HOW TO SUBMIT COMMENTS OPPOSING EXPANDED TERMINAL
AT BURBANK AIRPORT
THERE ARE TWO WAYS TO SUBMIT:
1. Preferred choice: submit comments opposing terminal in a letter by regular mail prior to March 1 to:
Mr. David F. Cushing
Manager, Los Angeles Airports District Office, LAX-600
777 S. Aviation Blvd, Suite 150
El Segundo, CA 90245
Please also email your letter to SCFQS at firstname.lastname@example.org so that we can provide the City with a record of what has been submitted.
NOTE THAT IF YOU CHOOSE TO USE REGULAR MAIL, THE COMMENTS MUST BE RECEIVED BY MARCH 1 AT 5PM SO YOU MUST MAIL IN ADVANCE!
2. If you have waited until the last minute and want to submit your comments opposing the terminal by email, send a letter, as a PDF or Word Document, BY FEBRUARY 28 to email@example.com and we will submit it for you by personal delivery. Please include Mr. David Cushing's name and address at the top of the letter as shown above. Please sign the letter with your name and address.
Deadline for ALL comments TO BE RECEIVED BY FAA
is MARCH 1, 2019
Below is a SAMPLE LETTER you can personalize and use. Please either write your own letter (best option) or copy/paste the following letter, or parts of the letter. If you use the form letter below, be sure to insert the date at the top, the city where you live in the first line, your own experiences where you see ALL CAPS, and your name and address at the bottom.
February ____, 2019
To: Mr. David F. Cushing
Manager, Los Angeles Airports District Office, LAX-600
777 S. Aviation Blvd, Suite 150
El Segundo, CA 90245
Dear FAA/Burbank Airport,
I oppose the New Expanded Terminal at Burbank Airport. I live in ________ and am one of many people suffering under the flight paths that were changed in early 2017 without notice or environmental study. The flight paths have seriously disrupted my life and my work. (EXPLAIN HERE HOW THE PATHS HAVE DISRUPTED YOU AND YOUR FAMILY PERSONALLY AND WHY YOU DON’T WANT A NEW TERMINAL THAT WILL INCREASE NOISE AND POLLUTION. INCLUDE STORIES ABOUT WORK, SCHOOL, YOUNG CHILDREN, SLEEP DEPRIVATION, ANXIETY, DIMINISHED HEALTH, ELDERLY, ETC.)
When I invested in my neighborhood, we had only occasional, insignificant air traffic. Now, the noise level is unbearable with a barrage of more than 260 aircraft overhead at all hours of the day and night from BUR and VNY, primarily BUR. The low altitudes of the aircraft combined with the higher elevation of our hillside, and canyon acoustics, cause the noise to be widely amplified and create a rebound effect that lasts for at least 90 seconds. Health effects of being so close to the aircraft are severe. The FAA must not allow the terminal expansion because that will further increase the health risk from noise and toxic jet particulates that fall to the ground.
Our hillside communities are unique in that they are in the midst of the Santa Monica Mountains National Recreation Area, one of the few quiet refuges that remain for residents, visitors, and wildlife in the metropolis of Los Angeles. The FAA, under the guise of safety and efficiency, is endangering our protected parkland and wildlife habitat, and admittedly without conducting any Environmental Studies for our area. The new, more efficient, expanded terminal must not proceed until the FAA moves the flight paths out of our protected parkland!
The film industry is an important part of our communities and a driver of our local economy. The current unauthorized flight paths have already diminished local filming and threaten the studios and thousands of people who work in the film industry. Home values are dropping which in turn is potentially reducing by hundreds of millions, tax revenues for the City of Los Angeles. A new, expanded terminal will give all the monetary benefit to the City of Burbank and export all the noise and pollution to the City of Los Angeles. The FAA must move the paths before proceeding with the replacement terminal!
For the above-stated reasons and all of those submitted by our local Quiet Skies groups, I oppose the replacement terminal at BUR.
1. First Charrette: Wednesday, March 27, 2019
6:00pm - 9:00pm (arrival time 5:30pm).
