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)


What Do We Need from FAA to Mitigate Aviation Impacts?

This Post returns to the impacts around KAPA, but also discusses JFK Airport (KJFK). These two airports offer an excellent example of the two largest impacts FAA is currently having on residential neighborhoods in the U.S.: ‘concentrated & repetitive’ closed pattern work associated with flight schools at KAPA, and ‘concentrated and repetitive’ arrival and departure streams associated with NextGen procedures and especially intense at KJFK and other larger commercial hub airports.

This Post also attempts to identify key elements of what we, the people, need from the federal regulator in charge of this system and its amplified impacts.

Click on this link to download the 5-pg PDF, for viewing offline, and feel free to share it onward.

20230731.. From the Oceans to the Mountains, What Do We Need from FAA to Mitigate Aviation Impacts (aiREFORM, 5p)cn2101
Scroll over the PDF above to activate the PDF viewer controls at the bottom; page-scroll with the arrows in the bottom left corner, or use +/- to zoom in/out.


Flight Training Impacts at KAPA & KBJC: An Analysis of the July 7th Denver Post Article

Below is a PDF copy of the text for a good article, published in the Denver Post, on July 7th. The writer, John Aguilar, provides a deep news compilation on how residents are severely impacted by airport operations at and near Centennial Airport (KAPA), and the Rocky Mountain Metropolitan Airport (KBJC).

This analysis by aiREFORM goes further. It is a markup of the Post article, with footnotes that expand on (and in a few cases clarify or correct) portions of the article. The goal of this analysis is to aid readers in better understanding the impacts. It is also to help more people navigate past the obstructionism and confusion seeded by FAA, the airport authorities, AOPA, and other aviation parties.

Click on this link to download the 10-pg PDF, for viewing offline at your leisure.

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.

20230707.. Suburban residents battle noise, lead pollution from busy metro Denver airports (J.Aguilar, DenverPost, 10p,markup)cn42-KAPA


In Letter to CACNR, FAA Regional Administrator Grady Stone Concedes Pattern is Elongated but Falsely Claims Traffic Volume is the Reason

Centennial Airport (KAPA, southeast of Denver) is one of the current top five impacting airports in the U.S. These are general aviation impacts, caused by small single-prop and twin-prop planes staying in the pattern and doing touch-and-goes to the west parallel runway (runways 17R/35L).
Back in May 2021, there was a midair collision when a Cirrus arrival to 17R overshot the final approach course (the line extending north of runway 17R); its prop slashed a series of cuts into the top of the fuselage of a KeyLime metroliner on final to land runway 17L. Amazingly, nobody was killed.

It is one thing for a midair to happen far from an airport, when two planes just randomly meet. But, this midair was particularly troubling, because the flights were being controlled by KAPA tower controllers. Through complacency, they failed to actually work the 17R arrival; they failed to apply positive control by extending the Cirrus on the downwind for just a few more seconds, and they failed to assure the pilots actually saw one another.

This failure triggered a reaction by FAA management: complacency was to be checked, and positive control was to be rigorously applied. But, no policies were implemented to actually LIMIT the number of aircraft in the pattern. Thus, abandonment of the near-lethal complacency standard forced KAPA ATC personnel to extend the overfilled 17R pattern to the north, impacting residents below.

Here’s a screencap showing two hours of KAPA flights last December. It is an ugly picture, but the numbing and incessant drone is even uglier. A red box has been added, outlining the region where base turns would happen in a pattern not overfilled with too many flights. Note the current 17R ‘pattern elongation’ extends miles further to the north, even over the reservoir. Note also that, if ATC chose to reduce risks and limit the number of aircraft staying in the 17R pattern, the base turns would be mostly confined to the smaller green box, much closer to the runway… and the impacts on residents would be significantly reduced.

This is the core frustration thousands have with FAA, CACNR, and the airport: the impacts are huge, and nobody is cooperating to mitigate the impacts.

More than two months ago, FAA attended a Centennial Airport Community Noise Roundtable (CACNR) meeting, on February 1, 2023. Questions then produced this 9-page letter from FAA Regional Administrator Grady Stone, to the CACNR Chair, Brad Pierce.

The letter is long and dry and somewhat confusing. Many of the FAA answers refer back to earlier answers, which tends to diminish letter comprehension. To fix this problem, a modified version of the original letter has been created; content has been reformatted, and each question and FAA answer is provided within a table. Reference portions have been added using a smaller red text. Two dominant response ‘themes’ have been highlighted in color: FAA’s declaration that they did not change how the KAPA traffic pattern is managed (oh, really?!?), and FAA’s assertion that they lack authority on many aspects of air traffic management such as making decisions about numbers of operations (yeah, right!!). Use these links to view copies:

  • [link] to view the modified version of the original letter, or
  • [link] to view a PDF copy of the original 9-page letter.

There was a third dominant response ‘theme’ in the FAA letter, and it is a doozy: a false claim that the KAPA traffic pattern has ‘elongated’ due to increased traffic volume. This is interesting. While the bulk of the letter is just repetitive denials by FAA, within the letter FAA does concede REPEATEDLY that, yes, the traffic pattern has elongated. But, instead of also conceding the cause of elongation we all know (reaction to the May 12, 2021 midair collision worked by the KAPA control tower), FAA insists traffic volume is the cause. As the Analysis below clearly shows, FAA is wrong, and FAA is lying.

A PDF copy rebutting FAA’s false claims about increasing traffic volume at KAPA is embedded below; move the cursor to the bottom left corner and use the up-down arrows to scroll through the three pages.

20230413.. Debunking false detail in ANM.RA.G.Stone’s letter, KAPA ops counts are solidly down (zz32KAPA, 3p)
Scroll over the PDF above to activate the PDF viewer controls at the bottom; page-scroll with the arrows in the bottom left corner, or use +/- to zoom in/out.