FAA To Re-Evaluate Method for Measuring Effects of Aircraft Noise

1. I had a text conversation with a friend who is active on the noise issue who dismissed this announcement as just a public relations stunt.

   I’d give it a little more credit. As a large federal agency, the FAA is bureaucratic with all that is both good and bad about bureaucracy. Bureaucracies that act as they should play by very specific rules and take those rules very seriously. The FAA has a standard in place that determines when they will respond with concern to a noise problem — the 65 decibel day night noise level. Communities like ours that don’t approach that noise level just won’t get every any real attention from the FAA as long as that is the standard, no matter how loud we shout. Courts will also defer to the FAA’s systematic inattention to our communities as long as the FAA is following its rules and the rules are not completely unreasonable.

   The only way the standard will change is through a review like the one they appear to have initiated. It is remotely possible that the study will lead to a change in standard which will recognize the impact of lower level but repetitive noise like that which our communities experience.

2. The process seems thorough and exhaustive but excessively protracted. I surely hope the Boston suburban area is chosen as one of the study areas, otherwise this will be in vain. The sooner we can solve this problem, the better. Summer is upon us and windows will be open The study ought to be especially responsive to the concerns of the most impacted and most sensitive of our citizens. For that would set a safe standard for everyone, as they are the first to sound the alarm. Any solution that appeases them would obviously please everybody. Hopefully this would be the case.

   1. Honestly, expect this to take 5 or 10 years.

3. As the source of the “publicity stunt” characterization – I felt the need to qualify my comment.

   It is been almost two years that we have been fighting to get the FAA to acknowledge that there has in fact been a significant impact to the residents and neighborhoods west of Boston under the new 33L RNAV SID flight paths. In getting into the details of how we got RNAV’ed it is quite apparent that the FAA has been aware of the inadequacy of the DNL and net noise reduction methodology. This methodology is antiquated and has never been updated to account for the shift from ground radar-based to satellite-based navigation systems used to manage our national airspace. DNL modeling and net noise reduction are what was used in the EA process and in the Finding of No Significant Impact that justified the implementation of 33L RNAV SID.

   Long-time members of the Logan CAC recounted that the issue of increased noise under concentrated RNAV flight paths and previously unaffected communities was openly discussed during BLANS Phase 2 meetings. Multiple commenters submitted these same issues as part of the public comment process on the 33L RNAV EA. These comments were disposed of since the FAA had found to their satisfaction that there was no significant impact.

   Why do I think this is a “publicity stunt” – because the press release is designed to deflect all of the direct and vocal criticism the FAA is getting on the issue of noise related to NextGen. It comes at a time when the FAA and specifically Administrator Huerta, are getting massive amounts of negative feedback about noise from citizens and their Congressional Representatives all over the country – Boston, Chicago, Minneapolis, NY/NJ Metro, Phoenix, etc. Since the FAA can no longer make excuses about the noise problem – they are now finally going to study something that an objective observer would able to see exists. I also find it interesting that this study is coming AFTER they have completed the switch to satellite navigation across the US as part of NextGen and deployed RNAV under their 2012 Categorical Exclusion at many airports.

   How has the study been designed? They say that they will be “beginning in the next two to three months, the FAA will contact residents around selected U.S. airports through mail and telephone to survey public perceptions of aviation noise throughout the course of a year”. How will the survey participants be selected? Will these residents be ones under RNAV paths or just random residents? We don’t even know if Boston is included since the study areas are secret.

   The FAA press release further states: “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.” To my knowledge, the FAA has not been in contact with the Logan CAC that represents communities that have been affected by noise from Logan airport.

   The facts here are undeniable. There has been a massive increase in noise complaints as recorded by airports where new RNAV procedures with narrow flight paths have been implemented. Community leaders and elected officials are spending an increasing amount of time dealing with residents who are being negatively affected by noise from Logan. Is this not enough to indicate to the FAA that there is a problem? Furthermore, the FAA is essentially policing themselves. Their Post Implementation Review of new procedures that they frequently reference does not give any consideration to noise complaints or community feedback. As if there is no possibility that their models, analysis or findings could have gotten it wrong.

   The Volpe Center in Cambridge, part of the Dept. of Transportation commissioned two studies in 2011 that examined noise metrics and extensive research on the topic of Noise Impact was done. This research included the collection of reports from other countries and primary research done at PARTNER—the Partnership for AiR Transportation Noise and Emissions Reduction – a Center of Excellence housed at MIT. See link to FAA – Environment and Energy Research & Development – Noise Impacts below.