Location: Hangar 40
BUR is recommending that participants park at Planet Fitness, 10832 Sherman Way, Sun Valley, at 5:30pm in order to catch a shuttle to Hangar 40. There will be shuttles running back and forth all evening until everyone has left Hangar 40.
If you want to Lyft/Uber directly to Hangar 40, the address is 2910-2930 N. Clybourn Ave.
SCFQS PARTIAL COMMENT FOR BURBANK'S NEW EXPANDED TERMINAL
The following impact analysis will show that BUR’s “replacement” terminal is essentially an “expansion” that will result in increased operations and efficiency such that it will significantly increase noise and pollution to the surrounding communities. According to National Environmental Policy Act (NEPA), the FAA must consider all cumulative impacts of the proposed terminal expansion.
This proposed Expanded Terminal represents a profound threat to our LA Valley communities. Through cumulative actions taken by FAA/BUR, our communities and protected parklands have been fundamentally degraded – severely reducing quality of life by massively increasing noise and pollution. The proposed Expanded Terminal at Burbank will guarantee increased efficiency, even without adding more gates. That means more flights, larger jets and jets flying even closer together. The proposed Expanded Terminal will add significantly to the numerous cumulative negative impacts we are already experiencing under the disastrous 2017 change in flight path that occurred without notice or environmental study, resulting in more than 260 overflights per day. We cannot allow the proposed Expanded Terminal to go forward without fundamental and comprehensive changes in the flight path, protection of our communities and parklands, and limits on airport growth and operations.
FAA’S Environmental Impact Statement (EIS) must define the “Affected Area” to include the footprint of procedures overflying the noise-sensitive hillside communities of Studio City, Sherman Oaks, and Encino, and the protected 4(f) Santa Monica Mountains. All Environmental Resource Categories should be evaluated and analyzed in the “Affected Area” thus defined.
Cumulative Future Impacts Directly Resulting From Proposed Expanded Terminal:
*The terminal expansion must not be considered in a vacuum. NEPA requires that the FAA evaluate the impact of its action (replacing the terminal) "when added to other past, present, and reasonably foreseeably future actions," whether direct or indirect (40 CFR 1508.7, 1508.8). The impact the proposed Expanded Terminal will have must be considered along with all other cumulative impacts.
*The proposed Expanded Terminal, with its greater size, increased amenities, and improved airside facilities, will increase efficiency, allow for processing of more passengers, and result in a greater number of flights and larger jets.
*The proposed Expanded Terminal is expected to have the same number of gates (14) as the existing terminal. However, with its increased size, it is reasonably foreseeable that more gates will be added in the future, and therefore must be considered as a cumulative impact. All it would take to expand beyond 14 gates is approval by the City of Burbank. The City of Los Angeles would have no say in the matter.
*The FAA is underestimating its impact on our communities and underestimating future growth. Although passengers (enplanements) at Burbank Airport (BUR) have increased 28% over the last 3 years (11.7% of that in 2018 alone), the FAA is projecting growth from 2019 through 2029 at only 1.2% to 2% annually. These projections are simply not credible. In fact, in marketing materials, BUR touts that growth is explosive, stating, "the airline industry is only now beginning to fully recover from the Great Recession" (LA Curbed Article 2/7/19). The proposed state-of-the-art Expanded Terminal will further increase passenger numbers, thereby multiplying the cumulative impacts on the Affected Areas.
*BUR estimates that the proposed Expanded Terminal will cost $1.24 billion, significantly increased from the originally estimated $400 million. To increase revenue, as they must do, BUR will increase capacity by bringing in more passengers in larger jets. Larger, heavier jets will make slower turns, driving the aircraft even further south, thereby contributing to increased future cumulative impacts and danger to the Affected Areas.
*Expanded Cargo Facilities will encourage more cargo jets creating heavier, slow-to-gain-altitude jets that are not subject to curfew, thereby flying over noise sensitive areas late at night and early in the morning.
*Expanded General Aviation Facilities will encourage more general aviation aircraft that are not subject to curfew, thereby flying over noise sensitive areas late at night and early in the morning.
