Subject: Failure of FAA to follow NEPA procedures – SDIA

Updated: Mar 19

16 March 2020


Federal Aviation Administration, Aviation Noise Ombudsman, AEE-2 800 Independence Ave., SW Washington, DC 20591


Dear FAA Western pacific Ombudsman:


I believe that there is strong evidence that the FAA and the San Diego County Airport Authority as well as some City of San Diego Officials have violated the spirit of NEPA, if not NEPA requirements, at San Diego International Airport. The first violation came decades ago when all post 10 pm departures were moved from the 275-degrees vector to 290-degrees vector. The second violation is associated with a change for all post 10 pm departures currently on the 290-degree departure track to move to the PADRZ SID.


There are three main runway 27 departures (lines shown in the Google Earth picture) ZZOOO (275 degrees straight out), PADRZ (turn to WNFLD after reaching 520 feet) and the post 10 pm nighttime noise abatement procedure are shown in Figure 1. ZZOOO is a 275 degree departure, PADRZ is a satellite navigation departure with nominally a turn to 295 degrees, and the nighttime noise abatement agreement is a 290 degree vector departure. The top white line shows an actual PADRZ SID departure crossing over the WNFLD waypoint off-shore. The second line down is an aircraft track on the 290-degree nighttime noise abatement agreement departure track. Note on this departure track, the aircraft flies very close to noise dot 2 off the coast. The bottom red line is a 275 vector used currently by the ZZOOO departure SID.


In 2017, the FAA implemented the PADRZ SID over Mission Beach and the ZZOOO SID over Pt. Loma and Ocean Beach. Prior to implementation of PADRZ, the departures on the 293 degree vector were more fanned out, resulting in less noise concentration on a smaller area of South mission Beach. Prior to the implementation of NexGen, the number of noise complaints from the Mission Beach community was very small; however, since then the number has increased dramatically to almost five thousand per week from about 35 households. As you can see from Figure 3, the majority of the complaints are early in the morning and at night.


As mentioned above, several decades ago, aircraft flying out on the 275 degree heading were redirected to the 290 degree heading post ten pm. There is no documentation supporting this move. It appears, although there is no direct evidence of this, that local officials worked with Air Traffic Control (ATC) on a handshake agreement to make this move. While complaints from Pt. Loma and Ocean Beach residents may have been the catalyst, there is no evidence that any formal action associated with a NEPA was used to assess the move. The move clearly resulted in a dramatic shift of the nighttime noise from OB to Mission Beach. While it is likely that more people living in Pt. Loma and Ocean Beach benefited than were negatively impacted in Mission Beach, the absence of any analytical assessment using NEPA makes this move illegal. Let me state this again. Apparently, local authorities took it into their hands in violation of federal NEPA law and moved all aircraft post 10 pm from the 275 degree heading to 290 degrees, which resulted in a substantial noise increase for the residents of Mission Beach, and possibly Pacific Beach and parts of La Jolla.


The second issue raised above is the elimination of the 290 nighttime noise abatement agreement and moving of the aircraft post 10 pm from the 290 degree heading to PADRZ. When the NexGen was implemented in 2017, it increased noise in La Jolla, Pacific Beach, Mission Beach and Pacific Beach and in East County. As a result, the ANAC stood up a committee that identified 22 ways to mitigate noise resulting from NexGen.

Figure 1 Comparison of Runway 27 Departures

Figure 2 Weekly summary of noise complaints at SDIA


The second issue raised above is the elimination of the 290 nighttime noise abatement agreement and moving of all aircraft post 10 pm from the 290 degree heading to PADRZ. When the NexGen was implemented in 2017, it increased noise in La Jolla, Pacific Beach, Mission Beach and Pacific Beach and in East County. As a result, the ANAC stood up a committee that identified 22 ways to mitigate noise resulting from NexGen.


The SDCRAA formulated two programs, a Flight Procedures Analysis and Part 150 Study, to study the 22 recommendations, supported by two committees, the Technical Advisory Committee and the Citizens Advisory Committee. The TAC dealt with recommendations that impacted communities outside of the 65 dB CNEL and the CAC dealt with recommendations for areas within the 65 dB CNEL. A Part 150 was performed in concert with the second study. At no time did any of the recommendations include elimination of the nighttime noise abatement agreement. In fact, it was stated that there would be no changes to the nighttime agreement.


