Categories
AvImpact-Noise

Comments by aiREFORM submitted to the ‘Noise Policy Review’ NPRM-RFC [Docket FAA-2023-0855]

A few hours ahead of the closing deadline, aiREFORM submitted a 37-page PDF to the Federal eRulemaking Portal, for ‘Docket No.: FAA–2023–0855: Request for Comments on the FAA’s Review of the Civil Aviation Noise Policy’. The pages break down as follows:

pages 1-4 Part 1: Summary, & General Concerns
pages 2-8 Part 2: aiREFORM comments to FAA’s 11 numbered questions
pages 9-10 Analysis of 1980-2022 ops at 39 major airports
pages 11-12 May 2015 Press Release – FAA to Re-Evaluate Methods for Measuring Effects of Air Noise
pages 13-37 April 2020 – FAA Report to Congress (25p)

The opening page includes this:

I ask FAA to join me in supporting the Aviation-Impacted Communities Alliance (AICA) comments submitted at Docket No FAA-2023-0855-2206. AICA has worked very hard to connect impacted citizens and organize our concerns about these ongoing (and at some locations expanding) aviation impacts. There are many good and solid proposals offered within the AICA comments.

My own comments follow, and are organized as follows:

    • Part 1: provides a summary & overview of this NPRM-RFC1 document
    • Part 2: provides FAA’s specified questions, and this citizen’s comments and suggestions

Part 1: Summary, & General Concerns

The comments that follow are provided by a retired FAA air traffic controller. During his career, he assisted many local residents toward mitigating aviation impacts. Since retiring, he has spent decades studying aviation impacts and working to assist residents across the nation. What he has found is that his former employer, a federal agency with supreme authority over all regulatory aspects of aviation, is failing. FAA is effectively a captured regulator. FAA is not serving the nation; instead, FAA is serving to enable excessive operations (and impacts) by aviation players, who gain financially with FAA inaction and delays, often aided by current FAA employees who have conflicts of interest due to other non-FAA aviation work.

People are being damaged; communities are being destroyed. This NPRM-RFC is centered on Aviation Noise, which is one of the three primary aviation pollutants (the others being air pollutants, and contamination of ground and water). In 2023, we are seeing FAA’s programs lead to rising noise pollution in many areas, but these two rise above:

At major airline hub airports, where NextGen technologies are automating procedures by both aircraft navigational systems and ATC systems, to tweak flow rates higher, all in the goal of accommodating airlines wanting higher airport capacities. FAA has been aggressively ‘collaborating’ with industry to achieve these goals, despite the fact that airline operations have been declining for more than two decades. Under these changes, thousands of homes are inundated with nearly nonstop stress-inducing noise patterns. Worst-case examples today include JFK, LGA, DCA, SEA, BOS, and many others.

At general aviation airports, where consolidation of flight training programs is creating intensive concentration of closed pattern operations at a select few airports. Private-equity funded, national-scale, flight schools are importing students from across the globe, and profiting from the impacts they impose upon communities below. The Front Range of Colorado is the current worst-case example. Operations at BJC, APA, and a handful of other regional non-towered airports have soared, as have pollutant impacts, in some cases doubling in a few years… yet no environmental analysis or public engagement process preceded any of this growth. On top of this problem, hobbyist pilots and some affiliated with these flight schools and other operators are using social media to identify and then bully the few citizens who try to aid their neighbors by speaking up. The bullying even includes an aviation variant of road-rage: the use of small planes to descend and circle low over homes of known concerned citizens, to intimidate them … and FAA is doing nothing to curtail this bullying. It is as if there were no real regulation by FAA; no accountability for the players who gain profits or just pursue their hobby, while spewing pollutants (often including lead toxins) in the air above our homes.

So here we are, today, offering comments requested by FAA, to assist this huge and deeply-funded agency in their quest of a review of aviation noise policies. Which begs the question: what exactly is the current ‘Aviation Noise Policy’ being reviewed?

