Does the Public Support Our Noise Policy?

Report Prepared by:
Robert A. Samis & Associates

Submitted to:

U.S. Environmental Protection Agency
Office of Federal Activities

July 1991

1.0 Introduction
1.1 Background
1.2 Method
2.0 Selected Testimony
2.1 Introduction
2.2 Validity and Use of the Ldn 65 Noise Metric
2.3 Interference Effects: Speech, Sleep, Natural Habitat
2.4 Health Concerns
2.5 Lack of Responsiveness to Citizens on the part of Civil Authorities
2.6 Summary
4.0 References

1.0 Introduction

1.1 Background

This report presents selected recent public comments by individuals and communities concerning reactions to aircraft noise. These are the words of the public, their chosen representatives, airport operators, and their environmental consultants. This study deliberately eschews formal appeals to the scientific literature, not because environmental regulatory policy should be based on unscientific speculations, but rather, because of the specific and particular nature of this environmental problem. The starting point and touchstone are the thoughts stated by Senator Bradley before the House of Representative's hearings on aircraft noise:

This Committee will hear from a number of different groups through out the course of the noise hearings. Many of the participants will be experts in their fields. But I would like to remind the Members that the real experts on the issue are the citizens whom you will be hearing from shortly. They are the people who will live with the constant threat of their home being invaded by aircraft noise. They are the ones who have formed a coalition and who are working together to try and solve this problem. ¹  

A common definition of noise is sound that one does not like. Almost all environmental noise problems fit into the class of nuisance or annoyance problems. Although there may be health effects directly caused by environmental noise or at least aggravated by such stimuli, the degree and precise mechanism for these effects is neither widely recognized nor generally agreed upon in medical or scientific circles at this time. Nevertheless, such concerns, along with non-acoustical perceptions and factors influence or accompany people's reaction to aircraft noise. We believe that an examination of this class of comments yields an understanding of why people object so strongly to aircraft noise. Founded or unfounded as these perceptions may be, they form an emotional truth which should be addressed by policy makers. We feel that this material sheds light on the central question, "Do the people who are affected by aircraft noise believe that their problems are being addressed?"

Aircraft environmental noise problems are widely recognized and are the focus of the Federal Interagency Committee On Noise (FICON). If the currently applied scientific theories and regulatory practices are efficacious and constructively address aircraft noise impacts in communities, then they should stand up well to the public's perception. If these practices are not effectively addressing the affected public concerns then there is likely room for revision and improvement. This review, then, is a reality check, an informal audit focusing on the true measure of success and achievement in this circumstance, the affected public's verdict. If government is to serve the people we must ask for their evaluation.


1.2 Method

Since environmental noise is inherently a subjective experience it would be highly presumptuous (and possibly unfounded) to assume, based on the selected application of certain theories, that current practice is comprehensive, responsive, efficacious, and efficient. We went through thousands pages of testimony from four relatively recent public dockets or documents which invited comments from the public at large. The primary source material came from the following sources:

Inquiries were also made of two major airport's noise abatement offices to ascertain the answer to one question: What is the proportion of complaints to the airport about noise from residents outside the DNL 65 contour? The responses were approximately fifty percent for Chicago O'Hare and forty percent for Baltimore Washington International airports.

Section 2 presents the selected testimony.


2.0 Selected Testimony

2.1 Introduction

This review presents selected statements from people who are affected by aircraft noise. We have, to the degree possible, sorted them into these four general categories which are listed below. Although we have classified these statements into categories it is also clear from many of the comments that many of these reactions are intertwined with the nature of the whole or gestalt or the human response.

Is the metric acceptable and understandable to the public?

Does the metric and its critical threshold value adequately identify the affected populations?

Is the metric useful for monitoring specific abatement actions or are supplementary indicators required?

"Annoyance" may be a state of mind, but aircraft noise does objectively interfere with many human and natural activities.
Increasingly, people regard aircraft noise as a health risk, rather than solely as an aesthetic issue.
Alienation appears to play a role in peoples' attitudes toward aircraft noise due to changes in attitudes concerning government, airlines, and social values.

This section is not intended to break any new ground. Rather, it distills recent experience and presents it before this group of Federal environmental regulators who are charged with protecting the public health and welfare.


2.2 Validity and Use of the Ldn 65 Noise Metric

Sherwin Lanfield, Donaldson Run Civic Association, Arlington, VA

In our neighborhood, the roar of jets is practically our traditional evil. Yet, the 65 LDN contour line encloses none of our 1,000 home community. Who is wrong, our neighbors or your definitions? 2

David A. Byers, AICP, Principal Planner, Brady, Byers and Associates, Inc., Sarasota, FL

The metrics used to define aircraft noise (SEL) and cumulative noise impacts (Ldn) are generally accepted measures among the professional community involved in the Part 150 planning process. However, it is very difficult if not impossible to discuss noise metrics and the dynamics of aircraft noise in a meaningful manner to the general public without encountering some hostility based on a distrust of something not understood. 3

D.M. Biddison, Des Plaines, IL

The O'Hare computer generated noise map is just another lie from the City of Chicago to the public. Their phony map states our area is 75 LDN, when in fact the U.S. EPA noise equipment readings in my backyard were 84.4 LDN.4

Anita Davis, Citizens for the Abatement of Aircraft Noise, Cabin John, MD

The 65 LDN measure is not adequate to predict where aircraft noise begins to exact these social costs. Recent scientific investigations have indicated damage occurs at much lower levels of noise than 65 LDN. I live at levels lower than 65 LDN, and I can tell you that I am affected.5

Susan Staples, Ulsterites Fight Overflight Noise, Ulster, NY

The 65 LDN methodology under counts the number of people affected by noise and has been criticized by the Environmental Protection Agency.4

James Schrader, Triangle Airport Noise Coalition of Raleigh, North Carolina.

Some families in North Carolina, when they first moved into their home out in the country didn't have a noise problem at all until the RDU airport expanded. Now in many days of the week they still have no noise problem, but for several days each week at the will of the wind their house is virtually useless as a home... The LDN noise measurement technique and guidelines did not indicate this problem...The average noise makes no more sense here than to say that a reservoir can be constructed near your home, because the average annual water level will be below your house elevation and therefore, is not a problem.

The Ldn level which is most commonly heard as the real threshold for the beginning of noise devaluation and real annoyance is Ldn 55.5

Cal Edmonson, Facilities Coordinator for the Raleigh/Durham International Airport

At Raleigh/Durham, we currently are defending lawsuits brought by more than 150 homeowners, most of whom reside outside the DNL 65 contour and many of whom reside outside the DNL 55 contour. 6

  Charles Price, National Organization to Insure a Sound Controlled Environment

...the Ldn metric which is increasingly seen as an inadequate measure of the actuality of aviation noise experience? 7

  Andrew S. Hams of Hams Miller Miller & Hanson, Inc., acoustical consultants

Many Part 150 studies are for suburban or rural airports where the low level of background noise might make more stringent compatibility criteria appropriate. 8

  Jorge H. Berkowitz, Ph.D., Director, Department of Environmental Protection, State of New Jersey

Regardless of the type of airport, the Part 150 as presently structured, does not address noise impacts in areas outside the 65 Ldn contour line. The great fervor that was created as a result of the implementation of the Expanded East Coast Plan has highlighted this weakness.... It is time to introduce a "Part 250" process that would examine not only the absolute noise level above 65 Ldn in an area, but also the relative change in noise level regardless where the initial level is. This would then apply to areas where the Ldn of an area is 55 after a change but only 45 Ldn before.

FAA should review the use of the Ldn methodology as the tool of establishing noise annoyance. Some way should be found to massage the data when respective single events occur. Strategies should be investigated that use various Ldn time frames such as hourly, 4 hour, 8 hour Ldn etc. These should be linked to public annoyance and ones chosen that most closely represent this annoyance.9

William B. Shermer, President Airport Coordinating Team, Inc. Severn, MD

With the advent of hub operations, the Ldn or DNL measurement standard no longer accurately reflects the negative impact that concentrated commercial jet transport operations have on surrounding residential communities. The existing noise standard needs to be modified or a new standard identified that more accurately determines noise exposure to a community during a worst-case peak one hour time frame in which hub operations are conducted at any given airport.

Noise contours for 60 and 55 Ldn need to be added to the Noise Exposure Map [(NEM) required by the Part 150 program, since the EPA recommends that outdoor residential exposure levels not exceed 55 Ldn.10

Albert Brown, Citizens for the Abatement of Aircraft Noise, Bethesda, MD

The FAA holds a myth that the only people who are seriously affected by aircraft noise are inside the 65 Ldn contour. This is a number selected by a committee and without measured justification. There has been no definitive study of the effect of aircraft noise on people. There is, however, considerable anecdotal evidence that there are serious effects well below the 65 DNL.

