June 28, 2016 Dear Members of the Select Committee on South Bay Arrivals, On behalf of multiple noise advocacy groups across three counties, we are grateful for your personal time and energy devoted to advocating on our behalf to resolve the issue of aircraft noise pollution. We know that you have a challenging task ahead and we hope to be helpful and constructive as you consider your response to the FAA Feasibility Report of May 16, 2016. This letter presents the consensus of our several undersigned groups as set forth below and in the attached three appendices. We are aligned in our belief that ordinary citizens should not be required to drive the complex regional solutions required to bring aircraft noise relief to Bay Area residents. This should be the role of the wellqualified experts at the FAA. However, we feel strongly that our role as citizens is to set some critical principles that must drive the search for regional solutions. We are united in our support of the following four principles to inform these solutions: First, noise, as experienced by citizens on the ground, must be made an FAA priority. Safety in our skies is paramount. However, noise pollution is not a necessary byproduct of safety. We insist that aircraft noise pollution limits be prioritized ahead of airline operational efficiency, just as air pollution limits have been prioritized above the operational efficiencies of the automotive and energy industries. Second, the FAA must adopt supplemental metrics for aircraft noise pollution that characterize the true impact of noise on people on the ground. The current metrics and methods (e.g. FAA Order 1050.1F), which did not predict any “significant” increase in noise on the ground with the introduction of NextGen, clearly do not represent an accurate model of the impacts of aircraft noise, as evidenced by the 3,844% (39 times) increase in unique people filing noise complaints since the introduction of NextGen. But the FAA initiative document published on November 19, 2015 (FAA Initiative to Address Noise Concerns of Santa Cruz/Santa Clara/San Mateo and San Francisco Counties) insists that the FAA will continue to evaluate the impact of air traffic management proposals with the outdated and inadequate DNL noise metric. Third, the process to review proposed changes must be open and transparent. Any proposed solutions must be assessed with empirically validated aircraft noise models and computer simulation and these assessments made available for public comment before implementation. Fourth, solutions must be neighborly and not create “noise ghettos” or “sacrificial noise corridors” . Noise mitigation does not have to be a zero sum game that pits residential communities against each other. International best practices demonstrate that aircraft noise reduction is possible.
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We find the process used by the FAA to address the issue of aircraft noise pollution in the Bay Area inadequate for the following four reasons: The FAA has made no commitment to address the issue of aircraft noise pollution. The FAA has not leveraged its own pool of experts to find the root cause of the problem but has relied on the input of the general public. The FAA Initiatives do not reflect input from all advocacy groups. The FAA has deemed “feasible” changes which are not grounded on our agreed principles or criteria about noise or noise pollution. We ask the Select Committee to insist on a systematic, robust analysis of the problem to identify the root causes and fix them. This must include a review of all suggestions that have been submitted, including those that have not yet been considered or prematurely declared “infeasible”. Attached to this letter, please find the following three important appendices: APPENDIX 1: RECOMMENDATIONS TO REPRESENTATIVES ESHOO, FARR AND SPEIER APPENDIX 2: PROPOSED COMPONENTS OF A REGIONAL SOLUTION FOR CONSIDERATION BY TECHNICAL WORKING GROUP APPENDIX 3: FAA’s FEASIBILITY REPORT PARAGRAPH 1fi We recognize that other communities in our nation are experiencing similar distress due to increased aircraft noise pollution. We hope we can help create a model process for solutions that can be implemented across the country. We are committed to working positively and collaboratively with the FAA to this end. With much gratitude for your support, Quiet Skies MidPeninsula Quiet Skies Belmont (signature attached) Quiet Skies Los Altos Hills (signature attached) Quiet Skies Woodside (signature attached) Quiet Skies Menlo Park (signature attached) Californians for Quiet Skies Portola Valley (signature attached) Californians for Quiet Skies Ladera (signature attached) Quiet Skies Redwood City (signature attached) Sky Posse Palo Alto (signature attached) Sky Posse Los Altos (signature attached) Sky Posse East Palo Alto (signature attached) Quiet Skies Santa Cruz San Lorenzo Valley Advocacy Group (signature attached) Quiet Skies Santa Cruz (signature attached) Scotts Valley (signature attached)
Quiet Skies Mid Peninsula
Quiet Skies Santa Cruz
(Signature Redacted) Michael Fassett Quiet Skies Belmont
(Signature Redacted) George Wylie, Jacqui Rice San Lorenzo Valley Advocacy Group
(Signature Redacted) Charlene Mercadante Quiet Skies Los Altos Hills
(Signature Redacted) Mary Andersen Quiet Skies Santa Cruz
(Signature Redacted) Raymonde Guindon Quiet Skies Woodside
(Signature Redacted) Laura Burns Scotts Valley
(Signature Redacted) Bill Evans Quiet Skies Menlo Park
(Signature Redacted) Tina Nguyen Californians for Quiet Skies Portola Valley
(Signature Redacted) Jeanne Gadol Californians for Quiet Skies Ladera
(Signature Redacted) Trudy Theiss, Lorianna Kastrop Quiet Skies Redwood City
(Signature Redacted) Jennifer Landesmann Sky Posse Palo Alto
(Signature Redacted) Don Gardner Sky Posse Los Altos
