CITY OF HUNTINGTON BEACH
2000 MAIN STREET, HUNTINGTON BEACH, CALIFORNIA 92648-2702
TONY STRICKLAND
MAYOR
July 19, 2023
Fed
eral Aviation Administration
U.S. Department of Transportation (DOT)
Docket Operations, M–30, 1200 New Jersey Avenue SE, Room W12–140, West Building Ground Floor
Washington, DC 20590–0001
Re
: Docket No.: FAA-2023-0855
Request for Comments on the Federal Aviation Administration's Review of the Civil Aviation Noise Policy
The City of Huntington Beach (the “City”) welcomes the opportunity to comment upon the significant noise burdens that were imposed on it by NextGen and the Southern California Metroplex (“Metroplex”) starting in approximately 2016. FAA’s current 65 DNL metric for assessing “significant” noise fails to account for the real-world, significant noise burdens created by multiple, continuous, minute-by-minute, moderate-level dB jet noise events. There is unceasing “drip, drip, drip” annoyance in areas that are not contiguous to any airports, yet current metrics find this noise not to be “significant.” This is a particular problem for Huntington Beach where arrival paths into three separate regional airports (Long Beach, Santa Ana, and LAX) have been designed by Metroplex to converge at altitudes between 1600 and 7000 ft. over large areas of our city. 1 We support changes, additions, or replacement of the current noise metrics used by FAA, or other actions that would reduce the real-world aircraft noise that adversely affects our residents, schools, and businesses.
Thi
s Comment addresses Question Nos. 2 (Operations of Air Vehicles), 3 (DNL), 4 (Averaging), 5 (Decision Making Noise Metrics), 6 (Communications), 7 (NEPA and Land Use Noise Thresholds Established Using DNL or for Another Cumulative Noise Metric), 8 (FAA Noise Thresholds Using Single-Event or Operational Metrics), and 11 (Literature Review).
FAA SHOULD CREATE SEPARATE METRICS FOR ECONOMIC
MITIGATION AND ANNOYANCE
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untington Beach specifically requests that FAA create two metrics. Similar to the current 65 DNL standard, the first would establish a measure for required economic mitigation. The second would not require mitigation outlays, but would separately inform airspace management decisions and recognize the real-world significance of the “drip, drip, drip” effect in areas such as Huntington Beach.
Huntington Beach believes that any changes to the economic mitigation metric being considered by FAA likely will have minimal application to the City and no improvement for residents, schools, and businesses. Nonetheless, Huntington Beach suggests that the current 65 DNL level is unreasonably high, and demeans the word “significant” as understood by our 1 This does not even include the additional noise burden from departure overflights from each of these three and other Southern California airports that cross Huntington Beach at higher altitudes. draft
constituents and the public at large. Accordingly, we recommend that FAA (i) adopt a CNEL standard as the economic mitigation metric, and (ii) adopt for that mitigation metric the 45 dB level recommended by the WHO, or at least the European level of no higher than 55 dB.
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Huntington Beach, a more important new metric should be adopted that would address the “drip, drip, drip” effect and inform airspace management decisions such as Metroplex.
Huntington Beach does not have the expertise to create a specific algorithm or metric for determining exactly how “drip, drip, drip” noise should be measured or considered. However, the City’s experiences with Metroplex and common sense suggests that in addition to any economic mitigation standards, FAA should use a second metric taking into consideration the following factors when modeling aircraft routing:
1. The number of aircraft flying within a horizontal proximity creating noise above ambient;
2. The altitude of such aircraft;
3. The noise above ambient of each aircraft;
4. The duration of each noise event above ambient;
5. The spacing between noise events above ambient; and
6. Any other factors impacting above ambient, but below economic mitigation noise.2 T
hese numbers can be determined by Zip Code or other location identifiers, and given a relative ranking of annoyance above ambient but below the economic mitigation threshold. That ranking would then be added to existing and future routing models as a factor to be weighed and considered. Adding these variables to computer models should result in airspace management that is not controlled by noise considerations, but which also does not ignore that the real -world consequences of airspace management decisions are significant even when they may not meet the economic mitigation metric. More important and as demanded by f undamental fairness, it would more equitably spread the regional noise burden from three major airports that Metroplex has singularly imposed on Huntington Beach in Southern California.3 RE
DUCING NOISE ANNOYANCE IN HUNTINGTON BEACH
In addition to revised or new metrics, in the specific case of Huntington Beach, two other changes are proposed by the City that would immediately and definitively lower noise over the City: firstly, a return for over-ocean approaches to Long Beach (KLGB) to pre-NextGen dispersion patterns; secondly, to make a CDA approach into KLGB the default for over -land approaches, rather than the current as-requested basis which is used over 70% of the time by arriving pilots. 2 One metric for consideration is the Number-Above (“Nabove”) or possibly Nabove per hour. Nabove is the only metric that combines single event noise with the number of aircraft operations. As noted by Penn State research, Time-above could also be a useful metric to properly account for the duration of aircraft operations over a particular area. The duration of large commercial aircraft over Huntington Beach ranges from 30 seconds to 3 minutes, depending on which of the three regional airports is involved and whether the aircraft are departures or arrivals.
3 If nothing has changed over Huntington Beach, as periodically has been suggested by FAA, there would have been no need for Metroplex in the first instance. FAA needs to abandon any notion that it would be “unfair” to shift to other areas any increased noise burdens imposed on Huntington Beach by Metroplex.
