San Francisco International
Airport/Community Roundtable
455 County Center, 2nd Floor
Redwood City, CA 94063
T (650) 363-4220
F (650) 363-4849
www.sforoundtable.org
Working together for quieter
skies
DATE 1
2 Billy Nolen
3 FAA Administrator (A)
4 Federal Aviation Administration
5 Via: Federal eRulemaking Portal
6 Re: DOCKET # FAA-2023-0855 FAA Request for Comments on Review of the Civil Aviation Noise Policy 7 Dear FAA Administrator Nolen,
8 Thank you for the opportunity to provide these comments in response to the FAA request for Comments 9 on the Review of the Civil Aviation Noise Policy.
10 Established in 1981, the San Francisco Airport/Community Roundtable, (Roundtable) represents more 11 than 1.5 million residents of the combined City and County of San Francisco and of San Mateo County. 12 Roundtable members include elected officials of the Boards of Supervisors of the City and County of San 13 Francisco and San Mateo County as well as from the City Councils of all twenty cities within San Mateo 14 County.
15 The Roundtable collaborates with the San Francisco International Airport, the Federal Aviation 16 Administration, airlines, members of Congress and other elected officials, noise-impacted communities, 17 and the public with the purpose of developing, evaluating, and implementing policies, aircraft 18 procedures, and mitigation actions that will reduce aircraft noise exposure in the neighborhoods and 19 communities in San Francisco and San Mateo Counties, and to advocate for aircraft noise related 20 legislation and programs, and to support research that reduces aircraft noise impacts. The pre-eminent 21 goal of the SFO Airport/Community Roundtable is to improve all aircraft procedures and operations 22 which have detrimental noise impacts to residents whether from ground operations or flight operations. 23 A special focus for the SFO Airport/Community Roundtable is nighttime airplane noise especially as a 24 health issue. If aircraft noise is seen only as “annoying” to residents, it would overlook the well25 documented deleterious effects of airplane noise on the health of residents. Documented in peer26 reviewed scientific journals, noise adversely and seriously affects blood pressure, cardiovascular and 27 other health issues in adults. Effects in children indicate that aircraft noise can result in an increase in 28 children’s blood pressure and can cause negative impacts on children’s education as shown by lower 29 levels in cognitive testing, task perseverance, long term memory, short term memory and reading 30 achievement.
31 The following comments in response to the FAA Request for Comments on Review of the Civil Aviation 32 Noise Policy, Federal Register Docket # FAA-2023-0855, were discussed by Roundtable Members with 33 input from the public at a noticed regular public meeting of the SFO Airport/Community Roundtable on 34 June 7, 2023, Roundtable members (unanimously?) voted to approve this document.
Attachment A
Meeting 343
Packet Page 31
35 We appreciate the opportunity to provide input on this request. Aircraft noise impacts are critically 36 important to the health and quality of life to our residents. We applaud the FAA for undertaking this 37 process and we look forward to working with you create quieter skies for our residents. 38 Very respectfully,
39 40 Sam Hindi, Chairman
41 SFO Airport/Community Roundtable
42 43 Cc:
44 Members of the SFO/Airport Community Roundtable
45 3 Members of Congress in SFORT area (also US mail)
46 California elected legislators (Assembly and State Senate) in SFORT area 47 SF/SMC elected officials: SF Mayor, all Members of SF & SMC BOS 48 FAA Reg Admin Dr. Rachel Girvin
49 Others?
Meeting 343
Packet Page 32
San Francisco International
Airport/Community Roundtable
455 County Center, 2nd Floor
Redwood City, CA 94063
T (650) 363-4220
F (650) 363-4849
www.sforoundtable.org
Working together for quieter
skies
SFO Airport/Community Roundtable www.sforoundtable.org Page 1 1 2
3 Airport/Community Roundtable Comment Letter
4 Response to Federal docket number FAA-2023-0855
5 Note: Gray text is used for FAA questions; black text is used for SFO Roundtable Comments. 6 Notice of public meeting and request for comments review key considerations of its civil aviation noise 7 policy in the context of noise metrics and noise thresholds. 8 FAA requests comments focus on the issues and questions identified below to be most helpful to them; 9 and that commenters identify the number of each question to which a response is submitted. 10 11 1. VEHICLE TYPE
12 When the FAA published the ANAP (27) in 1976, the impacts of aviation noise were related to 13 commercial jet service at or in the immediate vicinity of airports. What types or elements of current or 14 future air vehicle activity (e.g., unmanned aircraft systems (also known as UAS or drones), advanced air 15 mobility, rotorcraft, subsonic fixed wing, supersonic, or commercial space) should the policy describe 16 and disclose? How should this information be described using noise metrics? Should the FAA use this 17 information to make decisions or for public disclosure only? Please explain your reasoning. 18 Comment: The SFO Roundtable wishes to respond with three distinct aircraft type categories: (1) 19 supersonic, (2) helicopters and (3) emerging aircraft, e.g., eVTOLs. 20 (1) Supersonic Aircraft: A 2020 letter from the SFO Airport/Community Roundtable to the FAA 21 Administrator stated: “1) The FAA should follow its long-standing position of requiring new supersonic 22 aircraft to meet the same noise certification levels as subsonic aircraft; and 2) Supersonic aircraft 23 should meet or exceed Stage 5 requirements, which would remain consistent with subsonic aircraft…” 24 25 We continue to advocate for supersonic aircraft to comply with the noise certification standards in 26 place for subsonic aircraft at the time of aircraft certification. Whatever devices, procedures, 27 techniques, or other methods are used, such as a Variable Noise Reduction System (VNRS), to reduce 28 supersonic aircraft noise to meet current supersonic noise standards, should continue to be used in 29 flight through all altitudes in the climb until the aircraft reaches cruise flight level. Supersonic aircraft 30 should be subject to all other regulations applicable to standard aircraft such as a 250-knot speed 31 restriction below 10,000’MSL and other operational regulations as well as pilot certification and 32 training.
