"Final" Environmental Assessment; FAA's Request Comment on Chatham Airport's drafting of a

[Stephen Buckley]

Dear Mr. Doucette,

A very long time ago when, as a "NEPA nerd", I was working in the FAA's Office of Environment and Energy (AEE-200), my boss showed me that I could use my computer to go "online" rather than walk over to the U.S. EPA Library.

I quickly realized that, someday, people would no longer have to go to their local library to review NEPA documents .. someday, they use their personal computers to easily access, and comment on, the documents that federal agencies were using to make decisions that affected people's everyday lives.

And so, a new age of democracy would bloom!  (Or so I thought.)

Rather, federal bureaucrats (like I once was) have figured out that they can largely avoid dealing with the concerns of everyday people by using "information overload" combined with "bureaucratese".

The small airport in my hometown has, with money from the FAA, been upgrading its facilities.  Local people, residing near the airport, have noticed an increase in the amount of air traffic, along with an increase in the number of larger, more noisy, aircraft.

This, they feel, has affected their quality of life.

Now, the airport wants to upgrade its facilities even more .. to make its operations "safer".  However, the local people are concerned that "safer" will result in additional air traffic .. with additional noise .. and a negative impact on their quality of life.

Theoretically, their concerns would be properly considered by the FAA, before making a decision to fund those upgrades, as it is required to do under the National Environmental Policy Act of 1969 (NEPA).

However, the Environmental Assessment (EA) provided to the public by the local airport (not the FAA) provides no assessment about how the proposed upgrades might increase air traffic .. and, therefore, no estimate on how those FAA-funded upgrades might result in increased noise-levels to local residents.

According to the EA, there is no need to assess the impact from increased noise because because "forecast operations" (which are not provided in the EA) would not increase significantly enough to warrant an assessment and, therefore, any consideration by FAA of any increase in local noise-levels:

FAA Order 1050.1F, Appendix  B states that, “No noise analysis is needed for projects involving Design Group I  and II airplanes (wingspan less than 79 feet) in Approach Categories A through  D (landing speed less than 166 knots) operating at airports whose forecast  operations in the period covered by the NEPA document do not exceed 90,000  annual propeller operations (247 average daily operations) or 700 annual jet  operations (2 average daily operations).”  

See EA, page 10:

https://www.chatham-ma.gov/DocumentCenter/View/3667/CQX-Final-EA-7-15-2021-Report-Section

So, if we use our personal computer to locate "FAA Order 1050F",  we first find it here:

https://www.faa.gov/about/office_org/headquarters_offices/apl/environ_policy_guidance/policy/faa_nepa_order/

Specifically, the section on FAA's not considering an increase in noise-levels (Appendix B, page 112 of 132, pdf):

https://www.faa.gov/documentlibrary/media/order/faa_order_1050_1f.pdf

.. which then refers to another FAA document on what, they consider, to be a "signifcant" level of noise":

https://www.faa.gov/about/office_org/headquarters_offices/apl/environ_policy_guidance/policy/faa_nepa_order/desk_ref/

The interesting thing is that this "Desk Reference" (see page 4) says that it is okay to use a "noise screening tool" to confirm that an increase is insignificant .. for a less intensive NEPA document than an EA (!):

"Aircraft noise screening may rule out the need for more detailed noise analysis and provide documented support for a Categorical Exclusion (CATEX) if screening shows no potential for significant noise impacts." 

However, there is no way for anyone, even a former FAA environmental engineer, to challenge the thinking regarding the insignificance of increase in noise-levels .. if there are no numbers on air-traffic increase in order to plug into FAA's formula for noise-levels.

sincerely,

Stephen Buckley