The proposed policy document is valuable to communities in that it summarizes the recent history of aviation noise policies and legal decisions. This will enable newcomers to this complex debate to understand the immense difficulties of obtaining legal redress where aviation activity creates hardship.
The policy document is a mixture of past history, proposed research programs whose potential benefits lie far in the future, and present and near-future policies that form the bulk of FAA response to a prevailing and growing universal concern for the threat imposed by continuing airport expansion in and near large population centers. It is extremely disappointing as a guideline for the next 25 years in many respects, including the following:
The history presented on aviation noise reduction since 1976 is largely self-serving and without tangible substantiation -- and thus difficult to dispute. However, the broad picture as applied to the United States of America may appear, the specifics of a particular locality -- as, for example, the San Francisco Bay Area -- are not at all consistent with the claims of dramatically reduced noise levels.
Much space is devoted to the aggressive pursuit of ways to reduce noise impact and the reaffirmation of FAA intent to listen to communities and to include their proposals and suggestions in its strategic planning.
Unfortunately, these are hardly consistent with the history of FAA response to concerns of San Francisco Bay Area residents. Our organization of concerned homeowners' associations has submitted various proposals that have been studied by aviation consultants and legal counsel, only to find that they receive little or no serious attention from either FAA or local airport proprietors. It is clear that the entire FAA policy does not enable communities to enter the debate as equal participants.
While current regulations require formal evaluation of environmental impact and public participation, from our local experience with both Oakland and San Francisco airports we see public meetings staged as information shows that are conducted by public relations staff and that offer no opportunity for serious discussion with policy makers. The inevitable conclusion is that expansion policies have been sanctioned in advance by the transportation authorities and that any public presentations are a part of well-funded public relations campaigns. SFO is an egregious example.
The real backbone of FAA noise control policy for the immediate future is clearly defined as establishment of land-use compatibility. However, this never considers the question of whether a particular airport should be relocated because of its continuing impacts -- of which noise is merely the most obvious pollutant -- on the established community. For example, San Francisco airport -- which sits in another municipality -- proposes expansion which will clearly have a major environmental impact on both the entire region and the Bay. The Bay itself is a primary factor in the existence and well-being of all of the communities. This has been the topic of many scientific presentations, as have the profound effects of loading more and more aviation and aviation-related activity into this compact region. Nevertheless, consideration of non-operational Air Force facilities such as Travis Air Base - which has the capacity for expansion as well as for the FAA-favored "buffer" areas - are given little credence. In such examples, evidence of FAA's aggressive pursuit of solutions is hardly apparent.
Despite the importance placed on buffer zones in the FAA policy statement, page 43818 acknowledges planning for compatible land use as being under State and local planning jurisdiction. Further, it succinctly concludes that if residents do not like the effects of airport expansion, they are free to relocate. This is not consistent with the stated policy of seeking public participation.
It is particularly disappointing to read on page 43820 that the broad relationship of noise and annoyance presented by Dr. Schultz in 1978, from which 65 DNL was selected as a politically-viable regulation, is to continue as the sole descriptor of aviation noise for the next quarter-century. Still more disappointing is the fact that other descriptors such as SEL are totally rejected on the grounds that a substantial body of data on DNL has been compiled since its inception.
While the sheer quantities of data on other descriptors cannot compare with the DNL compilation, substantial evidence exists to support the inclusion of SEL with DNL data in assessment of specific situations. In addition, study of low frequency noise effects indicates that the universally-applied A-weighting -- which is the underlying fundamental of all DNL data -- is highly questionable when noise levels are very high, as in the take-off pattern of most airports.
In conclusion, the FAA proposed policy document for Noise Abatement Policy 2000 is an inadequate guide to what can only be a time of incredible technological advances. We recommend a substantial re-assessment of the stated policy guidelines, preferably with the involvement of scientific groups and local communities but, above all, by people who are completely independent of government agencies.
Respectfully submitted,
CITIZENS' LEAGUE FOR AIRPORT SAFETY AND SERENITY, ALAMEDA, CALIFORNIA
