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The original documents are located in Box 3, folder "Aircraft Noise (18)" of the James M.
Cannon Files at the Gerald R. Ford Presidential Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
Digitized from Box 3 of the James M. Cannon Files at the Gerald R. Ford Presidential Library
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
FAR Part 36 Compliance Regulation
OF
DIPARTMENT
*
*
UNITED STATES OF AMERICA
FINAL ENVIRONMENTAL IMPACT STATEMENT
Pursuant to Section 102(2)(C), P.L. 91-190 -
GERALD
FORD i LIBRARY
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
FAR Part 36 Compliance Regulation
FINAL ENVIRONMENTAL IMPACT STATEMENT
Pursuant to Section 102(2)(C), P.L. 91-190
CONCUR:
Assistant Judith Safety and Secretary Consumer for Affairs, T. Environment, Connor TES-1
11/10/76
Date
APPROVAL: bhals RDot
Director, Office of Environmental
11/10/76
Date
Quality, AEQ-1
SUMMARY
(Check One)
( ) Draft
() Final Environmental Statement
Department of Transportation, Federal Aviation Administration
1.
FAR Part 36 Compliance Regulation
(Check One)
() Administrative Action
( ) Legislative Action
2.
The action is an amendment of the Federal Aviation Regulations,
FAR Part 36 extending noise standards to civil subsonic
turbojet airplanes with maximum takeoff gross weight of 75,000
pounds or more, operating into United States airports.
3.
The regulation will provide substantial noise relief to persons
throughout the United States living near airports accommodating
the aircraft subject to the amended rule. Minor increases in
fuel consumption and air pollution from aircraft emissions may
result from compliance with the noise standards.
4.
The following categories of alternatives were considered:
A.
No action and deferred action.
B.
Noise reduction solely through operational procedures.
C.
Less stringent standards than proposed in NPRM
0
higher noise levels
0
allow tradeoffs and/or compliance with ICAO Annex 16
0
exempt international operations
0
modify JT3D aircraft only
D.
More stringent standards
0
establish more stringent standards than proposed, implying
refan (or reengine) for all non-Part 36 aircraft
5.
Comments have been requested from:
Environmental Protection Agency
- Office of Federal Activities
Federal Energy Administration
Office of Management and Budget
Civil Aeronautics Board
Department of Commerce
- National Bureau of Standards
Department of Health, Education, and Welfare
Department of Housing and Urban Development
Department of the Interior
- Bureau of Outdoor Recreation
- Bureau of Sport Fisheries and Wildlife
- National Park Service
National Aeronautics and Space Administration
Department of State
United States House of Representatives
- Appropriations Committee
- Committee on Science and Astronautics, Subcommittee
on Aeronautics and Space Technology
United States Senate
- Appropriations Committee
- Commerce Committee, Aviation Subcommittee
- Public Committee
State Aviation Agencies
City of Inglewood, California, Office of the Mayor
City of Burbank, California, Office of the Mayor
City of Santa Maria, California, Office of City Administrator
Village of Lawrence
Incorporated Village of New Hyde Park
Village of Cedarhurst
6. The final statement was filed with the Council on Environmental Quality
and made available to the public on November 17, 1976. The draft statement
was circulated for comment on December 6, 1974.
TABLE OF CONTENTS
Page
SUMMARY
I. INTRODUCTION: THE FEDERAL ACTION
II. PROBABLE IMPACT OF THE PROPOSED ACTION ON THE ENVIRONMENT
9
III. ALTERNATIVES
24
IV. THE RELATIONSHIP OF THE PROPOSED ACTION TO LAND USE PLANS,
36
POLICIES AND CONTROLS FOR THE AFFECTED AREAS
V. ANY PROBABLE ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT
36
BE AVOIDED
VI. LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE
37
MAINTENANCE OF LONG-TERM PRODUCTIVITY
VII. ANY IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
38
THAT WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE
IMPLEMENTED
VIII. BENEFITS TO COUNTER-BALANCE ADVERSE ENVIRONMENTAL EFFECTS
38
IX. PUBLIC COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
39
X. REFERENCES
51
APPENDIX A: NOTICE OF PROPOSED RULE MAKING
APPENDIX B: SUMMARY UNITED STATES AIRCRAFT FLEET FORECAST
APPENDIX C: IMPACTS ON NATIONAL ECONOMY: INFLATIONARY
IMPACT STATEMENT
APPENDIX D: ANALYSIS OF THE COSTS AND BENEFITS OF
THE REGULATION
APPENDIX E: SINGLE EVENT NOISE REDUCTIONS FOR
AIR CARRIER JET AIRCRAFT
APPENDIX F: IMPACT OF NOISE ON PEOPLE
APPENDIX G: COMMENTS ON DRAFT ENVIRONMENTAL
IMPACT STATEMENT
APPENDIX H: BIBLIOGRAPHY
APPENDIX I: FAR PART 36 COMPLIANCE REGULATION SUMMARY
FINAL ENVIRONMENTAL IMPACT STATEMENT
I. INTRODUCTION: THE FEDERAL ACTION
The Federal Aviation Administration issued (1) two Notices of
Proposed Rule Making (NPRM) entitled "Civil Airplane Fleet Noise
Requirements," and "Civil Subsonic Turbojet Engine Powered Airplanes:
Noise Retrofit Requirements." The latter was submitted to the FAA
by the Environmental Protection Agency (EPA) pursuant to the provisions
of the Noise Control Act of 1972. (Both NPRM's are in Appendix A.)
