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Aviation Expert Finds “Disquieting” Holes in FAA Study

by Harriet Kline

(May 18, 2006) Consultant Williams Aviation warns that FAA plans for airspace redesign, as described in the agency’s DEIS (Draft Environmental Impact Statement), may actually increase the number of aircraft flying over the Larchmont and Mamaroneck communities as new departures from La Guardia are routed over land rather than over Long Island Sound. Furthermore, the consultant states that the DEIS lacks relevant altitude data and “manipulates noise data by taking the larger and much noisier aircraft out of the fleet mix and substituting much quieter regional jets to show no significant impacts in their noise modeling.” The consultant’s report cites numerous other errors and inconsistencies in the DEIS. (See: PDF of Consultants' Executive Summary.)

Larchmont, Mamaroneck and New Rochelle officials were briefed on the Williams Aviation assessments by members of the Quiet Skies Committee of WRAIN at a Mamaroneck Town Board work session on Wednesday, May 17. (See: Quiet Skies summary below.)

Town Supervisor Valerie O’Keeffe reacted to the briefing the next day: “Certain anxiety is provoked in all of us because of the FAA’s apparent proposal to move the take-off route onto land right up the shore. We don’t want that, obviously.”

She will be contacting leaders in the Village of Larchmont, Port Chester and Harrison to encourage their support for comments Quiet Skies will be filing with the FAA. Larchmont’s Mayor Liz Feld will be reaching out to Rye and Pelham officials for their support.

The Quiet Skies Committee hired Williams Aviation to analyze the thousands of pages of the highly technical DEIS prepared as part of FAA efforts to redesign the northeast airspace. The villages of Larchmont and Mamaroneck and the Town of Mamaroneck contributed $15K each to help fund the cost of consultants. Additional monies were raised privately to cover an anticipated $100K bill. (See: Town Backs Quiet Skies Review of Airspace Redesign and Larchmont Contributing $15K to Quiet Skies Campaign.)

According to Patty Horing of the Quiet Skies group, the Williams Aviation findings will now be placed into a legal framework to conform to NEPA (National Environmental Protection Act) regulations and sent on to the FAA by the mandated June 1 deadline.

 

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)

 

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