*Now the Seattle RCAA
Aircraft Noise Group Response
__________________________________
In the Matter of:
Expert Arbitration Panel's Review of
Noise and Demand/System
Management Issues at Sea-Tac
International Airport
__________________________________
RESPONSE TO PROCEDURAL ORDER OF EXPERT
ARBITRATION PANEL
Organization of responses and enclosures
PART 1: We have organized our responses into two parts: Part 1
covers the first question listed in the Panel's scope in Page 4
of the Order. Responses to questions 2 and 3 of the order are
incorporated into Sections 2 & 3 of our Part 2.
"Question 1. Has the Panel been asked to determine
whether the goals of the Noise Budget and the
Nighttime Limitations Program, if achieved, would produce a
significant reduction in real noise impacts on-the-ground?
Question 2. If so, would achievement of the noise reduction
performance objectives of the Noise Budget and Nighttime
Limitations Program produce a significant reduction in
real noise impacts on-the-ground?
Question 3. Is the Noise Validation Methodology proposed
in by the POS a reliable method for determining, on the basis
of measurements of actual on-the-ground noise using the
existing noise monitoring system at Sea-Tac, whether
the noise reduction performance objectives of the Noise
Budget and Nighttime Limitations Program have been
achieved?"
PART 2: Part 2 of our comments covers the information the Panel
requested the public to submit on page 8 of the Procedural Order
in addition to responses to questions 2& 3 above.
"Request 1. Summaries of any methodologically sound
aviation noise data collected by local community
organizations or individuals. These summaries must be
documented with specific information on the procedures (including
calibration), time of day, date, locations, and equipment used to
collect the data, as well as a brief description of airport operations
during the measurements (e.g. north or south flow, nature of noise
[flyovers, ground run-up, etc.], background sources
and levels, and weather conditions.)
Request 2 Detailed descriptions of any technical reasons
why achievement of the noise reduction performance objectives
of the Noise Budget and Nighttime Limitations Program
established by the POS would not be expected to produce a
significant reduction in real noise impacts on-the-ground.
Request 3. Detailed descriptions of any technical reasons
why the Noise Validation Method proposed by the POS should
not be found to be a reliable method for determining, on
the basis of measurement of actual on-the-ground noise using
the existing monitoring system at Sea-Tac, whether the
noise reduction performance objective of the Noise Budget and
Nighttime Limitations Program have been achieved.
APPENDIX
To assist the panel, we have attached an Appendix containing
either full copies or the appropriate portions of copies of any
documents or reports referred to in our responses. If copies
were unavailable to us, we have provided a complete citation. If
the copies are already available to the Panel, such as PSRC
minutes, we make a note but don't include the copies.
Part 1:
The Expert Panel must determine whether the goals of the
Noise Budget and Nighttime Limitations Program would produce a
significant reduction in real noise impacts on-the-ground. This
program was adopted by Port for a different purpose at an earlier
time. It has offered it here as serving a new purpose, that of
PSRC Res. 93-03 and third runway expansion as well. The public
disagreed that it could serve two conflicting purposes. The PSRC
decided to accept the Noise Budget and Nighttime Limitations
program on the condition that it could be established by and
independent panel that it did suit the new purpose and would
produce a significant reduction in real noise on-the-ground. The
independent expert panel is supposed to settle this issue and
cannot do so without deciding whether the or not the goals of the
program would in fact produce a significant reduction in real
noise impacts on the ground.
An independent panel was chosen to arbitrate the issue
because the Port of Seattle sits rambunctiously on the PSRC
itself, thereby serving as both an vigorous advocate of its own
proposals and self-interest and as a decision-maker on those very
same proposals, precluding the PSRC from fairly deciding these
issues itself. If the Expert Panel failed to determine whether
the entire Noise Budget & Nighttime Limitations program--
including its goals--would produce significant reductions, it
would be failing to do the very task it was assigned.
The Noise Budget and Nighttime Limitations program was
adopted as the result of the "Noise Mediation" process. However,
the goals it is important to know that the goals were not adopted
as part of the mediation process. The Mediation was unilaterally
terminated by the Port, and the citizen caucuses dismissed prior
to the choice of goals. These goals were chosen by Port staff
after the termination and were announced six months later.
In fact, there was no mediation agreement adopting the Noise
Budget and Nighttime Limitations program. Attached is a Sea-Tac
Noise Bulletin from our group which was widely distributed both
in the neighborhoods and to local public officials at the time of
the Port unilaterally terminated mediation. A portion of the
"agreement" presented at that last mediation session is
reproduced showing that the goals were not filled in on the
proposed draft agreement passed out on the day mediation was
terminated. No agreement was ever signed, nor did the mediators
representing the Citizens causes have authority to sign them.
This newsletter also makes clear that the Mediation that
produced the Noise Budget occurred prior to institution of the 4-
Post Flight rerouting. In the subsequent lawsuit Seattle
Community Council Federation vs. F.A.A. that followed, the F.A.A.
argued that one of the reasons that there would be no significant
impacts from 4-post because no third runway was planned. The
Noise Budget and Nighttime Limitations Program did not
contemplate a third runway adding an estimated additional 100,000
operations per year. This is why the reductions of noise impact
on the ground must be "significant."
The term "on-the-ground" refers to three issues. First the
reduction of engine noise via the certification process does not
necessarily translate into actual noise reduction because the
weight of the aircraft and pilot procedures significantly affect
the amount of real noise generated on the ground. Second, local
terrain also significantly affects how much noise is received on
the ground. Third, the number and demographic characteristics of
people living on the ground beneath the roar affects the
significance of the impacts. The F.A.A. estimates that 66,000
people currently reside in 65+DNL. In the Flightplan DEIS, the
Port argued that there would be significant noise reduction
because only 2000 would be left in 2010 the rest having been
driven out by the noise in the intervening years. (The Port has
no plans to buy them all out, only a very few.) Deciding if this
sort of environmental "cleansing policy" constitutes a reduction
in real noise impacts on the ground also comes under the purview
of the Expert Panel.
Finally, the noise portion of the resolution was passed in
part because of complaints from the public in comments on the
(PSRC) Flightplan DEIS1 that the goals of the Noise Budget and
Nighttime Limitations Program would not produce reduced real
noise impacts and that the methodology for measuring them was
both theoretical, (not "real"), exempted intern