COMMENT TO FAA
OBJECT TO NEW PROCEDURES!
DEADLINE NOVEMBER 18!
CLICK HERE TO OPEN THE FAA'S COMMENTS FORM!!
Suggested comments below. Feel free to copy and paste. You can comment as many times as you like before November 18!
The proposed procedures will route 100% of Hollywood Burbank Airport's departure traffic over Santa Monica Mountains communities, 180+ jets per day, traveling in a narrow and low, concentrated path, causing massive disruption, noise pollution, and air quality and environmental degradation.
Demand an Environmental Impact Statement - the highest level of review under NEPA - based on the following:
Extraordinary Circumstances: A Categorical Exclusion (CATEX) is inappropriate in this situation where there are “extraordinary circumstances” such as degradation of 4(f) noise-sensitive protected parkland and monuments. The proposed procedures will multiply the negative environmental impacts and cause irreversible damage to the already dwindling parkland and wildlife in Los Angeles.
FAA Reauthorization Act: The proposed procedures directly contradict section 175 of the new FAA Reauthorization Act of 2018. The new procedures will send ALL 180 daily jets directly over hillside residents and many public parklands including the protected, Santa Monica Mountains Recreational Area – as well as over many Los Angeles Historic-Cultural Landmarks, including the Cantura Street Sycamores and the Laurel Terrace Historic Residential District. These are all, by law "noise-sensitive, 4(f)-designated areas." The public relies on their public parks as a quiet refuge from urban life and as a place to enjoy healthful recreation. A noisy jet superhighway will destroy this use and deny the public’s right to use their parks as they were intended to be used. Under section 175, the FAA must consider the feasibility of dispersal headings and/or other lateral tracks in order to avoid noise sensitive areas.
Highly Controversial: The proposed procedures have already been demonstrated to be highly controversial by the protests of thousands of community members (as evidenced by the Petition signed by over 3,250 people); the opposition of elected local, state, and federal officials; the opposition of Burbank airport itself; the over-capacity turnout at the recent Burbank-Glendale-Pasadena Airport Authority meeting and FAA Workshops; and blanket press coverage.
Cumulative Future Impacts: The CATEX does not consider the “cumulative impacts” of nearby flight paths from Van Nuys Airport, the proposed $1.24 billion expansion of Burbank Airport, and a projected 15% increase per year in air traffic. The recent Burbank Landrum & Brown study also identified global warming as a factor in lowering jet altitude and driving flights south. This also adds to cumulative impacts.
Artificial Baseline: In early 2017, the FAA shifted the flight path over our communities in a “vectored” NextGen-like path without study or notice. The FAA’s CATEX claims “No Significant Impact” by comparing the new proposed procedures to this “vectored,” focused 2017 path. This is an “artificial baseline.”To do an accurate comparison, the FAA must compare the new procedures to the time period prior to moving the path before NextGen was even being considered (compare to the historical flight path of 2014 or earlier).
Purpose and Need: The reason for the proposed action, according to Procedure documents obtained in July is “to mitigate departure route overflying higher terrain south of the airport.” The FAA informed us that the proposed action is necessary in order to comply with the undisclosed Benedict Hills settlement agreement, which is “confidential” and has not been made public. If the reason for the proposed change is indeed “to mitigate departure route overflying higher terrain south of the airport,” then why are the resulting procedures overflying higher terrain south of the airport along the entire path from JAYTE to TEAGN? Elevations in Benedict Canyon and Benedict Hills are similar to those in Studio City and Sherman Oaks, 800-1000 feet. Both constitute “higher terrain” and both are “south of the airport.” FAA must be consistent in applying its rationale to areas of higher terrain south of the airport.
Waypoints Above Schools: The proposed procedures include waypoints in the heart of our communities and directly over schools. The FAA has made the decision to place a mandatory waypoint 1,622 feet above 1,200 elementary school children and to create a flight path that brings thousands more students dangerously close to jet pollutants and noise. This is highly unusual and unconscionable, and there have been no environmental studies that support the safety of FAA’s reckless decision. Up until now, the nearest waypoints were 19 and 21 miles north of the Burbank Airport. Schools directly under the waypoints and in the path include: Carpenter Community Charter, Bridges School, Harvard Westlake School, The Buckley School, Dixie Canyon Avenue Elementary and Sherman Oaks Elementary.
Reasonable Alternatives: FAA has not studied “Reasonable Alternatives” to this highly invasive and destructive flight path, including returning to a dispersed path, multiple paths, or changing the general direction of departures to the north or east.
