GAO looked at 13 cases around the country where the FAA has implemented Precision Based Navigation (PBN). The case studies did not include the Northern CA Metroplex but we are appreciative of GAO’s explanation of how the FAA handles noise when implementing PBN and for GAO’s specific recommendations to improve FAA’s noise impact assessment practices and to better understand “what communities can expect from FAA, including the technical assistance FAA can provide.”
Our biggest takeaway from the GAO report is that, of the three levels of noise and environmental review that the FAA conducts to comply with National Environmental Policy, only two - Environmental Assessment EA, or Environmental Impact Statement EIS - assure public notice, involvement, and the negotiation framework to find least impact alternatives before final actions are taken. If an action is in “pre-implementation” or “post implementation'' also matters for FAA outreach. GAO notes that “FAA uses the term community involvement, defined as the process of engaging in dialogue and collaboration with communities affected by FAA actions. FAA frequently uses the term community engagement as well. For the purposes of this report, we use the term community outreach to encompass FAA activities related to informing, educating, engaging, and involving the community on PBN related projects.” We know from experience that when the FAA declares their lowest level review, or CATEX, there is no public notice to the people who stand to be affected, or formal post-implementation outreach. Thus, GAO’s third and final recommendation is important -”for the FAA to provide information on what the public can expect from the FAA in its post-implementation outreach.”
We will be following this closely but what is incontrovertible is that a hard look at projections of impacts from PBN - at the outset, with least impact alternatives incorporated in an FAA publication is key. GAO’s other two recommendations speak to this.
GAO’s first and second recommendations, 1) for the FAA to identify more metrics and, 2) communication tools for noise impact analysis, adds to the national consensus that FAA’s assumptions and explanations about noise assessment are inadequate for PBN. In GAO’s thorough analysis of the metrics problem they cite a model approach in Australia that employs a “variety of metrics and thresholds” to address environmental issues in a more comprehensive way. The GAO report states that the FAA agrees with GAO’s recommendations and mentions that “for a recently proposed change to air traffic procedures at San Francisco International and Oakland International Airports FAA officials stated that they used the “number above” metric in addition to DNL to better communicate noise impacts to members of the local community.”
We welcome the news that the FAA is moving to use “number above” and keep asking the FAA Ombudsman how to make that happen for PBN implementations affecting the MidPeninsula. GAO raises an important point as well, which is that some of the metrics to supplement DNL “may not incorporate all of the elements of noise required by law (for instance, metrics conveying the number of overhead flights may not account for the duration of noise events).” Duration matters because noise harm results from dosage and intensity over time, and PBN needs to be accounted for its cumulative effects. Thus, a combination of metrics is necessary to understand potential impacts.
A good outcome of the GAO report would be that improvements in outreach listed in the report will no longer be based on FAA’s benevolence to stretch their rules. Improvements noted in the report have not helped us so far. It’s also surprising that the FAA is asking communities to hire consultants to propose air traffic changes given the rejections of most community proposals to address PBN. With modernization, the menus for noise reduction with PBN should be more comprehensive. Missing from FAA’s approach to noise with PBN also are fair criteria and objective means to address competing stakeholder interests; measurable, ethical, and humane policies and practices to reduce aviation noise.
We have concerns about two items that the report did not expand on:
1. The aims of the Nextgen initiative, as described in the report, are to “increase safety and efficiency, accommodate growing demand, and reduce environmental effects such as fuel emissions.'' Noise is missing. When Congress was being asked to vote for funding, “reduction in fuel burn, emissions, and noise” was core to the aims of Nextgen. That noise was an important consideration can be confirmed with replays of congressional hearings; FAA reports to Congress; studies to justify Nextgen.
Interestingly, the description of Nextgen in the GAO report includes “accommodate growing demand” which effectively means to increase airport capacity with PBN. Capacity increases or the potential for capacity increases requires the highest possible level of environmental review, so for each of the 13 cases that GAO studied, FAA should have conducted an EIS for all, not just for one case.
2. We would have liked GAO to include more on thresholds of significance; how other countries use the World Health Organization guidelines to guide policies and investments in noise reduction and to protect health. GAO states that the “choice to use other noise metrics and thresholds when assessing the significance of noise impacts is a policy decision for the administration and Congress.”
Finally, we want to highlight something that the GAO report helps clarify. Some airports, roundtables, and activists over the years have argued that the 2012 FAA Reauthorization took away NEPA rights for airspace actions by virtue of being Nextgen actions. In spite of powerful lobbying and FAA resources dedicated to excluding Nextgen procedures from NEPA review, GAO’s report confirms that those efforts did not override NEPA. We maintain that what serves to override NEPA for practically all airspace actions is not 2012 laws but FAA’s 50-year-old policies and threshold criteria that no reasonable person could find appropriate for PBN.