Taxpayers for Responsible Planning

M E M O R A N D U M

TO: Distribution List

FROM: Executive Director, Bill Kogerman, Taxpayers for Responsible Planning (TRP)

SUBJECT: Noise Demonstration Considerations

DATE: August 7, 1998

Background. The County of Orange has formally considered and has set aside funding for an aviation "noise demonstration". In discussing this potential event, county agents have publicly disclosed that the conduct of an aviation "noise demonstration" need not be "overly realistic".

The public is left with the question, "what is the objective of any aviation noise demonstration? The answer should be obvious, but at a recent El Toro Citizen's Advisory Commission, the public testimony suggests otherwise. In providing input to defining the parameters upon which a noise demonstration would be based, the basic issue of the objective of such a demonstration is immediately raised.

Should the county limit an aviation demonstration to one specific variable, noise? If the County of Orange truly desired to sample the myriad of impacts of an aviation development of MCAS El Toro, wouldn't it be reasonable to expect such a demonstration to sample a host of aviation variables including: potential ingress and egress routing, airspace conflicts, impacts of particulate matter fall-out, etc?

If noise were the single issue in the El Toro reuse issue, couldn't the county save considerable money by simply transporting interested taxpayers to operating airports as John Wayne, Ontario, and Los Angeles International and have them experience the noise first hand? Tapes could then be made of aircraft noise with comparisons to everyday noises and provided to our citizenry if all we wanted to examine was aircraft noise. The conclusion that is obvious is that the County of Orange has shown little intention to conduct any meaningful aviation demonstration.

The public can legitimately suspect the entire proposed project because of statements made by county officials, the timing of the proposed event - prior to an election in November which pits an airport supporter against a non-aviation proponent - and the necessity to quickly expend public funds at a time when the issue is not yet political, i.e. not the subject of an initiative measure. However, in the interest of providing germane input into the design of a meaningful aviation demonstration related to the proposed commercial airport at MCAS El Toro, the following minimal guidelines are provided.

Project Parameters - Flight Profiles. Demonstration flight profiles must conform to all conceivable flight paths that could be approved by the Federal Aviation Administration (FAA) for MCAS El Toro. Each aircraft operation proposed in the Community Reuse Plan (CRP) and the Environmental Impact Report (EIR) #563 must minimally fly these flight paths. Additionally, all flight paths proposed since the submission of said documents and currently being studied by the County of Orange, as well as all conceivable flight paths resulting from a potential runway reorientation including: the proposed runway schemes under the county's plans and any reorientation from runway 34/16 to either 31/13 and/or 32/14 as proposed by the Airline Pilot's Association (ALPA) and others must be part of the demonstration.

Demonstration flight profiles must provide for all flights by commercial aircraft envisioned under current plans including all probable transitions from flights departing known air services routes from existing airports and arriving at MCAS El Toro. Such routing must be flown at such airspeed and altitudes and upon such arrival courses as can be anticipated by credible air space managers, both under Instrument Flight Rules (IFR) as well as IFR with a Visual Approach approval.

Included in the arrival parameters, provisions for aircraft approaches to MCAS El Toro must include, at a minimum, realistic profiles for aircraft intercepting the final approach fixes at the 6, 7, 8, 9, 10, 11, 12 and 13 mile distances for approach to runway 34 (which is the County of Orange's planned primary arrival runway). Similarly, both visual and instrument approach criteria to secondary approach runways must be demonstrated including approaches to runways 16, 07, and the proposed 31/13 and 32/14. Departures from each of MCAS El Toro's runways - 34/16, 07/25 - must also be demonstrated since such departures are "feasible" and probably enforceable. Moreover, circling approaches, missed and lost communication approaches must also be demonstrated. The arrival and departure procedure used in any demonstration must conform to those realistically appropriate for commercial operations at MCAS El Toro. Since dual runway operations are part of the county's proposed airport plan, concurrent departures and arrivals must be demonstrated.

Emergency procedure operations must be demonstrated including flying flight paths that would be envisioned in the event of loss of engines, communication or navigational equipment, and exergencies requiring expedited handling.