We are well outside the 65 DNL contour, well outside of it. Yet, I couldn't speak to you panel members if we were on Sycamore Island with an aircraft flying by.11

Peter Solderquist, Airport Director, City of Scottsdale, AZ

The airport has a fully approved Part 150 study completed in 1985. Our experience is that the process was well worth the effort. As viewed by an acoustician or their "expert" in airport noise, however, SDL does not have a noise problem. The 65 Ldn contour lies completely on Airport property and the 55 Ldn impacts only three blocks of residential development. Nevertheless, the Airport does receive calls from concerned citizens. It is our experience that the calls come from two sources: those that complain about overflight and those that complain about single event noise. 12

Joseph Karaganis, National Airport Watch Group, Chicago, IL

... the FAA has declared that the ambient noise quality standard for tolerable living is 65 Ldn. Yet, nowhere in the Federal preamble or in 20 years of FAA legislative activity do we see any attempt by FAA to develop a program which will achieve the 65 Ldn and take care of the noncompatible uses within the 65 Ldn of this country.l3

Leann Launstein, Airport Advisory Committee of Oak Creek, WI

Since the Environmental Protection Agency has already recognized that 55 Ldn for noise sensitive areas such as schools and hospitals will promote public health, we think that the FAA should also recognize it.l4

Sharon Spencer, Councilwoman, City of Grapevine Texas

It is time that the outdated, arbitrary Ldn noise measure be abolished...We don't hear noise at a constant 65 decibel hum over 24 hours. It can be very quiet, or it can be very loud whenever you're averaging it...I really, quite frankly, would like to meet the creature that came up with a 24-hour averaging methodology. I cannot imagine what kind of mentality was used, because it really doesn't make any sense...We already recognize, surely, that the 65 Ldn is inadequate, and we need to address that thoroughly.12

Peter Engelmann, Bethesda, MD

A major research effort should be initiated to reassess and, if necessary, modify the system currently used for determining the exposure of individuals to aircraft noise. (Selection of the Ldn metric limits in use seems both arbitrary and overly simple, apparently lacking in analytical basis by medical, psychological or sociological professions.)l3

Loren Simer, National Airport Watch Group, Minneapolis, MN

The 65 Ldn contours the FAA uses to describe the noise impact area are a calculated deception, used only to minimize the actual noise problem. Every 65 Ldn contour in the county encloses only a third -- a quarter to a third of the actual area subjected to severe aircraft noise pollution. All impacted citizens, all local public officials, and the airports themselves know that Ldn is a false descriptor.l4

George F. Doughty, Director of Aviation, City and County of Denver

There is a substantial lack of public confidence in the use of the Ldn noise metric and noise contours as being representative of the noise effects that people will experience from airport operations. More validation is needed on the psychological effects of noise and the reasonableness of the Ldn contours in representing these concems.l5

Joe F. Hill, Severn, MD

Integrated Noise Model (INM) uses a yearly day-night average which gives a false numerical rating to the actual noise disturbance. This model can in theory be defeated by use [off a scatter plan and by alternating arrivals and departures. Is noise more quiet by average?16

William F. Nolden Jr., President, Parkway Citizens' Association, Arlington, VA

FAR Part 150 results are consistently flawed because of the irrational way the Ldn are computed and used. The use of "average" noise figures is viewed by the affected public as an intentional deception on the part of the FAA.

Noise profiles and the resulting noise plans would be much more reasonable and impartial if single event noise statistics were the basis of planning. No one hears "average" noise, we hear takeoffs and landings.17

Arden Forrey, Aircraft Noise Group, Seattle, WA

Now, the FAA's dependence upon the Ldn 65 -- that's the day/night average 65 dB contour as the sole measure of the effect of noise on a community -- is due to the lack of any common conventions adopted in this country or abroad for the indices of the physical sound level, and the attributes that relate to annoyance and health effects.18

Lloyd Doctor, South Sound Aircraft Noise Group, Seattle, WA

The FAA's standard, the 65 Ldn standard and 3,000 feet, is just grossly unrealistic. I live in an area that has about 60 percent of the departures, so during months of the year when the wind tends to blow from the south to the north and we have departures over the south Sound, we get 100 percent of the departures, so that we have an Ldn significantly higher than the annual average. 19

Vicky Schiantarelli, Central Area Neighborhood, District Council, Seattle, WA

We also believe that the use of the 65 Ldn noise measurement technique is not a very good way of doing that. Apparently, no consideration is taken into the effect of single-event noise, which we find in a number of studies actually causes more ear and hearing damage than averaged noise levels.20

Andrea M. Wise and Joyce A. Church, People Over Planes, Inc. (POP), Pleasant Hill, CA

The Ldn measurement is inappropriate and unacceptable as a measurement of impact on surrounding neighborhoods. It does not take into account seasonal changes, heavy traffic times weighted against light traffic times, weather, land contours, etc. The FAA should choose another measurement system....21

Deborah Lunn, Acting Executive Director, Airport Operators Council International, Washington, D. C.

While Ldn may be appropriate for many or even most airport situations, AOCI recommends expanding Appendix A to allow for the use of a formula defining single event impacts and/or seasonal noise variations (for example, use of peak month average day-night) if it can be demonstrated that they are more representative of the actual noise situation.22

John Barber, President, Seattle Community Council Federation from report of R.O.A.R., Seattle, WA

Meadowlake Estates is located northwest of Hartsfield airport just outside, 500 to 1500 feet, of the existing contour 65 Ldn and their residents are complaining that they are experiencing their same disturbances as those within the contour.29

Ken Linder, Airport Manager, Ketchikan International Airport

The noise formulas and contour maps for our community indicated that these folks do not have a significant noise problem since the Ldn in the vicinity of those homes was below the magic 65. Nonetheless, these folks have had significant noise impacts due to frequent single event aircraft noise encounters substantially above the 65 definition.30

Robed N. Broadbent, Director of Aviation, Mccarran International Airport, Las Vegas, NV

Once the Noise Exposure Maps have been developed and the various noise abatement and mitigation alternatives are being explored, the area of concern is those areas exposed to Ldn 65 and above. There are no specific provisions for review of alternatives to mitigate noise outside this contour, while there may be communities directly outside this area and impacted by aircraft operations. The airport operator should have flexibility in determining those properties considered to be incompatible.31

Gary LeTellier, Port of Seattle, WA

First, we recommend that the Federal Aviation Administration evaluate and adopt supplemental systems that can be used in conjunction with the Ldn, or the day-night noise level, to paint a noise picture. Because Ldn is an annual average of noise, it is not viewed by residents as accurately describing their own personal experience, or residents are particularly interested in data that would reflect single-event noise, ambient noise, and seasonal changes in noise, as well as yearly averages.32

Paul Meyerhoff II, Executive Director, Alaska International Airport System, Anchorage, AK

The Airport feels that action should be initiated within the Federal Aviation Administration to develop additional noise guidelines which account for the single event noise impacts. It is within these guidelines that a formula be developed which would identify the conditions under which single noise event impacts should be mitigated.33

Robed N. Broadbent, Director of Aviation, McCarran International Airport, Las Vegas, Clark County, NV

Upon review of our noise exposure maps for 1987 and 1992, there was very little difference between the two maps. This is primarily because the increase in aircraft operations is offset by an increase in the percentage of Stage III aircraft. While this has also been happening in the past, we have noticed an increase in the number of noise complaints. This indicates that residents located around the airport are concerned with frequency of aircraft overflights as well as overall noise levels. They notice the quieter aircraft, but are concerned about the number of operations.34

Rodney Ruth, President, Citizens Air Rights, Inc., Allendale, NJ

The present noise measurement criteria of the FAA is grossly invalid. The method underestimates the extreme importance to frequency of noise events from aircraft. The "65 Ldn" measurement needs to be replaced with a better metric.35

Gloria Butts, Broadview Community Council, Seattle, WA

Noise is being measured in the wrong way; 65 Ldn doesn't pick up the noise from jetliners and the multitudes of small aircraft and seaplanes that fly in my neighborhood airspace, or the scary, low-flying single-event.36

John H. LeResche, Airport Commission, Torrance, CA

The 65 Ldn criterion was set to accommodate the noise generated at major commercial airports used by large jets. GA airports are told that they don't have a noise problem and are urged to increase both their activity and their usage by larger aircraft.37

Kenneth J. Delino, Executive Assistant, City of Newport Beach, CA

The first suggestion is to promote the use of noise metrics other than Ldn when devising Noise Control Plans. In Newport Beach and many other areas, Ldn simply does not predict or describe much of the public response to aircraft noise. This is particularly true at general aviation airports. Aircraft noise from John Wayne Airport (JWA) and many other airports is very successfully regulated by the use of SEL.38

Ronald L. Tulis, Senior Manager, KPMG Peat Marwick, airport environmental consultant

At air carrier airports, the noise created by general aviation is usually overridden by the air carrier operations in the INM. Nevertheless, in some communities, the "annoyance" caused by these general aviation operations (particularly early morning, nighttime, and weekend training) far outweigh the problems associated with the air carrier aircraft noise. Recommendations to reduce this annoyance are often met with resistance by the FAA because (a) the people reside in areas exposed to noise levels of less than Ldn 65, (b) the noise exposure area is not reduced, and (c) there are no perceived benefits as defined in terms of compatible uses as used in Table I of Appendix A of FAR Part150.

