Aviation Noise Comment Deadline - 3/15/21

Miki Barnes
March 9, 2021

FAA Neighborhood Environmental Survey Finds Significant Increase in High Annoyance Levels in Response to Aviation Noise.

The Federal Aviation Administration (FAA) is requesting input on civil aircraft noise. Public comments, which are due on or before March 15, 2021, may help to shape future aviation noise policies. The docket number, FAA–2021–0037, must be cited with all submissions. Recommended comments to include are available at the end of this posting.

Relevant links:

Per the docket, "the Neighborhood Environmental Survey (NES) was conducted to create a new nationally representative dose-response curve to understand how community response to aircraft noise may have changed" since the last study was done. "The NES consisted of over 10,000 mail responses from residents in communities around 20 statistically representative airports across the Nation, making it the single largest survey of this type undertaken at one time. In addition to the mail responses, the consultants also conducted a follow-up phone survey, which included over 2,000 responses to a series of more detailed questions."

For the purposes of the study, "Annoyance is defined as a 'summary measure of the general adverse reaction of people to noise that causes interference with speech, sleep, the desire for a tranquil environment, and the ability to use the telephone, radio, or television satisfactorily.'"

Neighborhood Environmental Survey (NES) Findings

According to the Federal Register, "The NES results show a substantially higher percentage of people highly annoyed over the entire range of aircraft noise levels (i.e., from DNL 50 to 75 dB) at which the NES was conducted. This includes an increase in annoyance at lower noise levels. The NES results also show proportionally less change in annoyance from the lower noise levels to the higher noise levels.

As explained by the FAA, "A new National Curve was created by combining the Survey responses from the question on "Noise from Aircraft" with the modeled aircraft noise levels. Compared with the existing Schultz Curve, the new National Curve shows a substantial increase in the percentage of people who are highly annoyed by aircraft noise over the entire range of aircraft noise levels considered, including at lower noise levels.

 

Recommended Comments to Include in Submission

The following suggestions were prepared by Cindy L. Christiansen, Marie-Jo Fremont, Anne Hollander, Darlene Yaplee from the Aviation-Impacted Communities Alliance (AICA) info@AviationImpactedCommunities.org.

The FAA is asking for public comments on its recently released Neighborhood Environmental Survey (NES) by March 15th. You can submit multiple comments but need to state, "this is an additional comment and is not meant to replace my previous comment(s).

Below are recommended comments we hope everyone will make. We encourage as many people and groups as possible to submit comments that include these points. Some advocacy groups will use them to create a simple template for members to use. Others will use them to customize their own letters.

    1. The Neighborhood Environmental Survey (NES) is scientifically rigorous and represents reliable new evidence that must be incorporated into FAA aircraft noise policies.
    2. The NES results show that a much greater proportion of people are highly annoyed by aircraft noise across all levels of DNL than was previously thought. It does not show that people are more sensitive to noise than in the past.
    3. Previous studies (Schultz curve, FICON study) underestimated aircraft annoyance because they included all transportation noise (e.g. road and rail), and used a mix of older, less robust methodologies. The NES study is specifically about aircraft noise annoyance and uses state-of-the-art methodologies for its design and modeling.
    4. The NES results should trigger a sea change in aviation noise policy because they refute the long-standing Schultz curve and FICON which have been the foundations of existing aviation noise policy.
    5. The FAA has an ethical obligation to change regulations that are detrimental to the public, that are under its authority, and that do not require new legislation.
    6. The FAA should provide a timely roadmap for changing its noise regulations and use the NES results as the new basis for decision-making on community impacts, including in the FAA's Environmental Review Process and Part 150.
    7. The FAA should use additional, existing metrics, notably "N-Above," which counts the number of aviation noise events over a certain location and decibel level, to better reflect noise impacts on communities. New noise metrics do not have to be developed or researched before changing noise policy.

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