EPA’s Online Resources

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(map and table, showing EPA’s ten administrative regions)

The U.S. Environmental Protection Agency (EPA) was created in 1970 “…for the purpose of protecting human health and the environment by writing and enforcing regulations based on laws passed by Congress.”

The effectiveness of EPA has been questioned by practically everyone; pro-commerce types swear EPA is too onerous, while pro-environment types insist EPA consistently falls short in protecting the environment.

Back in 1970, the year of the first ‘Earth Day’, our Congress was as constructively focused on environmental issues as they have ever been. Sadly, most Congress’s since have served commerce far ahead of people, passing laws, bending rules, and granting targeted exemptions that always further undermine EPA. This includes in the area of aviation impacts. Congress has consistently redistributed authority away from EPA and into FAA, on critical environmental matters including aviation noise and leaded aviation fuel. And, Congress has also consistently federalized authority; they’d rather strip local officials of their basic rights to run their local airports to serve the needs of their local community, and instead give that authority to faceless and unaccountable FAA bureaucrats.

A regulatory agency can be constrained by laws, but the most fundamental power is in information. Thus, even a defanged EPA can empower people, so that each individual can understand environmental impacts and effectively advocate for their family, to protect their environment. EPA can serve us – and they do, with work such as their ‘Citizen Science for Environmental Protection’ Program (selected content copied and archived here). But, and especially in the present political landscape, it is UP TO EACH OF US to do the work beyond the data: we have to take that data, formulate the message, and advocate the change.

So, for example, we can look at reports such as this one, showing diminished air quality and other impacts in the neighborhoods to the north of SeaTac Airport [KSEA]. We can also look at the December 2016 report done by the National Advisory Council for Environmental Policy & Technology, ‘Environmental Protection Belongs to the Public – A Vision for Citizen Science at EPA’.

Where Do We Go Now?

If we take away one lesson from the politics of 2016, it should be this: a Democracy is doomed to fail, where the people are not actively engaged in the decision-making process. We cannot expect to achieve the ideals we want and need as a nation (or as a small, local community), if people do not participate. We cannot be distracted; we cannot be lazy; we must guard against the manipulation of voting data and other forms of election fraud; and, we must not allow the selective disenfranchisement that is happening due to ‘the new Jim Crow’ discriminatory laws. Similarly, we cannot expect to benefit from the sound application of science where many of our elected leaders are collaborating with lobbyists seeking to discredit science; climate change denialism is a good example of this failure.

With that in mind, there is a glimmer of hope for the new administration. The GOP has championed de-federalization and expanded LOCAL authority in all matters. Thus, it is conceivable that we may be surprised; Trump, Ryan, McConnell and others may shrewdly use aviation as an example, demonstrating how to reduce bureaucracy, save money and localize control while de-federalizing the authorities that FAA has increasingly abused.

FAA’s Refusal to Manage Airport Capacity

Satellite-based (aka, NextGen) technologies have been in use for decades, and at most airports they have enabled minimization of distance flown and fuel burned. In fact, at the very few airports where NextGen is failing, the problem is not the technologies: it is too many flights, and FAA’s lazy refusal to impose more restrictive airport flow rates.

If you spend any time studying today’s routes and flight profiles for U.S. commercial passenger flights (and it is REALLY easy to do, with FlightAware, FlightRadar24, and other websites that present FAA’s ATC data), you will see that all flights are already capable of and actually flying optimized routes: long, direct flights from origin airport to destination airport, with smooth and continuous climbouts and descents. But, for a small handful of airports, you will also see that ATC ends up creating long conga lines of low, slow and loud arrivals (the Long Island Arc of Doom is the classic example) … simply because there are too many flights arriving in too small a time window.

The root problem is the hub system, and FAA’s policy of enabling undisciplined hub scheduling by the dominant airline. FAA does this to maximize a theoretical number called ‘runway throughput’, and thus to help the airlines to maximize their profits. In simplest terms, a hub airline can tweak their profits upward a percentage point or two, if they can process say a dozen simultaneous arrivals, sorting the passengers quickly between gates, then send all those flights outbound at exactly the same moment.