At some point, the pictures showing results of the Flight Procedures Analysis blurred the lines between the PADRZ and the 290 nighttime departure. The ANAC studies chart also made a conscious effort to blur the lines between the PADRZ and the 290. In the figure below, a number of blue lines that are clearly PADRZ and not the 290 degree departure. All departures on the 290 turn left and head south, so this picture is really screwed up and clearly trying unsuccessfully to make a point.


The ANAC bi-monthly reviews began including pictures of PADRZ annotated with 290 degrees. It became clear that the Airport Authority intended to move all of the nighttime departures onto PADRZ with the slight-of-hand being that 290 and PADRZ were synonymous.


At the March Symposium on Airport Noise and Emissions in San Diego, a class on NEPA was included that I attended. An outline of the NEPA process is shown below in Figure 3. One possibility that came out of questions at the symposium is that the FAA initiated a NEPA independent of the Flight Procedures and Part 150 studies. And that they decided after a preliminary assessment that the change was covered by a CATEX, or categorical exclusion.

There are two ways they could reach this conclusion:

1. They were told by the Airport Authority or surmised themselves that the 290 and PADRZ SID are one and the same up to the crossing of Mission Beach, or

2. They surmised that moving the aircraft from 290 to PADRZ would have ales than 1.5 dB effect on the 65 dB CNEL.


Figure 3 NEPA process overview


To pursue number 1 above would require a great leap of faith if one was to dive down into the data at all. The noise impact of moving the 15 to 20 aircraft that depart nightly on the 290 to destinations in the southwest, Midwest, and east, to PADRZ, which nominally have 2-4 flights nightly, will be huge.


And to the second point, it may be correct that the change from 290 to PADRZ does not change the 65 dB CNEL that much. But this is not the point. It does not appear that the FAA did any analysis; if they did in fact reach the conclusion to move 290 to PADRZ. This might be in part because if they showed that the change from 290 to PADRZ resulted in less than a 1.5 dB change in the CNEL, then maybe the change from PADRZ to the 290 using Noise Dot 2 as a flyover way point might also result in a less than 1.5 dB change.

In any case, we have not been able to find any reference to this potential change.



Figure 4 – SDIA 65 dB CNEL for 2018


Figure 5 puts the potential noise increase into perspective. If the change is made, then the number of departures flying directly over SMB will increase by a factor of about 5. To put the horizontal shift (moving departures north) into perspective, the 0.0 in this chart corresponds with the furthest tip of the Mission Beach peninsula at the southern end. The red dots are the 290 degree noise abatement departures, while the green dots are the PADRZ departures. There are several key points one can tell from the chart:

1. If the change is made, then all of the red dots will move over the green dots, resulting in many more departures over Mission Beach.

2. The red dots are at a lower altitude and therefore will be noisier.

3. The red dot aircraft are heading back to the southwest, Midwest east and south, meaning they are larger, heavier and noisier aircraft.


Making this change would be grossly unfair to the residents of Mission Beach and would violate the NEPA process.

Figure 5 Nighttime departures (post 10 pm) horizontal distance and altitude comparing the 290 nighttime noise abatement departure with the PADRZ departure.


CONCLUSIONS:

· The original move of the aircraft post 10 pm from the 275 to 290 degrees based on a nighttime noise abatement agreement did not follow NEPA procedures and therefore is illegal

· It is apparent that the FAA/Airport Authority are attempting to move the 290 degree nighttime departures to PADRZ

o What is unclear is the procedure or process they are using to do this, but

o It appears to be an illegal move

· There needs to be a meeting of the stakeholders to better understand what changes are contemplated for the nighttime noise abatement agreement

______________________________

Gary Wonacott g

Mission Beach Town Council

Chair, Airport Noise Committee

CC:

1. Congressman Scott Peters, 4350 Executive Drive, Suite 105,

1) Commissioner Greg Cox, County Administration Office 1600 Pacific Highway

San Diego, CA 92101

2) Mayor Kevin Faulconer, City Administration Bldg., 202 C. Street, 11th Floor, San Diego, CA 92101

3) Councilmember Jen Campbell, City Administration Building, 202 "C" Street, 10th Floor, San Diego, CA 92101 San Diego, CA 92121

4) Matt Gardner, President MBTC

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