By Anthony Stiegler / La Jolla Light / July 28, 2020
This is an update about the “Part 150″ study on commercial jet noise associated with departures from San Diego International Airport. On July 20, La Jolla representatives submitted comments and their proposal for coastal community wide noise mitigation. These are the highlights:
Quiet Skies La Jolla retained aeronautical engineering and noise consulting firm ABCX2 to offer noise mitigation opinions and a report. The core recommendation is to implement the “ELSO” procedure (equivalent lateral spacing operations), alternating three departure paths to disperse noise and keep flights farther from our coast and over the ocean.
Four central design principles underly this proposal:
• Avoiding any negative impact on the airport’s operational throughput, capacity and safety concerns
• Dispersing noise and avoiding repetitive concentration over any single community
• Not shifting noise from one community to another
• Making effective use of the Pacific Ocean to minimize noise along the coast
ELSO is a new departure procedure enabled by the Federal Aviation Administration’s rollout of the NextGen Metroplex navigation system. Using this new satellite “performance-based navigation” technology allows planes to safely depart on the three course tracks (275, 285 and 295 degrees) and then fly farther offshore before picking up the next leg of their course.
The benefits to the coastal communities, including La Jolla, Pacific Beach, Mission Beach and Point Loma, would be substantial. For La Jolla, it would keep northbound flights about one mile farther offshore.
The full text of our comments and the ABCX2 report can be found on our website at quietskieslajolla.org/noise-mitigation.
There are other benefits to our proposal. ELSO is a preferred, safe and approved FAA solution leveraging the nationwide airspace benefits of NextGen, reducing fuel burn, taxi time and carbon dioxide emissions. The FAA’s air traffic control can implement it without additional workload. Analysis showed that Hartsfield-Jackson International Airport in Atlanta saved $20 million by implementing ELSO.
Modeling ELSO also will satisfy the FAA’s obligations under the FAA Reauthorization Act of 2018 to study noise mitigation solutions, and the FAA already has approved ELSO in official FAA “document changes” to its Air Traffic Control Handbook.
ELSO has been implemented in Atlanta and Detroit and soon will be in Fort Lauderdale and Miami. As the busiest single-runway airport in the United States, San Diego is a perfect candidate for ELSO. It is the state of the art and is consistent with our “smart growth” principle — facilitating economic growth (and now recovery) for San Diego tourism, business travel and airport operations while mitigating noise for the city’s residents.
CEQA litigation
The California Environmental Quality Act litigation is progressing, addressing whether the San Diego County Regional Airport Authority’s taxpayer-funded $3 billion expansion plan for Terminal 1 adequately disclosed the human health risks associated with jet noise.
The CEQA case challenges the airport authority’s assertion that more jet noise from additional flight operations is a “necessary but unavoidable” consequence. We say the airport authority is putting profit ahead of human health.
“Neighborhoods and people pay the price for increased jet noise with their health,” said Dr. Matthew Price, president of Quiet Skies La Jolla and an interventional cardiologist at Scripps Clinic and director of the cardiac catheterization laboratory at the Anderson Medical Pavilion at Scripps Memorial Hospital La Jolla. “Peer-reviewed studies have demonstrated clear associations between jet noise and stress, high blood pressure, stroke, heart failure and atherosclerosis, sleep disruptions, cognitive abilities, anxiety and depression. These are serious risks to human health which are made much worse by more noise.”
The COVID-19 coronavirus pandemic calls into question whether San Diego still needs 11 additional gates, since air traffic continues to be off by 75 percent to 80 percent compared with 2019. Airlines are experiencing extreme financial distress, receiving federal support, laying off employees, mothballing planes and being pessimistic about a return to pre-COVID operational levels for years. So why is the airport authority plowing ahead now with the gate expansion plan? We have suggested a litigation stay or to dismiss the litigation if the airport authority withdraws its gate expansion plan, but those proposals were rejected. So, litigate we must to protect La Jolla and the San Diego coastal communities from a return to the noise levels experienced in 2019 in the event air travel does return to pre-pandemic levels.
