Dear Friends, 

Thank you to all who wrote to the City! 

In this update:

• City of Palo Alto reply to Sky Posse request to stop aviation greenwashing 
• FAA’s comment period extension to September 29
• Reminder - GBAS Update meeting at 6:00 PM. Monday, July 17 

City’s reply: 

The City replied to Sky Posse comments as follows:

“Thank you for taking the time to share your suggestions and comments. The City of Palo Alto is working with neighboring cities to see if there is interest in a joint comment response to the FAA. We will endeavor to incorporate your suggestions and comments into this letter. Please be advised that you can independently send your comments per the attached directions: https://www.federalregister.gov/documents/2023/05/01/2023-09113/request-for-comments-on-the-federal-aviation-administrations-review-of-the-civil-aviation-noise

Please note that the FAA has granted an extension of the comment period for the request for comments through September 29, 2023.”

FAA comment period extension: 

The FAA notes in their extension notice that the agency is “seeking input on its review of four key considerations of its civil aviation noise policy, in the context of noise metrics and noise thresholds. The civil aviation noise policy sets forth how the FAA analyzes, explains, and publicly presents changes in noise exposure from aviation activity.”

Based on the Federal Register documentation, we understand the four considerations to be as follows:  

1. Whether the agency should continue to describe noise impacts based solely on “community response” which is a term referring to annoyance or nuisance.
2. The FAA is also focusing on metrics that describe exposure to aircraft noise and potential revision (s) to the choice of the standard metric (s).
3. The FAA is reviewing its definition of significant impact for agency actions to comply with the National Environmental Policy Act (NEPA).
4. The FAA is also examining the level of aircraft noise exposure below which certain land uses are considered “normally compatible” with airport operations.

Very briefly, here are responses we are considering about the above four areas: 

• It is not enough to define the scope of adverse impacts solely on the basis of “community response” or annoyance because it disregards that the public is also concerned about health effects, sleep, quality of life, productivity, and impacts on vulnerable populations. How the FAA describes noise impacts needs to adequately represent citizen concerns.
• Noise metrics should include a standard (s) that compares with globally recognized guidelines like the WHO or EU. We also continue to advocate for an expanded menu of metric options to account for what the FAA called in a 2020 report to Congress the dynamic acoustical and operational characteristics of aviation noise. In a 2021 report on aircraft noise, the General Accountability Office investigated community concerns, and endorsed the metrics Number Above (NA), and Time Above (TA). In response to citizen concerns, the Select Committee on South Bay Arrivals unanimously voted in 2016 to ask the FAA to consider more metrics including dBC weighting to represent sound spectrum from aircraft more completely than dBA. 
• The FAA’s criteria for NEPA promote FAA practices that defy the purpose of the law which is a disclosure law to encourage stakeholder engagement and to find least impact alternatives before final actions. We want to see meaningful change to yield new noise pollution reporting standards, and regulation of aviation impacts. 
• Land use “compatibility” is inseparable from some of the issues raised above. This is an opportunity to address who is responsible for assessing and reducing noise, and what are the best practices to protect the public. 

The FAA’s solicitation also asks 11 questions about how the FAA should disclose and use the metrics for decision making - for current aircraft types like jets and also potential new vehicles. Because it is taking years for Congress and the FAA to be responsive to the public’s concerns about known effects from current vehicles like jets, it should be a priority to first resolve current public concerns about aviation noise before the agency or legislators make environmental judgements, or help fund or regulate new aviation vehicles that neither the agency or public have experience with.

We are taking the FAA’s extension to further refine our inputs and will share drafts before finalizing and submitting a response. Please let us know questions and comments as this keeps moving forward. 

Reminder - GBAS Update meeting at 7:00 PM. Monday, July 17:

SFO”s GBAS project has been under development since 2018 and there are still many issues that could make this challenging for our communities. We are concerned about the FAA’s hands-off position on community outreach for Precision Based Navigation (PBN) - not observing any of the GAO recommendations for PBN development and the environmental declarations being made - some that have already been made, and potential new ones about GBAS procedures that could be made in the future declaring “no significant impact.” The City of Palo Alto has a Council vote to be on top of potential opportunities to legally pursue higher level FAA environmental reviews, but the City has not updated residents in the last few years about how they are fulfilling this Council direction.