…

To read the rest, click on this link to download the 37-pg PDF, for viewing offline, and feel free to share it onward. Use the embedded PDF below to read the PDF online; dwell on the bottom left corner of the PDF to use up-down arrows (for page scrolling) or to zoom in/out. 20230929.. aiREFORM comments to Dckt FAA–2023–0855(37p)

Categories
Airports

FAA’s Forecast in 2000 Missed by Miles, and Now We Need More ATCs?

Ten days from now, FAA’s current authorization will end. Reauthorization has been ongoing at Congress all of this year. One party rules the House, and they came up with a Reauthorization bill that reads like a Christmas List for general aviation; the other party rules the Senate, and is still not finished with their version. It looks like we are heading for a showdown, and likely an extension or two. If past repeats, we may also see controllers staying at home, but getting paid for that added time-off when all the dust eventually settles.

Watching how poorly the parties function in Congress, and also how poorly our mainstream media fails us by not diving into the details (instead, just repeating past stories and reprinting press releases from FAA, NATCA, A4A, AOPA, etc.), it is easy to start to hunt for more info on the internet. The internet is filled with articles, FAA reports, GAO Testimonies, Congressional hearing transcripts, and much, much more. It is educational, but it is also depressing, seeing how themes and strategies repeat, and then they repeat again.

FAA loves to go to Congress and ask for more money, and commonly they do so by pulling big numbers out of (somewhere) and proclaiming the skies will fall if we do not spend a lot more: hire more controllers, build more runways, fork out billions for ‘capacity enhancement’ technologies like NextGen. But it has become much more sophisticated. All of the key players are constantly ‘co-lobbying’ (although FAA fondly calls it ‘collaborating’) with one another, fusing their advocacies to guide us toward even more waste. Their nests get feathered, despite the fact that FAA is doing a lot less while also using a LOT more automation. It is a racket, and this Post provides some insight into the racketeering co-lobbyists.

Click on this link to download the 4-pg PDF, for viewing offline, and feel free to share it onward.

Use the embedded PDF below to read the PDF online; dwell on the bottom left corner of the PDF to use up-down arrows (for page scrolling) or to zoom in/out.

20230920.. An FAA Forecast, Actual Ops Trends, and do We Need More ATCs (4p)

Categories
AvImpact-Noise

What Do We Need from FAA to Mitigate Aviation Impacts?

This Post returns to the impacts around KAPA, but also discusses JFK Airport (KJFK). These two airports offer an excellent example of the two largest impacts FAA is currently having on residential neighborhoods in the U.S.: ‘concentrated & repetitive’ closed pattern work associated with flight schools at KAPA, and ‘concentrated and repetitive’ arrival and departure streams associated with NextGen procedures and especially intense at KJFK and other larger commercial hub airports.

This Post also attempts to identify key elements of what we, the people, need from the federal regulator in charge of this system and its amplified impacts.

Click on this link to download the 5-pg PDF, for viewing offline, and feel free to share it onward.

20230731.. From the Oceans to the Mountains, What Do We Need from FAA to Mitigate Aviation Impacts (aiREFORM, 5p)cn2101
Scroll over the PDF above to activate the PDF viewer controls at the bottom; page-scroll with the arrows in the bottom left corner, or use +/- to zoom in/out.

Categories
AvImpact-Noise

Flight Training Impacts at KAPA & KBJC: An Analysis of the July 7th Denver Post Article

Below is a PDF copy of the text for a good article, published in the Denver Post, on July 7th. The writer, John Aguilar, provides a deep news compilation on how residents are severely impacted by airport operations at and near Centennial Airport (KAPA), and the Rocky Mountain Metropolitan Airport (KBJC).

This analysis by aiREFORM goes further. It is a markup of the Post article, with footnotes that expand on (and in a few cases clarify or correct) portions of the article. The goal of this analysis is to aid readers in better understanding the impacts. It is also to help more people navigate past the obstructionism and confusion seeded by FAA, the airport authorities, AOPA, and other aviation parties.