Quiet Skies San Diego is in favor of smart growth, economic recovery and expansion, putting the tourism industry back to work and a return to some semblance of normalcy. If updating Terminal 1 and adding more gates are necessary, do so with accompanying noise mitigation measures in our ELSO proposal.
For more information, visit quietskieslajolla.org or email info@quietskieslajolla.org.
Anthony Stiegler is co-founder and secretary of Quiet Skies La Jolla.
{ 16 comments… read them below or add one }
The Airport Authority Noise Abatement Office has frankly had its way with the communities over the last 30 years. The only way that this proposal and others, such as optimizing the thrust and altitude during takeoff, will move forward is if the coastal communities work together. The ELOS concept will result in an overall decrease in noise impact on the coastal communities, but we need to pull together to at least force the Airport Authority to perform the necessary analyses to confirm the proposal or at least determine which elements of the proposal make sense.
This article fails to mention that all the proposed departures actually fly straight into the heart of OB prior to shifting to one of the assigned routes making noise worse in the heart of OB. Comparing ELSO use at major airports with multiple runways is not really at good example of its possible success in San Diego.
Look at the current and proposed flight path the author of this article is pushing, directly from his website. He wants the flight path moved “1.5 miles south” DIRECTLY over central OB so it is further away from La Jolla.
https://quietskieslajolla.org/s/ABCx2-La-Jolla-Eval-180424-Corrected.pdf
Seems like the headline should be changed from:
“New Departure Procedure Would Provide Jet Noise Relief for Coastal Communities”
to
“New Departure Procedure Would Provide Jet Noise Relief for My Coastal Communitity, Sorry OB”
The “report” also has a gigantic lie in it, saying it would move it to “less populated” areas. OB is one of the most densely populated areas on the San Diego coast, while much of La Jolla’s coastline is spaced-out mansions. Another quote from the plan the author is pushing:
“this option places aircraft over areas not being currently overflown.” Yes, Anthony Stiegler, La Jolla resident, wants two new flight paths where none exist, one would cross over the beach directly above Long Branch and Spray, the other at Narragansett over the OB Pier.
The author of the article appears to be a corporate lawyer at a gigantic law firm called Cooley. Here’s the very first thing on the Cooley.com webpage:
“40% of the companies on the Wall Street Journal’s Billion Dollar Startup Club list use Cooley”
Why am I not surprised.
Well, with a name like “Quiet Skies LaJolla” they certainly have EVERYONE’S best interest at heart.
Right now this is a proposal that is looking at a variety of alternatives along with the airport authority. In 2016 and 2017, the FAA implemented their NexGen routes, ZZOOO and PADRZ, over OB and MB. In addition, they maintained the 290 nighttime departure procedure, which moved all departures post 10 pm from OB to MB. My investigation tells me this was not done legally, since it did not initiate a FAA NEPA assessment. Now in two studies to attempt to rectify the impact of the NexGen, the Airport Consultant appears to be moving the 290 departures to PADRZ, which is unacceptable to the residents of Mission Beach. The Airport Authority sensitive to this issue has proposed moving PADRZ 0.35 miles south of the peninsula to the 290 nominal route. The residents in OB have been pounded for years by the repeated overflights on the 275, NavGen departure ZZOOO. The La Jolla proposal would move have of those departures 10 degrees north, increasing noise in Mission Beach, Pacific Beach and to a lesser extent La Jolla, but would also move PADRZ south the 0.35 miles providing relief to Mission Beach, not La Jolla. La Jolla and everyone else primarily benefit by moving the north and south turn points for all aircraft farther out into the ocean. Would there be areas with increased noise. The Airport Authority proposes 2 departures PADRZ and ZZOOO while the La Jolla proposal suggests three departures, 275 (ZZOOO), a 285 (departs over Dog Beach), and the 295 (just south of the Mission Beach peninsula). While adding the third departure would increase noise in Mission Beach and certainly under the new 285 departure, it would (TBD) potentially reduce the size of the 65 dB CNEL currently projected to increase dramatically in the next 6-9 years depending on when the coronavirus impact on air traffic concludes. I would hope that the beach communities would together push the Airport Authority to continue with their assessment of all of these options and then we would have the information to make a rationale decision.
