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Comments by aiREFORM submitted to the ‘Noise Policy Review’ NPRM-RFC [Docket FAA-2023-0855]

A few hours ahead of the closing deadline, aiREFORM submitted a 37-page PDF to the Federal eRulemaking Portal, for ‘Docket No.: FAA–2023–0855: Request for Comments on the FAA’s Review of the Civil Aviation Noise Policy’. The pages break down as follows:

pages 1-4 Part 1: Summary, & General Concerns
pages 2-8 Part 2: aiREFORM comments to FAA’s 11 numbered questions
pages 9-10 Analysis of 1980-2022 ops at 39 major airports
pages 11-12 May 2015 Press Release – FAA to Re-Evaluate Methods for Measuring Effects of Air Noise
pages 13-37 April 2020 – FAA Report to Congress (25p)

The opening page includes this:

I ask FAA to join me in supporting the Aviation-Impacted Communities Alliance (AICA) comments submitted at Docket No FAA-2023-0855-2206. AICA has worked very hard to connect impacted citizens and organize our concerns about these ongoing (and at some locations expanding) aviation impacts. There are many good and solid proposals offered within the AICA comments.

My own comments follow, and are organized as follows:

    • Part 1: provides a summary & overview of this NPRM-RFC1 document
    • Part 2: provides FAA’s specified questions, and this citizen’s comments and suggestions

Part 1: Summary, & General Concerns

The comments that follow are provided by a retired FAA air traffic controller. During his career, he assisted many local residents toward mitigating aviation impacts. Since retiring, he has spent decades studying aviation impacts and working to assist residents across the nation. What he has found is that his former employer, a federal agency with supreme authority over all regulatory aspects of aviation, is failing. FAA is effectively a captured regulator. FAA is not serving the nation; instead, FAA is serving to enable excessive operations (and impacts) by aviation players, who gain financially with FAA inaction and delays, often aided by current FAA employees who have conflicts of interest due to other non-FAA aviation work.

People are being damaged; communities are being destroyed. This NPRM-RFC is centered on Aviation Noise, which is one of the three primary aviation pollutants (the others being air pollutants, and contamination of ground and water). In 2023, we are seeing FAA’s programs lead to rising noise pollution in many areas, but these two rise above:

At major airline hub airports, where NextGen technologies are automating procedures by both aircraft navigational systems and ATC systems, to tweak flow rates higher, all in the goal of accommodating airlines wanting higher airport capacities. FAA has been aggressively ‘collaborating’ with industry to achieve these goals, despite the fact that airline operations have been declining for more than two decades. Under these changes, thousands of homes are inundated with nearly nonstop stress-inducing noise patterns. Worst-case examples today include JFK, LGA, DCA, SEA, BOS, and many others.

At general aviation airports, where consolidation of flight training programs is creating intensive concentration of closed pattern operations at a select few airports. Private-equity funded, national-scale, flight schools are importing students from across the globe, and profiting from the impacts they impose upon communities below. The Front Range of Colorado is the current worst-case example. Operations at BJC, APA, and a handful of other regional non-towered airports have soared, as have pollutant impacts, in some cases doubling in a few years… yet no environmental analysis or public engagement process preceded any of this growth. On top of this problem, hobbyist pilots and some affiliated with these flight schools and other operators are using social media to identify and then bully the few citizens who try to aid their neighbors by speaking up. The bullying even includes an aviation variant of road-rage: the use of small planes to descend and circle low over homes of known concerned citizens, to intimidate them … and FAA is doing nothing to curtail this bullying. It is as if there were no real regulation by FAA; no accountability for the players who gain profits or just pursue their hobby, while spewing pollutants (often including lead toxins) in the air above our homes.

So here we are, today, offering comments requested by FAA, to assist this huge and deeply-funded agency in their quest of a review of aviation noise policies. Which begs the question: what exactly is the current ‘Aviation Noise Policy’ being reviewed?

To read the rest, click on this link to download the 37-pg PDF, for viewing offline, and feel free to share it onward. Use the embedded PDF below to read the PDF online; dwell on the bottom left corner of the PDF to use up-down arrows (for page scrolling) or to zoom in/out. 20230929.. aiREFORM comments to Dckt FAA–2023–0855(37p)