33 34 We oppose supersonic flight over the land of the United States and the US Territorial Sea (12NM 35 offshore) regardless of any purported “quiet sonic boom” technology.
Attachment B
Meeting 343
Packet Page 33
SFO Airport/Community Roundtable www.sforoundtable.org Page 2 36 Alternatively, if Congress, at some time in the future, agrees to allow supersonic flight over the land 37 of the United States, with or without any purported “quiet sonic boom” technology or other design 38 to reduce sonic boom noise, then no takeoff, landing or overflight from such a supersonic aircraft 39 should take place over any portion of the United States land or territorial sea (12 NM offshore) of the 40 United States from the hours of 10pm-8am local time under such supersonic flight. 41 (2) Helicopters: We value the services provided by medical, law enforcement, and military helicopters 42 and recognize the necessity of low altitude helicopter operations for special inspections, repairs, and 43 some actual business operations. (e.g., crop dusting, photo reconnaissance). But for simple 44 transportation of corporate executives or wealthy individuals, the FAA should consider setting a 45 minimum altitude of 2000’ -- or higher – over any populated areas and especially at night for the 46 enroute (not taking off or landing) phase of flight. 47 48 (3) Emerging Aircraft: Low Altitude autonomous aircraft, whether designed to act as “air taxis” (eVTOLs) 49 or to deliver packages should be strictly regulated in conjunction with local elected officials and the 50 public in the areas that they traverse. Please do not cede the low altitude airspace to an industry51 heavy FAA “committee” to set regulations and give away the low altitude airspace to the detriment 52 of residents’ health and quality of life.
53 54 Without regulation to protect residents, these vehicles will fill the low-level airspace impinging on 55 and affecting the residents in a very personal manner. Please implement a transparent, effective 56 method to involve local entities. This might entail involving local city councils or Boards of 57 Supervisors or expanding the role of already existing public entities dealing with land use 58 compatibility such as California’s Airport Land Use Committees or other representative public body. 59 60 Regulations controlling package delivery should provide strict operational limits if it is to fly over any 61 residences. Package delivery should not be permitted during the evening hours, the night hours, or 62 the early morning hours. No package delivery and no overflight between 6pm and 8am. 63 2. OPERATIONS OF AIR VEHICLES
64 Comment: The SFO Roundtable was established in 1981 as a voluntary committee to address 65 community noise impacts from aircraft operations at SFO. Therefore, operations of air vehicles remain 66 our primary concern, particularly at night.
67 a. What elements of aircraft operations (e.g., en-route, takeoff, landing) should the noise metric 68 evaluate and disclose? Should the FAA use this information to make decisions or disclose to the public 69 noise impacts? Please explain your reasoning.
70 Comment: The SFO Roundtable membership is limited to the areas within the counties of San Francisco 71 and San Mateo. These areas predominantly experience takeoff and landing procedures, so our 72 perspective may be more limited than others that may very well include en-route operations. In 73 addition, and due to our relatively uniqueness of predominantly one airport flow configuration 74 (approximately 90%) in “West Plan” that results in no overflights to the areas immediately west of SFO, 75 we also experience ground noise from aircraft operations, such APU usage, taxiing, start-of-takeoff roll 76 on departure and thrust reverse on arrival. We strongly believe that the noise metric must evaluate and Meeting 343
Packet Page 34
SFO Airport/Community Roundtable www.sforoundtable.org Page 3 77 disclose all these operations of air vehicles and this information is critical to make decisions and disclose 78 impacts.