All flight paths used in a demonstration must conform to a normal integration into the existing Air Traffic Control (ATC) system. Angled approaches respecting wake turbulence considerations must be demonstrated. Multiple simultaneous aircraft approaches and departures must be demonstrated to provide a sense of the synergistic aircraft environmental impacts. In all respects, the demonstration design should replicate as closely as possible anticipated actual operational conditions. Noise abatement procedure should not be made part of any meaningful demonstration.

Aircraft Configuration. The conduct of any meaningful demonstration must include representation by all aircraft that would reasonably be used at a commercial facility located at MCAS El Toro. Departing aircraft must demonstrate take-offs at maximum gross weight configurations. Arrival aircraft must demonstrate IFR and Visual approaches at their maximum allowable weights. The aerodynamic configurations for all arrival and departures must conform to industry standards and policies. Fuel loads must be planned to appropriately respect the requirement for en route reserves. Arrival and departure operations must be consistent with realistic altitude, speed, and power requirements. Passenger payloads may be demonstrated through the use of equal weights of cargo.

Type of Aircraft. Any meaningful demonstration must include participation of all models and types of commercial and private aircraft anticipated to be included in the aircraft mix envisioned for a commercial airport at MCAS El Toro. Any meaningful demonstration would not rely solely on the Boeing 757 since this "relatively quiet" aircraft would unrealistically skew the noise data. More appropriately, the 727 (with Stage III hush kits), the 737-300 ER, the 747 Series, the DC-10 and the MD-80 series aircraft must be included. Additionally, any meaningful demonstration must provide flights by representative corporate jet and turbo prop aircraft and such other aircraft less than 75,000 pounds in weight that would typically use the facilities at the proposed commercial airport.

Frequency, timing and meteorological conditions. Any meaningful demonstration would necessarily mirror the level of aircraft operations at peak hours sampling the maximum anticipated daily flight operations rate - in the Orange County's Option "C: that amounts to 492 daily operations, the demonstrations should then provide flights no less than 8 per hour and up to 12 per hour for peak hour comparisons. Such a sampling should replicate the impacts of a multitude of aircraft arriving and departing the El Toro area in a concentrated format over realistic demonstration periods. The demonstration periods should cover early morning, 0600 - 0900; midday, 1100 - 1300; late afternoon 1500 - 1700; early evening 1800 - 2000; late evening, 2100 - 2300; and late night, 0100 - 0400. The demonstration should be conducted in two sessions to compare the resultant environmental impacts during the spring/summer and fall/winter seasons.

These widely phased demonstrations should be conducted during periods of day/night visual meteorological conditions as well as day/night instrument conditions, to permit speculation as to the nature of the impact of weather - particularly cloud cover - on the variables under study.

Announcement, Measurement and Certification. Any meaningful demonstration must be publicly announced 30 days in advance of its commencement. Said public announcement should include media press releases, mailed notification to all residents residing in the anticipated over flight and or noise "impact areas", appropriate clearances from the Department of Defense (DoD), Federal Aviation Administration (FAA), local Air Traffic Controls (ATC), and local aviation facilities.

Residents residing in the anticipated "Impact areas" should be appropriately notified how to measure the nose of test aircraft and where/how to register their opinion of the demonstration. Additionally, such public announcement of the demonstration should contain a complete and accurate schedule for the event including: aircraft type, planned aircraft weights, altitude and speeds, aircraft configuration, direction of ingress/egress, maneuver, and time of event. Upon completion of the demonstration - which should be conducted over two (2), three (3) day's periods containing two (2) weekdays and one (1) weekend day - a complete and accurate "actually flown" schedule should be made public.

Finally, the issue of certification - truth in performance - must be addressed. While the best intentions of those proposing to conduct the demonstration are at question and while a failure to sample the full range of variable associated with the development of a major airport in an urban area will offer little more than a hint of the associated negative environmental impacts, no level of credibility will exist in such a demonstration unless there exists a system for certification of the events and results.

Therefore, it is essential to this project to ensure that bipartisan - pro and anti-airport - advocates monitor the entire process. These monitors should be made cognizant of all the scheduled events and provided access to all the relevant data under which the demonstration was conducted. Competent flight crew monitors must be permitted to participate in flight operations. Competent air traffic experts must be given access to Air Traffic Control during such operations. Competent environmental scientists must be permitted to monitor the events and take such measurements as required.

The document has been edited for website publication.