Updated: Sep 25, 2020
19 September 2020
Pictures need to be added.
Mr. James Kosanovich
District – Airspace and Procedures
Los Angeles Air Route Traffic Control Center (ARTCC)
Subject: NexGen Aircraft Noise Studies, Flight Procedures Analyses and Part 150 Study at San Diego International Airport Dispute
Cc: Ms. S. Knack, Mr. D. Probst, Ms. D. Watkins, Mr. G. trolf, Mr. K. Mendenhall,
Dear Mr. Kosanovich:
Last June 19, 2019, you received an email message from Ms. Sjohnna Knack, Noise Abatement Manager at SAN. In this email, Ms. Knack comments that they at SAN have developed a similar procedure to BLBOA RNAV SID, that she believes reflects the requests from the communities surrounding the airport. With all due respect to Ms. Knack, I do not believe her statement is entirely accurate. Yes, there are communities that support what was proposed, but in fact, there is one segment, the initial leg in the PADRZ SID departure that is universally opposed by our community and by others to our north.
My name is Gary Wonacott. I am a long-time resident of Mission Beach and have served on the Mission Beach Town Council as President in the 2016-2018 time period. I have a BS in Aerospace Engr. and a MS in Engineering Mechanics, with thirty-five years of experience solving problems in several industries. The last twenty years I supported the Missile defense Agency developing advanced technologies. In 2002, I formed my own company, which was sold in 2018. Beginning in 2016, I became involved in the SDIA noise issues, at times taking contradictory positions with Ms. Knack and her staff.
I assume you are familiar with SAN, but briefly, there are three runway 27 departures shown in the picture:
a. Yellow corridor is the current ZZOOO SID showing the dispersion based on data available in the public domain (all of the corridors represent a two-sigma spread).
b. Red corridor that is the nighttime noise abatement agreement 290-degrees vector departure, with the red pin at the west end of the polygon showing the average position of the departures and the red polygon showing the dispersion, and
c. Green corridor that is the PADRZ SID with the green pin showing the average position of aircraft on PADRZ, and the green polygon showing the dispersion.
I have two concerns or areas of dispute:
1. Decades ago, the San Diego City Council proposed and the Port Authority supported, a move of all post 10 pm departures on the predecessor to ZZOOO be redirected to the 290-degree vector departure. This became a LOA held by the FAA/ATC; however, after many searches, there is no evidence that a NEPA assessment was performed. The NEPA environmental impact assessment would have rejected this move because of the substantial shift of noise from Ocean Beach to Mission Beach. This move in our minds was and still is illegal.
2. The latest proposal, the subject of the June 19, 2019 letter, moves all of the nighttime departures from the 290 to PADRZ. This will only exacerbate the disruption caused by these flights to the residents of Mission Beach. Mission Beach is not in the 65 dB CNEL, and therefore receives none of the benefits of the Quiet Home Program. Many of the current 290 nighttime departures are at less than 2,000 feet when they pass over Mission Beach (supporting data). The aircraft on the 290 that are headed east are some of the loudest of the day, since they are larger aircraft (A321 and B 737-800) filled with passengers and fuel.
Unfortunately, it gets worse. We have reviewed the Flight Procedures Analyses (FPA) in some detail and have found serious discrepancies with the input assumptions to the model. For example, rather than assume that the 290 degree vector departure and the PADRZ SID are on two distinct tracks, they were combined into one track, which is the baseline PADRZ track. This same assumption was also made for the Part 150 AEDT analyses.
One of the Part 150 options is to move PADRZ south so that the nominal track coincides with the lower blue line in the picture. So, the 290 departures were first moved up to coincide with the PADRZ green track, and then all of the departures were moved down to the blue track. Naturally, this resulted in a greater shift of the 65 dB CNEL south than if the 290 departures had not been moved up to PADRZ to establish the baseline.
The Mission Beach representative on the ANAC and the TAC is Debbie Watkins. Our representative on the Part 150 is Gernot Trolf. Ms. Watkins correctly questions Ms. Knack about the initial leg of PADRZ being used for the candidate nighttime alternative in her June 19 email to you. For several years, Ms. Knack claimed that all post 10 pm departures were on the 290 degree departure and that PADRZ is not used for post 10 pm departures. However, we have large amounts of public domain data that shows the opposite, that both the 290 and PADRZ are used.
I have also included a communication from Ms. Watkins opposing the recommended nighttime departures that use PADRZ as the initial leg, which she has distributed to the Mission Beach community. So, again, not all of the communities are on board with the Ms. Knack’s proposal. In fact, if the Airport Authority wants to explore the use of PADRZ for nighttime, then the correct assumption for the baseline condition should have nighttime departures with destinations east on ZZOOO and nighttime departures going north on PADRZ, since the 290 was never properly assessed in a NEPA in the first place. It does not legally exist as a procedure.
ITEM 2: GOOGLE EARTH PRO overview of current and proposed runway 27 departures.
ITEM 3 Email communications between Ms. Knack and Mr. Kosanovich, June 17, 2019
ITEM 4: Picture of preferred nighttime departure from airport authority consultants. Notice the comment that procedure would maintain existing PADRZ2 heading from takeoff.
