Scheduled Air Carrier Jet Operations**
Average Daily, 1975
|Number of||Part 36 Noise|
Although the technology to retrofit these JT8D aircraft is available, the resulting reductions in noise levels is not as large as the reductions for the JT3Ds. A modified JT8D airplane is significantly quieter than an unmodified JT8D airplane, especially on approach.* We estimate that the cost of retrofitting all of these airplanes will be about $223 million in 1976 dollars. Since most of these airplanes have a long remaining useful life, we anticipate that they will be modified rather than replaced.
* Noise measurements taken during routine airline operations at airports in the New York City area showed that 727-200 aircraft with SAM retrofit treatment operated at 6.5 PNDB (estimated from dBD measurements) lower levels on approach than did 727-200 aircraft without retrofit.
Because of their larger numbers, more frequent operation, and more widespread use, the cumulative effect of reducing the noise of these JT8D aircraft is greater than that for the four-engine aircraft alone. By requiring that both the two-, three- and the four-engine aircraft meet Part 36 noise levels, we will realize significantly greater reduction at the 25 largest air carrier airports at the time compliance is completed. Additionally, many more air carrier airports would benefit from quieting of the two- and three-engine airplanes. Without including the two- and three-engine jets, which constitute 70 percent of that part of the operating fleet that does not meet Part 36 and which account for 80 percent of the air carrier operations nationwide, 75 percent of the air carrier airports in the country would not receive any noise benefit and 85 percent would not receive any significant benefits.
There are also about 50 early 747s that do not meet Part 36 noise levels. Economics clearly make retrofit the logical alternative for these aircraft, which have a long remaining useful life, and a retrofit kit for modification of these aircraft has been included in later production versions of the 747.
The following table illustrates the comparative reductions expressed in EPNDB of the retrofit of those airplanes that do not meet FAR 36.
The following table provides an estimate of the numbers of airplanes to be modified acoustically or replaced. Also included are what the associated capital costs of retrofit would be if the turbofan-powered 707s and DC-8s are not retired or replaced earlier than they otherwise would have been as a result of the new federal regulation.
|Airplane||Number to||Average||Total Cost||1975 Present|
|Type||be modified||Cost(million $)||(million $)||Value (million$)|
|737 & DC-9||448||.27||121||71|
|707 & DC-8||270||1.2||324||159|
These costs are in constant 1975 dollars, and do not include any tax benefits or changes in operating costs. The present values were computed using a 10% discount rate before inflation. If changes in operating costs are also included, the 1975 present value costs increase to a total of $440 million. These operating cost increases are primarily the result of the increased fuel inefficiency of modified 707s and DC-8s and include the cost of an additional 320 million gallons of fuel which would be consumed by these airplanes.
2. Economic Benefits from a Mixed Replacement and Modification Program
Despite the arguments that the variables and projections are uncertain, cost-benefit analysis is a useful tool to compare means of reducing aircraft noise. Our analysis indicates that replacement of all JT3D aircraft and acoustic modification of the JT8D aircraft will yield positive net benefits of $350 million to the airlines* whereas altering the scenario by retrofitting the JT3D airplanes instead would cost them $440 million. The primary reasons for these differences are varying fuel consumption and maintenance costs.
*See the FAA benefit-cost study published as an attachment to the Final Environmental Impact Statement issued November 17, 1976.
A replacement program also produces many benefits that are difficult to calculate, but which would be significant.
In light (if these benefits, we believe that it would be economically preferable for the Nation if most of the four-engine aircraft are replaced with new technology aircraft.
3. Time Frame
Since some combination of replacement and retrofit is advantageous in bringing current airplanes into compliance with the noise standards of Part 36, we have considered what would be a reasonable time frame to require such action.
In establishing a deadline, we have been concerned with the length of time needed to develop, certificate, produce, and install retrofit kits for those airplanes for which the operators decide that retrofit is best. The manufacturers have indicated that it will take six years to complete retrofit of the 747s, 727s, 737, and DC-9s, six to eight years to complete the 707s and DC-8s, including kit production* and installation time.
Retrofit kits are currently certificated and ready for installation for the two- and three-engine aircraft and the 747s, and are being installed on those aircraft that are currently in production. It may take 28 months and 36 months, respectively, to design and certificate kits for the 707s and DC-8s, with fabrication and installation time to follow. Thus, time to fabricate the required number of kits, and to install them during refurbishment periods for fleet aircraft must govern the mandatory compliance periods. Given these considerations, we have concluded that aircraft should be required to meet Part 36 noise levels within certain time periods.
The Federal Aviation Administration will promulgate a rule requiring that subsonic jet airplanes in domestic** service with maximum weight in excess of 75,000 lbs., that do not meet the present Federal Aviation Regulations Part 36 noise levels, must meet those noise levels or be retired from the fleet within six to eight years in accordance with the phased-in schedule set forth on pages 5-6 of this policy statement.
**Domestic service as used here includes flights to U.S. territories outside continental United States, generally classified as "overseas".