Obviously, this is only theoretically possible. Because of limited runway capacity, each arrival and each departure needs roughly a one-minute window where the runway is theirs alone, so the scheduled ‘banks’ of a dozen ‘simultaneous arrivals’ and ‘simultaneous departures’ get spread out over two 12-20 minute windows. To safely handle the arrival banks, ATC has to level off the arrivals and extend the arrival pattern to long final legs, spacing the flights at roughly one-minute intervals; to process the departure banks, ATC issues immediate turns on departure (with terrible impacts in places like Phoenix), so that takeoff clearances can be issued in rapid succession.

The reality that FAA and Bill Shuster refuse to accept is this: runway capacity is limited, and we can pretend to be creating new technological solutions, but so long as there are only so many arrivals that a key hub airport can handle per hour, it is folly for FAA to let hub airlines schedule in excess. It only guarantees delays, which then cascade into other airports that otherwise would never see delays. Also, it is important to note that hourly flow rates do not address the problem. Delays happen every time, when just two arrivals aim to use one runway at the same minute. So, if FAA is to work with the airlines to design delay-free arrivals, the schedule needs to look at small time increments, even how many arrivals every 5-minutes. Fortunately, this finer data granularity is easily studied with todays digital processing capabilities.

The solution is obvious: we need Congress to change the laws, so as to disincentivize excessive hub scheduling; and, we need FAA to aggressively restrict airport flow rates at key delay-plagued hub airports, so that the conga lines never need to happen.

An Example: Seattle Arrivals

Here’s an example of what happens at an airport, when just one more flight creates enough traffic, to necessitate ATC stretching the arrival pattern. Seattle is a great example, because it is a major hub airport but [KSEA] is far from other major airports, thus flight patterns are not made more complicated by airport proximity issues. The dominant airline is Alaska (including its feeder, Horizon), but Delta began aggressive hub growth in 2012. The airport has triple-parallel north-south runways; a south flow is by far the dominant airport flow configuration. Whenever ATC has enough arrivals to reduce spacing to less than two minutes apart, the arrivals are extended downwind, turning base abeam Ballard (12nm), abeam Northgate Mall (14nm), abeam Edmonds (20nm), or even further north (see this graphic that shows distances on final from the runway approach ends).

The scrollable PDF below has sample arrivals on December 29th, with altitudes added to the screencaps, to illustrate level-offs and descent profiles. Five sample arrivals are included:

  • Horizon #2052 vs Horizon #2162 vs Horizon #2405: all are Dash-8s, from KPDX. Horizon #2052 has no traffic and is able to use the preferred noise abatement arrival route over Elliott Bay; the other two flights both have to extend to well north of Green Lake, including a long level-off at 4,000ft.
  • Alaska #449 vs Alaska #479: both are from KLAX. Alaska #449 has no traffic and is able to use the preferred noise abatement arrival route over Elliott Bay; Alaska #479 has to extend to well north of Green Lake, including a long level-off at 3,800ft, starting to the west of Alki Point.
Click on the image below for a scrollable view; the PDF file may be downloaded.


UPDATE, 01/17/2017 — further details and graphic added, re distances on final for KSEA south flow.

2017-01-06: ‘Accountability Check’

Below is a sample of a recent query to FAA, and a reply by an FAA official. This example relates to NextGen impacts in western Long Island, near the [KJFK] and [KLGA] airports. The original query was directed to Carmine Gallo, FAA’s Regional Administrator, but passed on to Rick Riley at the FAA HQ Noise Ombudsman Office.

You can judge for yourself … how well did the FAA official do in the reply?