79 b. What interests or concerns do communities in the vicinity of airports have? How can these concerns 80 be addressed using noise metrics? What noise metrics would address these concerns? Please explain 81 your reasoning.
82 Comment: The main concerns of communities represented by the SFO Roundtable are related to the 83 operations of air vehicles include night operations and non-safety vectoring for efficiency of aircraft 84 from published procedures and/or noise abatement procedures. We appreciate the overwhelming 85 number of controllers who vector for noise abatement at night - directing planes over the San Francisco 86 Bay or other non-residential areas instead of over highly sensitive residential areas. 87 Assumptions that airplanes are quiet above certain altitudes (7000’ on descent and 10,000’ in 88 climb/cruise.) are inaccurate. Our residents have clearly reported that an airplane climbing at 10,000’ is 89 not a quiet airplane – especially at night.
90 There are some occasions when controllers offer or approve shortcuts to airplanes – allowing the planes 91 to leave their filed flight plan path to fly over residential areas in the middle of the night with virtually no 92 other traffic in the sky. ATC controllers should avoid non-safety vectors providing efficiency shortcuts to 93 aircraft over residential areas- especially at night. Perhaps the best metric is simply the number of 94 aircraft being vectored away from established procedures at night – as it only takes one such deviation 95 to awaken people as we know people are awakened from unusual operations. 96 c. What interests or concerns do overflight communities (28) have? How can these concerns be 97 addressed using noise metrics? What noise metrics would address these concerns? Please explain your 98 reasoning.
99 Comment: None
100 d. What interests or concerns do communities in the vicinity of commercial space transportation 101 operations have? How can these concerns be addressed using noise metrics? What noise metrics would 102 address these concerns? Please explain your reasoning. 103 Comment: None
104 e. What interests or concerns do communities in the vicinity of UAS (drone) package delivery or other 105 newly emerging technology operations have? How can these concerns be addressed using noise 106 metrics? What noise metrics would address these concerns? Please explain your reasoning. 107 Comment: None
108 3. DNL
109 What views or comments do you have about the FAA’s core decisionmaking metric, DNL? How would 110 these views regarding DNL be resolved if the FAA employed another noise metric (either in addition to, 111 or to replace DNL) or if the FAA calculated DNL differently? Please explain your reasoning.
Meeting 343
Packet Page 35
SFO Airport/Community Roundtable www.sforoundtable.org Page 4 112 Comment: In our 2016 Recommendations, in response to the FAA Norcal Metroplex Initiative, we said:
113 “In assessing impacts to the community, the Roundtable asks that consideration be given to the 114 limitations of using an annual average metric such as DNL to assess impact on the members of the 115 community. Impact to the community extends far beyond an arbitrary DNL level which is widely 116 acknowledged to be inadequate. There are other available noise metrics, including those that better 117 capture how frequency of flights affects communities; where available, these alternate metrics should 118 be factored into FAA decisions. We understand that the FAA is conducting a wide-ranging study of noise 119 impacts on the communities. When the results are available, we would recommend that more 120 representative noise metrics from this study be implemented as soon as feasible and that existing and 121 future flight procedures be reviewed considering the new noise data. (Italics in original) 122 So, this is not a new issue, and we would add today that living in 60 DNL or 55 DNL noise contours, 123 especially if the area also includes loud nighttime airplanes, limits residents’ amount of health-restoring 124 sleep, increases their susceptibility to serious disease and almost certainly results in very high levels of 125 annoyance.
126 The Environmental Protection Agency (EPA) in their March 1974 report “Information on Levels of 127 Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of 128 Safety”, concluded that a DNL of 55 dB or lower was the appropriate noise level for “outdoors in 129 residential areas…”
130
131 DNL could perhaps play a role in assessing land use compatibility for communities close to the airport, 132 but only if DNL is set lower at 55 DNL as recommended by the EPA in 1974 and additional metrics are 133 incorporated to help people understand the aircraft noise environment in which they reside. This lower 134 criteria with additional metrics could be used to qualify for the Residential Sound Insulation Program 135 (RSIP).
136 Even though DNL incorporates a “night penalty” of 10 dB, that is not sufficient compensation for the 137 effects of nighttime noise. For example, it may take only one or two loud airplanes in the middle of the 138 night causing awakenings to necessitate increased residential noise insulation even for 50 DNL and 55 139 DNL to protect the health of residents. Number of events above 50 dB or total number (below 18,000’) 140 of operations could be additional metrics to be factored with traditional DNL. But neither lower DNL, 141 coupled with operational frequency like number above or total number can account for the effects of 142 individual loud airplanes causing awakenings.
143 In a recent study conducted by Boston University School of Public Health (BUSPH) and Oregon State 144 University, (https://ehp.niehs.nih.gov/doi/10.1289/EHP10959) it was reported that that people who 145 were exposed to airplane noise at levels as low as 45 dB were more likely to sleep less than 7 hours per 146 night.