Metroplex and Cumulative Impacts:
* Proposed Expanded Terminal process must be halted until all cumulative actions taken by FAA/BUR that have already severely impacted Affected Areas are mitigated and alternatives are found.
*Previous cumulative actions taken by FAA/BUR that must be considered in combination with the proposed Expanded Terminal include, but are not limited to, the following:
-The current, unauthorized departure procedures implemented in 2017 at same time as Metroplex;
-Proposed departure procedures OROSZ THREE AND SLAPP TWO;
-Skyrocketing passenger and operations growth at both BUR and Van Nuys Airport (VNY);
-Changes in flight path at nearby VNY;
-Impending closure of Santa Monica Airport that has created increased operations at BUR and VNY; and
-Increase in helicopter traffic that must fly below the jets from both BUR and VNY, creating a stacking effect.
All of the above actions currently contribute to, and will continue to contribute to, increased cumulative impacts on residents, students, local business, film industry, and parklands that are under the narrow, focused flight path.
*The FAA's Environmental Impact Statement (EIS) must not claim a baseline that includes the currently flown unstudied and undisclosed departure procedures introduced in 2017. To do so would constitute a false baseline. To do an accurate comparison, the FAA must use pre-Metroplex conditions as a baseline to compare the impacts that the proposed Expanded Terminal would have on the environment and surrounding communities, in other words, compare the proposed Expanded Terminal impacts to the time period before NextGen was even being considered (2014 or earlier).
*It has already been determined by an independent analysis conducted by Landrum & Brown that the BUR flight paths shifted south in a concentrated path over the Affected Areas. This change in flight track occurred in early 2017 without notice or environmental study. Prior to 2017, there was only occasional jet noise. Now there is a constant, disruptive, low, loud jet disruption in our formerly tranquil, hillside neighborhoods. The proposed Expanded Terminal will amplify these impacts that the FAA/BUR has failed to address/mitigate despite intense and widespread public controversy.
*BUR proposed procedures SLAPP TWO and OROSZ THREE would make permanent the current path that FAA/BUR began vectoring in March 2017, without notice or environmental study, over the Affected Areas. BUR has stated that the FAA is planning to do an Environmental Analysis (EA) as a result of extreme public outcry. Such EA is expected to take 12-18 months. The proposed Expanded Terminal must be put on hold NOW and not proceed until the FAA completes its process.
*Through its own analysis, VNY reports an increased number of departures by 35% since 2016. It has also moved departure path HARYS TWO south and east (with institution of waypoint PPRRY in May 2018) to traverse the same portion of the Santa Monica Mountains that BUR currently impacts by its departures; and that the proposed departure procedures SLAPP TWO and OROSZ THREE will continue to impact by adding waypoints JAYTE and TEAGN. The proposed Expanded Terminal must not proceed until these paths, already cumulatively impacting Affected Areas, are changed, and paths consistent with Section 175 of the FAA Reauthorization Act are explored.
*Both BUR and VNY estimate a projected 15% increase per year in air traffic, which will contribute significantly to the current air noise over the Affected Areas. The proposed Expanded Terminal will compound these projections.
*Santa Monica Airport (SMO) shortened its runway in 2017 significantly reducing the air traffic out of that airport and causing more traffic to be routed to both VNY and BUR, thereby contributing to the cumulative impacts in the Affected Areas. SMO’s complete closure is scheduled to occur in 2028 and will further increase the traffic, along with air and noise pollution, in the Affected Areas.
*The Expanded Terminal has a cumulative, compounding effect on FAA prior actions (the current flight path and proposed procedures) that have been demonstrated to be “highly controversial on environmental grounds” under NEPA Rule 1050 1F 5-2 (10). Highly controversial is defined as “opposition on environmental grounds to an action, by a Federal, state or local government agency, or by a … a substantial number of the persons affected by such action....” Such opposition occurred during the comment period for the proposed procedures, SLAPP TWO and OROSZ THREE, ending November 18, 2018 as exhibited by the protests of thousands of community members (evidenced by the Petition signed by almost 3,500 people and climbing); 396,000+ noise complaints filed, the opposition of current paths and proposed procedures by elected local, state, and federal officials; the opposition by Burbank Airport itself; the over-capacity turnout at the October 18, 2018 Burbank-Glendale-Pasadena Airport Authority meeting, high public turnout at FAA Workshops on November 7/8, 2018, and blanket press coverage. Public Controversy continues during the comment period for BUR Expanded Terminal with high public turnout at the Public Scoping meeting on January 29, 2019, and a Petition opposing the Expanded Terminal so far signed by more than 1,200 people.