Similarly, special criteria need to be developed to permit greater flexibility in developing noise compatibility programs for general aviation airports where the Ldn 65 contour is often wholly within the airport boundary.39

Aviation Planning Associates, Inc, speaking for Bloomington-Normal Airport, Dayton International Airport, and Greater Cincinnati International Airport

At smaller airports ... single events become much more important since Ldn contours frequently do not extend beyond airport property.

We agree that seasonal Ldn maps are appropriate for airports with seasonal peaks, or other anomalies in their traffic. We are concerned, however, that the next request from citizen groups would be peak hour Leqs for connecting facilities. We would not be in favor of this, unless the FAA changed its landing criteria to allow for seasonal Ldns, or peak hour Leqs.40

Kathleen Blake, Harrison-Denny Community Council liaison with Seattle metropolitan area aircraft noise group, WA

The FAA should not use the 65-LDN noise measurement technique as an infallible guide to an acceptable level of jet noise. The regulations should recognize the effect of single noise events. And they should develop and apply new noise metric techniques. The FAA should not be using an approach that cannot assess and can only dismiss perceived levels of noise that distract and lower the quality of life of large populations.... the number of takeoff and landings per hour, and the flight patterns also have direct and important bearing for noise control.41

Mathew Rosenberg, Director O'Hare Citizens Coalition on Proposed National Jet Noise Policy, Des Plaines IL

Our members, the people who can no longer use their backyards, who so often cannot have a conservation, a phone call, or relax in their homes after a hard day's work without repeated long blasts of O'Hare jet noise, have reported again and again to us, to the O'Hare noise hotline, even to the FAA, that the main component of the jet noise problem is the number of noise events.42

Harry E. Mitchell, Mayor, City of Tempe, AZ

Single event noise level and single event peak hour noise level should be incorporated into the Part 150 noise study. It could be expressed in time over, noisiest hour, day or seasonal period. People relate to the single event more than the yearly average noise measurement. Peak hour noise contours should also be utilized.43

Gary Adams, Aeronautics Division Director, Arizona Department of Transportation

The communities within central and southern Arizona are known for their "winter visitors". The northern communities of Arizona are famous for their summer influx of tourists. With the current uneven balance of operations into these airports, the existing noise contour maps are not representative of actual noise exposures. The usage of "Seasonal" Ldn's does not address the issues of facilities that have higher usage during tile weekends or joint use unlit/public facilities which may have complex noise problems only during military maneuvers, etc. The best possible solution regarding the measurement of noise would be the worst cow scenario for existing operations and projected noise contours, I.e. ten to twenty years.44

Charles H. W. Talbot, Seattle Community Council Federation, WA

Of our 35 members, 33 -- excuse me; 32 are neighborhood organizations with strict geographical boundaries. You know where they are. Not one is within the 65 Ldn contour as it's presently drawn. Now, that should tell you something about whether the 65 Ldn contour realistically tells you where and where not noise impacts are being experienced in an adverse manner.

We could not have raised nearly 530,000 for our lawsuit against your agency out of -- if we had to rely on people inside the contour. If you map our contributions, they're almost exclusively from people who live outside the contour. The noise effects are severe, are felt to be severe, outside the contour.45

Joan Bell, Citizen's Alternative to Sea-Tac Expansion, WA

The invalidity of this standard of noise measurement was indicated by the Seattle (Community Council) Federation's attorney, when his research showed that the 65 Ldn standard had not been put through the required process of public comment for adoption as a regulation. Is the FAA not willing to make reassessments as years go by? Every successful business updates its assumptions in response to evolving public opinion. 65 Ldn belongs to an era when it was considered okay to smoke. In today's climate, we are becoming more aware of what impacts our health negatively. How can it be beneficial to be awakened two or three times during the night by very loud single-events, even if they average out to 65 Ldn over 24 hours?46

Don Bell, on behalf of Bob Swigart, Citizen's Alternative to Sea-Tac Expansion, WA

CASE members object to the obvious use of formulas, numbers, et mm, to paint a picture of airplane noise which we -- which you feel we should find acceptable at 65 Ldn, because it is only 5 Ldn above -- over normal conversation of 60 dB. How is this 65 Ldn obtained? By averaging all of the sound over a 24-hour period, including times when planes are not flying. This in effect, eliminates an accounting of the peak noise, which is exponentially above the 55 Ldn, and which causes us so much stress.

We ask you to better define the actual noise we are living with, and then take the appropriate steps to reduce it.47

Angie LaVigne, aircraft noise representative from Maple Leaf, WA

And again, apparently if an aircraft is above 3,000 feet altitude, or if it's in a region outside of the famous 65 Ldn, the effects of noise do not need to be addressed. And we really do hear those aircraft when they're above 3,000 feet, when it's below 65 Ldn.48

Steve Nemeth, Mirrormont Community Association, WA

The EPA believes that noise impacts occur outside tile day-night level 65 contour which are significant within the meaning of CEQ 1502,I, and should be incorporated into tile systematic analysis of noise impacts.

The FAA says that any land use outside of tile 65 Ldn contour is compatible, and needs no noise analysis. This contradicts what the EPA believes.

...we would like to ask that the discontinuance of the erroneous 65 Ldn criteria be dropped, and include single-event noise level measurements and dBA net increase limits in single-event occurrences with respect to the surrounding environments.49

Walter Whaley, Triangle Airport Noise Coalition, Raleigh, NC

The currently used "above 65 LDN" to define unsuitable for residential use is totally inadequate, par6cularly for airports impacting suburban neighborhoods where the background noise is on the order of 40 LDN.

As you know, the LDN metric is an average over a 24 hour period and, as a result, has conceptual shortcomings as a single set of criteria. A limit on single event noise appears very necessary.

In the event a comprehensive, more appropriate, metric cannot be developed in a short run, we urge that "above 55 LDN" be established as "noise impacted residential areas".50

Roger Chinn, Chairman, Airport/Community Roundtable, San Francisco International Airport, and Mary Griffin, San Mateo County Supervisor, Redwood, CA

Experience at SFO indicates that the single-event noise level is a critical consideration when it exceeds ambient levels in residential areas (this usually occurs during night and early morning hours). Single-event standards or procedures which include consideration of single-event impacts should be included.

Sound frequencies below 500 Hz exist up to six miles behind departing aircraft in residential areas behind runways 1L and 1R at SFO. Without a single-event noise standard and with the use of a weighing scale in the Ldn metric, there is a failure to identify and dimension this serious problem which impacts several cities.51

Betty Ann Kane, Chairman of tile Metropolitan Washington Council of Governments and Chairperson of the COG's Committee on Noise Abatement at National and Dulles Airports

Professional surveys conducted as pan of this test [Washington National Airport Scatter Test Plan] showed significant citizen annoyances at 60, 55 LDN and lower levels of LDN, significant in percentages that equal those percentages used to establish 65 LD originally. Our data suggest 55 LDN is a much more accurate level to use for land use planning...,our data and our experience suggests that the LDN itself, which is a blend of average noise levels and weighted for day/night flights, is a very unrealistic way to measure noise exposure and human reaction to it.

Frequency of flights, pink noise intensity, duration of sound are equally or sometimes more important measures. Experts tell us one stage two commercial overflight is equal in terms of cumulative LDN exposure the way the metric and the math works to many comparable Stage 3 operations.

None of us could tell our constituents that we would trade one Stage 2 aircraft for 10 or 100 Stage 3 going over one an hour versus one every minute. Although we understand the acoustical logistic between how the numbers work, it is not acceptable to our regions residents who are sensitive to the number of overflights as well as their sound intensity.52

Survey findings of residents near Dallas Fort Worth International Airport

Overall, residents say they are less bothered by the number of flights overhead titan by the loudness of the noise. However, those who complain most about aircraft noise are nearly twice as likely to say it is not just the level of noise, but also the number of flights that bothers them most.53

Cameron Priebe, Mayor, City of Taylor, MI

We think the measurement standards utilized aren't particularly useful. LDN, a process by which the average noise over the day and night, doesn't really measure the noise impacts in neighborhoods.