  1. Did he or she answer any questions?
  2. Did he or she inform and educate?
  3. Did he or she clarify who is accountable, or did he or she identify who is responsible?
  4. Did he or she go a step further and identify the problem, then take action to actually FIX THE PROBLEM?
  5. …or, did he or she just return a mumbo-jumbo form letter response, with added platitudes and pro-aviation propaganda, while obscuring accountability and kicking the can down the road?

View copies at these links: Query, Reply. Here’s how the impacted homeowner judged Mr. Riley’s email reply:

We need our questions answered from the FAA &/or the PA and we need them now!! No more shifting blame. Someone needs to take responsibility!!

One Table Shows the Reality of NextGen

Here’s some data to ponder as we start into a new year: a table, showing commercial operations at each of FAA’s OEP-35 airports, from 2007 onward.

Focus first on the pink column, three columns from the right edge; the airports are ranked in descending order, by the percent decline in annual operations, comparing 2015 with 2007.

Note that the largest declines, at Cincinnati [KCVG], Cleveland [KCLE], and Memphis [KMEM] are huge: down 61%, 53%, and 43% respectively. Note also, the declines are even larger when you compare Total Annual Operations in 2015 vs the various historic peak years for each OEP-35 airport, in the two columns on the far right; for these figures (which include general aviation and military operations data), all airports have declined, ranging from 74% to 2% and averaging 24%.

Click on the image below for a scrollable view; the PDF file may be downloaded.

Three facts stand out from this table, and they all strongly contradict the sales pitches that FAA and industry have been collaborating on the past few years:

  1. Note the bright green line across the table. Just under it are five airports: Charlotte [KCLT], Reagan National [KDCA], Miami [KMIA], Seattle [KSEA] and San Francisco [KSFO]. These are the only five of the OEP-35 airports that recorded an increase in commercial operations from 2007 to 2015; i.e., 6 out of 7 OEP airports SLOWED substantially while the national population grew.
  2. The airport identifiers marked in a dark-red background color are the airports that in 2016 had extensive noise complaint histories (documented online, and in the mainstream media) related to route concentrations under NextGen. Routinely, FAA has imposed these routes without adequate public review, abusing the ‘categorical exclusion’ process. Numerous legal actions have resulted.
  3. For all OEP-35 airports combined, commercial operations have steadily declined 11% from 2007 to 2015, nearly every year. This is industry contraction. And furthermore, the vast majority of U.S. commercial airports peaked in the 1990s, some more than two decades ago!

WIth the new year, we’ll see a new adminstration and changes at FAA and DoT. Don’t be fooled by the impending onslaught of yet another round of propaganda. The U.S. NAS is operating at far below historic peaks and continuing to trend downward. Growth is rare, and limited to key airports where airlines are concentrating flights into superhubs that severely impact local quality of life. The only true beneficiaries of NextGen and ATC privatization are industry stakeholders (especially the airline CEOs, FAA officials, lobbyists, and manufacturers, plus a few elected officials), who will narrowly share the profits while completely ignoring the larger environmental costs.

We don’t need oversold technology fixes pitching RNAV and RNP solutions that have been used for decades; technologies that could and would serve us all beautifully, if FAA would assert its authority with balance, and manage capacity at the largest U.S. hub airports. We need airports to serve communities while being truly environmentally responsible. And for that to happen, we need a new era of transparency and accountability at FAA. We need reform.

[KJFK]: PlaneSense 4 LI’s Latest Letter sent to Carmine Gallo, Seeking Relief

Elaine Miller’s letter lays out the facts about the ongoing and expanded Noise Hell, brought by FAA & NextGen (and sustained by the failure of elected officials to demand reform at FAA). This is a growinng problem, not just at Malverne (which is hit by KJFK ‘Arc of Doom’ arrivals to runways 22 and KJFK Runway 4 departures using the DEEZZ4 RNAV DEP and the JFK3 DEP, as well as Localizer arrivals to KLGA Runway 31), but across the nation.

Categorical Exclusions were a bad idea. They enabled FAA to approve more operations, at lower altitudes, closer in to the runways, and with excruciating repetition. Frankly, these past few years, FAA’s failed performance is serving only airline profits … and at great cost to the People. A change is long overdue.