(Signature Redacted) Marie McKenzie Sky Posse East Palo Alto
APPENDIX 1 RECOMMENDATIONS We respectfully ask the Select Committee to recommend the following to Representatives Eshoo, Farr and Speier: 1. Establish a permanent South Bay Committee for the Reduction of Aircraft Noise Pollution comprised of elected officials with a clear mandate to reduce aircraft noise in the Bay Area and to defend the wellbeing of all citizens on the ground. This Committee should be properly resourced and have access to industry and airport representatives and professionals at the FAA. It should implement a transparent and inclusive process and should be fully independent of the airline/airportcentric SFO roundtable. 2. Establish a permanent Technical Working Group that will follow a robust problem solving process to develop a cohesive set of regional solutions in cooperation with the FAA. The Technical Working Group will report to the above South Bay Committee and will include the FAA and TRACON but will be led by technical consultants hired by the permanent South Bay Committee to defend the interests of all people on the ground. 3. Insist on the adoption of international best practices for meaningful noise reduction e.g.: a. Route arriving and departing aircraft over nonresidential areas (ocean, bay, industrial areas); b. Eliminate or minimize use of delay vectoring over residential areas by making use of published holds at the beginning of the arrival; c. Use planned equitable dispersion (e.g. “herringbone” or “trident” or multiple entries to the bay); d. Eliminate night flights over residential areas; e. Use the steepest possible angle of descent for arrivals, keeping aircraft at cruising altitudes as long as possible; f. Employ engine idle descents. 4. Fund the Technical Working Group to measure noise on the ground in Northern California and to publish this data for analysis by allcomers. The FAA should use this data to build and v alidate aircraft noise models. a. Gather and publish both Aweighted and C/Zweighted noise measurements that better model aircraft noise as perceived by people on the ground. b. The new noise measurement infrastructure in Northern California should have an initial focus on measurement along arrival routes.
APPENDIX 2 PROPOSED COMPONENTS OF A REGIONAL SOLUTION FOR CONSIDERATION BY TECHNICAL WORKING GROUP Arrivals ● Use the "East Teardrop" (i.e., east leg of BDEGA TWO arrivals, which use waypoints LOZIT, BDEGA) over the bay waters as the predominant choice for arrivals from the North, West and Oceanic. ● Create new waypoints over the bay to be used in lieu of MENLO in order to maximize altitudes over populated areas. ● Take advantage of the full extent of the bay for arrivals (e.g. FAITH approach). ● Use the steepest possible angle of descent, especially on runway 28L given that it is closer to populated areas. ● Instruct ATC to distribute arriving aircraft to multiple transitions from multiple waypoints along the arrivals to multiple intersections along the approaches (e.g. ‘herringbone’ or ‘trident’ patterns). ● Raise and keep BRIXX altitude over Woodside and Portola Valley at or above 12,000’. ● Any aircraft should not cross the Woodside VOR and Skyline area at less than 8,000’ for the same noise abatement reasons that require this on the Oceanic Approach (in accordance with the Eshoo agreement codified in the FAA Facility Order NCT 7110.65U). ● Create new waypoints along Skyline and west of Skyline to maximize traffic over nonpopulated areas (e.g., a new waypoint in the unpopulated Phleger Estate Area as an alternate to Woodside VOR). ● Limit the number of arrivals in a given corridor. ● Eliminate or minimize use of delay vectoring over residential areas by making use of published holds at the beginning of the arrival. ● Use planned equitable dispersion (e.g. “herringbone” or “trident” or multiple entries to the bay). Night Flights ● Route all night arrival traffic over the full length of the bay. ● Eliminate night flights over residential areas (no flights between the hours of 22:00 and 07:00). Departures ● Raise the altitude of SJC departures to the Pacific over multiple MidPeninsula communities. ● Maximize offshore use and stay well west of Skyline Blvd for the SFO and OAK departures to Southern California (e.g. LAX, LAS, SAN, SBA) and the US Southwest. General ● Integrate noise abatement planning between all Bay Area airports. ● Design and route aircraft over nonpopulated areas (e.g. ocean, bay, industrial areas etc) for arrivals and departures. ● Require the FAA to issue an Airworthiness Directive requiring installation of vortex generators on all appropriate Airbus aircraft.
APPENDIX 3 FAA’s FEASIBILITY REPORT PARAGRAPH 1fi In the evaluation of this adjustment, the FAA proposal states: …“having hard altitudes at the suggested waypoints on the BSR would remove the possibility of implementing an OPD.” It also states, “It was instead suggested that these altitudes be adjusted in order to allow for OPD.” The FAA proposal to revert SERFR to the BSR ground track may provide relief to those currently suffering under SERFR, but only to the extent that equal suffering from jetnoise would occur in other Santa Cruz and Santa Clara County Communities under BSR. Imposing OPD at BSR would result in the lowering of BSR altitudes to essentially match the currently existing OPD altitudes at SERFR. In the MidPeninsula area, it is a matter of geometry. BSR and SERFR ground tracks progressively grow closer and eventually merge. Subsequently, any relief has a diminishing return from ground track changes the closer the ground tracks are to MidPeninsula, leaving a hugely populated area underserved if the issues of procedures, current and anticipated future concentration, and lowered altitudes are left unaddressed.