Click on this link to download the 10-pg PDF, for viewing offline at your leisure.

Use the embedded PDF below to read the PDF online; dwell on the bottom left corner of the PDF to use up-down arrows (for page scrolling) or to zoom in/out.

20230707.. Suburban residents battle noise, lead pollution from busy metro Denver airports (J.Aguilar, DenverPost, 10p,markup)cn42-KAPA

Categories
Airports

KAPA: FAA and Mike Fronapfel Need to Be More Transparent

Click on this link to download the 5-pg PDF.

20230511.. FAA and Mike Fronapfel Need to Be More Transparent (zz32KAPA, 5p)

Categories
AvImpact-Noise

In Letter to CACNR, FAA Regional Administrator Grady Stone Concedes Pattern is Elongated but Falsely Claims Traffic Volume is the Reason

Centennial Airport (KAPA, southeast of Denver) is one of the current top five impacting airports in the U.S. These are general aviation impacts, caused by small single-prop and twin-prop planes staying in the pattern and doing touch-and-goes to the west parallel runway (runways 17R/35L).
Back in May 2021, there was a midair collision when a Cirrus arrival to 17R overshot the final approach course (the line extending north of runway 17R); its prop slashed a series of cuts into the top of the fuselage of a KeyLime metroliner on final to land runway 17L. Amazingly, nobody was killed.

It is one thing for a midair to happen far from an airport, when two planes just randomly meet. But, this midair was particularly troubling, because the flights were being controlled by KAPA tower controllers. Through complacency, they failed to actually work the 17R arrival; they failed to apply positive control by extending the Cirrus on the downwind for just a few more seconds, and they failed to assure the pilots actually saw one another.

This failure triggered a reaction by FAA management: complacency was to be checked, and positive control was to be rigorously applied. But, no policies were implemented to actually LIMIT the number of aircraft in the pattern. Thus, abandonment of the near-lethal complacency standard forced KAPA ATC personnel to extend the overfilled 17R pattern to the north, impacting residents below.

Here’s a screencap showing two hours of KAPA flights last December. It is an ugly picture, but the numbing and incessant drone is even uglier. A red box has been added, outlining the region where base turns would happen in a pattern not overfilled with too many flights. Note the current 17R ‘pattern elongation’ extends miles further to the north, even over the reservoir. Note also that, if ATC chose to reduce risks and limit the number of aircraft staying in the 17R pattern, the base turns would be mostly confined to the smaller green box, much closer to the runway… and the impacts on residents would be significantly reduced.

This is the core frustration thousands have with FAA, CACNR, and the airport: the impacts are huge, and nobody is cooperating to mitigate the impacts.

More than two months ago, FAA attended a Centennial Airport Community Noise Roundtable (CACNR) meeting, on February 1, 2023. Questions then produced this 9-page letter from FAA Regional Administrator Grady Stone, to the CACNR Chair, Brad Pierce.

The letter is long and dry and somewhat confusing. Many of the FAA answers refer back to earlier answers, which tends to diminish letter comprehension. To fix this problem, a modified version of the original letter has been created; content has been reformatted, and each question and FAA answer is provided within a table. Reference portions have been added using a smaller red text. Two dominant response ‘themes’ have been highlighted in color: FAA’s declaration that they did not change how the KAPA traffic pattern is managed (oh, really?!?), and FAA’s assertion that they lack authority on many aspects of air traffic management such as making decisions about numbers of operations (yeah, right!!). Use these links to view copies:

  • [link] to view the modified version of the original letter, or
  • [link] to view a PDF copy of the original 9-page letter.

