Submit Comments on Civil Aviation Noise Policy to the Federal Register
On September 14, 2023, David and Miki Barnes filed comments on the Federal Register Civil Aviation Noise Policy regarding the adverse impacts of aviation activity on Washington County residents. It appears in its entirety below. In addition, it is available at this link.
Earlier this year, the deadline for submitting public comment was extended from July 31 to September 29, 2023.
Fourteen days remain for making your voice heard on how aviation noise is impacting you. To submit a comment electronically click here. Identify the docket number in your submission – FAA-2023-0855.
The Federal Register on this action including instructions for submitting comments by mail, fax, and hand delivery is available here.
Date: September 14, 2023
To: Federal Register docket FAA-2023-0855
From: Miki and David Barnes
This comment includes eleven FlightRadar24 screenshots showing aircraft targeting our home and the surrounding community. All depart from and return to the Port of Portland owned and operated Hillsboro Airport (HIO), a publicly subsidized facility that caters primarily to private pilots and hobbyists as well as flight training schools. Hillsboro Aero Academy, ATP, and Hagele Aviation are the primary schools that offer pilot instruction at HIO. They are essentially businesses that profit from pelting residents and wildlife with a steady barrage of noise, lead emissions, PM2.5, CO2 and a host of other carcinogenic pollutants on a daily basis.
Most users of HIO seem to feel entitled to exploit and bombard local residents with relentless noise while giving no consideration whatsoever to the local population. Moreover, for the most part, impacted residents are entirely excluded from the decision-making process.
Port of Portland statistics indicate that in the first 6 months of 2023, HIO logged 91,550 operations, on average more than 500 take-offs and landings per day. The majority are instructional flights which often engage in touch and go exercises and other repetitive training activities farther from the airport. These flights often go on for an hour or more before returning to the same airport they departed from.
One of the biggest offenders is HIO tenant Hillsboro Aero Academy (HAA), a flight school owned by two East Coast investment firms – Graycliff Partners and Renovus Capital. This company primarily serves foreign governments. According to HAA's website, of their 14 industry partners, eight are Asian airlines (six Chinese, one Korean, and one Japanese). Three – ADAC, Bristow, and babcock – are based in Europe. One of babcock's specializations is working with the United Kingdom Ministry of Defense. The remaining three industry partners – Alaska, Horizon and Ameriflight hearken from out of state. Regarding the nine collegiate partnerships, more than half are from the Asian Pacific region.
Similarly, ATP aircraft are registered to an address located at 251 Little Falls Dr. in Wilmington, Delaware. This company also offers flight training out of the Hillsboro Airport.
Background
Twenty years ago, we made a decision to leave our home in Portland in an effort to escape the noise and pollution generated by the Portland International Airport (PDX). Prior to our move, we consulted with the Port Noise Office. Due to a history of multiple noise complaints logged while living at our previous home, the Port was well aware that we were seeking a quiet location. We were told at the time that we might be subjected to overflights from aircraft flying to and from the coast but there was no mention of any plans to turn Western Washington County into an intensive flight training area for training pilots on behalf of the People's Republic of China and other countries that place restrictions and limitations on instructional flights in their own countries.
Our current home is in a rural-woodland low ambient noise area 25 miles from PDX and 12 miles from the Hillsboro Airport. Since we value the beauty and quietude of the natural environment, we made a conscious choice not to live next to an airport. Yet flight students and private pilots intentionally spew their toxic noise and emissions over our home on a routine basis. The screenshots below are examples of the type of aviation activity we are subjected to, often multiple times daily.
Flight Training Screenshots
The screenshots included in this comment represent but a miniscule sampling of air traffic over the area. Similar repetitive and relentless noise intrusions occur hundreds of times each day often overlapping with each other. As noted earlier, HIO averages 500 operations per day. In addition, residents are subjected to air traffic noise from neighboring airports. There are five public airports within 22 miles of HIO, including Portland International. Multiple private airports and airstrips located in Washington County, Oregon, and the surrounding area also contribute to the noise and pollution burden.
This screenshot was captured at 11:34 am on 9/12/2023. The flight track was produced by a single aircraft, N49194, registered to Hillsboro Aero Academy. The aircraft had been releasing noise and noxious pollutants as it looped and circled repetitively over homes, neighborhoods, wildlife and farmland for 58 minutes when this picture was taken.
The screenshot below shows Hillsboro Aero Academy flight N64942. The aircraft had been in the air flying repetitively over our home and the surrounding community for over an hour on Sunday, 8/27/2023, when this picture was taken at 12:06 pm. It was but one of a number of aircraft that targeted our home that morning. When filing this particular complaint, we asked the Port noise office to log seven separate noise complaints, one for each individual flyover.
The next screenshot was captured at 2:51 pm on 8/25/2023 after the aircraft had been in the air for over an hour flying repeatedly over our home and the surrounding area. The flight track was generated by a single aircraft, N14SK, registered to Hillsboro Aero Academy.
Following the aerial assault discussed in the previous screenshot another Hillsboro Aero Academy aircraft N48521 flew multiple times over our home. The aircraft had been in the air for more than an hour when the screenshot below was captured on 8/25/2023 at 3:59 pm.
The screen shot below of Hillsboro Aero Academy flight N6605P flying over our home also occurred on 8/25/2023. This aircraft had been in the air for 53 minutes when this screenshot was captured at 6:57 pm.
The next flight track was produced by a single aircraft on the morning of 8/11/2023. It was captured at 9:17 am after the pilot had spent more than an hour menacing the skies, degrading livability, and poisoning the environment. The aircraft N89312 is registered to Hillsboro Aero Academy.
