U.S. Citizens Aviation Watch Association Comments Continued


14. A moratorium must be enacted on all new airport construction and expansion, until such time as adequate and ENFORCEABLE environmental impact studies can be conducted by an unbiased government agency that places the welfare of the citizens and the environment ahead of commerce.

WE URGE YOU TO SUPPORT THE HALTING OF AIRPORT EXPANSION UNTIL THE FULL HEALTH AND ENVIRONMENTAL EFFECTS OF AIRPORTS ARE KNOWN AND PROPERLY MITIGATED.

It is obvious from recent news of airplane accidents, crowded airspace, shortage of pilots, labor disputes, antiquated air traffic control technologies, flight cancellations and delays, and mounting evidence of environmental degradation that the aviation industry and the FAA cannot manage what they already have. And yet, subsidized new airport construction and expansions continue. Is the airline industry simply trying to give "the people" what they want...the freedom to travel by air whenever they please? In every OTHER aspect of the travel industry, accommodations are made available ONLY as space permits. (For example, if the hotel one wishes to stay at is booked for the desired weekend, two choices remain: try another hotel or try another date). This inconvenience" might cause some people to reconsider their plans, and/or plan ahead. Either way...the demand on airports and the airlines would decline. The FAA and the airlines must say "ENOUGH" until they can provide safe, reliable and high quality services...with the resources they have NOW.

15. Environmental Impact Statements/Studies (EIS) and associated contracts must be legally enforceable.

On page 13 of the FAA Proposed Policy Document the following statement appears: "Changes in air traffic procedures that have potentially significant noise impacts on communities surrounding an airport require preparation of an environmental assessment or impact statement." As acutely demonstrated by Denver International Airport, these EIS are often based on educated guesses and groundless assertions as evidenced by the many lawsuits that local communities and organizations have brought forth. Promises/assurances made to local communities through the EIS are broken everyday and the citizens and local governments are left with no recourse as they discover that these documents are not considered "legal contracts". When legal contracts DO exist (as in the case with Adams County, Colorado) and violations occur, the court battles rage on for years at great financial cost to the citizens. In variably, the airlines and lawyers win...and the public and our environment loses.

16. Until the United States and its agencies fund unbiased research into the harmful effects of aviation noise pollution, they must look to the global community for guidelines.

The FAA often supports its position by pointing to the paucity of research in the field of noise pollution. In 1995 and 1999, the World Health Organization published respectively, Community Noise and Guidelines for Community Noise that provide a clear and comprehensive review of recent international research on the negative health effects of noise pollution, and relevant guidelines and recommendations pertaining to noise exposure and future research. The data and guidelines presented in these two documents should be studied by all federal agencies that are concerned with the health and well-being of this country's citizens and environment. Until further research occurs, new US noise policies should derive their noise exposure values from these two documents. The following section contains excerpts from the 1999 document.

(see: http://www.who.int/environmental_information/Noise/Commnoise4.htm)

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III: World Health Organization Recommendations

What follows in this section is an excerpt from the Guidelines for Community Noise published in 1999 without copyright by the World Health Organization, Geneva, Switzerland. This text presents the essential content of the document that we believe should form the basis of new noise pollution regulations in our country. Also included are the organization's recommendations for the implementation of guidelines and future research.

(see: http://www.who.int/environmental_information/Noise/Comnoise6.htm)

The reader is advised to seek out the complete document (http://www.who.int/peh/noise/noiseindex.html) in order to better understand the full content of the materials and to have access to all bibliographical references to the many research studies that are discussed in the report.

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ADDENDUM TO WORLD HEALTH ORGANIZATION GUIDELINE VALUES

At the time of this writing (October, 2000), the World Health Organization has taken under advisement the following additions to the guidelines published in 1999:

1. State LAmax values where currently NOT indicated as 15 dB higher than respective LAeq values.

2. Include the following C weighting correction:

If LeqC-LeqA>10dBA and LeqA<60dBA: ADD 5dBA to LeqA and LAmax values

If LeqC-LeqA>10dBA and LeqA>60dBA: ADD 3dBA to LeqA and LAmax values

3. Under "outdoors in parkland and conservation areas", state time base as 24 hours.

4. The number of allowable LAmax values are being considered by advisors to the World Health Organization, with total of ONE being proposed under the specific and extremely sensitive environment of "inside bedrooms at night" with time base of 8 hours. Under the environment "outdoors in parkland and conservation areas", ONE LAmax of 15 dBA above the normal quiet ambient level per hour, with time base of 24 hours, is being proposed.


cc: Multiple recipients

Jack Saporito
Pres., US-Citizens Aviation Watch Association / www.us-caw.org
Exec. Dir., Alliance of Residents Concerning O'Hare / www.areco.org