Here’s a copy of the latest letter sent to Carmine Gallo, Regional Administrator for FAA’s Eastern Region:

Click on the image below for a scrollable view; the PDF file may be downloaded.

NASA Research Papers on ATC Automation, from 1972 and 1989

NextGen efficiency improvements are pitched as ‘transformative’, but in fact the alleged changes are nothing new. The bulk of the alleged ‘benefits’ FAA, A4A and Bill Shuster claims NextGen can deliver have been realized for more than two decades. It doesn’t take much effort for online research to reveal substantial evidence of this fact. Here’s a short quote from an interview:

QUOTE

“…we built these descent trajectories to be an idle thrust descent all the way to the bottom . . . . you’re flying at thirty-five thousand and you know the route you’re going to fly. Now imagine you have to pick a time, while you’re flying, to land down there. You’re given the command, OK, close your throttles, never touch them again, but be assured that you’re going to get there without turning the throttles back on again….”

– interview comments by Heinz Erzberger, an ATC researcher at NASA Ames, discussing research back in the 1970s

Read more in copies of these research papers by Mr. Erzberger, from 1972 and from 1989.

[KORD]: Safety is Losing Out with the O’Hare Modernization Plan

One week ago, United 441 departed Orlando [KMCO] late in the day on a scheduled trip to O’Hare [KORD]. The flight history was normal up until the last moment, when the Boeing 757 slid off the edge of the runway and ended up in the mud at 12:53AM. FlightAware shows the flight made it to the gate two hours later.

It turns out, the flight was cleared to land on Runway 4L at a time when runway traction was reduced (after hours of light snow and mist) and the winds were poorly aligned with the runway (nominally a 70-degree crosswind per this official weather: METAR KORD 180651Z 33017G25KT 1SM R10L/P6000FT -SN BR BKN017 OVC043 M08/M11 A2994 RMK AO2 PK WND 33029/0618).

A group in the Chicago area, FAiR.org, issued this press release, making some very credible points. It appears that, in the mad rush to spend billions replacing the O’Hare runway system with a gazillion east-west runways, the busiest commercial airport in the world is losing its capacity to offer runways aligned with the wind, which are needed most during poor weather. The multi-parallel runways, and the NextGen reliance on automation (in the tower, and on the flight deck), are increasing runway throughput but decreasing safety margins.

Click on the image below for a scrollable view; the PDF file may be downloaded.

And what is driving all of this? The desire to be the world’s number one airport, in terms of operations per year. For a few years, Atlanta [KATL] took that title away from O’Hare. Atlanta operates using a set of five parallel east-west runways. Atlanta is Delta’s superHub, and an enormous fraction (well over half?) of arriving passengers never leave the airport… they sit and wait enjoying the comfortable seatpitch on the same plane, or they walk to another gate and depart on a different flight.

FAA is collaborating with the airlines with the same business plan at O’Hare, which is a superHub for both United and American. The safety consequences are not insignificant, but there are environmental impacts, too. Here’s two serious environmental problems with these superHubs:

  1. when a huge portion of arriving passengers are using the airport only as a connecting point, the number of flights in and out of the airport each day far surpasses what is needed to serve the actual community. So, you end up with double, triple, or more flights per hour as are needed. Under NextGen, some neighborhoods like Bensenville are inundated with nonstop noise related to the superHub airport.
  2. the carbon footprint for each passenger is greatly increased. Essentially, every time a passenger connects at a superHub not on the direct route between origin and destination, it increases miles travelled. It is quite common in the U.S. for airlines to offer discounted airfares to fill seats, so they offer itineraries that add 20% or more to the miles travelled. This translates to that passenger generating a proportional increase in fuel consuming to carry their butt/baggage to their destination. More time, more hassle, more CO2, but too many of us are conditioned to ignore that because we ‘stole a great deal’, saving $20 when we clicked the buy button.

