot determine whether the City’s proposed corrective action plan for Item 4 is acceptable. 

The City’s March 26 letter stated that its lease rates reflect a variety of factors that differentiate certain types of tenants from one another. The differences between Air Evac and the fixed wing tenants may substantiate different rental structures for businesses operating at the airport and for other fixed wing tenants, but without any type of documentation outlining the City’s rental structure for businesses
operating at the airport, MoDOT and the FAA cannot determine whether Air
Evac’s lease agreement is consistent with such rental structure. 

In order to address the remaining questions relating to Item 4, any future Air Evac leases should reflect a similar percentage increase in the base monthly rate to the increases experienced by other tenants from 2007-2013 pursuant to Title 49 United States Code Section 47107. In the alternative, the City should provide its cost allocation methodology for its rental rates. This methodology should be consistent with the FAA’s Rates and Charges Policy. 

MoDOT is available to work with the City to address these remaining corrective action plan items and to identify steps the City can take to ensure future compliance. If you have any questions, please do not hesitate to contact me. As soon as a response is received on these remaining items, I will coordinate with the FAA to determine whether the City’s corrective action plan is acceptable. 

Sincerely, 

Amy Ludwig
Administrator of Aviation
cc: Mr. Jim Johnson, Federal Aviation Administration
Ms. Lynn Martin, Federal Aviation Administration 

Again more worthless propaganda from the city.   The city is trying to show that it is not actively trying to destroy the airport, but when you do not take free money from the feds, it looks pretty bad on the part of the city.  Blum states that it is not his fault, and that a lack of pro-activity on the part of the city is not to blame for the status of the airport.   This is all hog wash on the part of the city.

MIRMA

In a telephone interview with Matthew Brodersen, the executive director of MIRMA, Mr. Brodersen explained how the MIRMA system works.  When asked if all 69 members equally share in the aviation insurance expense, he replied “yes that is correct.”   He was also asked, does that mean that each of the  MIRMA members share of the aviation insurance expense is around $800.  “Yes that is correct.”   Mr. Broderson was also asked if each member’s cost to insure the 29 airports is around $800, then would it be correct that each members cost to insure its own airport would be around $28?  Mr. Brodersen’s response was “Yes that would be correct.”

The airport coverage does not cover storm damage to the physical property itself, but Mr. Broderson also stated that that portion of the insurance cost should be distributed according to payroll. 

Mr. Brodersen also stated that the workmen’s comp portion of the MIRMA plan was about 40%.

That is straight from MIRMA.  So what we have here is the city charging the airport $8000 for $28 worth of insurance expense.   

AIRPORT ACCESS

The type of business that the St. Clair Enhanced Enterprise Zone is trying to attract is looking for an important element, airport access.  This was mentioned several times by the spokesman for the state department of economic development.  The St. Clair plan lacks this key element and it shows that the St. Clair plan is flawed.  Why would anyone want to eliminate the one of the key elements to an economic development plan?  Sullivan would be a more attractive site for future development due to its airport being a major element of what these industries are looking for.

This is from the St. Clair Agenda for next Monday.


3. Bill No. 2013-16 – An ordinance authorizing the Mayor and City Attorney to
execute such documents as required to surrender MoDOT Airport Improvement
Plan funds for the years 2008, 2009, and 2010. If approved Bill 2013-16
becomes Ordinance 1704.

ENHANCED ENTERPRISE ZONE

This is hilarious; St. Clair is going to clean up Villa Ridge, because it is a depressed area.   I can’t wait to hear the opposition to this stupid idea.  Calls have been received by residents of this area, asking if this has anything to do with the airport.  Apparently some of the residents have already contacted an attorney and are planning to fight this.  The response has been, St. Clair can hardly run its own town, where do they think they can tell the rest of the area what to do.  The residents and land owners don't want this, and they really don't want this if it part of the St .Clair plan.  They are seeing this as future annexation to St. Clair, and they don't want it. 

Sullivan has a more attractive plan than St. Clair, plus they also believe that the airport is a great city asset.  Sullivan would be the logical choice for anyone wanting to utilize this concept, it’s a no brainer.