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Dear Friends,
THANK YOU to all who reached out to Council on Palo Alto Airport concerns. It is good news that Council took no action on alternatives to expand the airport. However we remain cautious because Council asked staff to explore expanding the runway for pilot training so another set of alternatives with only aviation priorities could pop up. The runway meets safety regulation standards for flight training; if pilots need more practice, or training capacity it would be worthwhile to instead consider investing in a flight simulator that can also add practice for complying with noise abatement, reduce fuel burn and award pilots flight time credit.
The packed session in Palo Alto Council Chambers on September 16 to consider airport planning alternatives was momentous (photo). Over 70 speakers from Palo Alto, East Palo Alto, Menlo Park and environmental organizations succeeded in re-setting the discussion about Palo Alto’s airport planning, at least for now. Kudos to local citizens and environmental groups for providing leadership to protect people and the natural environment! This joint letter from local organizing groups captures community concerns. The 9/16 Council meeting generated more substantive issues than nearly two years of consultants or expensive, clunky, check box style and outdated FAA process.
POLICY NEWS:
On Friday, September 27th the FAA announced recent developments and next steps for their Noise Policy Review project and the completion of a Summary of responses of 4,857 unique comments to the FAA’s 2023 Noise Policy Review Federal Register. These inputs from community groups; elected officials; aviation industry and airport sponsors; consultants and individuals from around the country follow the 2021 General Accountability Office’s recommendation for the FAA to improve efforts to address community concerns, as well as a 2021 FAA solicitation to Inform National Aircraft Noise Policy regarding the FAA’s National Environmental Survey (results known to the agency since 2017) that confirmed what citizens have long observed: the FAA is using flawed assumptions to establish noise “significance” thresholds.
Unfortunately, the agency’s next steps to update the nation’s 1976 aviation noise policies keep getting protracted! The FAA has now revised their “approach and timelines” to incorporate two laws from the 2024 FAA Reauthorization: one provision from Congress calls for the formation of an Aircraft Noise Advisory Committee (ANAC) to “advise the FAA on issues facing the aviation community that are related to aircraft noise exposure and existing FAA noise policies and regulations.” Jointly, the FAA and the aviation community have had half a century to provide leadership to produce informed, reasonable, and immediate improvements to the nation’s aviation noise policies to better serve the American public. A new committee must confront how, in the face of ongoing public outcry and multiple lawsuits since 2014, the industry repeatedly expresses reticence if not a refusal to address noise with modern approaches. The multi-year delays in updating noise policies-and the refusal to provide adequate noise reporting and disclosures to communities-are a failure of Congress, the FAA and the aviation industry to respond to communities suffering from noise pollution.
Briefly, the above mentioned FAA Summary of the responses to the 2023 Federal Register (182 pages) offers comprehensive statistics on the 4,857 comments received; it shows from whom (community groups; elected officials; aviation industry and airport sponsors; consultants and individuals); overarching themes (issues about communities outside the 65 DNL, those inside the 65 DNL, the National Environmental Survey, vehicle types, and research areas) a high level summary of policy recommendations - p. 16 (on health effects, noise data sharing, alternative metrics, communications, and research among them); also summarized are recommendations with which the majority agree: for example “most stakeholders agree on the need for additional stakeholder engagement during this process, including an additional Federal Register Notice, before the FAA issues final policy.” At this point, we would argue that, impacts from new vehicles (where there is no data, agency or industry experience to have productive engagement) more analysis and stakeholder engagement makes sense; however, legacy issues are at the stage where it’s time to make decisions and take immediate steps to improve policy and communications.
For our analysis of the FAA’s Noise Policy Review project - or the needs we see are urgent to meet with policy changes, we will be adding the Supreme Court’s decision to end Chevron deference because the FAA (and industry) will no longer have the sole and final word on how to interpret and implement the National Environmental Policy Act (NEPA), a disclosure law and an independent law from the FAA. Stay tuned!
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