X.

        The FAA Must Re-Establish Local Citizen Control Over Airports  

Current FAA noise abatement policy is driven by those who benefit from 
airports and not by those adversely impacted by airport operations and  
pollution. This injustice can be corrected by giving back more local control 
to communities.

What is lacking is a procedure to ensure that airport decisions are made in 
such a way that they reflect resident interests as well as pro-aviation  
interest. There must be a better balance that gives more weight to residents 
living near airports.

What is needed is an increased voice of those most affected to ensure that  
residents and communities are compensated for any damage caused by airports 
and airport policy.
 
                                          XI.

          Airport Noise Has Increased, Not Reduce in the Last 30 Years  

The FAA claims that the number of people significantly impacted by aircraft 
noise is 7% of what is was 30 years ago. (See Noise Abatement Policy,  
Section 1: Introduction.) We believe that this is not true.

The FAA claims that they have substantially reduced the airport noise  
problem to 500,000 people impacted, mostly near the very largest airports in 
Chicago, New York, and New Jersey. Airport noise is a growing problem, not a 
decreasing one. The FAA's claims are misleading for several reasons.

(1) They inaccurately calculate the number of people effected.

(2) They rely on average noise levels that do not reflect the increase in 
the instances of interference resulting from more flights, 65 DNL, for 
example.

(3) Significant noise impact occurs well below the 65 day-night level that  
the FAA uses to establish significant noise impact.

(4) Nighttime flights have greatly increased, resulting in more people being 
awakened, but according to the FAA, awakenings are not a significant impact. 
  
(5) Airport expansion, new runways, and new flight paths are exposing people 
who have never been exposed before to airport and airplane noise. 
       
                                           XII.

                                   Concluding Comments
 
1. Of major concern to us is whether the FAA has the commitment, staffing,  
facilities, or the organizational structure to take on  greater regulation  
of jet and helicopter flight operations that create an enormous noise over a 
significant population. We question whether the FAA will be able to resist  
the heavy lobbying efforts of the aviation industry, including the National 
Business Aircraft Association (NBAA), the Airplane Owners and Pilots Assn.
(AOPA), the Helicopter Associates International (HAI), and local  
pro-aviation and media helicopter trade groups.

2. We are disturbed by the close and frequent contacts that exist between  
the FAA and NBAA, AOPA, HAI and others, with their heavy Washington, DC  
presence. It is essential that the FAA seek out local community groups to  
ascertain the real conditions and problems vis-à-vis noise issues.

3. We believe that the FAA's method of involving and informing the general  
public in noise matters in general is most unsatisfactory.  There are  
hundreds of noise organizations, and tens of thousands of individuals across 
the country that are actively engaged with airport, aviation and helicopter 
noise issues. The FAA should have made a much more massive and thorough  
attempt to reach these organizations for comment for Docket 30109.

Our organization, Homeowners of Encino (dba National Helicopter Noise  
Coalition [NHNC], Stop the Noise! Coalition [STN]), was actively involved in 
proposing minimum helicopter altitude regulations several years ago [See FAA 
Docket 27371]. Yet we were not informed by the FAA of the current docket  
effort. This speaks volumes about the intent and real commitment the FAA has 
to address fixed wing and helicopter noise problems. Our organization, which 
sponsors the Stops the Noise! Coalition (STN) and the National Helicopter  
Noise Coalition (NHNC), maintains an extensive list of groups and 
individuals across the country who should be informed directly by the FAA of 
Docket 30109. We will make this list available to the FAA, upon your request 
at no charge.

5. We find it distressing that such a short time frame was allowed by the  
FAA to gather public comment on the revised draft of the Aviation Noise  
Abatement Policy 2000. Many community groups and individuals are vitally  
affected, but cannot prepare the necessary response in the short time  
allowed for public comment.

6. The requirement for actual physical receipt of comments in triplicate is 
unreasonable. The FAA should also solicit comment by email, and fax, and  
establish a voice mail hot-line to record spoken comments.

7. Many community, citizen, neighborhood and volunteer groups hold monthly  
meetings, and frequently take off summers. These groups will not have been  
properly notified of the FAA's interest in seeking comment on the revised  
noise policy.

8. The FAA must resist the aviation industry distortions and pressure.
Hopefully the FAA will discount the flood of comments that may be received  
from the aviation industry and other vested industry groups. It would not be 
responsible for the FAA to revise the Aviation Noise Abatement Policy 2000  
based upon one-side and biased industry input.
 
                                           XIII.
 
Executed at Encino, California on August 10, 2000 by Gerald A. Silver,  
President, Homeowners of Encino.
 
_____________________________________
 Gerald A. Silver, Pres.