147 Other studies have correlated awakenings with Sound Exposure Level (SEL). We have seen that SEL is 148 about 7 to 12 dB higher than the maximum sound level for an average aircraft arrival or departure noise 149 event. Assuming the 45 dB was a maximum sound level reported above, a corresponding SEL may be 55 150 dB for the onset of the interior SEL for awakenings. Knowing that open windows reduce the noise by 10- 151 15 dB, an outside SEL of 65 to 70 dB (windows open), 75 to 80 dB (windows closed – an additional 10 dB 152 for standard home construction) and 85 to 90 dB (windows closed with sound insulation treatment 153 applied) may be an appropriate single-event noise metric to use as the onset of awakenings from 154 aircraft operations at night depending on the level of treatment applied.; and be used to determine the Meeting 343
Packet Page 36
SFO Airport/Community Roundtable www.sforoundtable.org Page 5 155 acoustical treatments required to provide for an adequate sleeping environments for residential 156 bedrooms.
157 4. AVERAGING
158 DNL provides a cumulative description of the noise events expected to occur over the course of an 159 entire year averaged into a representative day, described as an Average Annual Day (AAD). 160 a. Do you believe an AAD is an appropriate way to describe noise impacts? Please explain why or why 161 not.
162 Comment: Averaging metrics do not generally provide the kind of tailored data to account for variations 163 in aircraft noise that typically occur in our communities. However, averaging may serve some purposes 164 when combined with aggressive time carve-outs and used with additional metrics including Sound 165 Exposure Level (SEL).
166 b. If not, what alternative averaging schemes to AAD should be considered and why? What information 167 would the use of an alternative averaging scheme capture that AAD does not? 168 Comment: The FAA currently allows schools to base their DNL calculations for noise insulation 169 qualification based on their hours of operation instead of 24/7/365. That, too, should be available for 170 airports which have seasonal variations. For example, winter snow destinations with heavy winter 171 operations but few aircraft operations for the rest of the year, should be allowed to have their DNL 172 calculation based on their heavy season only because that is when those residents are most affected. 173 Similarly, residents should be allowed to calculate the DNL for their homes based on the days of the year 174 that they are subjected to the fights that typically comprise their DNL. For example, at San Francisco 175 International Airport, (SFO), the typical traffic flow is based on northwest winds with Runways 28L/R 176 straight out departure aircraft being the dominant factor in determining the 65 DNL contour for 177 residences underneath. However, for about 10% of days in the year -- when SFO uses other runway 178 configurations, little, if any, significant airplane noise is produced in the 65 DNL contour, but those days 179 are still added into the DNL 365 days calculation, thus “diluting” the impact of the noise that occurs 90% 180 of the time. In this case, it would be expected that if the DNL calculation deleted days when Runways 181 28L/R were not used for departures, then it would be likely that the 65 DNL contour would expand into 182 the adjacent 60 DNL contour levels, thus qualifying these homes for the Residential Sound Insulation 183 Program (RSIP).
184 5. Decision-making Noise Metrics
185 The FAA currently uses DNL as its primary decisionmaking metric for actions subject to NEPA and airport 186 noise compatibility planning studies prepared pursuant to 14 CFR part 150. 187 a. Should different noise metrics be used in different circumstances for decisionmaking? 188 Comment: DNL could be used for land compatibility and NEPA studies for changes near to the airport, 189 although it needs to find alternatives to the 24/7/365 constraint and needs to be augmented with 190 additional metrics from operations metrics as well as single event data. Based on the effects of changes 191 to flight procedures resulting from the FAA’s implementation of the NorCal Metroplex, it is clear that Meeting 343
Packet Page 37
SFO Airport/Community Roundtable www.sforoundtable.org Page 6 192 something other than DNL, specifically 1.5 dB change within the 65 DNL is needed to assess potential 193 impacts, particularly those resulting in the concentration of flight paths. 194 b. If the answer to Question 5.a. is “yes,” please identify: the metric, the information it provides that 195 DNL does not, and explain when and how it should be employed by the FAA in its system (e.g., should 196 the FAA use a noise metric other than DNL to evaluate noise exposure in quiet settings, such as national 197 parks, national wildlife and waterfowl refuges, etc.)? Should this metric be used when the FAA is making 198 decisions that affect noise in these settings? Should this metric be used alone or in combination with 199 another metric?
200 Comment: Metrics used to make decisions on new and modified flight procedures should be based on 201 operations data over a specified area using number of events above 50 dB or total number of flights 202 overhead (below 18,000’) along with additional metrics reporting individual aircraft using Sound 203 Exposure Level (SEL). The SEL data is required to identify individual loud aircraft during the nighttime 204 that could startle sleeping residents and lead to awakenings. 205 c. If the metric should be used in combination with another metric, please describe how they should be 206 used together for decisionmaking.