These time periods, which are established on the basis of the time it would take to complete the development, production, and installation of retrofit kits for most of the existing fleet, will start to run on January 1, 1977. These time periods are also adequate to enable the development of new technologies for replacement of older, four-engine aircraft if adequate financing is available. Measures imposed by other jurisdictions that would require more accelerated compliance with Part 36 requirements would conflict with the purpose of this federal regulation.
|From Production||Production Rate|
|Decision to First||Ship Sets Per|
4. International Air Carriers
The United States will seek early agreement through the International Civil Aviation Organization (ICAO) on noise standards and an international schedule for compliance with Annex 16 or Part 36. In the event that agreement is not reached within three years, from January 1, 1977, then regulatory action will be taken to require all airplanes operated by all international operators to meet the noise level standards of Part 36 or Annex 16 during the five-year period thereafter at a phased rate of compliance similar to that established for domestic operations. The ultimate requirements applied to U.S. international flag carriers will not be any more stringent than those applied to foreign air carriers, because it would place the U.S. international flag carriers at a competitive disadvantage if they had to comply with the noise standards sooner than their foreign competition. Anywhere U.S. air carriers serve both domestic and foreign routes, the delayed international requirements will be applied only for that percentage of total operations that are in international service. These requirements may be superseded by agreement reached through ICAO, in which the United States concurs and which does not discriminate against U.S. carriers.
B. Financing Mechanism
President Ford has instructed the Department of Transportation to promulgate rules to require that all aircraft in domestic service meet noise standards within eight years. He indicated at that time that he would again urge the Congress to enact his aviation regulatory reform measure to create an improved economic climate for the airline industry that would enable it to comply with these standards. He further directed the Secretary to begin public hearings promptly to assess whether additional financing assistance, if any, may be necessary to guarantee compliance with these standards within eight years.
At the public hearing, scheduled for December 1, 1976, we must first consider whether any financing arrangements at all are necessary. If there is persuasive evidence and documentation that such assistance is necessary, alternative financing proposals must be weighed against certain goals.
First, we would prefer that the costs of noise abatement be borne by users of air transportation, passengers and shippers. Any shift of that burden to the general public must be avoided. Second, enough financing must be available to enable the carriers to replace a significant portion of their noisy four-engine jets with a new generation airplane but not so much financing as to encourage the purchase of excess capacity. Third, federal involvement in any financing mechanism should be limited and not disturb unduly the mechanism of the private capital markets, nor unreasonably constrain the flexibility of air carrier management in determining how to comply with the noise regulation. Fourth, the cost of transportation to the passenger and shipper should not be increased. Fifth, assuming the enactment of aviation regulatory reform, we should consider both the need for additional financing in the improved aviation economic environment that will emerge and the consistency of any proposal with a less regulated aviation system. Finally, we should consider and assess the additional benefits to the public that would accrue from a replacement program, and the accelerated production of new technology airplanes, and determine whether these benefits outweigh the cost of such a program.
To address these issues and hear recommendations from concerned parties, a public hearing will be conducted on aviation noise financing on December 1, 1976.
C. Additional Federal Action
1. Source Regulation for Future Aircraft
The development of jet engine noise source technology since the high-bypass ratio engine was first produced will allow further reduction of noise emissions from aircraft designed in the future. Therefore, FAA proposed to reduce the Part 36 noise levels for future design aircraft in NPRM 75-37 issued October 29, 1975. While recognizing that the full benefit of such a rule will not be felt until the next generation of aircraft enter regular service in substantial numbers, the FAA will soon complete its consideration of new, lower noise standards for future design aircraft. These standards will require that recent advances in noise suppression technology be employed if they are practicable, economically reasonable, and appropriate for the particular type of aircraft. These regulations would be applicable to all newly designed subsonic aircraft type certificated after the effective date of the regulation. The FAA plans to issue these regulations by March 1, 1977.
On September 30, 1976, the EPA submitted a proposed regulation to FAA on the subject of source regulation for future design aircraft. That proposal has been published by FAA as a notice of proposed rulemaking (41 F.R. 47358) and a public hearing will be held on December 14, 1976. The only difference between the FAA regulatory proposal and that of EPA is in the establishment of noise levels for aircraft designed for the 1980-1985 time period and beyond 1985 as well. While these EPA proposals are being considered, the FAA believes it is important and prudent to establish lower noise levels for future designed aircraft and continue to analyze the technological developments to determine if even further reduced noise levels can be established.
In addition, the FAA is working through the International Civil Aviation Organization to obtain international agreement on noise standards which would make internationally established standards virtually identical to United States noise standards. This proposal was presented for public comment in the Federal Register on October 28, 1976, as NPRM 75-37C. Both of these important proposals and the comments received on them will be thoroughly considered and carefully analyzed before final action is taken.
The FAA has already established noise standards on the subject of noise produced by propeller driven airplanes. In developing those standards, the FAA received a number of suggestions from the EPA which were adopted and incorporated into the final rule. These included the use of six rather than four noise certification test overflights and the use of longer standard takeoff distances in calculating performance corrections. These suggested improvements were submitted to FAA in the course of FAA's rulemaking action on this subject and were subsequently included as part of a formal EPA noise regulatory proposal submitted to FAA. The proposed disposition of the EPA regulatory proposal has been forwarded by FAA to the EPA for consultation pursuant to the provisions of the Noise Control Act. The time for this consultation has been extended by FAA at the request of the EPA and therefore the FAA is deferring its final action on this proposal at this time at the request of the EPA.
Using information being acquired on a continuing basis from the Concorde demonstration, the FAA will act consistent with the statutory requirements to promulgate a noise rule applicable to supersonic aircraft not later than thirty days after the conclusion of the 16-month demonstration periods.