Responding to the Eshoo-Farr Letter of January 25, 2016

See the original letter of January 25 from Representatives Eshoo and Farr to attendees of the Quiet Skies Summit of January 16. See the response from the Mid-Peninsula group, hammered out over three weeks and signed by representatives of Los Altos, Los Altos Hills, Menlo Park, Palo Alto, Portola Valley, and Woodside. See the response from Quiet Skies NorCal signed by representatives of Los Gatos, Soquel, and Saratoga.

Quiet Skies Mid-Peninsula sought to respond to the Eshoo Farr letter with a consensus of all the cities present at the Quiet Skies Summits of January 16 and February 20. We thought that we should start by trying to establish a consensus with neighboring cities...believing that getting representatives from six nearby cities in the same Starbucks would be easier.

We were surprised by the diversity of opinion among even the mid-peninsula group. Some wanted to articulate solutions while others wanted to articulate principles. Specific solutions and principles varied. In the end, rather than reach consensus on details at a 1,000-foot level, we were forced to reach consensus on ideas at a 100,000-foot level. Once we hammered out our consensus letter, we offered our letter to cities beyond the mid-peninsula by email on February 25, but received no suggestions for how to modify our letter to make it acceptable to other cities. Our strategies were perhaps simply too much at odds.

We obtained a copy of the letter prepared by Quiet Skies NorCal on March 2, but have declined to endorse their letter. The remainder of this page seeks to explain why.

Let's start by realizing that we all have a common goal: we want the FAA to undo the damage it has inflicted on our communities and the Bay Area at large. There is a genuine disagreement about how to best achieve our collective goal, combined with some very strong emotions and some unfortunate group dynamics.

We understand wanting to pursue a solution which can bring immediate relief. We all want that. While we believe the group proposing this solution has worked hard, synthesized a lot of data and input from people in multiple communities, and done impressive work, we ultimately came to the conclusion that, while it could have positive impact, it’s not a slam dunk for LAH--and our neighboring cities have agreed.

Consider the following:

1. We can't know with certainty the impact of the proposed solution on our community: no noise modeling has been done, and the amount of noise we hear on the ground depends on temperature, humidity, geographic topography, type of aircraft and how it’s being flown, and psychoacoustic factors. Even then, a model is not the same as the real world results, especially when you take into account that airlines do not always fly a published procedure as-specified: airlines have a lot of discretion, and pilots may receive different direction from Air Traffic Control from time-to-time (delay vectoring, weather conditions at SFO, etc).

2. We don’t know how the FAA will evaluate the proposed solution, and if they will implement the proposed solution in whole or in part (e.g. change the path but leave in-place the noisy non-idle descent). We also don’t know what the FAA will do in the future (it’s unlikely the FAA will never want to change arrival and departure routes in the Bay Area again). Thus, the proposed solution comes with risk: once the routes are changed, especially without an agreement on how the entire region will evaluate the success or failure of a proposed solution, it may be very hard to change it back. What will happen if some communities find significant improvement in noise but others find no improvement or, worse, find increased noise. The specific proposal of moving the SERFR route back to the old BIG SUR ground track means these associated risks will be disproportionately borne by the mid-peninsula.

3. The proposed solution may well succeed in reducing the noise we hear per-plane but, by reducing delay vectoring (which currently spreads out plane traffic across a wide area), it could increase the number of planes over our homes. How does that net out: is the result an overall reduction in noise, or an overall increase?

4. Even if, in the end, the proposed solution makes the noise better for us: by how much will it improve? And, given NextGen’s stated goal of increasing capacity for more planes, for how long? Is there a better solution which would yield a greater, and more fair, reduction in noise on the ground?

Any proposed solution has these risks, which is why we believe it’s important to start by specifying the specific noise reduction results we wish to achieve, the process we want the FAA to follow in rolling out changes, and how we will evaluate the success of our efforts so that we have the opportunity to make corrections.

We believe this is a case of “be careful what you ask for”. The FAA is facing angry citizens in many locations around the country (e.g. New York, Chicago, Boston, Phoenix, San Diego, Washington DC) and, while we have their attention now, we believe there is a real risk of the FAA making nominal changes, declaring “victory”, and moving on. That could leave the residents of the mid-Peninsula holding the proverbial bag.