207 Comment: None
208 d. If the answer to Question 5.a is “no,” should DNL remain the core decisionmaking metric or should 209 another metric be substituted in all circumstances? 210 Comment: None
211 e. How would the use of the metrics that you recommend support better agency decisionmaking? 212 Please explain and illustrate with specific examples how the use of the recommended metric(s) would 213 benefit agency decisionmaking.
214 Comment: The significance threshold for “non-airport” NEPA studies (e.g., flight procedure changes) 215 could be based on a percentage increase from existing overhead operations - perhaps as low as 10% for 216 daytime/evening hours, but a far lower increase would only be required for nighttime hours. And even 217 an increase of one noisy flight at night might be sufficient to trigger further action under NEPA to assess 218 the impact on residents’ health. The number of events above does not adequately address the increased 219 frequency of flights. Flights occurring every 2 to 3 minutes are far more annoying than those occurring 220 every 20 to 30 minutes. Contrary, time above does not show the noise events that are noisy and may 221 lead to awakenings and other health issues.
222 6. COMMUNICATION
223 a. Please identify whether and how the FAA can improve communication regarding changes in noise 224 exposure (e.g., what information FAA communicates, where and with whom FAA communicates, what 225 information methods FAA uses to communicate and the venues at which FAA shares this information). 226 Please explain your reasoning.
227 Comment: Transparency is needed early in the process. Currently, the FAA’s PBN flight procedure Meeting 343
Packet Page 38
SFO Airport/Community Roundtable www.sforoundtable.org Page 7 228 process incorporates public engagement very late in the process, long after the flight procedure design 229 is largely finalized. While it is challenging to engage the public earlier when it might seem that there is 230 little to show them, this early consultation is exactly what is needed. Beginning public engagement after 231 a CATEX and after the flight procedure is almost fully developed defeats the purpose of public 232 engagement and leaves the FAA open to critique that the process is a “rubber stamp”. 233 When a new or significantly modified flight procedure is proposed, allow the opportunity for an aviation 234 Roundtable technical consultant and a qualified technical consultant for the procedure proponent to be 235 a part of the PBN Full Working Group (or similar) rather than just including FAA-controlled technical 236 staff.
237 The Federal Register and notices to Members of Congress are a start to effectively connecting with 238 residents who have noise issues. However, other ways should be added in such as communication to 239 recognized aviation Roundtables, known (or easily ascertainable) community aviation noise groups and 240 advocates (there are lists of aviation noise groups on various large group websites), information to 241 Boards of Supervisor’s (or similar) with requests to forward to appropriate entities could also work. In 242 addition, social platforms may also be another communication alternative. 243 Whether by design or evolved use, the FAA Instrument Flight Procedures Information (IFP) Gateway 244 does not provide any pertinent information to the public whatsoever. At the very least, the FAA could 245 categorize proposed new/modified procedures as “Procedural Change” vs. “Administrative”. 246 “Procedural Change” could indicate a new flight path, a significantly lower altitude or other changes that 247 could increase noise to residents. “Administrative” could describe a flight procedure that would propose 248 a minor waypoint name change, a non-significant altitude revision or a typo. 249 b. Should the FAA consider revisions to its policy on the use of supplemental noise metrics in the FAA's 250 NEPA procedures? Please explain how this policy should be modified to improve FAA communication of 251 noise changes when the FAA is making decisions that affect noise. Please explain your reasoning. 252 Comment: None
253 c. What information about the change in noise resulting from civil aviation operations (e.g., UAS or 254 drones, helicopters, fixed wing aircraft, rockets/commercial space transportation vehicles, and new 255 entrant technologies) should the noise metric communicate to the public? Please explain your 256 reasoning.
257 Comment: None
258 d. Please explain how the public will benefit if the FAA implements your proposal in response to 259 Questions 6.a and 6.b.
260 Comment: None
261 7. NEPA and Land Use Threshold Established
262 Using DNL or for Another Cumulative Noise Metric
263 The FAA has several noise thresholds that are informed by a dose-response curve (Schultz Curve (29)), 264 which historically provided a useful method for representing the community response to aircraft noise.
