Sign on in Support of Aviation-Impacted Communities Alliance (AICA) Federal Register Comments

September 20, 2023

The deadline is September 29, 2023 at 11:59 ET.

The mission of Aviation-Impacted Communities Alliance (AICA) is "to protect communities from harmful levels of aviation noise and emissions through selective projects for changes in legislation and industry practices in the United States." Over 70 community organizations throughout the U.S., including Oregon Aviation Watch, have supported AICA projects.

AICA submitted extensive, detailed comments in response to the Federal Register Notice on the Civil Aviation Noise Policy Review. To access these comments click here. So far more than 100 groups and individuals have expressed their support.

As pointed out by AICA, "The current FAA noise policy dates to the early 1970's. It does not capture the persistent overflights from the FAA's new GPS navigation and concentrated flight paths in what the FAA calls "overflight communities". It does not capture the unique disturbances from flight schools, helicopters, nor the emerging technologies like drones and air taxis. Because of intense pressure from communities from across the country, the FAA has started a process to update its aviation noise policies."

Below are a few excerpts from AICA's well-researched, highly informed, solution-oriented Federal Register submission.

"Use ambient noise, also referred to as background noise, to identify aviation noise events. Ambient noise which is the typical average noise in a community without the noise caused by air vehicles. Noise events that exceed ambient noise disturb people." (Pg. 3)

"Require and include aviation noise measures from all sources for decision-making purposes, total noise impacts. "All sources" means all air vehicle types, from commercial, general, and military aviation, for all procedures and vectors, to and from multiple origins and destinations, and all phases of operations (takeoff, landing, etc. and including elements of aircraft operations like continuous flight training maneuvers, hovering, and VTOL) instead of limiting the assessment to one procedure to or from one airport at a time or one vehicle type." (Pg. 3)

"For those in the vicinity of airports, the DNL threshold should be lowered to DNL 55 for land-use, NEPA, and for soundproofing or economic mitigation eligibility." (Pg. 4)

"The current policy of metrics and thresholds used for decision-making does not capture the negative health and quality of life impact-factors from NextGen's high volume and concentration low altitude aircraft. Many GA and commercial vehicle overflight communities are impacted by more than one airport, multiple routes, multiple vehicle types, and different elements of aircraft operations. Commercial vehicle overflight communities are also concerned about multiple procedures and vectors. Therefore, the total noise impacts should be assessed..." (Pg. 5)

"Nighttime penalties should be revised to reflect the substantial noise impacts of nighttime flights. It is likely the current penalties are insufficient." (Pg. 7)

"Communities are concerned about the premature rollout of UAS [drones] or other newly emerging technology operations before a new noise policy is available and that addresses the true impacts to communities...State and local governments laws should control, within their boundaries, all aspects of AAM [Advanced Air Mobility] that create noise impacts including locations of flights, low altitude airspace, land use, infrastructure, and aircraft operations... The evaluation and decision-making for environmental impacts, including AAM, should relate to and represent the layperson's lived experience...Community as a key stakeholder should be included early and in all high-level activities of the AAM Integrated Master Schedule." (Pg. 8)

"DNL is a statistically invalid metric for assessing aviation noise annoyance...the metric does not capture the variation in noise, which is what people react to. It does not report the frequency of events nor the change from ambient levels. The DNL metric does not adequately represent the noise impacts for overflight communities (GA, Commercial, and future AAM) who experience numerous and frequent flights, sometimes less than 90 seconds apart...Its calculation averages over multiple factors (noise, intensity, number of noise events, time, seasons, temperature, and aircraft type), allowing the same value to represent locations with large differences of sound intensity, weather, the number of noise events and aircraft types. (Pg. 9-10)

"Although the FAA noise policy is limited to Civil Aviation, the impacts of military air vehicles, including any space operations, should be counted when evaluating the total impact on communities." (Pg. 13)

"GA [General Aviation] impacts should be analyzed to understand how various vehicle types or elements of aircraft operations (e.g., hovering, continuous flight training maneuvers with multiple aircraft) affect communities experience. Penalties could be considered based on the analyses of the measured noise experience in GA environments. If insufficient data is available to determine the noise experience, then the data should be collected." (Pg. 14)

"The FAA does not have the expertise to develop a noise policy that captures the impact of aviation noise (and pollution) on the public's health. Health experts should address the Noise Policy Review health questions. An independent, unbiased, and peer-reviewed consensus report should be commissioned from the National Academies Division of Medicine on aviation impacts on public health. Congressman Lynch's Air Traffic Noise and Pollution Expert Consensus Act, H.R.2562 addresses this." (Pg. 22)

Click here to access the 32 page submission in its entirety.