If we were to set off a stick of dynamite in this room daily measured with the LDN standard, you would have no noise problem. If you lived directly next door to Kennedy, you could have two flights a day and not exceed 65 LDN'S.

I suspect the bomb in Hiroshima probably didn't meet your noise standards. Therefore we have to continue to use that measure but implement other measures impacting noise as well.54

Theodore J. Sophocleus, Councilman, Anne Arundel County, MD

Identifying the impacted area becomes an arbitrary issue since many aircraft turn too quickly, thereby altering the take-off vector causing a greater impact than is actually represented on the existing noise-zone maps. Couple this with the way the noise zone is calculated based on a 24-hour period of noise occurrences or events in order to establish an area's LDN. Consequently, many homes and families must tolerate excessive noise for six to eight hours a day but are not considered impacted because of the 24-hour averaging. I believe the noise average should be based on peak time occurrences. This would give a more realistic picture of actual impact on the citizens of our country.55

Richard Yukubousky, Director, Office of Long-range Planning, City of Seattle, WA

Noise does affect persons outside the LDN 65 zone. The use of LDN 65 standard inappropriately narrows the scope of the Environmental Assessment. By focusing on the LDN 65, the Environmental Assessment does not address areas where the changes in noise levels (both increases and decreases) will occur. These areas are largely outside the LDN 65 contour. The federal procedures, as applied, by the FAA, do not recognize the impact of noise on people's lives. ... There are substantial differences in the location of noise contours for lower levels of noise. The difference in the location of the contours for north and south flow ... in comparison with the annual average contour begins to show the leveling effect of averaged noise data.56

2.3 Interference Effects: Speech, Sleep, Natural Habitat

Gerald D. Patten, Associate Director, Planning and Development, National Park Service, U. S. Department of Interior

The data indicates that yearly day-night average sound is an inappropriate metric for use to categorize aircraft sound levels over units of the National Park System. Many visitors, especially those who go to more remote national park areas, expect to be able to escape the sights and sounds of modem life. Moreover, the Ldn metric as currently used fails to account for the very low ambient noise levels characteristic of most national park settings. Our research suggests that a far more appropriate metric would be deductibility.

It is our understanding that the Aviation Safety and Noise Abatement Act of 1979 was focused on impacts to communities. However, in 14 CFR 150 an Ldn level of 75 is stated as compatible with "parks" and other outdoor activities. We are not aware of any studies that support this assertion, and in fact, our research indicated that Ldn of 75 is inappropriate for remote park areas. The Federal Aviation Administration and the National Park Service have both agreed to adopt much lower Ldn levels at Grand Teton National Park.57

Conley L. Moffet, Acting Assistant Director, Fish and Wildlife Service, U.S. Dept. of Interior

The Fish and Wildlife Service has on numerous occasions expressed concerns regarding physical and noise impacts of planned and existing military and commercial airports on wildlife resources (e.g., proposed projects in South Carolina, Florida, Kansas, Colorado, Nevada, and California). Where wetland and other important wildlife habitats occur adjacent to airport facilities, noise impacts can and have adversely affected wildlife populations.58

Ms. Hubbard, former City Councilwoman, City of Dearbom, current Chairperson for County Commission's Special Task force on Aircraft Noise, MI

I sat here earlier today listening to the testimony from the Delegation from New Jersey, and I am here to tell you [it] is no different in Michigan. It is a very extreme problem. People are putting their homes up for sale. this change has affected what I would consider to be one of Michigan's most finest residential communities, and it is really devastating this community.

.... We are talking about people who have living in this residential community for years who never experienced any noise - in fact, that is why they moved and bought that house, was for its tranquil neighborhood. 59

Susan Staples, Ulsterites Fight Overflight Noise, 1000+ citizens group from Ulster county, NY

Our quiet places are a natural resource and they are a valued commodity. What has happened since the expanded East Coast plan is we are losing our quiet places. They are no longer available for or for the people of the metropolitan region who need a place that they can get away from noise and stress.

One of the arrival routes for Newark Airport was placed over Minnewaska State Park. As a result, you now have the experience of hiking three and a half miles off the road to get to a wilderness setting has that special kind of quietness that is very unique to wilderness area only to hear this quietness bombarded by the jet....60

Janet Perina, Staten Island, NY

I moved to Arlington Terrace with my little son a year and a half ago. He is now three. Since we have been there the nights that the plane fly over us his sleep is disturbed and he wakes up screaming from fear of the loud noise. This condition has been bad enough so that his sleep patterns seem to be permanently disrupted. I cannot say that he is particularly sensitive because I have been wakened from them too. My sister-in-law, who lives here too and who has three small children complains of the same problem with them. This condition is affecting the health of all the children. Sometimes the planes fly so low that we are afraid they will hit the buildings.61

Cameron Priebe, Mayor, City of Taylor, MI

Finally , quality of life. According to the environmental statement in 1986, more than 15,000 Taylor people were impacted in neighborhoods with 65 LDN. I think the LDN is totally unrealistic. According to the 65 LDN, 16,000 Taylor people have a noise problem. What this really means is people can't enjoy simple pleasures of life, having an outside barbecue, watching television, carrying on a normal conversation. 62

Geri Cullen, Staten Island, NY

You cannot talk on the telephone, sit down and watch TV or listen to a radio and any attempt to sit shuttered up in my own home is like sitting on a bomb shelter during a shelling. Shuttered up is the correct definition of how I am forced to live due to these aircraft. Something is wrong.

I cannot sit in my backyard and invite guests because any attempt to converse becomes totally frustrating....I must pull my drapes at night because my son is frightened by the beaming of headlights of these aircraft. And the FAA does not care. I have heard all the excuses, most, if not all, are weak and pitiful and I'm hear to tell you that they are unacceptable....What pitiful excuse will the FAA make when one of these jumbo jets fall out of the sky, destroying my home, my life, and God knows how many of my neighbors?63

Gladys Shapass, F.A.T.E., Staten Island, NY

The steady constant noise drowns our conversations, assaults our eardrums, terrifies our children, prevents us from falling asleep and awakens us prematurely.64

Mrs. Genevieve Roxland, Staten Island, NY

...Many of us are elderly, fragile and housebound. Our sleep is easily disturbed. We depend on the television for our entertainment and our telephones for communication with our family and friends. There are times when the planes are flying some particular paths when it is impossible either to hear or communicate with others. At one point the planes were coming over so fast and low that it was impossible because of the incredible noise to put an emergency 911 call through without delay. Their dispatcher simply couldn't hear over the constant background noise. Admittedly, this only happened once to my knowledge, but once is too often for a heart attack victim.

Our television transmission is continually interrupted. Both the audio and video are affected. Television is our only regular source of entertainment. Senior citizens are restricted, by their health and vulnerability to criminal activity, as well as by financial restrictions, to their homes, particularly in the evenings. In the world of the nuclear family we are alone, and some of us abandoned. Our world is our little coterie of friends, some worse off than we are, our little senior club, and our TV and the pernicious airplanes.65

Margaret Kimble, Staten Island, NY

The sound is so loud that my house rattles. My family and I have often been awakened from a sound sleep.

Once I had my elderly grandmother staying with me for a couple of weeks. She became so traumatized by the sound of the planes one night that I had to call an ambulance. They reminded her of World War II when England was being bombed by planes.

It is very difficult to watch television. Sometimes the planes fly over us one after another, every minute or so. We must put the sound up very high to enjoy a television program.

Verbal conversations are extremely difficult. Telephone calls are the worst problem. I often make or receive long distance telephone calls. I have to repeatedly ask the person on the line to wait until after a plane has passed overhead .... This is causing my callers and I higher telephone bills.

My daughter attends a school nearby. The roar of the airplanes repeatedly interrupts her classes.66

Sue G. Townsend, Memphis, TN

The volume control of our television cannot compete with airport noise, our pictures vibrate on the walls, and our ears literally hurt from the noise.67

Francisco Lopez, President, Pine Grove Condominium, Isla Verde, Puerto Rico

These noise problems not only are continuously creating discomfort to our standard livings, but they are generating many other troubles. For instance, they interrupt our sleeping hours, activate and force alarms to sound, also interrupt meetings, personal conversations, telephone communications and many other activities.68

Delbert M. Biddison, Des Plaines, IL

... when runway 22R was in full operation, their studies were interrupted 45 seconds out of every minute, due to low flying aircraft.

It was later proven by School District 62 that the children in Maple School had the lowest concentration factor in the District...Maple school has since been closed. ...Iroquois Jr. High School was built as a windowless bunker to reduce aircraft noise.

