Environmental Research Associates

Research & Consulting Ecologists

Airspace Redesign

Airspace Redesign23 Sep 2008 02:00 am

The following document is a September 10, 2008 letter to the editor of the Philadelphia Inquirer from the U.S. Congressional Offices of Congressman Joe Sestak and Congressman Robert E. Andrews in response to Philadelphia Inquirer Article by Tom Belden dated Sept 8, 2008 regarding the Philadelpia International Airport airspace redesign.

Click here to view the letter.

Airspace Redesign14 Jul 2008 08:42 pm

On June 11, 2008 a letter was forwarded to Mayor Michael Nutter by our congressman indicating that Philadelphia International Airport (PHL) has a Noise Compatibility Program (NCP) dated 2003 currently in effect approved by the Federal Aviation Administration (FAA) pursuant to FAA Regulation 150; a new one was to be finished his year, but seems to be on hold. PHL is owned and operated by the City of Philadelphia. 

The program is not in compliance primarily as a result of FAA’s airspace redesign mitigated headings that were rushed into effect on December 19, 2007 rather than the summer of 2008.  When fully implemented, thousands of people in Delaware County communities and southeastern Chester County would experience noise levels of 65 DNL dB.  Swarthmore and Media, for example, would be subject to these noise levels by 2011.  In Haverford, North-South Runway 17-35 extension, nears completion, with traffic flows in airspace over our heads that will be authorized for that runway; hopefully PHL will continue to comply with the NCP, however, this is by no means certain. Delaware County overflights occur on a regular basis during nighttime hours, up to 4am. Runway 17-35 with approach or departure over Haverford is perpendicular to East-West Runways 9-27.  While simultaneous use of  perpendicular runways can increase the number of planes an airport can handle in an hour, air traffic controllers (ATC) have said the procedure is not safe. There were two close calls, planes coming within about half-mile and 300 - 600 feet in altitude of each other, during the last week at JFK due to one plane aborting a landing and going around and the simultaneous use of perpendicular runways on a departure.

Currently, there is no relevant noise monitoring, just modeled data about noise impacts. 
Twelve lawsuits have been filed against FAA and have been consolidated in the U.S. Court of Appeals — Washington, D.C. Circuit, asking review of FAA’s Record of  Decision (ROD) for Runway 17-35 extension and airspace redesign at PHL; issues are now being teased out of each..

While noise is one of the issues in PHL’s failure to comply with its NCP there are other issues that need to be carefully considered; these include, adverse health impact, safety risks, air quality.  A noise workshop was not held in the area to be primarily affected by runway 17-35 airspace redesign.  Delaware County seeks only to influence legislators and will not undertake to measure either noise or air quality in either a baseline or continuing study.   

Recruiting and training air traffic controllers by FAA is a problem encountered now with  the present crop of ATC’s retiring primarily as a result of the firing of ATC’s under the Reagan administration.  The New York Post today reported that a 20-year old was recently recruited. 

At present, FAA’s attitude toward it’s three “masters,” - commercial air transport, the flying public and the impacted public on the ground is questionable primarily due to what has been expressed by others as incomplete or just plain bad planning, politics, influences of the airline industry and selected incompetences within FAA,  http://ejectsturgell.blogspot.com.JL1408BC.AIR

Airspace Redesign27 May 2008 02:42 pm

Download full White Paper on Airspace Redesign

Overview of Airspace Redesign Issues - April 20, 2007
As part of its effort to adapt our air transport system to the relentless increase in demand for capacity, the Federal Aviation Administation (FAA) is redesigning our national airpspace to improve its operational efficiency and planning airport capacity enhancements. This effort is essential to our national economic well-being, competitiveness, security and emergency response capabilities. This paper focuses on non-operational issues arising in connection with the FAA Airspace Redesign program. It contemplates remedial legislative as well administrative actions.

Unfortunately, the approaches and procedures being followed by the FAA in its Airspace Redesign program raise serious concerns. Among these concerns are that (i) the true costs and impacts have not been adequately evaluated, e.g. noise on educational development, air emissions on health, adverse effects on property values, and increased risks in ground safety (1), (2), (3), (4); (ii) the benchmarks, tools, methodologies and models employed are flawed or inadequate (5); and (iii) the Airspace Redesign program is driven by aviation operational efficiency considerations, even though Federal NEPA directives state “FAA’s decision making process for airport projects must consider the environmental, social, economic, and technical factors of a proposed action and those reasonable alternatives that meet the purpose and need.” (emphasis added) (6). Noise abatement was originally included in the Purposes and Needs defined in the NY/NJ/PHL Airspace Redesign. It should to be restored. Furthermore, the FAA needs to conform to NEPA-implementing instructions for airport projects (6).

It is essential that: i) sound, long-term planning for aviation occur in the context of the broader national transportation policies and other policies and strategies, including noise abatement; ii) externalities, including social costs, be calculated, iii) the value of expected benefits be documented in detail, and iv) full mitigation be provided to those who will suffer the adverse impacts from changes.

Comprehensive Long Term Planning
Air transportation planning should provide for the full projected need and make use of all available resources. In the greater Philadelphia region, demand for air transport is expected to increase by 50% in the next 20 years. The FAA=s Capacity Enhancement Programs and the Airspace Redesign together are expected to increase capacity by only 30%. The shortfall is not addressed.

In meeting increased demand, the proposals do not take advantage of substantial unused airport capacity in the region, available particularly if certain current aviation activities at PHL were encouraged to move to other regional aviation facilities. Further, the NY/NJ/PHL Airspace Redesign DEIS reveals the lack of serious attention to surface transportation alternatives that could reduce aviation demand. The “stovepiped” Federal approach to transportation planning undoubtedly contributes to this situation. We need to return to the concept originally embodied in ISTEA (1991) and expand it to include aviation. Unfortunately, in the years since ISTEA, intermodal planning has weakened, to the detriment of reasoned transportation infrastructure investment planning.

Noise is disruptive sound. The FAA measures sound (in decibels) using flawed models lacking adequate calibrations and metrics that mask the existence of intermittent and annoying sound. It does not then take the next step of effectively determining the disruptive effects of that sound. It relies on the defective Schultz Curve. Even transportation experts in the U.S. DOT’s in-house “think tank,” the John A.Volpe National Transportation Systems Center, have faulted these metrics, models and processes. Extensive studies exist concerning noise, its measurement, its impact on public health and its impact on the ability of humans to carry out cognitive tasks. These studies should be evaluated and used appropriately. It is not satisfactory to dismiss certain costs because they are thought to be difficult to measure. Restoration of a national noise policy - an updating of the defunct Noise Control Act of 1972 - would encourage due attention to noise effects on human health and the quality of life.

Read more… Download full White Paper on Airspace Redesign