The unfairness was shifting the burden of three major airports to Huntington Beach in the first instance. draft
Arrivals are a particular noise problem as Huntington Beach is simultaneously overflown for approaches into all three of these airports. LGB arrivals are generally at 2500 ft. and below over Huntington Beach; SNA arrivals are around 5000 ft.; LAX arrivals are around 7000 ft. However, some flights into LGB fly over Huntington Beach as low as 1300 ft. for no discernible reason.4 W
hile all jet aircraft are noisy, there is a direct correlation between aircraft altitude (proximity) and noise burden. But it is the cumulative “drip, drip, drip” effect of constant overflight noise minutes and at times seconds apart seven days a week into three separate airports with no relief that has dominated the noise complaints emanating from Huntington Beach residents. In fact, the number of noise complaints from Huntington Beach residents since the implementation of Metroplex have consistently outnumbered complaints from Long Beach residents because Long Beach residents only have to deal with noise from one airport while Huntington Beach has been getting non- stop approach noise into three major airports since the Metroplex implementation.5
In r
esponse to substantial noise complaints from citizens following the implementation of Metroplex, Huntington Beach formed a citizens’ Jet Noise Working Group and subsequently a City Council-appointed Jet Noise Commission. The Working Group and Commission separately tried on multiple occasions to engage FAA in discussions about the impacts of Metroplex and proposed alternatives. FAA has c onsistently failed to meaningfully engage or to even acknowledge that Metroplex created a significant noise burden over Huntington Beach. The City’s multiple requests for FAA engagement were supported via a bipartisan letter from U.S Congressional members and then-Quiet Skies Caucus members Michelle Steel and Alan Lowenthal to FAA Acting Administrator Billy Nolen, dated June 7, 2022. (Copy attached.)
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untington Beach is not seeking to expand noise mitigation costs. Rather, we are suggesting that real-life noise impacts need to be considered beyond those which would require costly mitigation outlays. Those can be as simple as making minor adjustments to aircraft approaches and altitudes that would ease the noise burden at least some. For example, Huntington Beach is under an approach path into LGB that has an IFR procedure to cross waypoint “LUCIG” at 3000 ft. and to do a continuous descent approach into the LGB RW30TZ. On VFR, pilots can fly close to that given permission from TRACON provided there are no safety issues.
However, it appears that TRACON routinely directs aircraft to cross “LUCIG” at 1600 ft. unless pilots request a higher approach. Roughly, 80% of the time pilots from one particular carrier request and receive approval for the 3000 ft. approach. However, other carriers have not been as sympathetic, and TRACON generally directs these flights to cross at 1600 ft.
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here is likely a > 1.5dB shift between crossing LUCIG at 3000 ft. and 1600 ft. Defaulting all commercial traffic to 3000 ft. at LUCIG would make a noticeable difference to the City’s noise exposure and reduce noise complaints into LGB. It also would not require any changes to Metroplex; it simply would be a direction to TRACON to default to the 3000 ft. altitude approach rather than 1600 ft. Safety exceptions would always apply.
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espite support for this change from Long Beach Airport and at least one major carrier, FAA refused to even consider such a minor modification that would (1) reduce the noise burden 4 These low-level approaches are still 10 miles from LGB, requiring aircraft to power up to maintain this low- altitude approach. This only increases noise levels, burns additional fuel, and creates unnecessary carbon emissions. These outcomes are entirely inconsistent with the stated goals of NextGen. 5 This does not include the higher altitude departures and overflights that add an additional noise burden to Huntington Beach.
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over Huntington Beach, (2) save fuel, and (3) reduce carbon emissions. It is unknown why FAA has not supported such a modification other than it appears FAA does not want to open a “can of worms” by acknowledging that noise is a significant problem below e xisting thresholds for economic mitigation. That defies common sense and ongoing studies evidencing adverse health effects from aircraft noise at levels well below 65 DNL.
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AA also ignores that the 1600 ft. approach not only unnecessarily burns extra fuel and adds to the carbon burden, it is well below the 3000 ft. mixing threshold for jet emissions. FAA has determined that 3000 ft. and above represents the altitude where aircraft emissions do not mix with air near the ground. The corollary is that mixing with ground air does occur when jet aircraft are below 3000 ft. If TRACON uses the 3000 ft. approach into LBG as the default rather than 1600 ft., that should significantly reduce pollution at ground level.
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NCLUSION
Beyond assessing noise metrics academically, FAA needs to acknowledge the real-world noise impacts of Metroplex on communities such as Huntington Beach, and work in good faith with local representatives on mitigating alternatives. As noted, we are located between three major airports in the Southern California region, Long Beach, Santa Ana, and LAX. Arrivals and departures from each of these airports now fly constantly over our residents spaced only a few minutes or less apart during waking hours and intermittently at all hours of the night seven days a week. There is no respite. Prior to Metroplex, aircraft were much more dispersed and at higher altitudes on approach. Unfortunately, the Metroplex changes have routed aircraft along much more condensed flight paths over Huntington Beach at significantly lower altitudes.
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untington Beach residents have been materially harmed by Metroplex in their quiet enjoyment of their properties and FAA’s continued reliance on the 65 DNL standard for noise “significance.” FAA needs to acknowledge the material and adverse effects concentrated, low - altitude jet aircraft have had on the City, and to work with the City particularly on approach alternatives that would provide at least some relief. Airspace routing determinations need to be informed by actual impacts over the ground as opposed to those designated for economic mitigation.
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e thank you for your consideration of these vitally important issues to Huntington Beach.
S
incerely,
T
ony Strickland
cc:
Honorable Katie Porter, U.S. Representative - CA 47th Congressional District draft