for the
EL TORO REUSE PLANNING AUTHORITY
by Eric G. Walther, PhD 21772 Northwood Lane Lake Forest, California 92630
March 17, 1997
Thank-you for this opportunity to talk with you about the potential noise impacts of the international airport proposed for the El Toro Marine Corps Air Station.
My purpose is to provide you with scientific information on noise and its impacts on human health, and to encourage the citizens of Orange County to develop a more beneficial reuse of the base.
My Professional Background
• My PhD is in atmospheric science.
• I have thirty (30) years experience conducting environmental research, including serving as a U.S. consultant to the United Nations.
• I have authored 50 scientific articles and hold a U.S. patent on measuring air pollution.
• My technical specialization is air pollution, including noise research I conducted for the National Science Foundation.
• I am the responsible director and author of several EIS/EIR air quality analyses for projects whose future revenue to southern California are worth over $30 billion.
Noise Issues
The Environmental Impact Report (EIR) prepared for Orange County violated the California Environmental Quality Act (CEQA) by not disclosing to the public the full magnitude of damage that will be inflicted by noise from the proposed international airport
The preparers of the EIR claimed that the CEQA tiered analysis process did not require them to provide more information in the first tier document that was certified by the Board of Supervisors on December 11, 1996. They took advantage of public confusion over the difference between providing more details versus disclosure of the full magnitude of impacts. CEQA allows more detail to be deferred to later tiers of analysis. On the other hand, CEQA requires, even in the first tier analysis, that the full scope and magnitude of environmental impacts be disclosed to the public.
Concerning noise, the Response to Comments in the Final EIR presented a new curve (Illustration 8) that dropped to only 2 percent the frequency of awakenings caused by 70 dB single events, down by a factor of 25 from the 50 percent awakenings published in the Draft (Illustration 9). This switch of curves without comprehensive scientific justification violates CEQA, which requires the use of the more conservative data in estimating maximum impact.
The EIR attempted to minimize the estimate of potential noise damage to human health by assuming people will close their windows and doors in response to aircraft noise. Such an assumption is not conservative, and hence, again violates CEQA. Properly conservative noise analysis cannot take advantage of a 20 dB reduction between outdoor and indoor levels by assuming all windows and doors are closed.
Completely aside from considerations of proper analysis, closing all windows and doors of homes in Orange County is tantamount to imprisoning us indoors after we chose southern California to enjoy being outdoors.
The EIR analysis of noise impacts ignored the 1972 aircraft noise study by the Orange County Health Department, perhaps because it reveals the following fatal flaw in the EIR noise analysis.
Potentially, a full 45 percent (Illustration 11) of the approximately 300,000 residents (Illustration 12) who would be exposed to at least 70 dB brief sounds, such as an aircraft overflight, will not be able to go to sleep.
At a frequency of one takeoff or landing every 3 minutes between 10PM and 7AM, sleep would not occur. Therefore, awakening from sleep becomes a meaningless question. There would be no sleep from which to awake.
The EIR did not disclose particularly relevant studies of potential noise damage to human health.
The 1993 study by Meecham and Shaw showed that noise around LAX caused the following:
• cardiovascular disease to increase 18% for people over 75 • suicides to double for people between 45 and 54 • accidental deaths to increase 60% for those over 75. • overall, approximately 60 more people died each year due to aircraft noise.
What would be the comparable excess death rate for a 24-hour commercial airport placed near Leisure World, Casa del Sol and other senior citizen residential areas in Orange County?
One of the nice things about noise impact analysis is that the lay person can use common sense drawn from real life experience. Ask yourself, how did you feel and what were the after-effects on you of the following when they occurred in the middle of the night?
• a loud sound system at a neighborhood party • a neighborhood dog barking incessantly all night long • your baby had colic throughout the night • a neighbor's car security alarm went off • a police helicopter flew over your house at low altitude • some yo-yo wound up his ninja motorcycle engine racing down the street
It becomes obvious after thinking about noise impacts on a common sense basis that , despite its ominous findings, the LAX study did not even analyze all potential impacts, including the following:
• infant awakenings and distress, leading to parental awakenings and health damage • non-lethal accidents the next day for people who work with potentially dangerous machinery and who did not get enough sleep
Misinformation on potential damage of noise has characterized other related documents as well as the EIR
For example, the November 21, 1996 Environmental Management Agency Staff Report to the Planning Commission misstated that "...jet aircraft generate more noise during take-off than they do when they make their approach."
As can be seen in Illustrations 16 and 17, arrival noise levels are higher, by up to 15 dB, than departure noise levels for Boeing 757, 767 and 737 aircraft. These are exactly the latest models that will increasingly make up the bulk of commercial fleets and are proposed to land directly over the 20,000 elderly residents of Leisure World.