FAA NOISE POLICY REVIEW INSTRUCTIONS FOR COMMENT

Deadline September 29, 2023, 11:59 ET

CLICK HERE FOR COMMENT PORTAL https://www.regulations.gov/commenton/FAA-2023-0855-0001

Fill in all fields on the comment portal:

  1. Write a Comment – See Comment Options below.
  2. What is your comment about? – Click on the dropdown menu, click Public Comment(s).
  3. Upload File(s) – Ignore this field unless you have a document you want to upload.
  4. Email – Add your email address.
    • Check the box – "opt to receive email confirmation of submission and tracking number?"
    • Note that your email will not be posted publicly.
  5. Tell us about yourself! I am...
    • Click "An Organization" for your group or "An Individual" or "Anonymous". Using anonymous will not include the entity associated with the comment or city/state.
    • Fill in the required fields of First Name and Last Name (or just your last initial if you want to maintain your privacy).
    • If not "Anonymous", fill in your city and state as the FAA will use this information to summarize the source of comments.
    • Do not add your phone number.
  6. Check the box: "I read and understand the statement above."
  7. Click "SUBMIT COMMENT"

Note: The extended deadline is Sept. 29, 2023. Please ignore if the previous deadline of July 31, 2023 is listed.

TWO SENTENCE AICA COMMENT

COPY/PASTE AICA COMMENT BELOW (TWO SENTENCES) INTO COMMENT PORTAL

  • Add your own text if desired in addition to the AICA two sentences below. There is a character limit (~4900 with spaces) in the form field.
  • The AICA posted comment document is 32 pages, all you need to do is reference it by its Comment ID number (see two sentences below), you don't need to attach it.

HERE ARE THE TWO SENTENCES FOR AICA COMMENT - COPY/PASTE ENTIRE AICA COMMENT BELOW INTO COMMENT PORTAL

This comment is in addition to any previous comments.

We support the Aviation-Impacted Communities Alliance (AICA), Comment ID FAA-2023-0855-2206.

The section below is from Quiet Communities, a 501(c)(3) organization "dedicated to helping communities reduce health and environmental harm from noise and pollution." Please consider becoming a member and supporting this important advocacy organization.


Important: Share Your Aviation Stories with the FAA – There is Still Time!

Please let the FAA know how aviation noise is affecting you and your family's mental health, quality of life, learning, and productivity.

The FAA is under pressure to update its noise policies and has clearly stated that it will use the information received through public comments to inform its updated noise policy and metrics for determining "significant impact" and appropriate land use going forward. It is crucial to share your personal "lived experience."

The FAA states that "a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making." Here are some details to include:

Characterize the problem:

  • Types and number of flights (general aviation, commercial jets, helicopters, private jets, etc.)
  • Proximity to airport
  • Times of day of flights (day, night)
  • Frequency of flights (how many per day and how many per hour, particularly during the busiest times)
  • Experience of noise inside the home as well as outdoors
  • Concerns about emerging aircraft (e.g., drones, air taxis)

Describe the Impacts on you, your family, your neighborhood - BE SPECIFIC

  • Sleep interruption and/or disruption
  • Physical and mental health and well-being
  • Emotional impacts
  • Work, learning, concentrating
  • Effects on children – their ability to learn, concentrate, play
  • Optional: Is the average annual sound level of 65 decibels (DNL 65) sufficient to protect you from the impacts you experience?

If you have tried to complain or get help:

  • What has been the response?
  • Was the response helpful?
  • How did it make you feel?
  • What would you like to see done to mitigate the problem?

EXTREMELY IMPORTANT: Conclude by stating that you hope and expect the FAA will adopt a new noise policy and new metrics that protect overflown communities and near-airport communities from harm based on the lived experience of people like you!

The DEADLINE to send your comment is September 29, 2023 at 11:59 PM ET.

Here's how to submit comments:

  • Online: https://www.regulations.gov/commenton/FAA-2023-0855-0001
  • Mail to: Docket Operations, M–30; U.S. Department of Transportation (DOT), 1200 New Jersey Avenue SE, Room W12–140, West Building Ground Floor, Washington, DC 20590–0001
  • Fax to: Docket Operations at 202–493–2251

Make sure your submission includes Docket Number FAA–2023–0855.

An article on AICA's submission, UPDATED NOISE POLICY SHOULD INCLUDE NEXT-GEN IMPACTS, NEW ANNOYANCE DATA by Anne Kohut was published in the Airport Noise Report newsletter on 9/15/2023.

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