HomeMy WebLinkAboutReso 6047-1973 RESOLUTION NO. 6047
CITY COUNCIL, CITY OF SOUTH SAN FRANCISCO, STATE OF CALIFORNIA
A RESOLUTION REGARDING
CIVIL AIRPLANE FLEET
NOISE REQUIREMENTS.
WHEREAS, South San Francisco citizens continue to
suffer from intolerable levels of aircraft noise; and
WHEREAS, the Federal Aviation Administration continues
to delay implementation of noise reducing regulations; and
WHEREAS, the Civil Airplane Fleet Noise (FNL) Require-
ments currently'being proposed would provide substantial
relief from noise;
NOW, THEREFORE, BE IT RESOLVED that the City Council
of the City of South San Francisco does hereby endorse and
support the FNL rule and does hereby urge its immediate
adoption with the modifications proposed in the attached
technical response.
I hereby certify that the foregoing Resolution was
regularly introduced and adopted by the City Council of
the City of South San Francisco at a adjourned regulameeting
held on the 12 day of March , 19 73 , by the
following vote:
AYES, COUNCILMEN Patrick E. Ahern, William A. Borba,
F. Frank Mammtui and Warren Steinkamo
None
None
ATTEST:
NOES, "
ABSENT, "
~lerk
EXHIBIT' A
RESOLUTION NO, 6047
TECHNICAL RESPONSE TO FAA ADVANCE NOTICE OF
PROPOSED RULEMAKING RE: CIVIL AIRPLANE FLEET
NOISE (FNL) REQUIREMENTS
Docket No:12534~ Notice No. 73-3
1. Support for Proposed Rule. The City of South San Francisco supports the
proposed rule as a meaningful step towards reducing aircraft noise
pollution. As indicated in more detail below, it should be looked upon
as an interim measure, a partial solution only; however, with certain
modifications the concept could provide a nearly total solution. In any
case, whether the rule is retained in its present form or modified as
proposed below, it should be adopted as soon as possible.
2. Cost/Benefit Analysis. In January of 1971 the City of Inglewood, Calif-
ornia~ conducted a cost/benefit analysis of engine retrofi't for noise
-abatement. This study was performed in response to the FAA's Advance
Notice of Proposed Rule~making regarding: Civil Airplane Noise Reduction,
That study applies equally well to the Fleet Noise Level concept; the
purpose of any rule should be noise reduction, not installation of specific
hardware The costs and benefits of such noise reduction are outlined in
Table 1 of that report (copy attached) and the conclusions are contained
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in the summary and errata sheet (copies attached). Overall, the report
shows that retrofit (or fleet noise requirements) would provide a net
overall economic and environmental ~ain to the nation valued at $12 billion.
This more than overshadows the costs, estimated now to be less than $1
billion for the entire fleet. These costs could be paid for by a passenger
fare increase of less than 1~.
3. Technological and Economic Feasibility. As indicated in the present Notice,
the problems of technological or economic feasibility have been or are
being overcome. Our understanding of research underway is that retrofit
devices are proving more effective and less costly than earlier estimates.
New production aircraft of older type designs can now be ordered to comply
with FAR Part 36. Quiet engine research currently underway at NASA is
also showing greatly reduced noise levels. Since Inglewood's study two
years ago showed that the benefits far outweighed the costs, this conclusion
is even more true now.
4. Schedule. South San Francisco is of the opinion that there has been gross
negligence and delay in implementing a rule such as the one proposed The
Advance Notice of Proposed Rulemaking regarding Civil Airplane Noise Reduc-
tion was published November 4, 1970; more than two years has elapsed since
that time. The responses to that proposal should have been an adequate
basis to support a Notice of Proposed Rule-making now rather than only an
Advance Notice. The implementation date has likewise slipped from June 30,
1975 recommended in our previous report to July 1, 1978 proposed now. Even
this date is likely to slip unless further delays in the rule-making process
are eliminated. We believe that a final regulation should be adopted in
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EXHIBIT A
RESOLUTION NO. 6047
the first half of this year so that the initial FNL ceiling can be made
effective on September 1, 1973.
5. Exemptions'. The City of South San Francisco understands the international
implications of attempting to impose the FNL rule on foreign carriers.
However, we see no reason for exempting overseas air carriers. Overseas
airplanes are often the noisiest types, often fly during nighttime hours.,
and therefore have significant adverse effects on United States citizens.
Furthermore, overseas routes lend themselves well to utilization of the new
generation wide body aircraft which would make compliance with the proposed
rule even more easy. The City of South San Francisco urges that the proposed
rule be made applicable to intrastate air carriers also. IntraState
carriers constitute a large portion of the overflights over South San
Francisco.
,. 6. Ultimate Level. The FNL requirement should not end with the attainment of
FAR Part 36, Appendix C noise levels for all aircraft by July 1, ].978.
These noise levels are still quite loud and disruptive to residential
communities (levels above 100 EPNdB would still be common). Quiet Engine
· technology currently in progress or which would be spurred by regulatory
requirements should be capable of achieving a further 10 dB noise reduction
for all aircraft by 1990. This is what we proposed two years ago. A mid-
way limit point FNL in 1985 also seems reasonable. Part 36, Appendix C
should be revised to require these lower noise levels in aircraft certifi-
cation. '" '
7. Cumulative Effects. While we support the proposed Fleet Noise Level Re-
.quirements wholeheartedly, we hasten to add that they are by no means a
total solution to the aircraft noise problem. In particular, they do not
address the problem of the cumulative impact of many flyovers. The City of
South San Francisco is especiall~ concerned about this problem, since the
major portion of the aircraft noise impact emanates from overhead flyovers
in the San Bruno Gap with its rising terrain. The FNL requirement would
reduce the average noise of aircraft in each airline fleet, but it would
place no limit on the total cumulative noise. To do so would be fairly
simple; the formula for FNL would merely have to be revised slightly so
as to take a form similar to the NEF formula. Then the initial ceiling
and future limitations would be in terms of the cumulative noise effect,
instead of the average noise effect.
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8. Conclusions. The City of South San Francisco urges that the proposed FNL
requirements be adopted as soon as possible. Our analyses have shown that
the benefits of such a rule far exceed the costs. The rule is technologically
feasible and economically reasonable. Further delays should be eliminated
s° that the rule can become effective by September 1, 1973. Overseas air-
craft should not be exempted. The ultimate FNL requirements should be 10
dB lower than present FAR Part 36 levels. Consideration should be given to
limiting the cumulative noise of each airline's fleet as well as limiting.
the average noise of all aircraft.
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