At the July meeting of the LAX / Community Noise Roundtable Boardmember Steve Alverson summarized the LAX specific changes in the draft Environmental Assessment. He listed some of the proposed changes to arrival and departure procedures and the extent to which Roundtable noise abatement recommendations were incorporated into the proposed procedures.
It’s worth viewing, particularly starting at page 12- though admittedly these slides may appear cryptic as they won’t represent the oral presentation and discussion made during the presentation.
The EA describes the “purpose and need” of some of the flight path changes in Section 2 and The Design Team Tech Report describes the result. What’s missing From the EA is:
- An explanation to “why” the proposed action was determined to be the most optimal,
- The expected impacts on the ground in metrics and population exposure to noise.
An impact analysis of each flight track change, specifically any altitude lowering or significant lateral movements over population should be within the proposal. Environmental Assessments are considered cursory, possibly an EIR could better communicate the impacts to the community.
The Roundtable has sent their comment letter which addresses the following points in a summary fashion:
- The Shifting and Exposing Noise to New Residential Areas
- Aircraft Flying at Lower Altitudes
- Concentration of Flights
- Making adjustments to Procedures after implementation
- Integrating the round Tables September 2012 recommendations
- The Deconflicting of SMO & LAX Departures
- Use of supplemental Noise Metrics
- Insufficient information in the Draft EA
You can explore the rest of the document in this PDF:
If the above doesn’t work in your browser, I’ve include the first 2 pages here and a link at the bottom:
September 2, 2015
SoCal Metroplex EA
Federal Aviation Administration
Western Service Center – Operations Support Group
1601 Lind Avenue SW
Renton, WA 98057
RE: Comments on the Draft Environmental Assessment for Southern California Metroplex Project
Dear Sir or Madam:
The Los Angeles International Airport/Community Noise Roundtable (Roundtable) is a voluntary and independent body that consists of membership from local elected officials and staff, representatives of congressional offices, members of recognized community groups, airlines, Los Angeles World Airports (LAWA), and the Federal Aviation Administration (FAA) as a non-voting member. These parties work together to identify noise issues that affect communities surrounding Los Angeles International Airport (LAX) and seek feasible solutions to reduce aircraft noise in those affected communities.
The Roundtable recognizes the FAA’s efforts to improve efficiency and enhance safety in the Southern California airspace by developing approach and departure procedures that take advantage of satellite-based navigation technology. These new satellite-based procedures are intended to enable aircraft to fly more efficient, direct routes and enhance safety through improved predictability and repeatability of procedures. The new procedures will also change where and how aircraft fly and may potentially affect the residential communities.
The FAA prepared the Draft Environmental Assessment (EA) for the SoCaI Metroplex Project to document the potential environmental effects associated with the proposed procedures and initially provided the public with 30 days to review and submit comments. After receiving a number of requests, the FAA extended the public comment period by 60 days with a new deadline of September 8, 2015. The Roundtable appreciates the FAA extending the comment period to allow the public additional time to review and provide comments regarding the potential environmental impacts of the project. Roundtable’s Concerns and Suggestions
The specific comments contained in this letter are not intended to be comprehensive, but instead are representative of the general concerns that this body has identified. The Roundtable is concerned that if the Metroplex procedures are implemented as proposed in the EA, they will result in: 1) shifting noise from one community to another; 2) exposing new residential areas to aircraft overflights; 3) lowering aircraft altitudes over certain communities; and 4) creating a concentration of flights over a narrower area when compared to the existing conditions.
Shifting and Exposing Noise to New Residential Areas
Some of the most prominent changes with the proposed procedures occur during east flow operations with the two main LAX arrival routes, used by aircraft arriving from the east, shifted north and south of their current location by 2.3 and 1.6 nautical miles, respectively, on the LAX BIGBR1 and BRUEN1 STARs. These proposed arrival procedures will cause aircraft to fly over residential areas that did not previously experience aircraft overflights. In addition, the proposed departure procedures for east flow operations will shift noise from one location to another. For example, the LAX TRTON1 SID directs aircraft to make tighter turns after departure toward the east, resulting in shifting of noise that affects the beach cities. The LAX GARDY1 SID directs aircraft heading eastbound to fly a route that will expose residential areas that do not routinely experience departures from LAX to new aircraft overflights. These proposed changes are significant enough to cause residents to notice a change in flight patterns even though east flow operations only occur about five percent of the time during the course of a year.
To help minimize noise exposure associated with these and other proposed changes that result in shifting and exposing noise to new residential areas, the Roundtable suggests that the FAA reduce the shifting of aircraft routes where possible and develop procedures that mimic current flight routes as much as possible. If modification to existing routes is required, consider routing aircraft over commercial and industrial areas instead of residential areas to avoid noise exposure to the residential neighborhoods.
Aircraft Flying at Lower Altitudes
Some of the proposed changes will cause aircraft to fly at lower altitudes over certain communities. The FAA created the CLIFY waypoint to replace the SMO VOR for the purpose of satellite navigation. Aircraft arriving to LAX normally fly over the SMO VOR at 7,000 ft. during Westerly Operations (normal daytime traffic pattern) and at 8,000 ft. during Easterly Operations (wind conditions) and Over Ocean Operations (normal nighttime pattern from midnight to 6:30 a.m.). With the proposed changes, aircraft will fly over the CLIFY waypoint at 7,000 ft. regardless of the traffic flow configuration. This will cause aircraft to fly 1,000 ft lower during Easterly Operations and Over-Ocean Operations, creating a noticeable change for this area community that is already sensitive to the high volume of air traffic descending for arrival.
Another example of aircraft flying at lower altitudes is associated with the proposed LAX LADY J departure procedure. This procedure will lower the altitude requirement for aircraft flying over Malibu. As proposed, aircraft will cross the waypoint LADYJ located in Malibu at 8,000 ft. rather than the existing CHART waypoint at 9,000 ft. Aircraft will be flying 1,000 ft. lower over Malibu and cause residents to notice a change in altitude.
The Roundtable recommends that the FAA maintain existing altitude requirements for the SMO VOR (CLIFY waypoint) and the LADYJ waypoint. Residents will indubitably notice aircraft flying at lower altitudes at these locations if the minimum altitudes are lowered by 1000 ft. The FAA can avoid this potential noise issue altogether by not lowering the altitude requirements for any procedures.