We hope you are well and having a good Memorial Day Weekend.
We have two important items in this Update:
- A Survey that we put together to capture impressions and opinions about the recent changes in noise and air quality resulting from the pandemic "shelter in place" measures in effect around the country during March, April, and May 2020.
- The FAA’s Report to Congress on Alternative Metrics.
The Survey - Please participate and we need YOU to share it!
The above link allows easy sharing via Facebook, Twitter, and more. We will also send the same in a separate email to you so that you can forward via email.
Please ask neighbors, friends, and your contacts around the country to participate. The next weeks are a critical time to capture the inputs that we seek in the survey.
FAA’s Report to Congress on Alternative Metrics:
On April 14 FAA delivered a Report to Congress on two noise provisions pursuant to
the FAA Reauthorization Act of 2018 that was signed into law on October 5, 2018
, Sections 188 and 173.
We appreciate the FAA’s analysis of DNL and alternative metrics, and the report is an excellent framework to advance discussions about modeling and noise measurement practices. There is a problem with the report, however, which is that a provision of the 2018 FAA Reauthorization -
Section 173 - is
. We have provided this preliminary comment to Representative Eshoo, and her staff in D.C. kindly replied that they will be sharing our concern with the Congressional Quiet Skies Caucus. Please read the report; we welcome any suggestions, questions, and ideas to include in a more detailed follow up with members of Congress. Some highlights are as follows.
This is one of the most consequential documents on noise from the FAA, and it was made possible only because of the persistence and efforts that citizens (YOU) have made to address Nextgen. If we had this report six years ago, discussions would have been very different.
With this report, the FAA makes clear that they
alternative metrics and concede that no single metric can cover all situations.
Among the reasons the FAA did not accurately predict Nextgen impacts was reliance on a single noise metric, and doing predictive analysis using wrong assumptions.
For example, their modeling for the Bay Area was not based on where the planes would actually fly, the amount of traffic that would be shifted from other routes to the new routes, or flight altitudes. For years, we have stressed to local policy makers that current FAA noise policy allows for alternative metrics and official bodies (airports, counties, cities) are not constrained from proposing alternative metrics to help inform FAA decisions - this is really up to our local and regional officials and airports. Nor are local discussions constrained from using modern analysis tools which can provide not only predictive analysis but historical assessments as well. But without an official position coming from the FAA, airports and roundtables have been slow, uninterested or confused about whether they could or couldn’t use alternative metrics.
As of April 14 there should be no excuse for local noise discussions to be stuck in DNL
, and the use of modern analysis tools to employ alternative metrics which, in conjunction with noise measurements (a responsibility usually carried out by airports), can more fairly and transparently inform airspace design decisions.
FAA states in their cover letter to the Committee on Commerce, Science and Transportation that “the information contained in the document (written for Section 188)
also fulfills the FAA’s response to Section 173.
” However, Section 173 is about the
65 DNL standard
, not the discussion of the metric DNL.
Per FAA’s own caution - on page 16 of the report for 188,
”It is important to draw a distinction between a particular noise metric and any accompanying noise threshold values (in decibels) used to inform project or policy determinations. Determinations of threshold values depend on multiple technical and policy considerations that, while related to the choice of noise metric, require separate consideration.
The choice of the metric is
from the threshold standard that the FAA uses for crucial policies and practices affecting the public. The dismissal of Section 173 considers neither what the FAA knows about the distinction of metric and threshold standard, nor does it reflect public concerns, or what Congress asked for. In a
2015 press release
, FAA stated, “The FAA is taking an updated look at its approach for measuring noise
as part of an ongoing dialogue with stakeholders,
including communities and leaders of a number of cities across the nation…..If changes are warranted, the FAA will propose revised policy and related guidance and regulations, subject to interagency coordination, as well as public review and comment.”
The dialogue about FAA’s noise policies and practices can’t happen without the FAA being willing to fulfill the law of Section 173 and any NEPA decisions that the FAA makes until this is resolved (including Categorical exclusions which are defined by the 65 DNL standard) are a breach of public trust. FAA’s exclusive use of 65 DNL for policies and analysis of noise will also affect future policy affecting noise - for instance, the Supersonic transport rules coming up for review. Congress’ directive to the FAA about potential new Supersonic rules was not informed by how devastating excessive and unlimited noise can be to people. Because of the reliance on a single metric and a permissive threshold standard, the FAA has barely scratched the surface to understand the problem of noise. For the FAA to proceed with SST noise rulemaking in the face of weak to nonexistent mitigation options to protect public health and welfare, is unacceptable.
The SCSC Roundtable is meeting this week on Zoom Wednesday, May 27 1- 4 PM.
The SCSC’s recommendation for comment for SST is on the
344 page packet
contains a myriad of details but unfortunately this is not transparency. Nowhere to be found are noise analysis of MidPeninsula impacts or the issue of
, or the number of planes that keep getting concentrated. Or a hard look at MidPeninsula complaints. The FAA is arbitrarily choosing what to address, despite creating a Metroplex, public resources are used to deal with each airport or community piecemeal, it’s all buried in these pages. We will continue to press for fair attention.