Impacts to Protected 4(f) Parkland:
*Under Section 4(f) of the U.S. Department of Transportation Act, the FAA must avoid potential impacts to "publicly owned parks, recreation areas (including recreational trails), wildlife and water fowl refuges, or public and private historic properties" (23 SFR 774). The FAA is required to look at all other alternatives to avoid overflying 4(f) protected parkland and has failed to do so. The new, more efficient Expanded Terminal must not move forward until the FAA abides by this statutory law and finds alternatives to the cumulative actions already taken by FAA/BUR. Viable alternatives have already been presented to the FAA in a comment letter by the City of Los Angeles, dated November 16, 2018, that the FAA has failed to consider thus far. The Expanded Terminal will further degrade our public parklands – our quiet refuge from noisy city life. It will negatively impact the already dwindling wildlife and increase fire risk in an area where ingress and egress by emergency vehicles is severely limited. Mountains Recreation & Conservation Authority and Santa Monica Mountains Conservancy consider "quiet to be a critical component of the natural lands visitation experience"(SMMC Letter 1/28/19). The Expanded Terminal combined with other actions taken by FAA/BUR "contribute to a continually increasing level of impacts inconsistent with the recreational and quiet refuge values of the affected natural parklands" (SMMC Letter 1/28/19).
Mountainous Topography Amplifies All Cumulative Impacts:
*Hillside/canyon acoustics exacerbate noise. Many of those in the Affected Areas live in the Santa Monica Mountain range and foothills at elevations of 800 to well over 1000 feet, thereby making aircrafts' effective Above Ground Level (AGL) altitude lower than if overflying flat land. Noise concentrates in bowl-like canyons and sustains and bounces off mountains in all directions, creating more noise for everyone, even spilling and deflecting to neighborhoods outside the immediate hillside area. The FAA/BUR has failed to consider this aggravating circumstance when taking previously cumulative actions to re-route low-flying jets over this type of terrain and must consider, study, and measure the unique topography when considering how the Expanded Terminal will further amplify already devastating cumulative noise impacts.
Wind and Weather Impacts:
*Wind and weather paths are increasingly becoming the norm. Wind Day Paths bring arrivals over affected communities instead of departures. Extremely low landing altitudes over terrain with many obstacles increase danger to aircraft and passengers as well as to those on the ground. Significant health risks are magnified. The efficiency of the state-of-the-art Expanded Terminal will increase the frequency of low altitude arrivals and contribute to an already dangerous action taken by FAA/BUR.
*Increasingly, simultaneous departures and arrivals, often within 1,200 feet of each other, are occurring over mountainous terrain. This practice contributes to and significantly worsens the dangerous cumulative safety impacts and the welfare of our communities. The new, more efficient Expanded Terminal will increase this phenomenon. It will also increase the sheer number and frequency of aircraft traversing the mountains at lower altitudes, thereby compounding the probability that a crash will occur over dry parkland, creating catastrophic urban wildfires, that will spread through the Santa Monica Mountains. Lack of ingress and egress through the terrain make it impossible for emergency vehicles to pass. This is exceedingly reckless and constitutes a dereliction of the FAA's obligation to society.
*The new, more efficient Expanded Terminal will increase the already burdensome cumulative negative health effects from constant, low-flying jets over elevated terrain that degrade air quality and cause serious health problems:
-Health effects of jet pollution are severe. Jet fuel emissions are a toxic stew of benzene and hazardous chemicals. At or below 3,000 feet (mixing level), particulates fall to the ground rather than being absorbed in the atmosphere. Fine particulate emissions are dangerous and cause respiratory disease, heart disease and cancer. Children and the elderly are "sensitive receptors" and are most susceptible. Air quality degradation will be increased, 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.