... We also have problems with rattling doors, windows, items in the home, trying to listen to radio or TV and talking on the telephone.69

Jane Benjamin, Memphis, TN

Noise wakes us up at night every morning between 3 & four o'clock every morning. I half to get up at 4:30 to go to work. We have our windows rattle a lot. The noise is a problem. In summer you can't go outside & talk just anymore because of the noise problem we are having. ...We are not trying to stop progress anyway. We just want to be considered. Would like a response from you all. Is their anything you all can do for us?70

Jean Gaines, Memphis, TN

From morning around 11 :30 A.M, until 5:30 P.M, we are constantly getting noise from aircraft. The noise is so great, at night we are kept awake by the rattle of windows, pictures sometime fall from the walls. The dust and especially fuel fumes are sometimes unbearable when you walk outside.71

Louis A. Miranda, Isla Verde, Carolina, Puerto Rico

At time, the noise from cars, trucks, and motorcycles that transit on the Baldorioty de Castro Avenue are more annoying than that of the aircraft that come and to from the Luis Munoz Mann International Airport. But there are times when the authorities at the airport allow aircraft to land on the landing strip that runs alongside the Baldoroity Avenue at 2, 3 and 4 o'clock in the morning. Now, that is nerve wrecking. When this happens it becomes very difficult for me to go back to sleep.72

Richard P. Washington, East Point, GA (near Atlanta Hartsfield International Airport)

When aircraft are passing though our area glasses on shelves rattle, windows hum and vibrate and the force can even be felt through floors and furniture. It is often difficult to hear telephone conversations, TV and radio broadcasts at normal sound levels or even converse outside without practically screaming.

We are often kept awake by the roar even until 2:00 a.m. Curiously the jetblast is extremely loud during very cloudy or rainy weather conditions. The planes pass directly overhead at seemingly low altitude and get lined up for hours.73

Survey findings of residents near Dallas-Fort Worth International Airport

Respondents say that aircraft noise interferes with a wide range of daily activities at home, especially relaxation and activities requiring concentration or that performed outside:

John Barber, President, Seattle community Council Federation submitting report of R.O.A.R.

With Sea-Tac, Beacon Hill did not qualify for the Part 150 area although about 80,000 jets fly overhead per year --- over 250 per day. Sea-Tac jets impair conversation, overpower television or music in homes, disconnect thought of many residents, and interrupt other activities of people on Beacon Hill. Doctors in First Hill clinics and hospital can not use their stethoscopes and other sensitive equipment while jets thunder overhead. Professors in universities and teachers in classrooms in schools and colleges on Capitol Hill and as far north as the University District must pause for jets to pass. People along the instrument landing system corridor and under the "east turn" report that jet noise drowns out telephone conversations, especially listening. The F.A.A.'s standards rule all of this disruption out.75

2.4 Health Concerns

Anita Davis, Committee for the Abatement of Aircraft Noise (CAAN), Cabin John, MD

These powerful vibrations affect our bodies and health as well as our buildings. The racing pulse, the churning stomach, all made worse by frequency of overflight as noise vibration builds on noise vibration.

This is not to mention the hydrocarbons that you can see streaming out of every jet that goes over. These wastes pollute our water and our air, and their social costs include their effects on our bodies, monuments, and houses.76

Susan Staples, Ulsterites Fight Overflight, Ulster County, NY

Given the large number of studies showing an adverse effect of noise on the health of individuals, it is not defensible to dismiss this cost as unquantifiable. Studies have shown strong evidence that loud noise has a variety of physiological effects apart from hearing loss. Among the effects are high blood pressure, peptic ulcers, and depressed immune response. Six years after the opening of a new runway in Amsterdam, Dutch researchers found that the sale of anti-hypertensive drugs doubled. A 1982 study by William Meecham at the University of California at Los Angeles found a higher rate of cardiovascular death, strokes, murder, and suicide among 20,000 residents of a flight path corridor near Los Angeles International Airport than in the rest of the city.

Other health effects are psychological and involve learning and behavior. Noise has been related to learning problems such as poor concentration and failure to read, and to aggression and to a dampening of altruistic tendencies. Meaningful decisions about noise and capacity cannot be made if the health care costs, including days lost in the workplace, of noise impacts are ignored.77

David Anderson, private citizen from West Palm Beach, FL

With respect to the environmental impact, noise stress is a serious hazard and over a period of time is known to be cumulative.78

Joseph Karaganis, National Airport Watch Group, Chicago, IL

The preambles to the proposed rules and the supporting documentation acknowledge that aircraft noise associated with airport operations causes serious health injury, such as cardiovascular disease, and I'm quoting now from the background document, which we received last Friday. "There is strong suggestive evidence that aircraft noise is a causal factor in cardiovascular disease... " -- this is the FAA Background Report -- ".., sleeping disturbances and mental disorders, stomach complaints and hypertension, learning impairment in our children and job-related industries."

The whole premise of protecting public health, which is at the heart of local decision making, you get from the ability of local authorities to say, "We're going to protect that health of those homeowners out there" because you don't provide a quantitative index to that loss, and then you say, "If we can't provide a quantitative index, it can't be a basis of the justification."

There are health injuries out there undergoing on a massive scale, both for noise-related injuries and air pollution-related injuries of aircraft, and the local communities have to have an opportunity and the ability to consider those qualitative harms if they can't be quantified, and I suggest to you that they be quantified.

Dale Miller, Councilman, Ward 20, City of Cleveland (quoted by Joan Hockenberry, Cleveland Airport Area Commission), OH

The problem not only causes a great deal of environmental stress from high noise levels and damage to homes from vibration and possible damage from discharges from aircraft, but also seems clearly associated with higher levels of hearing loss, breathing difficulty, and other health problems.79

Bill Stone, Airport Interested Residences, Inc., Milwaukee, WI

The level of sound has a psychological effect on our bodies. Many studies have suggested a link between the noise and high blood pressure.80

Alderman Ducinski, 41st Ward, Chicago, IL

I predict that as science develops its evidence of the relationship between severe exposure to severe noise and the effect it has on the human being, we will see lots of these effects multiply. It could very well be very serious financial trouble because of lawsuits. So I hope that you will certainly make every effort to speed up this particular issue.81

Loren Simer, National Airport Watch Group, Minneapolis, MN

Aircraft noise is harmful to human health. Aircraft noise can cause an increase in hypertension, blood pressure, cardiovascular disease, and gastric disease. Also, aircraft noise can increase anxiety and stress, interfere with sleep and relaxation, and produce serious psychological problems and mental disorders, profoundly disrupting concentration, learning, and convalescence. Aircraft noise has been implicated in decreased birth weight of infants when the pregnant mother was exposed to aircraft noise. Like cigarette smoke, it is dangerous to expose humans to airport noise pollution, and should be avoided.82

Carla Janes, Citizens Against Noise and Aircraft Pollution, Seattle, WA

...if, by some miracle, this bill works and takes care of the noise problem by 1999, we still have to be concerned for the people on the ground for the next 8 years. Even then, we still have to face up to the great problem of aircraft pollution. Is it -- does this mean that in 1999 we will quietly poison the people on the ground.

...We went door-to-door directly under the flight paths and we were shocked to see so many people that were complaining about asthma problems. And we saw a lot of home asthma machines.83

Vicky Schiantarelli, Central Area Neighborhood District Council, Seattle, WA

And it's documented that excessive noise on a regular basis over along period of time not only impacts senior citizens and middle-aged individuals but our children, as well. We're particularly concerned with the health effects, the fact that the hydrocarbons are carcinogenic, and that when you fly planes over residential areas and jet fuel is ejected and dropped from these planes, that it is going somewhere. It's falling on the neighborhoods.84

Don Bell, Citizen's Alternative to Sea-Tac Expansion, WA

Jet noise, with its combinations of deep roar and shrill screech, is creating a major health problem. It is well established that noise can alter physiological processes, such as the functioning of the cardiovascular system. Such changes, if extreme, are considered potentially hazardous to health. Physiological changes produced by noise consist of nonspecific responses typically associated with the stress -- with stress reaction. These include increases in vascular constriction of the peripheral blood vessels, and the diastolic and systolic blood pressure. Jet noise has been observed to exacerbate pulmonary diseases, particularly in elderly people.85

Marie Wilson, Rainier Beach Community Club, WA

We know that the impact of noise has consequences, severe consequences, to humans and animals. We need more information about the cumulative effects of jet fuels and the consequences when they are dumped. Must we always be too late in acknowledging the very real dangers, and either eliminating them or ameliorating their negative effects.86

Samuel H. Book, private citizen, Cabin John, MD

...We also suffer from hydrocarbon exhaust fumes which spew out of low flying planes onto our yards, our homes, our porches, and, we believe, our lungs.87

Janet Perina, Staten Island, NY

...There are times that I find my car, which is parked in an open lot, covered with black, sooty flecks and/or with a oily substance that can only be attributed to the planes and their noxious fumes and fuels. If this is all over the cars, what is in our lungs?88

Bill Stone, Airport Interested Residents, Milwaukee, WI

One of the most serious risks that we are exposed to is air pollution caused by the airplanes flying over our homes. There is documentation in Dangerous Air by Lucy Kelerva that states that excessive burning of jet fuel is only one of the many ways modem civilization is threatening our atmosphere.