Just a reminder to all that even at the year 2030 with the buildout of the Airport Development Plan, no portion of Mission Beach or La Jolla are located within the 65 dB CNEL contour.
Thanks Paul for the comment. In 2017, when the FAA implemented the NexGen, there was a dramatic increase in the noise levels under the PADRZ SID track. Noise complaints increased from just a few quarterly to 3,000 to 7,000, at some periods more than were coming in from OB/Pt. Loma (recognizing that the number from these communities have diminished over the years since there does not seem to be a correlation between number of complaints and action by the Airport to mitigate that impact). The ANAC Subcommittee was formed to identify noise mitigation ideas both inside and outside the 65. Two separate studies, the FPA and the Part 150 were designed to address the ideas for the 65 and non-65 ideas. But some of these ideas are coupled to both 65 and non-65. Unfortunately, it seems that the FPA study is now completed, whcih in my opinion is stupid, and so those ideas deferred are being looked at under the Part 150. But this was never intended to be a 65 only study. Those in the non-65 should be equally represented.
Looks great if you live in La Jolla. Sucks if you live in Ocean Beach!
I really don’t understand the methodology of having a 285 track, which basically splits the to current current tracks. Current tracks at the shoreline are about 7,000 feet apart and noise from both tracks affect OB, adding a third track will provide relieve for no one. The two current departure tracks are used for northern (generally 292) and eastern (generally 275) departures. Depending on time of day, the split is close to 50/50. I believe the split also allows the airport to use opposite tracks to provide diverging departure course for less separation and a 285 heading wouldn’t enough separation. Uust watch departures at 6:30am if we ever get back to normal.
To reduce noise impacts there are really only 4 choices: 1.) extend flight overwater prior to turning, 2.) convert flights from current models to newest aircraft (737MAX vs. 737NG, 302 series vs. 320 series NEO), 3.) some type of Orange County power setting mandates. 4.) Stricter departure curfews by delaying first departure to 0700.
The easiest and most helpful in reduction or noise would be conversion from current engined aircraft to new engined aircraft, especially since the industry will be removing older aircraft and having a smaller operation and fleet. The current law is obsolete as it was a 30 year old deal that mandated Stage 2 removals in trade for no new local controls over airport restrictions. Its’s time to have a new law that mandates accelerated removal of current engined aircraft at noise impacted airports.
I just read the quiet skies pdf linked in one of the replies and see the idea is to split the 292 heading into a 285 and 295 heading. Since the two current headings are about 50/50, the proposal would change leave the 275 heading unchanged in total departure and split the 292 departures to 25% each of operations. This moves 25% of the operations closer to the pier and moves zero departures away from the pier. Yes, quieter for the people who design the proposed change, not the majority under the path of jets before the shoreline.