-Health effects of noise are severe. According to the World Health Organization and a 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.
-Noise increases disruption in schools and interferes with students’ ability to learn. Hillside schools are not designed to be under a flight path. They were not built near a freeway and therefore do not have soundproofing, triple paned windows, or air filtration. Flight frequency due to the higher efficiency of the proposed Expanded Terminal will increase cumulative impacts already suffered by our children as a result of previous actions taken by FAA/BUR.
*The new, more efficient Expanded Terminal will increase the economic loss already experienced in the Affected Areas.
-Negative effects on local businesses and restaurants will increase.
-The film industry centered in Studio City is already disappearing due to current unauthorized flight paths that a New Terminal would exacerbate. 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 severely affected by the Expanded Terminal. Crews already have to "hold a shot" every 90 seconds as a flight passes due to other cumulative actions already taken by FAA/BUR. Many on-location shoots are simply moving elsewhere due to the constant noise.
-Home values have already been impacted and are on the decline. Cumulatively, this, in turn, causes a massive reduction in tax revenues to the City of Los Angeles.
Construction Environmental Impacts:
*Residents near BUR and along the soil export route have grave concerns about vast amounts of contaminated soils traversing their neighborhoods, potentially exposing them to dangerous materials. Residents near BUR also have concerns about the growth of the airport, as well as increased traffic surrounding the airport, and air pollution from traffic.
*Based on prior actions taken by FAA/BUR, mitigation of harm must be implemented before plans for the proposed terminal can continue. The damaging and unreasonable cumulative impacts resulting from BUR/FAA action, as evidenced by widespread public controversy, must be addressed and resolved. Meanwhile, all plans for the proposed Expanded Terminal must immediately cease.
-FAA must address and consider request from BUR to use Section 175 of the FAA Reauthorization Act to create dispersed lateral tracks away from the 4(f) protected Santa Monica Mountains. Use of Section 175 has the support of the City of Los Angeles through its Resolution dated 2/5/19.
-FAA must consider a full "reset" of BUR path to the historical dispersed path.
Other alternatives must be considered such as:
*Rerouting the flights east or southeast over Burbank, Glendale, and Pasadena. They are reaping the profits from the airport but are not sharing in ANY of the air noise and pollution. Los Angeles receives all the negative impacts with no reward or profit.
*Redesign by modifying and regrading the 15/33 Runway so it can be regularly used for northern takeoffs.
*Redesign considering a dedicated Runway for Southwest Airlines, Burbank’s largest carrier, to depart to the north.
*Redesign Runways and Departures to accommodate departures on other runways, in other directions to reduce southwestern departures.
*Redesign Runways and “Wind” Arrival Procedures to provide alternatives to descending over mountainous terrain.
*Redesign runways to accommodate alternate procedures for some “less competent jets” that can’t always complete their turns prior to the 101 freeway.
*Restoring the pre-NextGen historical 6-mile wide flight path, proven safe for decades.
*Creating multiple tracks and alternate tracks in ALL directions. There is webtrak evidence of numerous successful northern departures by all jets, as well as eastern departures.
*Transferring or shifting some of the General Aviation or Cargo operations to another existing public airport (or airports) in Southern California.
*Retiring all General Aviation operations. The Expanded Terminal will encourage more General Aviation including large jets that are not subject to BUR's voluntary curfew, and will therefore fly over noise-sensitive areas late at night and early in the morning.
*Retiring or reducing Cargo operations. The Expanded Terminal will encourage more cargo and heavier slow-to-gain-altitude jets that are not subject to curfew, and will therefore fly over noise-sensitive areas late at night and early in the morning.
*Relocating the airport to a less populated area. The Expanded Terminal will have Metrolink connections to Antelope Valley and Ventura. These high-speed rail lines are two-way. A New Airport designed to meet all FAA standards could be located on the other end of either line in a less densely populated area.