There was a third dominant response ‘theme’ in the FAA letter, and it is a doozy: a false claim that the KAPA traffic pattern has ‘elongated’ due to increased traffic volume. This is interesting. While the bulk of the letter is just repetitive denials by FAA, within the letter FAA does concede REPEATEDLY that, yes, the traffic pattern has elongated. But, instead of also conceding the cause of elongation we all know (reaction to the May 12, 2021 midair collision worked by the KAPA control tower), FAA insists traffic volume is the cause. As the Analysis below clearly shows, FAA is wrong, and FAA is lying.

A PDF copy rebutting FAA’s false claims about increasing traffic volume at KAPA is embedded below; move the cursor to the bottom left corner and use the up-down arrows to scroll through the three pages.

20230413.. Debunking false detail in ANM.RA.G.Stone’s letter, KAPA ops counts are solidly down (zz32KAPA, 3p)
Scroll over the PDF above to activate the PDF viewer controls at the bottom; page-scroll with the arrows in the bottom left corner, or use +/- to zoom in/out.

Categories
UnspinningTheSpin

Rep. Scott Perry talks about ‘Pucker Factor’ while aiding AOPA Dispensing Leaded Fuel Disinformation

Some bizarre disinformation was shared during a dialog at a House Aviation Subcommittee hearing on March 9th. Click on this [link] to Watch the video (4:27).

It is a fairly classic study in how elected officials conflate different issues while grandstanding with statements that make their target audience smile, despite the fact the statements are easily shown to be flat out lies. Regardless of party, we are all so tired of the abuse of technologies to share shreds of information that deceive, leading far too many minimally informed people to dead-end and even dangerous nonfactual opinions. This pattern has become quite entrenched: screw serving those in your actual district; instead, take every opportunity to connect with an elite nation-wide group with the money to donate, if and when they feel you are a crusader for their privileges. Is it any wonder we have become so divided and uncivilized in the last decade?

Attendance was low at a hearing apparently chaired by Rep. Rudy Yakym (R, IN), a House newbie and Vice Chair.

In this case, a Representative from Pennsylvania was blowing dog whistles to his buddies in the aviation community, by leading a dialog that aimed to scare people into thinking small planes are crashing because leaded fuel has been banned at an airport in Santa Clara County. He alludes to a dangerous crash in July 2022, by a small plane departing Reid-Hillview Airport [KRHV] in the eastern neighborhoods of San Jose. The facts of that accident are relatively simple: the pilot had brought his aircraft in for maintenance; days later, he chose to take off with nearly zero fuel, and  his engine died less than a half-mile from the runway end; he crashed (euphemistically a ‘forced landing’) between houses and a schoolyard.

The Representative, Scott Perry (R, PA), used the forum of an aviation subcommittee hearing to initiate a dialog with a guest, Mark Baker, who is the leader of a large aviation lobby, AOPA (Aircraft Owners & Pilots Association). The two are both aviation bosom buddies, as Perry flew helicopters in the Army. The pair spin the accident as a ‘mis-fueling’. Think about that: a pilot knowingly takes off with near-zero fuel, and our elected officials and lobbyists have a public discussion implying it was a fueling error? Perry goes even further to connect it to “…insane Green New Deal woke ideology…,” not once, but repeatedly.

The dialog goes on with Perry waxing about ‘Pucker Factor’ … something he surely understands, given his role in trying to overthrow the last Presidential election results. Google it, and decide for yourself, the quality (or lack thereof) of this particular Representative.

At one point, Baker replies to Perry’s query with a statement, “…but the engine came apart, uh, slightly after takeoff.” That’s not what the NTSB found, not at all. No, Mark, the engine ran out of fuel. That is a risk, enabled by any pilot who ignores a near-empty fuel tank and takes off. Gravity does not give a damn about pilot stupidity, and this guy was lucky to survive (just as residents were lucky he did not kill any others within the impact zone).

A little background:

This hearing was by the Aviation Subcommittee of the House Committee on Transportation & Infrastructure. The Wikipedia page for the subcommittee is not yet updated, so, if you want to investigate the Aviation Subcommittee membership and activities, you will need to use this link to the actual Congressional subcommittee webpage.