Paul again thanks for your comment. For clarification, currently we have a 275, a 290 (nighttime 10-11:30) and PADRZ, which has not associated heading angle, but on average is around 295. There are distinctive average crossing points over the coast for each of these departures. The proposal keeps the 275, moves PADRZ down south of the MB peninsula, about 0.32 miles, putting this at 295 and adds a new 285. The origin for these three tracks is about 1 mile from the end of the runway. Here is the idea how this is a compromise. First, need to understand two background factors: 30 or 40 years ago, the City and Port illegally moved the nighttime departures from 275 to 290, approximately up the channel between OB and MB. Illegal because Illegal because the increase in noise in MB should have initiated a FAA NEPA assessment. The FAA simply agreed to the change. Second, the FAA now wants to do away with the 290, a vector heading, and move the aircraft to the PADRZ SID over MB. They tried to hide this move in their analyses and have been caught. Since MB will not accept the move of the 290 flights to PADRZ, the next easiest step is to move PADRZ to 290; however, with the origin of the La Jolla proposal at 1 mile, the 290 becomes a s295. And so wallah, we would have a 275, a 285, and a 295, and ELSO. The potential compromise would keep the noise between OB and MB about the same, would provide some relief to those under the 275, increase the noise under the 285, which would also increase the noise levels in MB. The move from 275 to 285 plus the move of 290 to PADRZ does have the potential to move the 65 out to MB for 2026. So the compromise comes with the move of PADRZ down to the 295 south of the MB peninsula. And lastly, the waypoints in the ocean would be moved farther west, providing some relief to all. Now the last point I want to make is that all of this moving of 275 and PADRZ has virtually no effect on Bird Rock or La Jolla. The only benefit to LJ is moving the turn points further west out into the ocean. The only way to confirm any of this is by performing preliminary analyses. And if it looks reasonable, then conducting a test program in a year or two to confirm and work out bugs to ensure that there is equal dispersion on the different SIDs, but the airport and the FAA are very motivated to do this since this will result in the maximum departure capacity for SDIA. The Airport Authority and their consultants have made some of this possible since, whether intentionally or not, they effed up their inputs in at least the FPA analyses and likely the Part 150 analyses, and therefore must redo them with the correct inputs. This is all going to take time, but everything you want to do right always does. The Airport Authority in their Terminal 1Expansion Project supporting analyses are projecting a substantial increase in the size of the 65 dB CNEL with a lot more people living in the incompatible noise area. The two ideas that offer the best opportunity to solos down this effect is by optimizing the aircraft departure altitude, thrust and velocity. We need to take the lead from the work at JohnWayne Airport that is currently conducting flight tests with the big four airlines, which have been delayed by the coronavirus. Secondly, we know that the louder Stage 3 are being phased out by the airlines, but don’t know how fast. We need an assessment done either by the FAA or by our AA consultants. Once back on track from the coronavirus, if everything returns to normal, then the airport will increase its operations annually to capacity about 6 years after the comeback. There is nothing the airport can do about this. This is a hard stop. So, as far as the economy of SD, there will not be a huge impact if the airport reaches capacity in 6 years or ten years. I think if it can be shown analytically that the transition to all Stage 4 and 5 results in a substantial decrease in the 65, then limits should be added annually to the number of operations commensurate with the phase out of the Phase 3 aircraft. This will keep the 65 from growing to a maxim. This has been done at SDIA in the 1980’s.
Thanks for the details Gary. All I know is that the RAA is totally off base with their projections of aircraft mix in their last push for terminal additions. As far as I know SAN has for decades only had reducing contours on the west side due to a changing fleet mix from unregulated aircraft, to stage 1, 2, 3 and NEO. The mix changed by economics of newer aircraft, regulations phasing out Stage 2 aircraft and curfew restrictions on departures to Stage 3 or better. Today the law for fleet mix and curfew departure restrictions has no affect in required fleet mix buy airline at SAN or any other airport except maybe SNA. The only restrictions at SAN is the curfew and limited runways capacity.
Of course there are regulations on noise limits of new aircraft and airlines will buy new aircraft and retire older models, but there is no regulation to phase out Stage 3 aircraft or limit Stage 3 use to daytime only. We need an updated law to phase out older aircraft at noise impacted airports.
That being said, the RAA used very unrealistic numbers on future fleet mix, which is projection expanded contours with added flights. The RAA shows current engine aircraft like 757s, 737NG and Airbus 320 family CEO’s flying up to 2050, when many of those aircraft would be pushing 30-50 years old.