Even the El Toro Citizens Advisory Commission and the Planning Commission both recommended Continued Study of Noise and other subjects
To the extent that these recommendations are based on the inadequacy of the EIR in disclosing the full magnitude of environmental impacts, such as increased mortality due to noise, the EIR will hopefully be found in current litigation to be legally uncertifiable.
So Where Do We Go From Here?
1. We work together to get this kind of scientific information out to the public in understandable terms.
We mobilize the local population to stand united in opposition to the airport because of its potential damage from noise, air pollution, lost home value and deteriorated quality of life.
2. We build an image of a far more beneficial use of the 4,700 acre base, which should probably be some combination of university extension, research park, general business and industrial development, recreation and off-airport terminal connected by rail to LAX.
3. We develop a third initiative for public vote in November 1998: the first vote of Orange County citizens having information available on the environmental impacts of an airport. List of Illustrations
FACT SHEET
on POTENTIAL NOISE IMPACTS
of proposed
INTERNATIONAL AIRPORT at EL TORO
• Noise levels are taken from Environmental Impact Report
(EIR) prepared by Orange County.
• Impacts published in EIR violated California Environmental Quality Act
(CEQA) by not disclosing the full magnitude of health damage that will
be inflicted on the nearby population by noise.
• Two-minute frequency of evening (7 PM to 10 PM) landings and departures
of jet aircraft would degrade the quality of life of nearby residents.
• Four-minute frequency of night (10 PM to 7 AM) landings and departures of jet aircraft would cause nearby communities to experience noise levels over 70 dBA, damage public health, and reduce the life expectancy of elderly citizens in Leisure World and the other nearby communities.
• Maximum noise level would be approximately 90 decibels (dBA, where A designates a frequency weighting that matches the response of the human ear) single event noise exposure level (SENEL).
• A noise level of 90 dBA is roughly equivalent to that of a power mower outdoors or a food blender in the bedroom.
• Suburban residents desire a noise level no higher than 30 dBA at night when they sleep.
• Suburban residents will accept a slightly higher noise level 40 dBA without undue complaint.
• A community will complain vigorously once people experience noise levels over 20 dBA above such acceptable levels.
• Note that reacting after the international airport is built will not unbuild it.
• At least 75 percent of sleeping people will be awakened if exposed to noise levels over 74 dBA.
• More importantly, over 50 percent of people will not be able to go to sleep if exposed to noise levels higher than 74 dBA.
• The resulting sleep deprivation would potentially affect over 100,000 of the 700,000 people living in the communities surrounding the proposed commercial airport.
• Three-minute frequency of daytime (7 AM to 7 PM) landings and departures of jet aircraft would degrade student learning at our local schools.
• Such noise levels would make teaching and other interpersonal communication difficult.
• Noise analysis by project proponents was deceiving because of the effect of mathematical averaging in reducing unsteady noise events like takeoffs and landings.
• The EIR attempted to minimize the estimate of potential noise damage to human health by assuming people will close their windows and doors to reduce aircraft noise by 20 dB.
• Forcing the closure of all windows and doors of a home is tantamount to imprisoning people indoors after they chose to live in southern California to enjoy being outdoors.
• A 1993 study showed that noise around LosAngeles International Airport (LAX) caused: - cardiovascular disease to increase 18% for people over 75 - accidental deaths to increase 60% for those over 75. - suicides to double for people between 45 and 54 - overall, approximately 60 more people died each year due to aircraft noise.
• The LAX study did not analyze the following additional impacts: - infant awakenings and distress, leading to parental awakenings and loss of sleep with its consequent health effects - non-lethal accidents the next day for people who work with potentially dangerous machinery and who did not get enough sleep
• What would be the comparable excess death rate for a 24-hour international airport placed near Leisure World, Casa del Sol and other senior citizen residential areas in south Orange County?
• How did you feel, and what were the after-effects on you, when you heard the following in the middle of the night? - a loud sound system at a neighborhood party - a neighborhood dog barking incessantly - your baby had colic - a neighbor's car security alarm went off - a police helicopter flew over your house at low altitude - a biker wound up his ninja motorcycle engine racing down the street
What do you need to do to protect your family?
• Ask yourself what you can do to get this information to your neighbors and friends who might be impacted.
• Ask yourself what you can do to mobilize the local population to stand united in opposition to the airport because of its potential damage from noise, air pollution, lost home value and deteriorated quality of life.
• Help build an image of a far more beneficial use of the 4,700 acre base, which could be a combination of university extension, research park, general business and industrial development, recreation and off-airport terminal connected by rail to LAX.
• Ask yourself how you can help build such an alternative image in the public eye.
• Would you support a third initiative for public vote, after having the availability of information on the environmental impacts of an airport?
This fact sheet was assembled by Dr. Eric G. Walther.
If you would like further information, write Dr. Walther at 21772 Northwood
Lane, Lake Forest, California 92630.
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