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November 7,2003
The Honorable Barbara Favola
Chair, CONAANDA and Part 150 Community Advisory Committee
777 N. Capitol St. NE, Suite 300
Washington DC 20002-4290
Dear Ms. Favola:
In response to your committee’s request for suggestions from citizens on
what should be included in a major update of the” Noise Compatibility Study”
for Reagan National Airport, Advisory Neighborhood Commission 3D (ANC3D) in
the District of Columbia forwards to you the following recommendations,
endorsed by the commission at its meeting on Nov. 5, 2003.. The
recommendations are based in large measure on the June 19 public hearing on
aircraft noise sponsored by the Community Advisory Council and established
as part of the noise study (an ANC3D report on that meeting is attached.).
ANC3D is an elected, D.C. government body representing the interests of
such neighborhoods as Foxhall, the Palisades/Kent, Spring Valley and Wesley
Heights, with a total population of around 20,000. ANC3D is uniquely
qualified to comment on airport noise since it represents the section of the
District most directly affected by noise of airplanes taking off and landing
at National Airport. It is not all unusual for our neighborhoods to be
subjected to aircraft noise exceeding 65 decibels–the accepted threshold for
determining when noise becomes objectionable It is with the hope of reducing
the adverse impact of that noise that our commission submits the following
recommendations:
Curfew– Many of our citizens suffer under the understandable
misunderstanding that there is a 10p-7a curfew on flights in and out of
National that is constantly being violated by the airlines. Indeed, at one
point there was a de facto curfew as the Federal Aviation Administration set
noise standards for takeoff and landing of aircraft that older generation
aircraft could not meet. With the introduction of newer, quieter aircraft,
planes are routinely flying over our homes late at night and in the early
morning house, disrupting our sleep, polluting our air and lowering our
quality of life. We feel the time has come for a seven-hour curfew from 11p
until 6a on all flights. We believe this would strike a fair balance between
the needs of the airlines and their passengers and the physical needs and
inalienable right of our residents to get some sound sleep. The airlines
would be able to schedule late-evening arrivals from departures in earlier
time zones, such as Chicago. Early departures would be permitted for
passengers seeking a head start on their business trips.
The airlines would be accommodated in their scheduling, but a new balance
would be struck between the profit-driven needs of the airlines and the
needs and desires of those living under the fight paths of their airplanes.
The time has come to accommodate the beleaguered residents living under the
flight by establishing a curfew that would guarantee them seven hours of
noise-free sleep. In striking a balance, it is noteworthy that our
neighborhoods, unlike many other neighborhoods near airports, did not expand
under the flight paths but existed long before the current frequency and
noise of aircraft operations out of National.
Compliance and Enforcement–The Federal Aviation Authority and the
Metropolitan Washington Airports Authority must assume responsibility for
enforcing existing and any future noise-abatement measures. We were amazed
and appalled to be informed at the June 19 meeting that compliance with
noise restrictions at National is voluntary on the part of the airlines and
their pilots and that there is no enforcement of the restrictions by
National Airport or the FAA. When it comes to the airlines, this laissez
faire attitude is analogous to the old saying about letting the fox into the
chicken coop, The airlines, of course, comply with safety restrictions; if
they do not, they are fined by the FAA.. But when it comes to noise, the
airlines can evade the noise restrictions and never be put on report, much
less fined. Ever mindful of the bottom line, airlines are tempted to cut
corners to save money and to suit the pilots’ convenience. Thus, at the June
19 hearing, several residents from Virginia and Maryland complained that in
recent months airplanes had been observed taking shortcuts from the
designated flight path, turning right or left before reaching the American
Legion Bridge, the designated turning point. Nobody seems to care except the
homeowners on the ground.
We urge that National Airport and the FAA institute a
compliance/enforcement program in which it monitors individual aircraft,
their flight patterns, and their observance of clear-weather flight paths
over the Potomac, all of which is feasible with modern radar and computers.
We then urge that National Airport and FAA put on report those individual
flights that do not comply with noise restrictions that repeated offenders
be fined, and that a public record be made of the offenders. The latter
public report may prove to be the most effective enforcement mechanism for
it will permit the public to boycott airlines that consistently ignore the
noise restrictions.
Flight Paths–There is a common complaint in our neighborhoods that even when
visibility is good, airliners do not necessarily fly over the Potomac River
even though that is the designated noise abatement path for aircraft
approaching National from the North. Instead, they tend in our neighborhoods
to take a path to the east of the river, putting them over residential
neighborhoods in the Palisades. In other cases, when instrument landing
rules are not in effect, pilots, at their own discretion as we understand
it, choose to follow the ILS approach which takes them at low altitudes
directly over homes in Palisades/Kent until they reach the turning point at
Georgetown Reservoir. For the pilots it is a much easier, indeed automatic
approach, less demanding than banking to keep over the turns of the Potomac.
But this is another case where the convenience of the pilot must give way to
concerns of those on the ground. We recommend strict enforcement of a rule
that pilots must fly over the river unless instrument landing conditions
prevail, and when
they do not, a pilot must receive special permission from the control tower
to use the ILS path It should be pointed out that planes approaching on the
instrument approach present
a particular sound nuisance in the Palisades/Kent neighborhoods. The planes
tend to be noisy because they are flying at low altitudes, and when they
reach Georgetown Reservoir they send out a blast of noise as the pilots rev
up the engines to offset the drag of landing gear lowered at that point. The
landing procedures need
reexamination.
Future Control Measures– We understand that new flight management systems
are coming along, using such technologies as Global Positioning Satellites,
that will permit pilots, even in adverse weather conditions, to follow the
Potomac River. We urge that National Airport be given priority for
installation of such a system on the grounds that few if any other airports
in the nation are so plagued by a location in the middle of an urban area
with approach and takeoff paths that take aircraft directly over residential
and commercial areas.
Safety–Safety considerations would dictate keeping the planes on flight
paths over the river. Should a plane crash while over the river, there would
be much less likelihood of the plane causing disastrous damage in a
residential area.
Air Pollution–The exhaust of airplanes contribute a significant portion to
the air pollution plaguing the Washington Metropolitan area. At the same
time the Washington area is struggling to meet air quality standards set by
the federal government. We urge that aircraft pollution be taken into
consideration in number of scheduled flights, the type of aircraft permitted
to land and takeoff, and restrictions on flights when “Code Red” condition
of air pollution prevails. It seems to us that in addition to the noise
pollution, air pollution becomes a determining factor in resisting
Congressional pressure to increase the number of flights out of National.
Hearings–We found the public hearing conducted by your advisory committee to
be a useful exchange of views between government and citizenry in the best
democratic tradition. We urge that the dialogue be continued and that even
after your current study is completed, you hold periodic public hearings so
the citizenry can voice their complaints or suggestions and the government
can respond. Part of the problem in the past was that the citizenry felt the
National Airport and FAA turned a deaf ear to their complaints.
Submitted on behalf of ANC3D,
John W. Finney
Chair, ANC3D |