SAN actually shows an increase in operations by aircraft that are currently out of production and being retired – one wonder where m,ore flights at SAN from a shrinking fleet would come from. RAA projections of NEO aircraft is way low. I’m not quite sure why the RAA would like to show growing contours while pushing for expansion when the aircraft mix could not be what they have projected. SAN has always gotten more that its share of newer aircraft due to longer haul flying vs. East Coast airports and aircraft performance requirements at SAN.
Paul, as usual, you make some very good points. Looking at the airplanes that are currently being parked in the desert by nearly every carrier, we’re seeing the older, less efficient and noisier airplanes going first, and, given the absence of a vaccine, they are likely to stay there for a long time if not forever. I personally am not sad that we do not have the nightly BA 747 flying overhead (I can hear the cries of the A.Net guys and spotters reading this), although I am hopeful for personal reasons that SAN/LHR service will return . I believe that BA was projected to start using an A350 (2021?2022? I can’t remember) for this route, which would be fantastic both for passengers and for those of us who live in OB. However, given the state of things, who knows?
One thing I always try to stress when looking at the SDCRAA’s or anybody else’s aviation forecasts is that they are based on a set of assumptions. This goes for the fleet mix used for the forecast, too. As in 2001 and in 2008-9, we are currently being overtaken by events that will render the forecasts inaccurate for years to come. Ordinarily, increases in propensity to fly is based on growth of population and growth of personal income, that that is going to be stood on its head until effective vaccines and/or treatments are widely available.
I don’t know if OB residents know that 40 or so years ago, the nighttime noise abatement agreement was implemented that moved all departures post 10 pm from the 275 heading to a 290 departure heading, up the channel between Mission Beach and Dog Beach. This agreement was is illegal, since it was worked out between the City Council, and the Port Commission and the FAA ATC under an agreement or policy. It is not however, a flight procedure. It is illegal because there was no NEPA performed, no critical assessment if noise was being moved from one community to another. As a result, if pushed hard enough, the FAA could be forced to reverse the policy. There are compromises to be had, but at this point, after 40 years of bearing the noise from what should be aircraft going over OB, enough is enough.
The following has been written by the undersigned members in good standing of the Citizens Advisory Committee for the current FAA Part 150 Study of Lindbergh Field (“CAC”), on behalf of the specific “resident constituents” living within or adjacent to the Part 150 Study Area. This FAA Part 150 Study is specifically focused on Loma Portal, Ocean Beach and areas east of the runway known as the 65 dB CNEL contour (indicated by the largest red outline shown on the map below; “Study Area”). The Study is primarily looking at westbound departure alternatives that would help to mitigate the increasing noise impacts within the Study Area (forecasted increase of 7,305 housing units\ 14,937 population additionally impacted by 2026; see table below).
To date, we do not believe any of the proposed operational alternatives being modeled as part of the 150 Study by the Airport Authority and their consultants accomplish the set goals. In fact, the proposals appear to focus primarily on noise mitigation outside of the 65 CNEL while pushing noise inside the 65 CNEL south of the San Diego River and further into the heart of Ocean Beach. Further, we believe input from CAC constituent members and others that could help complete a meaningful Part 150 study have thus far been dismissed.
Most recently, a few CAC members, also known as Quiet Skies La Jolla (“QSLJ”), issued a proposal for flight departure route modifications within the ongoing FAA Part 150 Study, with summaries sent to local news publications.
Unfortunately, the Part 150 “resident constituents” who are also Members of the Part 150 CAC were not consulted with nor advised of QSLJ’s written departure route proposal and the subsequent publication of their summary views of their proposed Part 150 modifications (see newly impacted area; “Alternatives with Population Density” map above). While we believe there are elements of their departure route proposals that might offer favorable impacts to the current and future noise issues within the Study Area, we, as constituents living within\adjacent to the Study Area, do not agree with many of QSLJ’s representations nor their conclusions.