AOPA is the principal US lobbyist for general aviation pilots and small-plane owners; been around since 1939, and has been very successful maneuvering electeds to grant huge subsidies to private pilots, while also ensuring FAA serves aviation and protects pilots and airports from people. It is not a stretch to note: AOPA is the NRA for those who own or fly aircraft. And it is a fact that, the number of pilots who fly recreationally and/or solely for personal use are outnumbered roughly 1,000 to 1 by the rest of us (really… less than 0.1% of the population are pilots but not employed as pilots!). This elite group garners the privileges and protections of FAA and Congressional subsidies, to impose lead pollution, air and noise pollution, and damnably inappropriate safety risks upon the much larger civilian population.

Below is a 6-page PDF document compilation, including a transcript of the portion of the hearing (2p), a copy of the NTSB Preliminary Report for the crash (2p), and a third 2-page document, which was testimony submitted to a Part 16 process. This third document is interesting, because it was created as a witness statement but aimed at advocating against the ongoing ban on leaded fuel sales at Reid Hillview Airport. Part 16 is an administrative hearing process in which privileged members of the aviation community are empowered to voice a complaint, and FAA jumps through hoops to accommodate. This particular Part 16 filing was AOPA vs Santa Clara County Airports. Yup, Mark Baker’s AOPA, the small plane and pilot lobbyist, using Part 16 to prolong the right to pollute toxic lead while flying recreationally, because the health of kids and non-aviation residents pales next to the glory of flying. In this context, it is not surprising Baker would happily engage in lies and disinformation, when dialoging with Perry at the March 9th subcommittee hearing.

KRHV.20230320.. 3 docs re N300BH PA28 crash & 09MAR Hearing where Perry & Baker call it a misfuel (6p)

Categories
AvImpact-Lead

[KAPA]: Monthly Fuel Flowage Data for 2021

Data was recently obtained by activists impacted under the flight training ‘closed pattern’ at Centennial Airport [KAPA]. The data shows ten years of monthly fuel flowage figures, both in gallons and revenue dollars; it is all compiled into the spreadsheet below:KAPA.20230327.. Fuel sales & revenues by month for CY2021 (1p)

Background:

At most General Aviation (GA) airports, the two largest revenue sources are leases (for hangars, land, or parking spaces), and the ‘fuel flowage fee’. This is an amount, commonly between a nickel and a dime per gallon, supposed to be assessed on all fuels dispensed at the airport. As such, the fuel flowage fee revenue data provides a valuable metric for evaluating airport activity. Sadly, airports often make it difficult or impossible to get this data. Fortunately, this time, the data was produced.

Something Unusual: the Airport Authority reduced fees and took a large revenue loss

Starting in 2018, the airport authority chose to reduce fuel flowage fees by roughly a third. This was an odd ‘business’ move, a huge gift to pilots that reduced airport revenues. In the first year, fuel flowage fee revenues dropped 30%, while volume sold went up 5%. For the four years 2018 onward, versus the six years prior to lowering the fuel flowage fees, there was a 25% decline in revenues and ~12% increase in fuel sales.

Questions Raised by the Data

  1. for the AvGas portion, the data indicates that, in an average year, as much as 2,900 pounds of lead are dispensed for use by KAPA aircraft. Can the airport authority clarify, precisely how many gallons of unleaded fuel were sold during each month of the past ten years? (i.e., what percentage of the avgas sales data were for 100LL, versus other types of avgas)
  2. what was the intent (as articulated by airport management and/or the Board) and the reason for the reduction in fuel flowage fees in 2018?

Suggestion for Improving Airport Transparency

Fuel flowage fee revenues and other metrics should be shared by each airport authority, with their impacted communities. FAA would do well to mandate this type of transparency, especially regarding data that quantifies aviation impacts.