In my career, I dealt with the government, mostly the Army Missile Defense Organization, for many years. I know that you do not have the time to go into depth on FPA and Part 150 studies and must rely on the Airport Authority and their consultants to provide accurate data and information to support their recommendations. I am sure that most times they do just that, but here we have a special case, one that was built on a political decision to move the post 10 pm departures, but not do the NEPA, instead to create a LOA, which has no legal basis. And now there is a double-down on the initial lie.
To their credit, the consultants did state what they were doing in a committee meeting attended by Ms. Watkins, but her questions were simply blown off. And the consultants did document their assumption to move the 290 to PADRZ in their final report, so it is very difficult for there to be any rationale disagreement with what I have outlined above.
In summary, the residents are opposed to moving the current 290 departures to PADRZ (we have a petition with over one-hundred signatures stating this point). And, there are alternatives that do not necessarily move all of the nighttime noise back to Ocean Beach (e.g., ALT 1B) in the Part 150 study. It’s just that the analysis needs to be corrected with the 290 and PADRZ on separate tracks for the baseline case. In fact, the residents are more than opposed; we outright reject any action that puts these very low flying, loud aircraft over our community, and we feel that we would prevail if this issue is not resolved.
Resident, Mission Beach
Sent: To: Cc: Subject: Importance: High DRAFT CAN YOU PLEASE REVIEW ASAP FOR ACCURACY? Amy/Brendan, Below is as short of a summary as I could make on what we have done for Flight Procedures and what we are currently working on. I had a conversation with Steve Smith who reminded me of one procedure that was “put on hold” based on the outcome of some analysis in the Part 150. This procedure could be the one that Tony is referring to, and I think it gives us a good “give” at this point. Let me know if you have any questions. What Have We Done? Flight Procedure Analysis Study – Procedures Outside the 65 dB Contour:
Requested FAA relocated Noise Dots #4 & #5 to avoid aircraft flying over the tip of the Point Loma Peninsula. Went to ANAC 6/19/19 for approval to send to FAA. Request letter sent to FAA on behalf of ANAC on 8/19/19, letter on our website here. FAA rejected the request on 11/5/19, letter can be found on our website here.
Requested FAA modify ZZOOO RNAV SID (one of the two main departures to the west out of SAN) – during daytime. This modification requests to move the JETTI waypoint further east so aircraft have to fly farther before turning left. Submitted in IFP Gateway (FAA) on behalf of ANAC on 8/19/19, request on our website here. We have checked in with the FAA (Brendan Reed) on a couple occasions to get an acknowledgement that it is currently in process of review.
What is in Process? Flight Procedure Analysis Study – Procedures Outside the 65 dB Contour: 1. Request to FAA to modify the PADRZ RNAV SID (the other main departure to the west out of SAN that flies to Northern or Eastern Destinations) – during the nighttime. This procedure turns aircraft after 1.5 NM to fly slightly to the south (increasing the distance between the aircraft and La Jolla) while maintaining the FAA Noise Dots. Current Status: ANAC/TAC/CAC agreed to hold this concept until other flight procedure concepts are addressed in the 14 CFR Part 150 process. The review of a nighttime noise abatement heading and departure noise abatement profile could lead to a change in the initial departure heading from the runway and impact the requested modification to the PADRZ RNAV SID. This request is on hold until the analysis of alternatives is done in the Part 150 study update. This analysis is anticipated to be completed this summer. NOTE: We could move forward with this modification, going to ANAC to request to submit to FAA in IFP Gateway. However, it will be at the initial departure heading.
What is in Process? 14 CFR Part 150 update – Procedures Inside the 65 dB Contour: 1. Request to FAA Create a new RNAV SID similar to ZZOOO RNAV SID – during the nighttime. Currently, aircraft filing the ZZOOO SID after 10PM are issued an amendment prior to departure. This amendment has them flying the 290 heading and then rejoining the SID. Sometimes when transferred to SOCAL TRACON, the controller “vectors” the aircraft or tells the pilot to fly to the next waypoint which can have the airplane flying a path that is different than the ZZOOO SID. This nighttime RNAV SID would mimic the same route as the daytime ZZOOO, Knack Sjohnna Friday, April 3, 2020 2:30 PM Stephen Smith (email@example.com) Payne Jim FW: Summary Points on Flight Procedures and Related Part 150 Elements that is currently in the IFP Gateway for a modification (see above). This procedure may decrease overflights over Point Loma and La Jolla, so long as the FAA keeps the aircraft on the published course. This request is currently being analyzed in the Part 150 study update. This analysis is anticipated to be completed this summer. 2. Additional alternatives including Nighttime Noise abatement Heading, Departure Noise Abatement Profile and modified departure heading to allow for decreased separation ‐ Equivalent Lateral Spacing Operations (ELSO) is currently being analyzed and results will be completed this summer.
Sjohnna Knack, Program Manager Airport Planning & Environmental Affairs (Aircraft Noise) San Diego International Airport Sknack@san.org I (619) 400‐2639