Jet airplanes that fly over our homes is the equivalent of 10,000 cars being driven over it. In addition, a study by the Frankfurt Airport in Germany shows that airplanes on the tarmac at the airport generate more carbon monoxide and nitrogen oxide emissions than all the vehicles on the road surrounding the airport. The National Aviation Policy does not attempt to measure, monitor, document, or control this air pollution generation at our airports. 89

Margaret Kimble, Staten Island, NY

The fuel exhaust from the airplanes is another major concem. We have often seen the vapor from the airplane exhaust coming out of the planes and drifting down on us. Yes, you can actually see it! My house and car are always covered with a film that is extremely difficult to get off. I don't know what these fumes are doing to us, but I do know that they aren't healthy.90

Bill Appel, Ravenna-Bryant Community Association, WA

All of a sudden, after about 15 minutes after a flight has gone over, there is this tremendous smell of aircraft fuel, which passes after a time.91

Patricia E. Hannan, Elm Park, Staten Island, NY

How are the fruits and vegetables we grow and consume affected? Mine are strangely spotted with unusual growths.92

Jean Crisson, Arlington Community Association, Staten Island, NY

My children's health is affected by their constant presence. Their hearing will soon be impaired by the rumbling engines of these constant, low flying planes. The pollution engines emit every time one flies over --- what is it doing to my lungs? My children don't sleep. My 10 month old wakes every time an airplane flies over and my 3 year old won't sleep in his own bed because he is frightened of both the noise and the lights these planes bring each time one flies over.93

Margaret Kimble, Staten Island, NY

As a mother, my greatest concern is for my children. I fear that they will suffer permanent physical damage. If I could, I would move away from Staten Island.94

Elizabeth A. Dates, Property Manager, Grenadier Reality Corp. Staten Island, NY

I myself have an office on the complex and can verify that the noise emanating from the planes is deafening.95

2.5 Lack of Responsiveness to Citizens on the part of Civil Authorities

Lee Daniels, Illinois State Representative, House Minority Leader

... the Part 150 process is deficient in adequate citizen participation in planning and review of noise mitigation measures. Citizens are asked to submit suggestions, whereby a remote committee has the tendency to dismiss all but the most innocuous of those easiest to invoke. The process gives the appearance of citizen involvement when only a token approach is undertaken. The process is incomplete at best.96

Cameron Priebe, Mayor, City of Taylor, MI

Part of the problem is those of us that are impacted, those of us that are neighbors of that airport have no real voice, no real input into the process, into the decision making associated with that airport. That should be corrected.97
We request the Federal Government mandate operators to establish noise policies and that we have meaningful local involvement in that entire process.98

John H. LeResche, Airport Commission, Torrance, CA

The Part 150 program is being used to co-opt local noise controls. If a local airport authority accepts a Part 150 study, they lose control of noise abatement to the FAA. Long Beach CA learned this to their cost.99

Ed McNamara, Wayne County Executive, MI

The FAA changed our flight tracks and departure and arrival policies. They explain that they worked internally for 2.5 years prior to making the change, and that was designed to dramatically improve a very unsafe airspace and reduce workload on a chronically understaffed operation. Everyone is for safer airspace and I truly believe the changes have helped in that regard.

Unfortunately, this change occurred just one month after we completed a two year noise study which cost hundreds of thousands of dollars and involved hours and hours of labor by community leaders. Although the FAA was involved in our noise study, we were not cognizant of any changes in airspace under 5,000 feet that would create any significant noise impact 100

Under the new scheme, pilots take their foot off the brake, put the engine in full thrust and keep thrusting straight out until they reach 10-15,000 feet. The whole time the engines are pointed down at homes in some of our most affluent and densely populated neighborhoods. No longer do aircraft follow industrial or open non-residential flight tracks.

The consequences of this action have been as you could expect. Citizen outrage against the airport flourished as far as 12 miles from the airport. A recent poll confirms this. Whereas one year ago, only 2 percent of Wayne County residents felt noise was the most important problem at the airport, that has now multiplied by 10 to nearly 20 percent.

And instead of 65 percent of all Wayne County residents supporting airport modernization, we have lost 20 points with only 45 percent of all residents favoring modernization today. 101

... Although these actions may anger the airlines, Department of Transportation or the FAA, we believe we have no choice but to protect ourselves. There are two very clear reasons why we feel this way:

First, the unbridled ability of the FAA to inflict airspace changes that are so injurious to the quality of life of our citizens and ultimately the economic vitality of the region represents such an unfair imbalance of power that results in a "battle-station" mentality-induced paralysis leaving our communities facing the double jeopardy of unbearable noise and a strangled economy.

The second reason that Wayne County has to devise its own noise plan is plain and simple: The Federal Government hasn't...leaving every airport operator to fend for themselves.

And at that time initially, we went to the FAA and said there haven't been any drastic changes and we in turn told the citizens things were not that different, but the more citizen complaints we got, the more we realized things were different and it was pretty much done unilaterally.

Mr. Oberstar. With no prior consultation?

Mr. McNamara. No consultation, only that the plan was presented....102

Susan Staples, Ulsterites Fight Overflight Noise, Ulster County, NY

Our citizens who call Eastern region noise abatement basically are given the same message. The message is that, one, nothing has changed; two, that nothing can be done about it; and three, "Aren't your reactions perhaps excessive?" This doesn't not convey to the public a concern with taking noise abatement seriously. 103

Paige Miller, Commissioner, Port of Seattle, operator of SEATAC International Airport, WA

During our mediation process, the FAA representative attended, but were prohibited by current FAA policy from actively participating in some key discussions. This made the committee's work much more difficult.

However, the FAA did help us by announcing plans in the middle of the mediation process for major flight track changes because of concern over safety, congestion and capacity. The uproar over this announcement nearly destroyed the mediation process.

Two days after the committee finished its work, the FAA imposed its flight track changes, known as Four Post. Many, many communities in our area vehemently opposed these changes. 104

Glover W. Barnes, Seattle Community Council Federation, WA

...No more intrusive, damaging, and dangerous flight paths could have been chosen, even with the assistance of the most sophisticated computer models. 105

Jim Street, Seattle City Councilman, WA

I met with a community group and FAA during this debate, and what FAA told us was noise it [is] not a priority. Noise is something we cannot give the kind of priority you want us to give, because of existing national policy, and unless national policy changes we are not going to change.106

Margaret Kimble, Staten Island, NY

The attitude of the FAA has made us even more upset. They first said they had to do a study before they could help us. Then we found out that these planes were rerouted over us without any study. Now they simply refuse to do anything at all. 107

Sherwin Lanfield, Donaldson Run Civic Association, Arlington, VA

Now, I do know that, in addition to its safety function, Congress has given the FAA the job of being a Department of Commerce to the Airlines, which explains why its documents sometimes read this way. But Congress also gave the aviation noise function to the FAA instead of the EPA, and yet it so rarely sounds that way. Double standard.

There was an EIS when 750 feet of safety overrun area was added a few years back. Yet, the total rebuilding of that airport now to wide body specifications and the determination to admit almost any quantity of jets at night appears not to have safety or environmental effects suggesting an EIS to the FAA.108

Susan Staples, Ulsterites Fight Overflight, Ulster County, NY

The policies and procedures of the FAA minimize the environmental and health effects of noise.

Further, the FAA does not consider environmental factors in the placement of electronic navigation aids and routinely plans routes without the benefit of mapping protected public use or semi-wilderness areas. These deficiencies in FAA environmental policy suggest that it is not in a good position to make determinations concerning the cost of unregulated noise.

Historically, its primary concern has been safety and capacity. Indeed, it has a record of considering environmental impacts only after outside bodies force it to do so, examples being the EPA and single event noise.

The priorities of the FAA are safety and capacity. It is a biased mediator of noise and capacity issues. It is too large and removed a bureaucracy to effectively manage the competing interests of noise control and capacity at a particular locality. 109

Louise Chestnut, private citizen, Alexandria, VA

These voters and taxpayers must find at least part of the money to allow this growth in airport facilities to take place. DOT and FAA might find their future plans more readily acceptable to the public if the FAA proposals for airport noise and access restrictions were as concerned with and considerate of the public as they are of the airport operators and of the airlines. 110

David Anderson, private citizen, West Palm Beach, FL

Government has no right legally or morally to put its citizens at risk. The protection of its citizens should be a primary obligation and function of the FAA and the United States Govemment.111

Kathy Lane, National Airport Watch Group, Chicago, IL

The people, frankly, see through the National Noise Policy. They know that attempts to impose a national solution on distinctly regional problems can offer only the lowest common denominator in noise regulation, which benefits only the industry.