Therefore, we do not support QSLJ’s intial proposal as it pertains to flight route alternatives.
Subsequent to this proposal publication, we have been in contact with QSLJ and are now collaborating on viable alternatives for consideration that build off of their initial ideas to appropriately share the resulting noise impacts within the target Study Area, as well as in other coastal communities. Ultimately we believe that this collaboration can become a win for everyone who lives in close proximity to the airport, providing noise relief from Point Loma and Ocean Beach, to Mission Beach, Pacific Beach and La Jolla.
However, any successful mitigation of the significant negative impacts forecasted (see table and map above) will be dependent upon material support from the Airport Authority representatives, their consultants and the FAA which will in turn require significant and broad public involvement and encouragement (written and verbal) to gain and motivate their attention. Residents involvement in this effort would be very helpful and therefore you are encouraged to contact the Airport Authority, visit the Airport Authority Part 150 web page (https://sannoisestudy.com/) and\or contact Ms. Nancy Palmtag, CAC Member and Loma Portal resident for additional information (npalmtag@msn.com).
Respectfully,
Marc Adelman Robin Taylor
Bob Herrin David Kujawa
Nancy Palmtag Casey Schnoor
Mike Tarlton
Right now, La Jolla, MIssion Beach and Pt. Loma/Loma Portal/OB are all trying to find solutions to future noise problems from the airport, but unfortunately, we are not on the same page. So, I predict in the end, the Airport Authority will be the big winner, if the three communities cannot find some common ground.
But as long as we are weighing, Mission Beach also has some bones to pick. Back in the 1980’s, the City Council initiated the 290 nighttime noise abatement agreement, which moved all departures from OB to MB. This change, signed off on by the Port Commissions, the airport managers at the time, was illegal then and it still is. The FAA’s NEPA prevents moving noise from one community to another without an extensive noise assessment, which was not done in this case. So, a complaint has been filed with the FAA to move these nighttime departures back to OB. And one of the ideas proposed by the Pt. Loma folks is to add a second departure at 285 degrees. Again, this requires a NEPA assessment, since the current Part 150 is focused on those inside of the 65 dB CNEL.
But in one big way, the Pt. Loma people have really missed the boat. The motivation for the work by the ANAC Subcommittee that began in 2017 were the thousands of new noise complaints originating in La Jolla and Mission Beach for different reasons. In Mission Beach, it was the concentration of departures on the PADRZ SID that increased noise complaints from a few to 5,000 monthly. A substantial number of the 21 recommendations approved by the ANAC and the SDCRAA are associated with reducing the impact of both day and nighttime noise over MIssion Beach. The Flight Procedures Analyses planned to evaluate many of these ideas, although some were deferred to the Part 150 study.
Many of the recommendations In the FPA were dismissed by the Airport Authority, but we have now determined that there was a flaw in one of the key inputs to the study, also repeated in the Part 150. This flaw was an attempt to legitimize putting the 290 nighttime noise abatement agreement departures on PADRZ, which would dramatically increase departures and noise over Mission Beach. That is simply not going to happen.
Also, several of the ideas to move the PADRZ south of the Mission Beach peninsula were dismissed because of the 15 degree rule. Now we find out that use of a 10 degree rule is picking up supporters at a number of airports around the country, which would allow PADRZ to be moved south.
But, the it seems that the CAC members living in Loma Portal/Pt. Loma/OB are completely dismissing the objectives of the Subcommittee and trying to refocus all of the efforts on reducing noise in their communities. Trouble is that pretty much everyone on the CAC committee has to agree before any really effective new ideas can move forward. So, we need a compromise that benefits all of the parties.
I believe there is a compromise that can be had, but every community must give up something. So, we need to keep talking keeping the big picture in mind. These different communities have more to gain by collaborating and agreeing on a compromise than going alone, because the real enemy is the Airport Authority.