Meeting 343
Packet Page 39
SFO Airport/Community Roundtable www.sforoundtable.org Page 8 265 Two of the noise thresholds informed by the Schultz Curve are the FAA's significant noise impact 266 threshold for actions being reviewed under the National Environmental Policy Act and the land use 267 compatibility standards established in 14 CFR part 150, Appendix A. Both of these rely on the cumulative 268 noise metric DNL and are referred to collectively in this question and questions 8–10 as “the FAA noise 269 thresholds.” On January 11, 2021, the FAA published the results of the Neighborhood Environmental 270 Survey, (30) a nationally representative dataset on community annoyance in response to aircraft noise. 271 The Neighborhood Environmental Survey results show higher percentage of people who self-identify as 272 “highly annoyed” by aircraft noise across all DNL levels studied in comparison to the Schultz Curve. 273 a. How should the FAA consider this information (i.e., the Schultz Curve and Neighborhood 274 Environmental Survey findings) when deciding whether to retain or modify the FAA noise 31) 275 established using the DNL metric or to establish new FAA noise thresholds using other cumulative noise 276 metrics? Please explain your reasoning.
277 Comment: Now that NES data shows the high level of annoyance at lower levels of noise, and that 278 residents far outside the 65 DNL contours are highly annoyed, many of the FAA’s previous assumptions 279 are based on outdated inaccurate premises and the noise policy should be completely revised. 280 Use of the DNL metric as a standard for NEPA, specifically in reference to changes in the airspace beyond 281 the airport boundaries, is wholly inadequate. Please note our comments regarding DNL in section 3 of 282 this document. Use of NEPA Categorical Exclusions (CATEX) should be severely limited for new or 283 significantly modified flight procedures. Use of CATEX for flight procedures operating 24/7 or in the 284 nighttime should be viewed with intense scrutiny. All assumptions made leading to CATEX 285 determination must be reviewed and revised considering the data provided in the Neighborhood 286 Environmental Survey and as well as a groundswell of scientists reporting serious health impacts from 287 airplane noise in scientific journals.
288 Clearly, the following FAA NEPA guidance (FAA Order JO 7400.2P) on situations where no further 289 environmental review is required beyond the initial environmental review (IER) has been written in a 290 way that almost entirely avoids environmental scrutiny of flight path changes. No further review is 291 required if the proposed flight path change:
292 (a) Is above 18,000 ft AGL
293 (b) Is above 7,000 ft AGL for arrivals and/or 10,000 ft AGL for departures and/or overflights 294 (c) Does not result in 1.5 dB increase for 65 DNL and higher for procedures between 10,000 ft and 295 18,000 ft AGL
296 With residents’ reporting high level of annoyance at lower levels of noise, as noted in the NES, the above 297 items (b) and (c) should be assertively modified.
298 b. Should the FAA consider other or additional information when deciding whether to retain or modify 299 the FAA noise thresholds that were established using the DNL metric or to establish new FAA noise 300 thresholds using other cumulative noise metrics? Please describe the reason for the recommendation 301 and identify the data, information, or evidence that supports the recommendation. 302 Comment: None
303 c. How should research findings on auditory or non-auditory effects ( e.g., speech interference, sleep Meeting 343
Packet Page 40
SFO Airport/Community Roundtable www.sforoundtable.org Page 9 304 disturbance, cardiovascular health effects) of noise exposure caused by civil aircraft and vehicles be 305 considered by the FAA when it decides whether to retain or modify the FAA noise thresholds (32) that 306 were established using the DNL metric? How should the FAA consider this same research when deciding 307 whether to establish new FAA noise thresholds using other cumulative noise metrics? Please explain 308 your response.
309 Comment: None
310 d. In examining whether to change its metrics and thresholds for noise, the FAA needs reliable 311 information to support any changes. One type of information that the FAA can rely on is epidemiological 312 evidence. This means the study (scientific, systematic, and data-driven) of the distribution (frequency, 313 pattern) and determinants (causes, risk factors) of health-related states and events (not just diseases) in 314 specified populations (neighborhood, school, city, state, country, global). What amount of 315 epidemiological evidence is sufficient to provide the FAA with a sound basis for establishing or modifying 316 the FAA noise thresholds (33) either using the DNL metric or another cumulative noise metric? Please 317 explain your response.
318 Comment: None
319 e. Should the FAA consider using factors other than annoyance to establish FAA noise thresholds (34) 320 using the DNL metric or other cumulative noise metrics? What revisions to existing FAA noise thresholds 321 or new noise thresholds do you recommend be established and why? Please explain your response. 322 Comment: None
323 8. FAA Noise Thresholds Using Single-Event or Operational Metrics 324 As the FAA learned from the results of the NES, people are bothered by individual aircraft noise events, 325 but their sense of annoyance increases with the number of those noise events. Should the FAA consider 326 employing new FAA noise thresholds (35) using single-event or operational metrics? If the answer is 327 “yes,” which metrics should be used to establish the FAA noise thresholds? What should be the relevant 328 noise exposure level for the new noise thresholds you propose? Please explain your reasoning. If the 329 answer is “no,” please explain your reasoning.
