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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.

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