Improper Baseline used to determine impact

Over the City of Culver City, the levels of impacts stated by the OAPM EA to support their finding of No Significant Impact are based on comparing the proposed new flight paths to a “no action” alternative. The “no action alternative” is based on current flight patterns — assessed as of December 2012, and projected into 2015 and 2020. Thus, the current and former flight patterns constitute a baseline against which future proposed levels are compared.
The baseline is, however, inaccurate. The true baseline should be 6 months before in June 2012 prior to a flight path change implemented without public notice and comment. The EA’s December 2012, 2015 and 2020 baselines therefore skew the before-and-after analysis by choosing a “before” level that already reflects the pre-accomplished lowering of altitudes over a recently peaceful and jet-fuel-emissions-free residential environment.

There was a slight lowering of aircraft altitudes in 2012 after the implementation of the SADDE RNAV/LAX KEACH STAR overlay which ends at SMO.

pre-2012 & Current flight altitudes over Culver City ( West Flow)
LocationAverage 2010-11Average 2012-142012 Change
Rancho Higuera63106206-104
Carlson Park65596384-175
Lindberg Park68786201-677

The EA needs to include the cumulative impact of the LAX KEACH STAR overlay of the western part of the SADDE STAR, which was implemented while the SoCal OPAM project was under way. In the OAPM study team analysis of the CRSHR STAR, they stated ” The OST identified no gain in efficiency between the KEACH and the SADDE and expects no change in operations due to its implementation.” If they were effectively equivalent, as this presumption states, the baseline evaluation needs to exclude the KEACH from noise analysis and use the earlier SADDE conventional as baseline.