   There are obviously some very knowledgeable people right here in Cambridge at MIT and Volpe who should be able to tell us if the modeling done by the FAA as part of their 33L RNAV EA was in fact an accurate indicator of the impact of the concentrated RNAV paths on those residents and neighborhoods underneath those paths. That is what residents and communities west of Boston under 33L RNAV paths are asking for – an objective assessment of what life is now like under an RNAV flight path. That is a fair thing to ask considering the negative health impacts of both noise and air pollution related to these flight paths.

   I further find it ironic that the FAA commissioned the development of the Noise Quest site in conjunction with Penn State that among other things – provides information about buying a home in proximity to an airport: http://www.noisequest.psu.edu/communitytools-homebuyers.html. So homebuyers in Belmont, North Cambridge, East Arlington, West Somerville and Watertown who purchased their homes prior to June of 2013 and asked their realtor about airplane noise would have been told – “no, we don’t get a lot of over flights”………… a statement that in 2014, after the implementation of concentrated RNAV flight paths, would be false.

   The FAA can and should do their study but they should not be able to use the study as an excuse not to reevaluate the very real impacts of 33L RNAV SID. The communities west of Boston have been impacted and the FAA needs respond to the Logan CAC request for reexamination by having an honest dialog about exploring modifications or alternatives that would result in a more fair and equitable sharing of overflights from runway 33L departures.

    

   Links: 

    

   FAA – Environment and
   Energy Research & Development – Noise Impacts

   https://www.faa.gov/about/office_org/headquarters_offices/apl/research/science_integrated_modeling/noise_impacts/

    

   These reports were commissioned by The Volpe Center in 2011:

   Technical
   Support for Day/Night Average Sound Level (DNL) Replacement Metric
   Research Report Part 1 (PDF)
   Technical
   Support for Day/Night Average Sound Level (DNL) Replacement Metric
   Research Report Part 2 (PDF)
   Technical
   Support for Day/Night Average Sound Level (DNL) Replacement Metric
   Research Report Part 3 (PDF)
   Updating
   and Supplementing the Day-Night Average Sound Level (DNL) Report (PDF)

    

   The Number-of-Events
   as a Predictor Variable in Aircraft Noise Annoyance Models

   http://web.mit.edu/aeroastro/partner/reports/proj24/proj24-2013-002.pdf

    

   Aircraft Noise Regulation Must Be Revised to Protect
   the Public Health and Welfare Posted on February 17, 2015

   https://airportlaw.wordpress.com/2015/02/17/aircraft-noise-regulation-must-revised-to-protect-the-public-health-and-welfare/

    

    

   1. Myron, the point is just this: DNL is their standard. As good federal professionals, they are going to apply their standard until they formally adopt a different standard. As far as their standards driven process goes, they just cannot recognize the problem, no matter what the increase in complaints. The only way they bureaucratically address the increase in complaints (here and at RNAV-affected airports across the country) is through changing the standard and that is a very big national deal that will take years to accomplish. They cannot, on an ad hoc local basis, address complaints that don’t meet their standard for complaining. That is the ride we are in for.

      1. Phoenix seems to have found a way through persistent and focused political pressure (and hiring Holland-Knight, a high-powered DC aviation law firm) to get the FAA engaged in direct discussions about their RNAV flight path issues which are based directly on an increase in noise complaints from the affected residents and neighborhoods.

         https://skyharbor.com/pdf/May192015_MeetingPressRelease.pdf
         https://skyharbor.com/flightpaths/WhatsBeingDone.html

         Here you can read Phoenix residents feedback on the FAA’s announced study:
         http://www.phoenixnewtimes.com/news/phoenix-residents-unimpressed-with-announcement-of-new-faa-noise-study-7324773

         1. PS. Is it good Federal policy to have representatives of the FAA – a Federal agency presenting at meetings with officials – like the one they held with some legislators as part of the 33L RNAV EA back in 2013 and the meeting on 4L RNAV last week – telling officials and residents that those who will be under new or more concentrated flight paths have “nothing to worry about”. The change in noise won’t be significant. This flies in the face of the actual experience of almost every case nationally where concentrated RNAV paths have been put over populated areas.

         2. Correct me if I am wrong, but I don’t read these articles as suggesting that the FAA is backing away from RNAV in Phoenix. RNAV annoys a percentage of the people in the affected communities everywhere and the FAA should not ever say it doesn’t put a burden on people. But they go by their current standard — 65DNL in determining whether they should do anything different. That is law to them.

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