The Federal approach to airport noise is fundamentally flawed. Airport noise is an environmental disaster raining down on the heads of the public, as a result of deregulated airlines bent on competing until the biggest and the strongest drive the rest out of business.

Airport expansion is the result of big airlines protecting their investments in terminal facilities, rather than developing new facilities that could offer the public safer and more efficient air travel. Rather than recognizing these realities, the Federal Government has bowed to pressure from the industry to treat noise-impacted citizens and communities as though they were in fact the problem.

Restrictions put in place by responsible airports are viewed only as a patchwork quilt of obstructions to the growth of air traffic. This is simply backwards. Noise is the problem. Uncontrolled air traffic growth is the problem. The citizens are the victims. FAA should not further complicate or confuse the real issues in this debate by attempting to extend its power through the rule making process. 112

Joseph Karaganis, National Airport Watch Group, Chicago, IIU

So we're prepared for a dialogue, but the fact is that the present set of rules appears to be a stacked deck by FAA in favor of the industry.113

Congressman Henry Hyde of Illinois (delivered by Ellen Zisook)

I have reviewed the rules which the FAA proposes to implement under the authority of the Act, and have found that the FAA has attempted to subvert the will of Congress by proposing rules which do exactly what the legislation did not do. The proposed rules are a clear attempt to prevent airport operators, including state and local governments from protecting their citizens from airport noise, and an attempt to force expansions of airport capacity to levels higher than the local community may desire. The Act does not compel nor does it authorize such rules. 114

Michael D'Hooge, Bridgeton Air Defence, St. Louis, MO

We often ask ourselves, why are we doing all this? The answer, unfortunately, is that we do not trust that Lambert and the FAA have our rights as a high priority. ... Based on our experience with the FAA, we do not believe the FAA will be responsive to our concerns. If you have a noise problem, you can call the FAA's 1-800-FAA-SURE complaint line. They tell you to call your local community relations office. In St. Louis, this will get you nowhere.

... our engineers have done a literature search of 19 airline crashes which have occurred in the United States and plotted on a map where these crashes would land in relation to the end of the new runway. The map clearly shows that many of these crashes would have landed on McDonnell-Douglas buildings and workers, and we have copies of these maps to give to you.

Our point is this. The FAA, by allowing this very serious safety violation to remain alive, has violated its public charter for providing a safe and efficient air transportation system. If the FAA cannot be trusted with their most basic goal, how are airport neighbors expected to believe that the FAA will fight for our noise abatement rights. 115

Loren Simer, National Airport Watch Group, Minneapolis, MN

The Airport Noise and Capacity Act, however, is an environmental disaster. The FAA, generally perceived as a tool of the airlines, is now given the responsibility for protecting the environment around airports. This was accomplished by establishing a national noise policy which removed the local airport proprietors' power to impose noise-related restrictions on the use of the airport. This Act is a triumph for economic greed over the rights of citizens. It is a painfully clear demonstration of the power of a well-financed airline lobby.

Naturally, citizens everywhere are profoundly disturbed. There are a lot of them. Contrary to your slide show, the EPA -- the EPA says there are 45 million citizens enduring aircraft noise pollution beyond what is, and I quote, "physically safe," unquote.116

Congressman John Miller (read by Bruce Agnew), 1st district (Seattle), WA

The FAA must begin to demonstrate an understanding that capacity and noise are two sides of the same coin; without satisfying aircraft noise concerns, capacity is sure to further to decline into crisis. 117

Carla Janes, Citizens Against Noise and Aircraft Pollution, Seattle, WA

...In 1981, big business, in the name of budget cuts, reduced this 1972 Act of Congress to worthlessness by reducing the Environmental Protection Agency's noise staff from 150 to zero.

...But I must say about the FAA that in Seattle we have a history of the FAA working hand-in-hand with the Port against the people on the ground. It was the FAA that allowed the Port of Seattle to buy out houses in a different pattern than the Sea-Tac community's plan required, taking away the fights of the people directly under the flight paths. It was the FAA that allowed the 4-post plan to be instituted without an environmental impact study. In fact, it was the FAA that said it wouldn't impact us. And lastly, the FAA overrides our Washington State noise laws presently on the books.118

Glover W. Barnes, Seattle Community Council Federation, WA

The FAA's existing device of closing its eyes and ears to the environmental impact with the aid of obscuring regulations should be discarded. 119

Lloyd B. Parr, Director of Aviation, Missouri Highway and Transportation Commission

During our observation of the Part 150 studies we have noted real frustration on the part of local citizens who reside near the airport. In many cases they do not agree with all of the results of the study but feel powerless to do anything about. Some perceive the study as nothing more than a series of applied formulas, the results of which tell them that it they are within a 65 LDN contour they should not be bothered by noise. The consultant confirms this by pointing out that 65 LDN is an Federal Aviation Administration (FAA) standard for acceptable noise. Many people cannot accept this but are simply told that's the way it is. We believe more time should be devoted to the legitimate concems and questions of the citizens....120

Andrian Meewis, Chairman, Concemed Citizens of Ontario, Inc., CA

We the people (the suffering residents under the flightpath) have no representation in the process. There have never been a dialogue between the jet noise enforcers and their jet noise receivers. Meetings about airport matters are being held unannounced. Information about such meetings and actions taken is given afterwards. Appointed members of committees having to do with noise abatement are either residing in other cities or outside the jet noise impacted area.

... as stated before "WE WANT TO BE PART OF THE PROCESS. "121

John C. Freytag, PE, Principal Consultant, Charles M. Salter Associates, Inc., acoustical consultant for four Part 150 studies in past two years including Ontario, CA

On several FAR 150 studies, an attempt has been made to eliminate participation by communities with long standing complaints about airport noise. Reasons for exclusion include alleged missed deadlines for formally filing an interest in the FAR 150 program, and community location outside of the probable 65 dB DNL contour. Attempts to exclude concerned communities only bring bad feeling and threats of legal action, which are the actions the FAR 150 study attempts to prevent. 122

Kathleen Wortel, Mayor and Pat R. Danial, Village Trustee and Chairman, Blue Ribbon Committee - Airport Issues, Village of Noah Syracuse, NY

Recommendation I: Residents of neighborhoods experiencing airport noise problems should be made to feel that their participation in the FAA noise study will be meaningful, worthwhile, seriously considered.

From the outset, we would like you to be aware of the rather unique -- and vulnerable -- position in which neighbors of Hancock Airport find themselves. The airport is owned and operated by the City of Syracuse; however, it is located in the county. As a result, the elected city officials who control the airport are not accountable in any way to the people who are affected by the airport and are not, therefore, as responsive or sensitive to the fights, needs, and concerns of residents as they might be if we were their constituents.

...Not one recommendation not already suggested by the city and its consultants was contained in its final report -- at least to the extent that it was suggested but then, for explained reasons, rejected. l23

Francis P. Kulka, Senior Airport Planner, Calocerinos & Spina Engineers, P.C., (consultants for Syracuse Part 150 study) Liverpool, NY

... the Part 150 programs lacks credibility not technical or programmatic procedures. Consequently, looking to improve or provide uniform formats, "report cards" and other review procedures, in my opinion, misses the point of the program and the problem, we have become technical pharisees. The problem rests with finding acceptable and effective public participation measures in those instances where jurisdictions overlap, extend beyond municipal boundaries and accountability for abatement lies in indirect or judicial remedies of little use to any one.l24

Len Oebser, Citizen's Alternative to Sea-Tac Expansion, WA

The FAA and airports must assume more responsibility than at present regarding these peak noises that emanate from aircraft to those communities adjacent to airports. The FAA must redefine, in my mind, what a healthy environment is in terms of noise, and be responsive to those people who are in this environment because of jet airplane activity. l25

Charles Barb, Mercer Island City Council, WA

But the public is skeptical of the institutions that they have been dealing with. Appreciate the skepticism -- and I guess that's a flattering word -- that the public has toward the FAA as the result of the mediation process.l26

Laurene McLane, private citizen, Seattle, WA

I think it the mediation process at SEATAC was an absolute public relations triumph for the Port of Seattle, and for the airlines, and for the air carriers. An absolute public relations coup.

