KEY ISSUES & PROBLEMS WITH FAA’s AIRSPACE REDESIGN DEIS

By Quiet Skies Committee of Larchmont & Mamaroneck
Citing Williams Aviation Consultants’ Executive Summary

New Departures over Sound Shore

• In the “Modifications to Existing Airspace Alternative”: New LaGuardia (LGA) departure headings will move all flights from Runway 4 from over the Sound to over the land area West of the Sound. “Departing aircraft are very noisy and the movement of the route from over water to over land will adversely impact the communities along the Western edge of the Long Island Sound” (the Sound Shore communities). FAA has provided no altitude information for such a shift, and thus no noise quantification is available or even possible. (pp. 2, 6)

Lack of Relevant Data –Altitudes:

• FAA “has not indicated the altitude of aircraft using any of the existing or proposed air routes.” (p.13) Noise cannot be evaluated without altitude information (see also p.14). “The FAA omitted the specific altitudes for all of the arrival and departure routes and as such the impacts of those routes cannot be assessed. The DEIS is deficient in providing supporting data and should be rejected on that basis.” (p.22)

Manipulated Noise Data

• “The FAA’s consultant manipulated the fleet mix by taking all aircraft weighing less than 255,000 lbs (B-737, 757, 767, MD-80, etc.) and reclassifying them as regional jets. By taking the larger and much noisier aircraft out of the fleet mix and substituting the much quieter regional jet, they were able to show no significant impacts in their noise modeling.” (p. 13)

Incomplete Noise Modeling

• In addition to omitting altitude data, FAA eliminated the last 90 minutes/day of LGA flights from its noise calculations, thus vastly reducing the appearance of noise impacts in its analysis (noise differential is greater at night, when ambient sound is lower). (p.15)

False Skew of Airports/ATC load Analyzed

• “The FAA’s Consultant is only studying eight airports, and some are being studied to a ‘lesser degree’. This allows the FAA to control the results of the DEIS and allows them to eliminate nearly 80% of the Study Area airports. The FAA also eliminated general aviation and military aircraft from their analysis, thereby artificially inflating the benefits of the alternatives by reducing the number of aircraft in the ATC [Air Traffic Control] system.” (p. 10)

False Skew of Aircraft Analyzed

• The DEIS excluded all “VFR” (noncommercial) air traffic in its study; excluding VFR traffic artificially increases the benefit of the project. (p. 2)

Labor a Factor in Volume Control

• Since 2000, LGA has had a 300% increase in volume delays. Williams feels strongly that “employee satisfaction issues” -- the poor relationship between TRACON Air Traffic Controllers and management -- played a major role in this problem. (p.3)

Faulty Premise:

• “The FAA has, in our opinion, failed to demonstrate that the airspace design is responsible for air traffic delays or that the airspace is unreliable…. The DEIS does not consider the cumulative benefits of congestions management alternative, airport infrastructure improvements or technology advancement in addressing the aviation problems in the project area.” (p.5) “[Further,] there is no evidence offered that this airspace project in any of its iterations will resolve the inherent constraints of the region.” (p.19)

ICC Not Viable in DEIS Timeframe

• “The only viable options within the lifespan of this EIS are those options that do not include the ICC [which will take more than 5 years to establish]. The options without ICC do not provide any discernable benefit and thus the need for this airspace realignment is virtually non-existent.”….”The combination of terminal facilities [the ICC] doesn’t require a DEIS, and, in our opinion, is only used to complicate the issue and obscure the environmental impacts though a list of unachievable benefits.” (pp. 9-10)

CONCLUSION:

“The FAA’s consultant has failed to consider the cumulative benefit of the initiatives that could be implemented at this time to address the issues of airspace and efficiency delay reduction and increased capacity. None of the alternatives that can be implemented during the timeframe specified in the DEIS provide any significant ability to reduce delays or enhance airspace efficiency…. If actual conditions were modeled for noise and capacity, none of the alternatives would meet the purpose and need, and the true adverse impacts to areas surrounding the region’s airports would be revealed.” (p.23)