The FAA has issued a detailed Draft Environmental Assessment for implementation of the NextGen air traffic control procedures for the Southern California Metroplex. This is one in a series of such ATC enhancements based on the new technology—Seattle, Denver, Louisville, Atlanta, Newark, Memphis and most recently Phoenix. The Congress enacted special statutory language which allows these NEPA reviews to be “fast tracked.” Not all of these reviews have been completed to the communities impacted. This announcement of an opportunity to be heard is a critical communication between the communities and the FAA over the final structure of the SoCal airspace.
Here are some “do’s and don’ts” for trying to influence the outcome.
First, the FAA is a technical, not a political, view of noise. Unlike elected officials who collect and count all of the letters/emails which they receive on an issue, the FAA is not likely to be influenced by an avalanche of form letters.
Second, while you may feel that the FAA’s 65 DNL standard is inappropriate, such a policy change is not within the authority of this review. A very different type of document would have to be issued for such a revision to the FAA’s standards on noise disturbance would include another statement of the issues and the scope of the impact. It might be worthwhile to articulate your position in this docket (the FAA might cite such statements in a broader NPRM), but it would be wise to limit your comments on this issue.
Third, ranting and raving are not good approaches to convincing the FAA to change. Such expressions may reflect your true sentiments, but diatribes do not advance your cause. The FAA staff will reach and summarize every comment (or repeated theme in a single note); strong language is unimpressive.
Fourth, your best approach is to deal with the FAA on technical grounds. The FAA experts are more impressed with professionals in noise measurement (acoustics), land use, air traffic architecture, ATC procedures, aircraft performance, flight routings’ efficiency and SAFETY. Remember that the So Cal airspace is not only the densest ATC environment in the world; it also has the most complex design. A general list of problems without any technical suggestions will not impress the FAA.
Fifth, the most powerful approach to trying to impact the FAA’s final decision is to propose safe, efficient alternatives which also benefit your community. NextGen is a massive investment of your tax dollars nationwide. Here and everywhere the FAA is implementing these new precise procedures (optimized descent profiles, performance based navigation, required navigation performance, RNAV, etc.). The benefits of these new ATC capabilities have been touted by the FAA to Congress for their nationwide reduction of fuel use, greenhouse gas, particulate matter, noise pollution and safety. They FAA cannot and will not exclude these benefits based on local concerns, even if the objections are well expressed. Thus, it is critical for your comments to offer win/win solutions. Experts can examine alternatives which may both meet the FAA goals and at the same time reduce the noise impact on your community. Unfortunately, ATC is not intuitive and to create such viable options, Subject Matter Experts are required. They are not cheap, but the dollars spent will make your case more effective.
Sixth, individual, well-considered comments are useful, but a consolidated position is the most powerful voice in these proceedings. Noise transfer tends to be a zero sum game; Community A is ecstatic and Community B is furious. Such split decisions allow the FAA to move forward with its preferred option. “No one can agree; so the original proposal obviously is fairest since all are equally opposed” will be the opening line of the FAA final record of decision. Working among communities, especially those who know the particular nature of their specific residential areas, commercial developments, noise sensitive areas (i.e. schools), noise proof uses (i.e. major transportation corridors), etc. can identify geography in your areas which can accommodate the overhead air traffic and those to be avoided.
Working with technical experts, it may be possible to divine a route which avoids Community A’s sensitive area, flies over B’s acreage which is unaffected by noise and that option might allow the ATC route to fly higher over Community B’s residences. The technical explanations and thorough materials presented by LAWA suggest that that organization might be able to help develop consensus. Such a community optimal solution could move the FAA to reconsider its preferred option.
No doubt that there are a lot of citizens who will be impacted by the FAA’s Southern California Metroplex. It is never wise to assume that the FAA is motivated by malice. It is, however, a useful hypothesis to attribute the preferred solution to the ATC staff’s best efforts to devise a fair solution.
Given that operating hypothesis, advocacy, which does not deride the FAA or claim incompetence, will be heard by their decision-makers. Content, which uses the technical jargon of the ATC “science” or art, will find an audience who will read your points carefully and consider your thoughts as wisely expressed and helpful. A paper, which offers a well-constructed and carefully designed alternative based on the FAA’s NextGen goals, may supplant the FAA’s initial option. If the position reflects a consensus among all or most of the affected communities, it is fair to predict that it will be the final solution adopted by the FAA in its final Record of Decision.