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Friends,
Please see the REVISED email sent to the Planning Commission.
To add your voice, questions, or to support the points we make please email by 5PM TODAY cpc.sforadp@sfgov.org Copy city.council@cityofpaloalto.org, daniel.lurie@sfgov.org, mike.nakornkhet@flysfo.com, Eric.Henshall@mail.house.gov
Sky Posse Email to San Francisco Planning Commission:
Subject: REVISED: SFO DEIR is inadequate without the consideration of flight path impacts
Dear Commissioners:
On behalf of thousands of Midpeninsula residents impacted by noise and air quality impacts from SFO-bound flight paths, we respectfully submit that SFO’s DEIR is inadequate as long as it does not consider flight path impacts. At the May 22 public Hearing SFO’s presentation suggested that “There are no changes or expansions proposed to the existing runway or to aircraft flight paths, which are the sole purview of the FAA." As this report and process is meant to protect the environment and people who stand to be negatively affected by SFO's development plan, please consider our feedback as follows:
INACCURACIES:
#1 SFO is incorrect to say that flight paths are “the sole purview” of the FAA. An airport’s role is required in flight path oversight.
After serious miscalculations about regional noise effects from the implementation of the FAA’s Nextgen program for Northern California in 2014, the FAA expanded the role of airports as regards flight paths. SFO has since been on the FAA’s Technical Working Groups for flight path design and the Government Accountability Office recommended for the FAA to clarify how a flight path change is initiated and processed. The FAA’s publication “How the FAA engages with Airport and Community Roundtables” now describes the role of an Airport authority;
Step 2 of the FAA’s criteria for Flight Path development states,
“All requests not made by the airport authority or internal FAA sections responsible for air traffic control (ATC) and flight procedure development (e.g., ATC, flight standards, FPT, etc.) require airport authority concurrence prior to submission."
This is consistent with US Aviation policy which states that aircraft noise is a shared responsibility between airport authorities, airlines, state and local government, communities, and the Federal Aviation Administration. Furthermore, communities expect airport sponsors to balance the interests of various stakeholders.
#2 It is also inaccurate that flight paths will “not change” when petitions for changes are ongoing largely from airlines and the airport itself.
The FAA continuously makes changes to flight paths in response to SFO’s needs and the needs of the National Airspace System. It is impossible for flight paths to be static given that in addition to the FAA’s internal changes (e.g., ATC, flight standards, FPT, etc.) requests are initiated by airlines - including for private use flight paths. SFO also has flight path procedures (navigation rules) for its new landing system “GBAS” which can INCREASE noise and SFO controls these procedures.
It is evident that the FAA looks to airports to provide local context in efforts to be responsive to the public and to consider the environment and people. SFO's misrepresentation that “flight paths will not change” has broken trust before. Unless this is addressed, SFO is misinforming the FAA on current and future projects, and leaving the public in the dark about potential consequences from SFO’s operations.
INCOMPLETE INFORMATION AND MISSING REGIONAL HISTORY:
SFO’s claim that “no changes or expansions proposed to the existing runway or to aircraft flight paths” mixes two sets of airport infrastructure that have distinct impacts and mitigation options.
The public needs to be informed that while runways are not changing, SFO’s flight paths are not static; flight path procedure (navigation rules) design and the level of usage of flight paths from increasing operations can increase noise and air quality impacts. Not only are flight paths distinct infrastructure from runways, flight paths can be more deleterious in terms of affecting more sensitive areas and people. The menu of potential mitigations for flight paths is also distinct. Quieter aircraft engines for example do not help address flight path noise but thoughtful flight path design and compliance can meaningfully mitigate night time noise. These mitigations however cannot be employed if the airport is denying how directly their project will impact noise. Adding a gate to serve more passengers means more flights, more flight path impacts. Moreover SFO’s plan leverages powerful airline programs to induce more operations for more profits. As noted by public comment at the May 22 Hearing, United Airlines has a $2.6 billion construction project to re-establish SFO as the airline’s global gateway. This expands United’s route networks with more flights, including promotional flights that are not at full passenger capacity but add more noise.
Airport-airline projects influence noise as happened with Nextgen when airlines requested lower altitudes for SFO’s arrivals which greatly increased noise. The failure to recognize community concerns over flight path changes led to an FAA Initiative and official community meetings with FAA and local leaders in three counties; thousands of citizens weighed in over months to come up with consensus recommendations to address flight path noise and night time operations. The DEIR's omission of the impacts of flight path changes undermines recent regional history to address just this issue, and ignores opportunities identified by citizens, local officials and the FAA to mitigate flight path impacts affecting people's health, quality of life, and the environment.
INQUIRY ON THE NOISE SIGNIFICANCE THRESHOLD:
We would like to know the reason why SFO looks at the +1.5dB increase in 65 CNEL criteria when the FAA’s Environmental Policies and Procedures Guideline Order 1050.1F looks at a 3 dB increase in DNL 60-65 dB and +5 dB for 45-60 dB as well.
CEQA allows the flexibility to use significance thresholds below 65 CNEL and more metrics to consider local context, so it is disappointing that only the higher threshold criteria (65) is applied which effectively lowers the standard for SFO’s environmental review. As SFO is aware, the FAA has scientific studies that provide substantial evidence that 65 DNL or 65 CNEL is no longer supported to identify community concerns. The FAA surveyed 10,000 residents living near 20 representative airports with results showing that aircraft noise causes greater levels of community annoyance compared to other transportation noise, and a need for more sensitive criteria to evaluate aircraft noise. There are also legal considerations about noise threshold criteria to assess areas that qualify for insulation, vs National Environmental Policy Act requirements.
RECOMMENDATION:
We recommend that an additional report is needed on SFO's Arrival flight path noise impacts to inform on regional impacts; at a minimum to consider the top five areas with the highest number of complaints. Particularly an analysis of all night time overflights is necessary; sleep being critical for physical and mental health and productivity. SFO has extensive data to accomplish regional noise assessments, and with various metrics. In addition, provide details such as target altitudes and current navigation rules for SFO arrival flight paths. The report should also describe how SFO makes decisions on flight path requests; how pre- and post-implementation reviews of flight path changes are managed, and who is responsible for keeping communities informed.
Please reject any environmental review for SFO that excludes SFO’s regional impacts.
Thank you for your attention,
Sky Posse Palo Alto
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