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Dear Friends,
Please see the following email that we sent to Palo Alto City Council today regarding an environmental review notice for an SFO expansion plan to serve 72 million annual passengers from the current 52 million. Also, a brief update about the FAA’s Noise Policy Review is here. If we missed anything in the email to Council, let us know at skypossepaloalto@gmail.com.
EMAIL to City Council
Subject: Request for Council and City public outreach on City's response to SFO DEIR - SCOPE due on May 30
Dear Mayor Lauing, City Council, City Manager, City Attorney,
Upon the April 30 CEQA notice for a Draft Environmental Impact Report (04/16/2025) regarding an “SFO Recommended Airport Plan” to expand SFO airport capacity from currently serving 52 million passengers to 72 million passengers, we request that the City please establish regular updates to residents about what is happening and the City's response. SFO’s expansion plan drawn up in 2016 and 2019 (postponed during Covid according to SFO) does not consider Palo Alto and neighboring cities' complaints and it leaves citizens without any consideration of noise, air pollution or safety concerns.
We expect the City to forcefully defend Palo Alto from SFO’s expansion plans. Families move to Palo Alto for quality of life, our schools, the weather and outdoors. Our community places extraordinary value on our local parks, open space preserves, clean air, and nature. Peaceful nights, and to be able to think, study, and work without industrial level noise pollution are essential to quality of life and Palo Alto’s economy, built over generations - NOT to be damaged by an out of control airport. We did not move to the airport. SFO is 20 miles away, managed by San Francisco 30 miles away. Please represent that we have been working since Nextgen was implemented for a REDUCTION in impacts.
In 2019, the City Manager wrote a thorough letter to SFO to inform SFO’s DEIR scope with some of our concerns; the need to include noise impacts on Palo Alto and other cities within at least a 50 mile radius of SFO; measurement of emissions on the ground, specifically the level of ultrafine particles in locations where aircraft fly below 5000 feet; permanent noise monitoring, and a cumulative impact of noise and emissions of all current and anticipated air traffic operations at all three of the Bay Area’s international airports (SFO, Oakland and San Jose). The Bay Area Air Quality Management District which has Palo Alto’s Vice Mayor on the board also sent a 2019 letter on air quality issues. The 2019 inputs from Palo Alto continue to be critical, and below we recommend adding attention to what was NOT contemplated in 2019 - or 2014, and 2015 when SFO’s plans were being hatched while the airport tried to convince us that “nothing has changed” with the Nextgen implementation.
First, in the last decade not enough has been done to address how airport CEQA airport reviews prioritize airport building construction disruptions which are temporary but exclude flight path impacts on populations while the FAA’s flight path reviews do not evaluate airport capacity expansions or air traffic increases; an arrangement that we suggest demands legal and safety review. NEPA being a disclosure law should have guidance when two agencies that share responsibility for an issue are effectively denying an airport’s core and most consequential impacts on populations. We are also concerned about what is considered “significant impact” for CEQA because A. the noise metric and threshold historically used by the FAA and airports are under review precisely because local and national public outcry prompted FAA studies that substantiate that the NEPA significance threshold is insensitive and inadequate and B. We argue that the historical noise metric and threshold policy has been improperly applied to produce NEPA public disclosures because 65 DNL was meant for a completely different law for land use planning/a voluntary Part 150 insulation program which a DEIR is not. To further inform the City’s response to SFO, we ask that the following key concerns also please be considered. SFO evidently can refuse to provide any analysis or responses even as their operation and all airports enjoy perennial federal subsidies, but we recommend that it is incumbent on all cities (including San Francisco) and counties impacted by SFO to obtain both the environmental information laid out in Palo Alto’s 2019 letter, and the information below, to adequately represent citizens:
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SAFETY Review: The FAA repeatedly stated in their implementation of Nextgen, including in court, that the agency did not consider or review airport capacity expansion. Safety should be part of a CEQA analysis for any transportation impact. A safety analysis for SFO traffic should include a review of how SFO has been reducing the distance between runways (less safe); an analysis of go-arounds over time; the number and historical tracking of airspace procedures that the FAA manages for SFO; a comprehensive review of all the “letters of agreement” between SFO and FAA; a list of operating procedures, and an overview of any and all know airport safety criteria.