[KSEA]: One Way FAA can Use NextGen to Optimize Noise Mitigation

Here’s a tip for how to very effectively expose FAA’s NextGen failure: study how ATC handles arriving flights during low-traffic time periods. For example, at the SeaTac Airport [KSEA], where Delta’s decision to start up a new hub in 2012 is causing substantial growth in annual airport operations, the arrivals stay busy through most of the day, but there are a few hours each night when you can find only one arrival being worked. So, the question is, what is the shortest arrival routing ATC will issue when working a single, all-alone arrival, and how does that arrival route change with the addition of more arrivals?

When you study the empirical flight data, you quickly find the answers, and they consistently show: FAA’s largest impediment to system efficiency is simply TOO MANY FLIGHTS. In other words, if FAA really cared to optimize safety and efficiency, they would focus on managing capacity, keeping operations per hour below thresholds that precipitate delays and congestion.

Consider a Recent Arrival: United 505 from Denver

One example of this was United 505, which arrived after 2AM on Tuesday, December 20th. First, notice the overall flight on the satellite view below: as has been the case for many decades, they flew a straight line from Denver, with no zig-zags. Notice, too, that the only significant distances were added at Denver and at Seattle, as needed to accomplish transition to and from the enroute portion of the flight.
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How Can FAA Better Use the NextGen Technologies?

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(VFR sectional with a red curve added, depicting an optimized noise mitigation approach over Puget Sound and Elliott Bay. Crossing altitudes at 8000ft and 3000ft are added, red text on green background.)

The residents of Seattle are lucky to have a large water body that aligns well with their main commercial airport. But, the basic design elements needed to optimize noise mitigation were not fully considered when FAA was selling NextGen. Key design elements should have included:

  1. keep the arrivals high as long as possible. (way back in the 1970s, FAA actually had a noise mitigation program called ‘Keep em High’!)
  2. for the final ten miles, set up each arrival for a continuous rate of descent, optimally at around 300-ft per mile flown. (thus, arrivals should be designed to cross a fix at roughly ten-miles from the runway end, and 3,000ft above airport elevation)
  3. for the distance from 20-miles to 10-miles from the runway end, design a higher rate of descent, perhaps 500-ft per mile flown. (thus, arrivals would descend from 8,000ft above airport elevation to 3,000ft above airport elevation, during this 10-mile portion of the arrival; with this design, commonly used flight automation systems would enable pilots to easily comply with the designed optimized descent profile and route)
  4. plan to have ATC accomplish sequencing, spacing and speed management to the point where the final 20-miles of the approach begins. (in this case, roughly mid-channel over the Vashon ferry route, at an altitude nominally 8,000 feet MSL)

Interestingly, this proposal is quite similar to one of the approaches that FAA designed and implemented, the RNAV (RNP) Z Runway 16R Approach:ksea-20161204cpy-rnav-rnp-z-rwy16r-ifr-plate
For years, in an extended and heavily-coordinated pitch to sell the NextGen program in Seattle, FAA and others pushed the idea that all arrivals from the west side (from California, Oregon, Hawaii, coastal BC & Alaska) would be routed inbound over Elliott Bay during the predominant south flow landings at SeaTac. This was a good idea, but FAA did not go far enough. I.e., when FAA designed this approach procedure, they focused solely on the portion from the middle of Elliott Bay to the runway; they should have also focused on how each flight would get to that point in Elliott Bay (look for ‘SEGAW’ in the plate above). A truly optimized approach would define fixes and precise altitudes, starting between the fix VASHN (on the approach plate above) and the Fauntleroy ferry dock; such an optimized approach would route each arrival over-water and eventually over the vicinity of the stadiums, and would include speed and altitude profiles easily achieved by today’s air carrier fleet. Note that the profile view for the current deficient approach procedure (above) starts at fix WOTIK, which is at a 6-mile final and well south of Spokane Street.