Safety Cumulative Impacts: The proposed procedures significantly worsen the dangerous cumulative safety impacts and the welfare of our communities. Gaining altitude while flying into a mountainside - with no ground access for emergency vehicles in case of an accident, and the potential for catastrophic urban wildfires - creates extreme danger. Further, increased operations at Van Nuys Airport contributes to safety cumulative impacts since Van Nuys departures travel the same path through the mountains, at the same elevation and from the opposite direction – directly toward Burbank departures!
Cumulative Health Effects – Pollution: Health effects of jet pollution are severe. Jet fuel emissions are a toxic stew of benzene and hazardous chemicals. Fine particulate emissions are dangerous and cause respiratory disease, heart disease and cancer. Children and the elderly are "sensitive receptors" and are most susceptible. The FAA's claim of "no impact" on air quality defies the obvious. Air quality under this path will be degraded, threatening the health of residents, students, and visitors. The greater the volume and frequency of jet overflights, the greater the pollution, and the greater the cumulative health risk.
Cumulative Health Effects – Noise: The health effects of noise on human health are severe. According to the World Health Organization and a recent Columbia University study, noise has been proven to cause heart and lung disease, strokes and even reduce longevity. The greater the volume and frequency of jet over flights, the greater the cumulative health risk.
Combined Cumulative Health Effects – Pollution and Noise: Combined pollution and noise effects are truly dire. Both have been proven to cause heart and lung disease, strokes and even reduce longevity. Children and the elderly as "sensitive receptors" are more susceptible.
Noise – Hillside/Canyon Acoustics: Hillside/canyon acoustics exacerbate noise. Noise bounces off mountains in all directions, creating more noise for everyone, even spilling and deflecting to neighborhoods outside the immediate hillside area.
Noise – Effect on Students/Communities: Noise interferes with students’ ability to learn. Our hillside schools and homes are not designed to be under a flight path. They don't have soundproofing, triple paned windows, or air filtration.
Studio City Film Industry: Waypoint JAYTE is directly above Gunsmoke Drive, in the middle of CBS Studio’s back lot. TV and film shoots in Studio City and Sherman Oaks - a critical part of our local economy, with CBS Television Studios a huge contributor of jobs and local tax revenues - would be adversely affected because crews have to "hold a shot" every 90 seconds as a flight passes. Many on-location shoots would simply move elsewhere due to the constant noise.
Reduction in Home Values/Los Angeles Tax Revenues: Property owners who purchased their homes prior to the “vectored” change in flight path in 2017 have a reasonable continued expectation of peace and tranquility. The vast majority of affected properties are in Studio City, Sherman Oaks and Encino, i.e., the City of Los Angeles. And yet the flights over them originate in Burbank - a neighboring city - from an airport owned by Burbank, Glendale and Pasadena (the City of Los Angeles has no control or say). Flights should turn east over Pasadena, where the residents/taxpayers have some ownership of the source of the noise and pollution.
Official FAA Request: The proposed procedures should be moved one mile from the start of elevated terrain, with more dispersal and higher altitudes, so that no one community is exposed to the hyper-concentrated noise and pollution that Studio City, Sherman Oaks and Encino currently endure. In the meantime, we demand that the FAA immediately stop "vectoring" flights over our hillside communities pending a full Environmental Impact Statement.
Why is the FAA accepting public comments on its proposed Burbank departure procedures?
Because of widespread public concern and press coverage.
Wasn't there a comments period in August?
Yes. That was for FAA internal use. This is for the public - ahead of the proposed procedures becoming permanent on April 25, 2019.
Why do I need to submit comments?
We must challenge the FAA's refusal to conduct environmental studies! Public comments make a huge difference. If the FAA gets its way, the character of Studio City and the surrounding areas, including the protected 4(f)-designated wilderness of the Santa Monica Mountains Recreation Area, will be changed forever - and the health of approximately 10,000 children who attend schools directly under new FAA flight path will be put at severe risk. This new public comment period is open for only four weeks - a deliberately short period - so we have to move fast!
The FAA is a huge bureaucracy. Won't they just ignore us?
Maybe. But commenting gives us "standing" to take legal action up to 60 days after the departure procedures are published in the Federal Register. Other cities have made the huge error of failing to comment in time, leaving them powerless to fight. But both the City of Los Angeles and a group of private citizens are already considering lawsuits.
Do I have to make comments online?
No. Comments can also be submitted via mail to:
Federal Aviation Administration