330 Comment: Please see our comments in other sections of this document which can be applicable here as 331 well.
332 9. FAA Noise Thresholds for Low-Frequency Event
333 Should the FAA establish noise thresholds (36) for low-frequency events, such as those associated with 334 the launch and reentry of commercial space transportation vehicles authorized by the FAA Office of 335 Commercial Space Transportation? If the answer is “yes,” which metrics should be used to establish the 336 noise thresholds? What should be the relevant noise exposure level for the new noise thresholds you 337 propose? Please explain your reasoning. If the answer is “no,” please explain your reasoning. 338 Comment: Low-frequency noise thresholds should not be limited to launch and re-entry of commercial Meeting 343
Packet Page 41
SFO Airport/Community Roundtable www.sforoundtable.org Page 10 339 space transportation as suggested in question nine. Due to our relative uniqueness of having 340 predominantly one flow airport configuration (approximately 90% in “West Plan”) that results in no 341 overflights to the areas immediately west of SFO, we experience ground noise from aircraft operations, 342 such APU usage, taxiing, start-of-takeoff roll on departure and thrust reverse on arrival. These 343 communities have long reported that “A-weighted” noise metrics are insufficient to describe this noise 344 which relentlessly impacts residents’ sleep and health. In an August 24, 2021, letter to the FAA 345 Administrator, the SFO Roundtable recommended that the FAA use an appropriate noise metric and C346 weighting in the analysis of ground-based noise. 347 We continue to believe that C-weighted noise best describes the “backblast” noise from aircraft taking 348 off and it should be addressed and remediated. We would advocate that the FAA perform an evaluation 349 to determine if C-weighted or A-weighted noise data better represents people’s annoyance and sleep 350 disturbances under the conditions described above. If there is a linear difference, consider an offset 351 applied to DNL to account for this annoyance. If there is no linear difference, determine the 352 circumstances where C-weighted noise should be factored into the land use compatibility and/or 353 eligibility for sound insulation to mitigate such noise. 354 To better understand how ground based noise propagates through the communities adjacent to SFO 355 from aircraft departures, the SFO Roundtable, through its Ground-Based Noise Subcommittee, produced 356 the 2021 San Francisco International Airport Ground Based Noise Modeling Study available at the SFO 357 Roundtable website: Ground Based Noise Modeling Study. 358 Currently, the Roundtable through its Ground-Based Noise Subcommittee is conducting a limited study 359 using portable noise monitors to determine whether low-frequency noise is a larger contributor to noise 360 at the start of take-off vs. noise on the departure path. We will provide the results of the study to the 361 FAA.
362 10. Miscellaneous
363 What other issues or topics should the FAA consider in this review regarding noise metrics, the method 364 of calculating them, the establishment of noise thresholds, (37) or FAA’s method of communicating the 365 change in noise exposure? Please explain your response. 366 Comment: Over the past decades, laws, regulations, processes, and procedures have largely limited the 367 Roundtable’s ability to make significant improvements in reducing airplane noise to residents. The most 368 troubling of these is the lack of recognition and focus by some that nighttime aircraft noise is a serious 369 health concern to residents. In 2016, the SFO Airport/Community Roundtable submitted the SFO 370 Roundtable Response to FAA Initiative to Address Noise containing a comprehensive set of recommendations 371 to the FAA in response to the FAA implementation of the Norcal Metroplex. We said then: “AIRCRAFT 372 NOISE AS A HEALTH ISSUE: If aircraft noise is only seen as “annoying” to residents, it would overlook the 373 well-documented detrimental effects of noise on the health of the members of communities underlying 374 flight paths. Documented in peer-reviewed scientific journals, noise adversely and seriously affects 375 blood pressure, cardiovascular and other health issues in adults. Impacts to children show that aircraft 376 noise can result in an increase in children’s blood pressure and can cause negative impacts on children’s 377 education as shown by lower levels in cognitive testing, task perseverance, long term memory, short 378 term memory and reading achievement.”
Meeting 343
Packet Page 42
SFO Airport/Community Roundtable www.sforoundtable.org Page 11 379 Today, many peer-reviewed scientific journal recognize the deleterious effects of nighttime noise and 380 recognize that sleep disturbances can lead to serious health concerns. The very real and very serious 381 health concerns to residents, as well as the economic costs from nighttime airplane noise exposure 382 necessitates bold action on the part of the FAA and the airline industry. 383 • No longer can we accept that adding a few extra flight track miles is a valid reason for 384 awakening residents multiple times in the night.
385 • No longer can we accept that avoiding a few minutes of flight delay is a valid reason for 386 awakening residents multiple times in the night.
387 • No longer can we ignore options that might help prevent awakening residents multiple times in 388 the night.
