Avoid past Controversy? FAA must reexamine the same issues
Pitfall: airspace limitations?
Pitfall: Terminal(s) already being constructed
Pitfall: difficult to restrain future flights
The Herald.net provides some wise counsel to the neighbors of, the sponsor of and the proposed airlines tenants of Paine Field, Snohomish County Airport (PAE) as well as the public/private partner Propeller Airports at Paine Field. The editors urge their readers not to relitigate old issues, but rather to focus on limiting the prospective impacts.
The review process which the FAA will utilize to consider how future operations will affect the environment, the National Environmental Policy Act, the implementing regulations of the Council on Environmental Quality, and FAA Order 1050.1F, and Order 5050.4B.While the lead agency may not want to reinstate the animosity generated by past reviews Final Environmental Assessment FONSI-ROD, December, 2012, BUT the analyses performed then must be reviewed now.
The 2013 Record of Decision (Appendix A) is not significantly more contentious than other similar EAs, but some of the more cogent criticisms point to the forecast of flights beyond the years assessed. The FAA’s by-the-handbook response was that NEPA and the FAA Orders do not require such estimates because such numbers are too speculative. 2018 is now the present.
To be clear existing FAA policy requires if the approval of a Title 14 of the Code of Federal Regulation (14 CFR part 121or 135 operation specification (OpSpec) C070 amendment could significantly change the environmental impact of aircraft operations at an airport, then an appropriate NEPA review should be initiated (FSIMS Volume 11, section 4, paragraph 11-127). Here is the detailed explanation:
Order 1050.1, Section 4-3.2. A reasonable effort should be made to determine whether the approval of OpSpecs would cause added or increased aircraft operations/type aircraft that are likely to be highly controversial on environmental grounds. Highly controversial means that a substantial number of persons or a governmental unit is against the action. Environmental grounds does [sic] not include safety or environmental reasons unrelated to the proposed OpSpecs. Awareness of controversy can come from knowledge of past community opposition to increases in levels of service or a background of community opposition because of other issues at the airport.
Likely the most contentious issue will be the arrival and departure patterns to/from PAE. The above map laid out some possible routings and the projected noise impacts. As the Herald.net forewarned, mitigation of effects of aircraft flight on the communities below. The design of these tracks involves SAFETY, efficiency and noise; its minimization requires detailed information about the land use. However, usually the AT architect Is not afforded with an infinite range of choices. The prime constraint is safety; aircraft performance does not permit some climb rates, turns and other maneuvers.
A secondary aspect of AT design limitations is other aircraft traffic. Controllers CANNOT guide their planes into existing AT routes. PAE is less than 40 miles from SEA. After a lengthy process, the arrival/departure architecture for NexGen there was established[i]. As shown by these rather crude depictions, the degrees of freedom in drawing these lines in the sky may have been reduced. Thelevel of detail of these graphics is not precise enough to determine whether there will be any interference, but the FAA design time will have to examine the geometry.
What may be unusual is that Propeller is already building a terminal at PAE; it appears that Alaska Airlines is also in construction there; and there is a picture showing what purports to be United’s site. There is a concept in environmental law called segmentation, in which a project is “segmented” into smaller projects to avoid or minimize the entire impact. Building the terminal(s) before the EA process has begun may be a form of reverse segmentation. The land being used is part of the ALP and the FAA’s acceptance of its use BEFORE the NEPA process began. By approving the ALP amendment, is the FAA prejudging the EA of the carriers’ OpSpecs?
The FAA forecasting will have reduced speculation in analyzing future level of operations with these three airlines declaration of intent. It is clear that come of the residents’ fear that PAE’s schedule will increase beyond that initial offering. While Propeller may revel in the prospects of greater demand, it is fairly well-established law that once such flights begin, it becomes difficult to limit new entrants.
These depictions envision a beautiful terminal. The Herald.net’s admonitions express similar optimistic view of the FAA NEPA review, but PAE’s past history has had some contentious moments. Those old issues are not likely to be suppressed by NEPA’s inclusive policies. Consideration of PAE’s future flights, integration of AT with SEA’s Greener Skies design and the existence of some other possible impediments may delay the FAA issuance of an ROD.
[i] Greener Skies Over Seattle initiative, a collaborative project between the FAA, airlines, the Port of Seattle, and Boeing Corporation that will leave Seattle’s skies quieter and greener. The FAA will add 27 new procedures, expanding the use of Optimized Profile Descents (where the airplane essentially glides in idle to the runway threshold), Area Navigation (RNAV) arrivals (which are GPS-guided arrivals) and Required Navigation Performance (RNP) approaches (which take RNAV to an additional level of precision). These procedures will be available to any properly equipped aircraft next spring.
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