It’s just past midnight. on 10/8/20115, at 11:59pm I submitted my last comment to the FAA about the SoCal NextGen Project. There has been no announcement of an additional extension for the comment period. After 4 months of feedback it look like the deadline will stick- its time to take a break.
The comment period for the Draft Environmental Assessment(EA) for the FAA’s SoCal NextGen project had been extended twice already. When The FAA released the draft EA in June, they declared “No Significant Impacts” and was poised to carry out their changes to the airspace. I believe enough evidence has been delivered to the FAA about specific shortcomings of their EA that they need to pause and take, in what is called legal language, a “hard look” at their SoCal implementation of NextGen.
The Sierra Club Angeles chapter was very generous, enthusiastic and patient when I proposed the project to provide specific comments in line with the Sierra Club’s concerns. I’m glad that the Club was able to voice comments on this important issue. I recommend reading the Document- It’s 21 pages- half of them are tables and pictures so it’s not a tough read. To summarize though I’ll share some highlights of the Sierra Club comments to the FAA Socal Metroplex below.
Highlights of Sierra Club Comments
Communicate with the Public.
Public involvement means more than sending a press release to the major newspapers inviting people to read your 800 page document. The 11 public meetings introduced was heartening but still falls short when it comes to communication. When people come to a document, or a meeting – they want to know whats the big picture, what things will change for me, what are my options?
People hear aircraft noise one – plane – at – a – time and need to be given feedback in a way that hooks into this comprehension. Instead, the EA describes noise as an average of noise events over the day. An average describes the measure but fails to communicate the quality of the noise. Using a supplemental metric, such as number of times a plane over 60dB will fly over – a conversation pausing noise level – can help bridge this need for understanding.
Sites needing special consideration.
Here is the Sierra Club’s map of 400 natural resource sites and areas that will be affected by increased noise from the Proposed Action.
Special status is given by the FAA to sites and resources within the DOT’s Section 4(f) list. These are publicly owned public parks, recreation areas, or wildlife or waterfowl refuge sites. The SC argument is derived from the one I explored in my EA fails on Federally identified Noise Sensitive areas comments.
These 4(f) sites and cultural resources are not constrained by the noise criteria and, according to FAA regulations and legal precedent, they are eligible for special consideration which includes cumulative effects- the incremental increase of aircraft noise over time. A claim of “No Significant Impact” can not be made until it is proven across these sites.
The list of the Sierra Club’s 400 4(f) resources are those which have an increase of 1.5 dB or more – and are included as Appendix A( also in this map.)
I believe this argument on 4(f) sites is so important that it’s reiterated separate from just the noise impacts. The Sierra Club asks that diligence be pursued in the evaluation of any potential impacts to endangered, threatened and sensitive wildlife species found at all 213 ecological or wilderness reserves, wildlife refuges, sanctuary’s, preserves and study areas affected in the Metroplex.
Demand Environmental Justice
A few days ago I did a search on “comments to FAA Environmental Assessment” and got distressingly few results. In a region of 19,249,073 people there were three communities: Culver City, Newport Beach and Point Loma- which are the hot spots for comments. Residents may disagree about this but these 3 communities are not the worst off.
Yesterday I called the City of Orange, perhaps one of the hardest hit communities close to me, and reminded the assistant City Manager of the FAA’s deadline. Seems the FAA doesn’t reach out to the communities most strongly affected.
All government agencies are COMPELLED by Executive Order to take the steps to make sure that high and adverse impacts don’t affect low-income and minority populations disproportionately.
Here is a sample across the Metroplex that shows someone was flying on autopilot when they summarily dismissed the need to study these high or severe impacts. *The FAA’s criteria for low income in the SoCal Metroplex area is 11.7% and 40.5% for minorities.
|Locale||Tract||Max increase in noise||Ethnic Majority||% of majority||Population||100% poverty level||200% poverty level|
|Home Gardens||414.12||3.7 db||Hispanic||56%*||4695||8%||36%|
|Pine Valley||212.02||4.9 dB||White||79%||2828||12%*||28%|
|San Bernardino||110.01||5.8 dB||White||66%||2375||19%*||45%|
If that doesn’t make you cry, you’re not a bleeding-heart liberal. There are some affluent white people too that will be surprised by a 6dB DNL increase of aircraft noise day-one of implementation. Since the wealthy don’t live packed as close together, with a narrow flight path, the disadvantage remains with those already disadvantaged.
Though not included with the Sierra Club comments, an interactive map of noise impacts used to help research is here.
How Efficient is it?
One of the more disappointing pieces of information is that the Proposed changes will not result in saved fuel or reduced emissions. It will cause 8.2 metric tons (MT) of added fuel to be burned this coming year resulting in 27 MT of additional CO2 and other non specified pollutants – including particulate matter (PM10 & PM2.5).
If the efficiency of the routes do not increase, what is the purpose of creating more ground impacts through razor-precise flight paths that concentrate noise, shortening of approach and descent paths (with resultant altitude drops over residences), and the unilateral discarding of established community noise abatement procedures? NextGen did not deliver on its promise.
There are good things about satellite navigation and it should be more widespread. Unfortunately NextGen, as implemented by the FAA, carries disproportionate burdens to people on the ground. Other problems are a result of the FAA not taking their full responsibility to protect the people on the ground.
I sincerely hope the FAA will take a harder look at their proposal, adjust it accordingly, and embark upon a mature, and understandable, Environmental Impact Statement. At that time I, along with the Sierra Club project team, will be happy to supply further positive comment.