Second Iteration of thoughts on how to impact the FAA’s SoCal Metroplex ATC Draft Assessment

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NextGen is a massive transformation of the way in which the FAA can direct air traffic. The application of those technological benefits is a challenge on a micro scale. The project to transform the Southern California basin with its 6 major airports, 3 secondary facilities and 5 minor airfields plus their separate arrivals/departures, TRACON patterns and the overarching en route trails is among the most complex Air Traffic Control environmental exercises ever attempted by the FAA. To prove that point, the Administrator announced the initiation of the project; that’s rare.

This is the densest airspace in the world. The swift implementation of NextGen benefits (RNP, RNAV, ODP, etc.) is critical to the FAA’s efforts to convince users and Congress that this new technology has real returns on the tax dollars and the stakeholders’ equipage expenses.

In response to this specific, detailed, complex draft Environmental Assessment , aside from intelligently advocating their position (6 tips on how to respond), what can the public to do?

 The implementation of NextGen cannot be reversed. Congress has already acknowledged its national importance when it enacted statutory language which fast tracks the review of these projects. It is a reality with which these communities and others will have to deal.

This is an unusual EA in that the FAA is the federal actor. It defined the proposed action, the purpose and needs, alternatives and impacts. The same team which spent much time drafting the EA will now review the public’s input. Quite clearly the writers have invested in the document. Therefore, do not expect that even the most brilliant critiques, suggested alternatives and environmental analyses will alter the recommended action. Most courts are likely to defer to the FAA’s technical safety judgment, but may be open to challenges of procedures.

Review of the draft EA makes it clear that the purpose of the SoCal Metroplex is to enhance the safety and efficiency of this airspace. It was taken as a given that the design of the new routes would optimize the technology. Based on that premise, the FAA assessed the impact of the NextGen new operations on the community and then measured that against the old tracks (altitudes and directions over the ground)(No Action Alternative). The tentative conclusion, subject to public comment, is that the FAA’s proposed option meets NEPA’s standards. The noise measurements appear to be projected over the entire length of the new and old routes. These appear to be area assessments rather than specific points of impact.

It should be noted that the Draft EA cites the historic criterion of 65 DNL, which is currently being reviewed, but will remain in effect throughout this process.

The FAA’s chosen track is driven by efficiency and safety. Exhibit 3-2 (above and in the draft EA) shows a specific decision of where future flights will be aligned and in particular, the points at which aircraft will converge and diverge. Those points and lines will define where the new noise will be concentrated with even greater precision. The differences between the new specific waypoints (particularly the points of convergence and divergence of traffic) and the old noise levels at the points of significant changes cannot be found in the draft EA.

Such a specific point impact has not been calculated in past FAA NEPA cases, but the navigational benefit of NextGen’s precise routes may create significant impacts in these micro spots. That significant benefit/negative impact may cause a court to review the FAA’s Final EA on a procedural deficiency basis.

If the selection of specific waypoints under NextGen procedures constitutes an impact requiring greater NEPA examination, a remand may create local political problems. For example, if a second Environmental Review must assess whether the waypoints should be moved, most likely to a point further from the airport and at a higher altitude, the result may move the point of impact from the current waypoint to another community. Community A may benefit and Community B may receive more noise than in the initial pattern; hopefully the net noise will be a win/win option in the hard numbers. However, noise perception and noise measurement are not congruent; Community B may oppose the new point of convergence/divergence.

Whatever approach taken by individual communities, a NIMBY response will be easily rejected by the FAA. Saying No will not suffice, but “have you considered another track which is still efficient and safe” may achieve your goal by moving the FAA.

It must be acknowledged that the Draft EA documents and processes are exceptionally transparent (although the terminology, acronyms and technical analyses are a bit obtuse). This project will go forward, but there may be discretion to move the proposed tracks while meeting the FAA’s overriding purpose—implementing NextGen in the SoCal basin.

 

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