389 One of those options to consider would be to allow Airport Directors at least some discretion to grant 390 incentives to airlines willing to request and implement nighttime noise abatement procedures. Another 391 option to consider is modifying 14CFR161--NOTICE AND APPROVAL OF AIRPORT NOISE AND ACCESS 392 RESTRICTIONS to allow Airport Directors to have increased discretion to insist on reasonable nighttime 393 noise abatement procedures.
394 This might take the form of modifying the criteria or standards for granting a Part 161 Airport request or 395 modifying the Part 161 process which is controlled by the FAA at every step including the final approval 396 or disapproval. Since it’s 1991 implementation, not one airport has successfully restricted operations of 397 aircraft certified as Stage 3 or beyond through the Part 161 process. It would be easy to say that some of 398 these restrictions are due to Congressional legislation, but if the FAA were to request modifications to 399 these regulations from Congress, it is very possible that such requests would find support. 400 In 2016 as part of the SFO Community Roundtable’s recommendations as part of the FAA Norcal 401 Initiative process following Metroplex implementation, the SFO Community Roundtable suggested that 402 the FAA Mission Statement be updated to include noise as a priority. It currently reads:
403 “Our continuing mission is to provide the safest, most efficient aerospace system in the world.” 404 The Roundtable commented that “We support action to amend the FAA Mission Statement to include 405 “noise, health, and other impacts to the communities” along with efficiency, as a secondary 406 consideration after safety. While nothing can be more important than safety in our skies, it is the 407 opinion of this Roundtable that noise and adverse health impacts to the communities should be 408 included to be at least as important as efficiency.” Considering recent scientific studies, the current 409 Roundtable believes that while the FAA mission should always place safety first and foremost, it is past 410 time to add noise impact to residents on an equal basis with efficiency. 411 11. Literature Review
412 In this review, the FAA will examine the body of scientific and economic literature to understand how 413 aviation noise correlates with annoyance as well as environmental, economic, and health impacts. The 414 FAA also will evaluate whether any of these impacts are statistically significant and the metrics that may 415 be best suited to disclose these impacts. A bibliography of this body of research is available for review in 416 the Background Materials tab in the Docket and as Appendix 1 to the FAA framing paper entitled, The 417 Foundational Elements of the Federal Aviation Administration Civil Aircraft Noise Policy: The Noise 418 Measurement System, its Component Noise Metrics, and Noise Thresholds. This framing paper is Meeting 343
Packet Page 43
SFO Airport/Community Roundtable www.sforoundtable.org Page 12 419 available at: https://www.faa.gov/noisepolicyreview/NPR-framing. Please identify any studies or data 420 regarding civil aviation noise not already identified by the FAA in the bibliography that you believe the 421 FAA should evaluate. Please explain the relevance and significance of the study or evidence and how it 422 should inform FAA decisions regarding the policy.
423 Comment: The SFO Airport/Community Roundtable identifies the following three literature references 424 for FAA review and evaluation:
425 (1) Reported in EHP and funded through the Federal Aviation Administration (FAA), this study, 426 “Associations between Aircraft Noise Exposure and Self-Reported Sleep Duration and Quality in the 427 United States-Based Prospective Nurses’ Health Study Cohort,” concluded, in part, that:
428
429 “The increasing recognition of the importance of adequate sleep for maintaining health and optimal 430 daytime functioning has spurred research aimed at identifying modifiable factors for improving 431 sleep duration and quality. Environmental risk factors—including noise pollution—represent targets 432 for improving sleep health that been underinvestigated…” 433
434 “We found evidence for adverse effects on sleep at exposures as low as 45 DNL dB(A), the lowest 435 modeled noise level, and evidence further showed an exposure–response relationship between 436 aircraft noise and short sleep duration…”
437 Reference: EHP: Environmental Health Perspective, Association between Aircraft Noise Exposure and 438 Self-Reported Sleep Duration and Quality in the United States-Based Prospective Nurses’ Health 439 Study Cohort, April 2023
440 (2) This publication reported that: “Aircraft noise is one, if not the most, detrimental environmental 441 effect of aviation. It can cause community annoyance, disrupt sleep, adversely affect academic 442 performance of children, and could increase the risk of cardiovascular disease of people…” 443 Reference: Aviation Noise Impacts: State of the Science, Journal Noise and Health, Mar-Apr 2017 444 (3) Although European in focus, this 321-page OPEN ACCESS book includes extensive discussion of 445 nighttime aviation noise impacts to human health (pp.173-218) In general, the book provides step 446 by step explanation of airport noise and related annoyance, discusses the future of aviation noise, 447 and explains how to engage communities when trying to manage aviation noise. 448 Reference: Aviation Noise Impact Management: Technologies, Regulations, and Societal Well-being 449 in Europe, Editors: Laurent Leylekian, Alexandra Covrig, Alena Maximova, 2020.
Meeting 343
Packet Page 44