This screenshot below of N867LA from 7/11/2023 shows a flight track produced by an aircraft registered to Hillsboro Aero Academy. It was captured at 3:24 pm after the flight had been looping and circling over the area for more than an hour.
This flight track below, produced by Hillsboro Aero Academy flight N25221 on 7/11/2023, had been in the air for one hour and 25 minutes when this screenshot was captured at 4:15 pm.
In addition to ongoing aerial assaults at a distance from HIO, residential communities close in to the airport are subjected to low flying, noisy and toxic aircraft engaged in touch and go training maneuvers often at altitudes well under 1000 ft. These occur 100's of times per day. Bear in mind that 15 schools, serving over 51% of the Hillsboro School Districts total enrollment, are located within a two to four mile radius of this airport.
The next two screenshots were captured on 9/13/2023. They both involve aircraft registered to Hillsboro Aero Academy. N48868 had been practicing touch and go maneuvers for over an hour when this screenshot was captured at 12:58 pm on 9/13/2023. Between 11:52 am and 12:58 pm, this low flying aircraft circled nearby residential communities at least 13 times.
A second Hillsboro Aero Academy aircraft was also practicing touch and go's around this time. N49824 had circled at low altitude over the same general area multiple times between 12:14 and 1:17pm when this screenshot was captured. These two aircraft combined were responsible for more than 20 circuits over nearby neighborhoods during an 85-minute interval.
This final screenshot shows the extent to which neighboring towns and rural communities, that are systematically denied a voice in the process, are flagrantly exploited and adversely impacted by HIO aviation activity. Hillsboro Aero Academy flight N5265L had been in the air for close to an hour and a half when this screenshot was captured at 10:30 am on 9/13/2023.
Harmful Effects of Aircraft Noise
This excerpt from pages 20-21 of the Town of Middleton, Wisconsin Board of Supervisors Federal Register Noise docket submission addresses some of the negative impacts of aircraft noise. See Regulations.gov.
"Aircraft noise exposure is an environmental stressor and has been linked to various adverse health outcomes, such as annoyance, sleep disturbance, and cardiovascular diseases. Aircraft noise can trigger both psychological (annoyance and disturbance) and physiological stress responses (e.g. activation of the cardiovascular system and release of stress hormones)...constant exposure to aircraft noise can cause a continuous state of stress."
These adverse aircraft noise impacts are relevant for the general population, but also vulnerable groups such as children and the elderly. (Benz, S., Kuhlmann, J., Jeram, S., Bartels, S., Ohlenforst, B., Schreckenberg, D. (2022). Impact of Aircraft Noise on Health. In: Leylekian, L., Covrig, A., Maximova, A. (eds) Aviation Noise Impact Management. Springer, Cham. https://doi.org/10.1007/978-3-030-91194-2_7, Abstract.
A review of the current state of scientific knowledge regarding the adverse effects of aircraft noise emissions on the public can be found at: Noise Health, 2017 Mar-Apr; 19(87); 41-50, at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5437751/.
An informative chart titled the Physical Manifestations of Noise Stress can be found at https://www.healthline.com/health-news/loud-noises-bad-for-your-health and lists the following adverse impacts of noise stress as follows:
- Delayed cognitive development in children
- Psychological triggers for individuals with PTSD
- Lower threshold for noise resulting in sleep disturbance
- Increased heartrate
- Changes in immune system
- Anxiety
- Annoyance, mood shifts
- Elevation of cortisol production
- Hypertension
- Myocardial infarction
- Vasoconstriction
- Elevated blood pressure
- Elevated adrenaline levels
In contrast, the health benefits of silence can include:
- Lowering blood pressure
- Improving concentration and focus
- Calming racing thoughts
- Stimulating brain growth
- Reducing cortisol
- Stimulating creativity
- Improving insomnia
- Encouraging mindfulness
We support the submission by Daniel Fink MD in his Federal Register comments on behalf of the Quiet Coalition (see Regulations.gov). The quotes below speak directly to the damaging effects of noise on human health.
The FAA is clearly endangering the health of Americans exposed to unsafe levels of aviation noise. The FAA must recognize and acknowledge that it is knowingly endangering the health of Americans exposed to aviation noise and must take action to protect the health of the America public. The FAA's stated mission, "to provide the safest, most efficient aerospace system in the world," must be extended to those living near airports or under aircraft flight paths, to provide them safety from dangerous aviation noise exposure.
He further explains the link between aircraft noise and the stress response,
A review of the literature on stress and the adverse health effects of aviation noise allows one to make a direct connection between the FAA's annoyance metrics and the adverse effects of aviation noise, which include increases in adverse physiological measures (e.g., blood pressure and stress hormone levels) and increased cardiovascular mortality. These associations are now thought to meet the Bradford Hill criteria for causality10 and are no longer mere statistical associations or correlations...The question is no longer whether noise causes cardiovascular diseases; it is rather to what extent. [Emphasis added.]
Unfortunately, the adverse impacts of aviation are not limited to noise. Among 20,000 airports, HIO is the 8th largest source of lead emissions nationwide. In addition, it is a significant source of PM2.5, benzene and host of other carcinogenic toxins. Due to these serious health effects, it is incumbent upon the FAA and the federal government to take immediate steps to substantially reduce air traffic in Washington County, Oregon, and other communities across the country. Current unjust, unfair, undemocratic, and unsustainable FAA policies that allow pilots and aviation businesses to target and exploit local communities for personal gain place an undue burden on impacted residents. Local communities should be empowered to establish legally enforceable regulations to protect themselves, their families and their neighbors from the extensive damage to livability, the environment and biological diversity caused by aviation activity.
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