Exposing a NextGen Fraud: the so-called ‘Conventional’ ZigZag Routes

It is quite clear that, with the election results and the imminent White House occupancy change, coordinated efforts are ramping up to try and push through the latest pet projects: ATC privatization, and accelerated NextGen funding. These efforts are sourced in some backroom ‘collaboration’ between top-level FAA officials, key aviation leaders in Congress, and the industry (the airlines, the manufacturers, and the lobbyists).

As has always been the pattern, the Av-Gov Complex will knowingly lie to sell their schemes. One of the most graphic lies of the present cycle is variations of this graphic:

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This misleading graphic is liberally posted in news articles, FAA reports, etc. It implies that today’s air navigation systems are primitive, needing to upgrade via a progression from zigzag routes (left image) through RNAV routes and eventually RNP routes. An important fact being hidden, though, is that RNAV and RNP routes already exist, as they have for years. (SOURCE: pg.7 of FAA’s SatNav News, Summer 2011 edition)

Time and again, this image is pushed to help brainwash the Public (and especially Congress) to believe the current ATC system is incredibly archaic and shockingly inefficient, with flights zigging and zagging all across the continent. They pitch NextGen as ‘transformative’, while ignoring and concealing the facts that:

  1. commercial passenger flights have been flying mostly direct flights for decades, and thus these graphically presented zigzags are a complete lie;
  2. RNP & RNAV procedures have been available and usable by these flights for roughly two decades, and thus the whiz-bang NextGen changes are not really changes (we can accomplish the expensive NextGen goals by smartly using what we already have); and,
  3. an entirely new class of delays has been recently invented – enroute delays, at altitude; typically 100-200-miles from the destination airport, these are used to smooth out arrival surges because FAA refuses to restrict appropriate arrival rates to accommodate known airport capacity limits.

FAA et al need to be called out on this misinformation. It turns out, you will find two versions of this deceptive diagram in Chapter One of nearly every recently completed ‘Environmental Assessment’ for various airspace changes around the nation. Here are some examples, from recent OAPMs (Optimization of Airspace and Procedures in the Metroplex); look at the identical content in any of these cookie-cutter documents, at these pages:

  1. June 2013: Draft EA for DC OAPM (216p; see pages 6 and 14 in chapter one, marked pages ‘1-6’ and ‘1-14’)
  2. March 2014: EA for Atlanta OAPM (122p; see pages 1-6 and 1-14)
  3. July 2014: Final EA for NorCal OAPM (134p; see pages 1-5 and 1-11)
  4. December 2014: Draft EA for Charlotte OAPM (118p; see pages 1-5 and 1-11)
  5. August 2016: Final EA for SoCal OAPM (144p; see pages 1-6 and 1-12)

‘NextGen Fixes’ Tend to be Slow, and Tend to Serve to Advance the Propaganda

Thankfully, some progress has been seen for the [NextGen impact case] at [KSFO], but the repetitive noise impact problems persist nationwide, and in fact, appear to be worsening. In almost all cases, the rare ‘NextGen-fixes’ have three key elements:

  1. the NextGen-fixes further crystallize FAA’s ongoing delay tactics; i.e., just getting to the time when an announcement can be made with a new NextGen-fix eats up months and even years. Moreover, the declared ‘solution’ consistently contains absurdly long timelines for each subsequent goal or step.
  2. the NextGen-fixes tend to help the Public nowhere near as much as they serve FAA and the elected officials. The announcements make elected officials look like they are serving their constituents, thus bolstering their incumbency chances … even though these same officials could and should be far MORE aggressive in demanding performance and immediate corrective actions by FAA. And,
  3. the NextGen-fixes continue to sell NextGen as a solution, when in fact it is the problem. I.e., the news releases and other documents are constantly laced with keywords and quoted lines from FAA’s fraudulent NextGen salespitch.

Here’s a short (just over 1-minute) home-video showing and explaining the impacts FAA’s NextGen SERFR arrivals are having on residents between Santa Cruz and San Francisco.

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(click on image to view source video at Facebook)