For the rest of us, with the exception of the Part 150, it was largely a hollow and irrelevant exercise. And the reason for that was that, although we all entered this really in good faith, and we started off like the beginning of George Orwell's Animal Farm, where this was going to be the society that was going to be perfect. We soon found out that some pigs are more equal than others. And those pigs were the FAA, the Port of Seattle, the air carriers, the freight, air freight, and the pilots. And the rest of us, we could talk all we wanted about noise, but those certain powers, those superpigs, made it absolutely clear that there were two non-negotiable items, and the two non-negotiable items that made all the difference were flight tracks and scheduling. It was not convenient or profitable to any of those superpigs to deal with that at all. That was off the docket.

And so we were hamstrung at that point to deal with very minor things. And the lesson that I take from this, that I hope the FAA on a national scale will address, is that if you do not deal with flight tracks, and you do not deal with scheduling, which you have a lot of room to manipulate, then it's going to be an incomplete and inadequate noise policy that is simply going to address only the noise that individual planes make. Because a lot of us in the Seattle area that participated in the mediation came out with more noise than we dreamed possible because flight tracks were not included. 127

Dale E. McDaniel, Deputy Assistant Administrator for Policy, Planning and International Aviation, FAA

Two things happened with regard to aviation noise. One is physical, and the other is psychological. People react individually to the physical events of noise somewhat in different ways. It's more annoying to some than to others. They also react to the psychology of why they think the noise is happening, and I believe you touched on this. If they believe that the noise is for a good purpose and if people understand and care about their reaction to noise, they are far more tolerant then if they think someone is not paying attention and noise is being foisted upon them without recourse. 128

Congressman C. Thomas McMillen, Maryland

Last week at another hearing on this same issue I asked Mr. McDaniel of the FAA if the FAA had ever gone into any airport anywhere in the country, to evaluate their noise abatement plans. He told me no. 129

George Conklin, Raleigh-Durham Noise Abatement Committee member, NC

The rules proposed under the noise and approval of airport noise and access restrictions may seem to airline operators as a gift from heaven, the unmitigated fight to lay down noise without regulation. But such rules, especially in the long term, probably will do more harm than good to our air transportation industry. The public will respond by opposing airport expansion.130

2.6 Summary

The comments cited above come from all regions of the country - Mid-Atlantic, Southeast, South, Midwest, Southwest, West, even Alaska. Dozens of volunteer, spontaneously formed ad hoc citizen groups have formed to respond to their aircraft noise problems even to create national coalitions. Airport operators ranging from major hubs to general aviation facilities recognize deficiencies in the current approaches. Surprisingly, even a number of consultants with extensive experience in the field, offer numerous frank suggestions and comments. It is clear that these comments represent the heartfelt feelings and observations of substantial elements of their communities. To ignore these concerns renders harm to the fabric of our representative government and the social contract which underlies it.

A number of questions were raised at the beginning of this paper. We have found that there is some basic misunderstanding of what DNL represents. The people who do understand its definition frequently take issue with either the reasonableness of the approach for representing human responses and/or the application of the threshold criteria of 65 dBA. There are many calls for incorporating criteria which account for the following factors:

A range of health concerns beyond just hearing loss were raised including air pollution, odors, effects of pollutants on plants including food and property, stress related diseases including cardiovascular effects, mental health, pulmonary functions, fetal development, carcinogenic properties of exhausts. There is a mixture of both documented and unknown concerns.

Finally an aggravating and underlying factor is the attitude and responsiveness of governmental authorities to the plight of these citizens and residents. The FAA receives few compliments for the role that their air traffic and headquarters personnel take while their local representatives are seen at best as observers to the local efforts at noise mitigation. The patterns of denial, obfuscation, delay, stonewalling, and total disregard for environmental noise impacts is repeated from coast to coast underlying the need for altered attitudes as well as technical procedures and processes.

4.0 References

1. Senator Bill Bradley, statement before Subcommittee on Aviation of the Committee on Public Works and Transportation, House of Representatives, 101st Congress, Second Session, September 25, 1990, U.S. Government Printing Office, Washington: 1991 (101-86), pg14.

2. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p25

3. FAA Docket 25660.

4. FAA Docket 25660.

5. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p31

4. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p81

5. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p114

6. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p126

7. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p187

8. FAA Docket 25660.

9. FAA Docket 25660.

10. FAA Docket 25660.

11. FAA Airport Noise Control Public Meeting, March 6, 1991, Alexandria, VA, p267-268

12. FAA Docket 25660.

13. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p46

14. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p90

12. FAA Airport Noise Control Public Meeting, March 12, 1991, Rosemont, IL, p301

13. FAA Docket 25660.

14. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p46-47

15. FAA Docket 25660.

16. FAA Docket 25660.

17. FAA Docket 25660.

18. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p179

19. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p210

20. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p221

21. FAA Docket 25660.

22. FAA Docket 25660.

23. FAA Docket 25660.

24. FAA Docket 25660.

25. FAA Docket 25660.

26. FAA Docket 26433.

27. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p241-242

28. FAA Docket 25660.

29. FAA Docket 25660.

30. FAA Docket 25660.

31. FAA Docket 25660.

32. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p8-9

33. FAA Docket 25660.

34. FAA Docket 25660.

35. FAA Docket 26433.

36. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p20

37. FAA Docket 25660.

38. FAA Docket 25660.

39. FAA Docket 25660.

41. FAA Docket 26433.

42. FAA Docket 26433.

43. FAA Docket 25660.


45. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p31

46. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p75

47. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p84

48. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p121

49. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p129-132

50. FAA Docket 26433.

51. FAA Docket 25660.

52. HR 101-86 p50

53. Apogee Research, Inc. "Dallas-Fort Worth Airport Noise Study: Survey Results", November 1990 for Cutler & Standfield, Washington, D.C.

54. HR 101-86 p58-59

55. HR 101-86 p747

56. HR 101-86 p313-314, 316

57. FAA Docket 25660.

58. FAA Docket 25660.

59. HR 101-86 p62

60. HR 101-86 p83

61. HR 101-86 p814

62. HR 101-86 p61

63. HR 101-86 p825

64. HR 101-86 p826

65. HR 101-86 p818

66. HR 101-86 p829

67. FAA Docket 25660

68. FAA Docket 25660

69. FAA Docket 25660

70. FAA Docket 25660

71. FAA Docket 25660

72. FAA Docket 25660

73. FAA Docket 25660

74. Apogee Research, Inc., Dallas-Fort Worth Airport Noise Study: Survey Results, November 1990, for Cutler & Stanford

75. FAA Docket 25660

76. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p35

77. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p84

78. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p201

79. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p79

80. FAA Airport Noise Control Public Meeting, March 12, 1991, Rosemont, IL, p96

81. FAA Airport Noise Control Public Meeting, March 12, 1991, Rosemont, IL, p333

82. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p49

83. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p91

84. FAA Airport Noise Control Public Meeting, March 14, 1991, Seattle, WA, p223

85. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p80-81

86. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p109

87. FAA Airport Noise Control Public Meeting, March 6, 1991, Alexandria, VA, p318

88. HR 101-86 p814

89. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p97

90. HR 101-86 p829

91. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p65

92. HR 101-86 p820

93. HR 101-86 p822

94. HR 101-86 p830

95. HR 101-86 p832

96. FAA Docket 25660

97. HR 101-86 p59

98. HR 101-86 p61

99. FAA Docket 25660

100. HR 101-86 p64

101. HR 101-86 p66-67

102. HR 101-86 p68

103. HR 101-86 p84

104. HR 101-86 p99

105. FAA Airport Noise Control Public Meeting, March 14, Seattle, WA, p190

106. HR 101-86 p105

107. HR 101-86 p829

108. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p25

109. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p85-90

110. FAA Airport Noise Control Public Meeting, March 6, 1991, Alexandria, VA, p113

111. FAA Airport Noise Control Public Meeting, March 6, 1991, Alexandria, VA, p199-204

112. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p34

113. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p51

114. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p105-106

115. FAA Airport Noise Control Public Meeting, March 11, 1991, Rosemont, IL, p112-117

116. FAA Airport Noise Control Public Meeting, March 14, Seattle, WA, p43

117. FAA Airport Noise Control Public Meeting, March 14, Seattle, WA, p83

118. FAA Airport Noise Control Public Meeting, March 14, Seattle, WA, p85-92

119. FAA Airport Noise Control Public Meeting, March 14, Seattle, WA, p191

120. FAA Docket 25660

121. FAA Docket 25660

122. FAA Docket 25660

123. FAA Docket 25660

124. FAA Docket 25660

125. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p87

126. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p118

127. FAA Airport Noise Control Public Meeting, March 15, 1991, Seattle, WA, p157-159

128. HR 101-86 p560

129. HR 101-86 p746

130. FAA Airport Noise Control Public Meeting, March 5, 1991, Alexandria, VA, p71

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