Opinion / Guest Commentary / Our Readers Write:
This update covers the San Diego County Regional Airport Authority’s (SDCRAA) release of its recirculated Draft Environmental Impact Report (DEIR) on Sept. 19, 2019 which addresses the proposed $3 billion Airport Development Project (ADP) and its impact on commercial jet noise.
• SDCRAA set a deadline of Nov. 4, 2019 to file written comments about the DEIR. Please do, by submitting them to: SDCRAA, Attention Ted Anasis, P.O. Box 82776, San Diego, CA 92138-2776 or by e-mail: firstname.lastname@example.org, attention Ted Anasis.
• A public hearing is set for 4-7 p.m. Thursday, Nov. 21, 2019 at the Airport Noise Authority Office, 2722 Truxtan Road in Liberty Station. Please attend and voice your views.
• Airport Development Project: The ADP proposes a currently unfunded $3 billion-plus project to add 11 new gates, 29 overnight jet parking places, a new airport administration office and improvements, like restaurants and stores, to enhance the customer experience at Terminal 1. However, the ADP does nothing to mitigate the increasing jet noise that will affect the surrounding communities as a consequence of the expansion.
• Draft Environmental Impact Report findings: DEIR notes there will be very “significant but unavoidable harm” to human health associated with the ADP, associated with increased jet noise, due to more frequent flight operations during all hours, and significant risks of human physiological harm, stress, cardiac issues and cancer.
The DEIR notes the ADP will cause atmospheric environmental harm from greenhouse gas emissions and damage to environmentally sensitive areas and biodiversity. The DEIR acknowledges the FAA Reauthorization Bill of 2018 requires the FAA to study these issues, but then concludes human-health issues are “too speculative” to consider and dismisses them from further consideration in the DEIR and ADP.
The FAA and SDCRAA have it exactly backwards. Before spending $3 billion-plus on an airport improvement project that coincidentally enables the airlines to reach maximum capacity at SDIA sooner, the studies should be conducted and assessed first, before the ADP progresses — and the damage to human health and the environment is irreversible.
SDCRAA concedes that project implementation would cause a 3db or more increase in noise sensitive areas starting as early as 2024, due to a substantial increase in flight operations from the current average of 40 flights per hour now to an average of 50 per hour. That means La Jolla, where noise levels have traditionally been around 40-45 db, will be substantially impacted. The 29 additional jet overnight parking places will essentially guarantee about 29 more departing flights in the 6:30-9 a.m. window, and 29 more arrivals at night, as there is no curfew for arrivals, which fly directly over La Jolla Shores, La Jolla Mesa, and Soledad Mountain.
Perhaps worse, the SDCRAA also reveals that “implementation of the proposed project would cause a substantial increase in the number of night-time flight operations that produce Sound Exposure Levels sufficient to awaken an increasing population starting in 2024, which would be significant and unavoidable.”
The SDCRAA asserts its passenger and flight operations forecasts, which are used to justify the $3 billion-plus proposed project, predict unrelenting growth at San Diego International Airport, which is already the single busiest one-runway airport in the United States. SDCRAA says its forecast is primarily based on “the demand for air travel particularly in light of a strong economy and a robust tourism industry.”
However, those optimistic forecasts are based on assumptions the economy will continue growing at the same rate and the demand for air travel will continue unabated. The latter is already undermined by a current UBS Financial Services report issued Oct. 1 that predicts slowing demand for air travel and consequently jet orders at Boeing and Airbus — attributable to consumer concern over climate change and the contribution of jet-fuel carbon emissions. Further, forecasts disregard that the United States and global economies may be nearing final stages of their historic 10-year bull market run.
The DEIR and SDCRAA argue the increase in flight operations at SDIA would occur, with or without the ADP, because airlines will figure out a way to pack more flights into the airport schedule to meet customer demand, regardless of whether the airport is expanded. Yet, the SDCRAA also concedes the ADP and its 11 new gates and 29 new “remain overnight” jet parking places would enable SDIA to reach maximum capacity much faster.
