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Dear Friends,
On Monday September 16, there is a Council study session where City staff “recommends that Council receive an update on the Airport Long-Range Planning process and provide input to support development of a preferred alternative.” The staff report is here. The Palo Alto Weekly has published a story on the topic, here.
Our review of the staff report is that the current planned “next steps” and commitments from the City sideline noise by not presenting how the airport will address and manage arguably one of the most problematic concerns from airport operations - noise.
The staff report reveals that eVTOL planning on behalf of commercial interests may be a key driver for the pursuit of FAA grants to change the airport. eVTOL noise is comparable to helicopter noise. And the FAA and airports ignore, among other things, their low frequency vibrations which is critical to consider because these vehicles are being sold for taxi services, portending traffic levels and lower altitudes that can very negatively affect residential neighborhoods and the natural environment.
Per the staff report,
"Staff has met with several companies interested in partnering with the City to introduce eVTOL aircraft at the airport. Other companies have approached the airport in support of eVTOL operations by providing sustainable alternative fuels like charging stations and possibly hydrogen. These companies have identified the Bay Area, and specifically the airport as an ideal location for eVTOL operations in the future."
eVTOL companies lobbying our local officials are a formidable lobby, some with former FAA Administrators on their boards. The Palo Alto Weekly quotes the president of the California Pilots Association who helps airports acquire federal grants suggesting, misleadingly, that “the city is already considering the environmental impacts of any alternatives and that it would be required to fully assess these impacts before any construction occurs.” Per the staff report, the City has no steps to consider noise impacts in planning; if the retort is that FAA’s environmental rules for noise are being followed, that also means that they are not considering noise impacts because even brutal levels of noise such as the Nextgen noise problem get a Finding of No Significant Impact from the FAA. Moreover, the 1.07% forecasted annual increase in operations for Palo Alto Airport is NOT an indication of potential noise impacts. For example, Nextgen noise erupted in Palo Alto when SFO operations were down, and a historical assessment commissioned by the City in 2015 showed that SFO operations grew by 9% over an eight year period, or roughly 1% annually but the increase in levels of noise in that time frame, and the growth in number of people affected is massive.
Council must consider that it is premature to plan for eVTOLS for PAO, or for the City’s name to be used to promote these vehicles. It is Council’s duty to first thoroughly understand how inviting eVTOLs would permanently bring NEW noise that is not mitigated even by physical barriers. The flaws with Nextgen implementation show that aviation companies, the FAA, and airports have not modernized their tools or metrics to evaluate noise impacts. At the same time, there are various options and metrics to assess noise; it is reasonable to ask for progress on assessments to better communicate about aviation noise, and before launching new problems.
Before committing to a plan that incorporates aviation and eVTOL priorities, the City needs to have an understanding with the community about how the City plans to assess, track, and report noise - and who will pay for this. It is a fiduciary duty to plan for all potential costs; credible noise assessment being essential to be responsive and transparent with residents and neighbors. Currently, Bay Area airports escape expenses to “fully assess” noise with artifacts such as the FAA’s 65 DNL. Thus our request for the City to present a feasibility and cost analysis of what modern day noise assessments and permanent noise tracking options can provide. Many of the questions from the community at the airport’s June public outreach meeting were about noise impacts. At the time, the City's consultant said an FAA process in the future would address our concerns about noise but this is misleading, and it is why we also ask the City to provide a regulatory review that would establish a framework for addressing noise issues.
City Policy statements for managing aircraft noise:
City staff has compiled City policy statements and guiding documents to ensure that the airport planning process is consistent with various City positions, but it disregarded the body of position statements and guiding principles about aircraft noise. Namely the statement at the top of the City’s Regional SFO Airport Coordination/Airplane Noise, link here.
"The City is committed to working with our citizens, Congress, the Federal Aviation Administration (FAA), SFO, SFO’s Community Roundtable, neighboring city and county agencies, regional airports, noise groups, and all stakeholders associated with air traffic in Silicon Valley to find solutions which restore the quality of life of our community."
This type of commitment is missing from the airport planning staff reports and the City should not have double standards for how to address aircraft noise concerns. Noise does not happen in siloes, or airport by airport. All airspace related actions - from safety to noise - are interrelated and interdependent. Furthermore, there are regional policy positions on aircraft noise that were voted on during the Select Committee, by three counties and accepted by three Congressional districts that should also be incorporated in the planning process.
The City’s various positions on aircraft noise need to be added to the documents guiding airport planning, including Council’s joint advocacy with the Town of Los Altos Hills, Cities of East Palo Alto, Los Altos, Menlo Park and Mountain View to among other things replace the DNL metric with the NAbove metric.
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