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Flight Path Governance and Oversight Review: The decision-making structures for flight paths that FAA services for SFO operations needs attention. Currently, the jurisdictions that profit from the airport have an advantage with the FAA to address noise for their constituents from SFO’s landlord San Mateo County and San Francisco; cities like Palo Alto are handled on the side with no accountability to Palo Alto citizens. The last outreach from SFO using the City of Palo Alto was to sell SFO’s GBAS project as a noise reduction project which is an example of how FAA staff and community time and resources are used by SFO practically for SFO’s and San Mateo County’s sole benefit because GBAS can increase noise. Given adequate scrutiny, there are obvious conflicts of interest with these arrangements, lack of transparency, and very real risks.
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Audit of OAK, SFO, and SJC growth projections: It’s overdue to have an explanation of Bay Area airport projections, why they rely on Million Annual Passenger (MAP), how the FAA is one of the sources for these types of numbers - what does the FAA base their estimates on; when was the last time the agency updated their projections that are fed into the airport projections. We have seen first hand with Nextgen and our own Palo Alto airport that aviation plans are meant to promote aviation; driven by industry aspirations, featuring benefits for the public while denying local community needs and concerns. At the very least SFO, OAK and SJC airport projections need an independent review.
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Performance statistics for SFO’s flight paths: The FAA’s Nextgen Advisory Committee (NAC) has started to produce some flight path efficiency/performance planning information that includes SFO. The DEIR should explain the efficiency statistics and Nextgen PLANS; how these ongoing airline and airport initiatives can affect noise and air quality emissions. And ideally, it’s time for an EIS for SFO to finally correct the problems with the Metroplex EA done in 2014.
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Improved environmental impacts analysis that the public can digest: It is unreasonable that hundreds or thousands of pages can be produced for a CEQA document and still leave virtually ALL of the environmental impacts that are causing public outcry off of a report. It happened with Oakland airport’s CEQA report and yet their officials certified it. Local officials have a leading role and responsibility to see that environmental reviews are not used to hide problems and that noise and emissions assessments reports are produced with high standards and the most updated methods.
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Consideration of Regional Consensus: In response to meetings with community groups in Santa Cruz, our grassroots organization in Palo Alto, and congressional officials, the FAA issued its Initiative to Address Noise Concerns of Santa Cruz/Santa Clara/San Mateo/San Francisco Counties leading to a Select Committee of Bay Area officials who called for the need to use more noise metrics than DNL to address flight path concerns, particularly to address bass frequency noise which is not reflected in CNEL or DNL but can make up a major part of noise because this frequency travels farther and penetrates buildings. As the Select Committee’s technical advisor, FAA spent months in Palo Alto and FAA leadership made recommendations to address nighttime noise for Mid Peninsula cities. After the FAA left, the potential solutions for SFO arrivals affecting MidPen have held a backseat to SFO Roundtable priorities which exclude Palo Alto; a decade later, nothing that the FAA recommended to help address night time noise for MidPeninsula cities has been instituted.
In short, there are serious SFO air traffic impacts and governance problems that are unresolved. SFO’s recommendation for its own expansion is happening with no oversight. Not from the FAA, not state or regional. San Francisco does not attend the SFO Roundtable meetings where noise is discussed, but its planning department repeatedly scopes an environmental review without looking at the Nextgen flight paths that make the airport operable; protecting no one suffering 24/7 from SFO’s impact or future impacted people and areas. Any SFO action, much less an expansion, in the age of Nextgen, can quickly become OUT OF CONTROL. It is simply irresponsible. The City of Palo Alto must please stop this madness and lead on establishing better governance of SFO’s and other airport actions that impact our City which only the City and Council can negotiate on behalf of its current and future residents.
Thank you,
Sky Posse Palo Alto
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