Moreover, if the SDCRA is right that the ADP would “merely provide a better level of passenger service and more efficient terminal operations,” why spend $3 billion to $4 billion on the project?
• Adverse impacts to human health: The DEIR notes that if the ADP moves forward, the 65 db-75 db noise contour directly around the airport will significantly expand and the “noise would be significant and unavoidable.” The noise will not stop short of La Jolla and the increased noise is not good for humans.
The DEIR admits there are sleep disturbance, stress and cardiology issues associated with jet noise, but dismisses them. Buried in the DEIR is the statement that while a “relationship between noise and health effects seems plausible, it has yet to convincingly be demonstrated” and “it is not known whether changes in pulse rate and blood pressure cause harm or are a sign of harm”. The medical community, which seems eminently more qualified to opine than the self-interested FAA and SCRAA, thinks otherwise.
Indeed, the DEIR even notes that a 2018 World Health Organization study strongly recommended reducing noise-exposure levels produced by aircraft to below 45 db during the daytime and below 40 db at night, because of the causal relationship between noise and cardiovascular disease, sleep disturbances, cognitive impairment, adverse birth outcomes, mental health and quality of life.
Remarkably, the DEIR only addresses the probability of being awakened by jet noise, but conveniently provides no data about the inability to begin the sleep cycle until after jet noise from departures subsides at 11:30 p.m. each night. The DEIR notes implementation of the ADP “would result in a significant cancer risk human health impact,” which is “significant and unavoidable.”
The DEIR further says human perception of “annoyance from noise depends on frequency” and noise adversely affects children’s school performance for reading ability, concentration, motivation and long-term learning retention.
• Disregard of the FAA Reauthorization Act of 2018: The DEIR notes the FAA’s Reauthorization Act of 2018 requires additional noise studies to be completed, including a “health impact study” for many airports across the United States, of which one is the San Diego International Airport. Inexplicably, however, the DEIR concludes the California Environmental Quality Assessment (CEQA) Guidelines authorize an agency “who finds a particular impact too speculative after a thorough investigation, to note this conclusion and terminate the discussion of the impact.”
The SDCRA then unilaterally concludes: “The discussion above shows that, at this time, the effects of noise on cardiovascular health at noise levels below 65 CNEL are too speculative for further evaluation in this CEQA document,” and proposes to plow ahead with the ADP in the face of scientific and peer-reviewed medical concerns for human health.
• Ongoing plans to mitigate jet noise overlooked by DEIR and ADP: The DEIR is particularly troubling in light of the ongoing Flight Path & Procedure and Part 150 Studies, which are evaluating proposed solutions to mitigate jet noise arising from SDIA.
As discussed previously in this column, these proposed procedures require departing jets to fly further west over the ocean, away from La Jolla, before turning north or south. Further study will aslso be performed of proposals that consolidate the cone of departures to a 10-degree radius off the end of the runway, rather than 15 degrees; thereby keeping the planes away from the coastline north and south, pursuant to recent technical advances in satellite navigation.
These studies are projected to be completed in 2021 and should proceed to conclusion before the DEIR and ADP are further considered. The solutions from these studies should be required conditions before any EIR for the ADP is approved.
Let’s put the surrounding communities’ interests for quiet, healthful living ahead of the airlines’ and SDCRAA’s desire to maximize their revenue by building out the airport to accommodate 50 flight operations per hour. The correct order should be 1) assess and implement the current proposals to mitigate jet noise that affects the community, 2) gather and assess the medical evidence regarding the health risks of the San Diego Airport expansion, and 3) then consider expanding the airport operations which will increase the frequency of flight operations and the associated noise. SDCRAA and the FAA have the process exactly backwards.
• What can you do? Two things: First, submit a written comment by mail or e-mail the SDCRAA before Nov. 4, as described above. Second, attend the public workshop and hearing on Nov. 21, 2019 and make a statement. We need all hands on deck to insist and compel the SDCRAA to take steps in the right order to promote smart growth that synergizes airport expansion with noise mitigation for the San Diego community.
— For information about Quiet Skies La Jolla, visit quietskieslajolla.org
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