These proposed regulations would require U.S. civil subsonic turbojet
engine-powered airplanes to meet the noise requirements of FAR
Part 36. The first NPRM was applicable to airplanes with maximum
weights of 75,000 pounds or more, while the second NPRM had no such
limit. The only significant difference between the two NPRMs is
that the EPA proposal regulation would extend to business jets. In
addition, both proposed regulations require operators of these
aircraft to show that they are progressing toward compliance with
these standards in a phased program.
It is not the purpose of this EIS to describe the regulatory action
being taken in detail or respond to all comments on the regulatory
proposal. This impact statement considers the consequences of the
final rule which requires civil subsonic turbojet aircraft over
75,000 pounds maximum weight to comply with FAA Regulation Part 36
noise requirements under a schedule beginning January 1, 1977, and
ending December 31, 1984. The final rule will consider, with more
specificity comments received in the docket, public hearings, and
interagency review.
2
In extending the FAR Part 36 noise standards to aircraft which received
airworthiness certificates prior to applicability of FAR Part 36, the
FAA is acting pursuant to the Federal Aviation Act of 1958, as amended
by the Noise Control Act of 1972. By that Act, the Congress directed
the FAA to afford present and future relief and protection to the public
health and welfare by the control and abatement of aircraft noise with
the requirement that any standards or regulations must be consistent
with the highest degree of safety in air commerce and must be economically
reasonable, technologically practicable, and appropriate for the particular
type of aircraft. This amendment to the Federal Aviation Regulations
is the result of a number of years of study of these factors by the FAA
and consultation by the FAA with the EPA and the Secretary of
Transportation which balances the considerations of public welfare,
safety, economic reasonableness, and technological practicability.
Under the requirements of the Noise Control Act of 1972 (18), and previous
legislation, the FAA and other Federal agencies have been developing a
comprehensive program to reduce public exposure to aircraft noise. In
addition to FAA-sponsored research in reduction of turbomachinery noise
through the use of sound absorbing materials (SAM), NASA has conducted
a parallel program which included SAM, but also focuses on reduction
of JT8D jet exhaust noise by redesign of the engine itself by increasing
the engine bypass ratio through replacement of the two-stage fan
with a larger diameter single-stage fan (refan). Complementing
these programs in source noise reduction, FAA and NASA have also
been examining the use of operational procedures for further reductions
in noise.
3
Aircraft noise is a significant annoyance for six to seven million
Americans. The problem is particularly serious at some of the major
airports, such as those in New York, Los Angeles, Boston, Atlanta and
Chicago. It represents, moreover, a significant or potential problem
for residents living near many other airports across the nation, and
as air travel increases, noise will become a serious problem at some
of these other airports as well. Aircraft noise is a problem of national
scope because a significant portion of the American people are affected
by it at many locations throughout the country. For example, the 1973
Annual Housing Survey conducted by the Bureau of the Census for the
Department of Housing and Urban Development, indicated that of those
surveyed, 20.2% experienced noise from airplane activity in the vicinity
of their home. Of those experiencing noise - 34.2% considered the noise
to be disturbing, harmful or dangerous; 6.3% felt airplane noise to be
so objectionable that the household would like to move from the neighborhood.
Airplane noise is also a peculiarly local problem, varying substantially
among airport communities depending on the air service provided,
the type and frequency of operations, the airport design and geographical
arrangement, the mix of equipment and route patterns, the numbers
of people who live nearby and their reaction to aircraft noise, and
the general compatibility of land use in the surrounding areas.
The aircraft noise issue became increasingly important in the early
1960s as airlines introduced jet aircraft to their fleets. The rapidly
increasing number of commercial jet operations in the latter part of
the decade further increased the importance of this problem. Because
4
of its adverse effect on people, noise was soon recognized as a major
constraint on the further development of commercial aviation, and action
was taken to address it. The engine manufacturers and the Federal
Government both engaged in extensive research into quieting jet engines.
In 1968, Congress gave the FAA the responsibility to regulate aircraft
design and equipment for noise reduction purposes, and the FAA then
embarked upon a long-term program of controlling aircraft noise at its
source. FAR 36 set standards for turbojet aircraft of new design
in 1969. A 1973 amendment extended the same standard to all new
aircraft of older design. A third major milestone in the source noise
control program is this one, in which the previously built subsonic
air carrier aircraft must be brought into compliance with the noise
limits of FAR Part 36 or be retired from service in the U.S. by the
established compliance dates. (See Appendix I for regulation summary.)
Compliance deadlines for each aircraft type have been established
on the basis of what is technologically practicable and economically
reasonable. See Appendix D for the analysis of the cost and benefit
of the regulation.
5
The United States will work through the International Civil Aviation
Organization (ICAO) to reach agreement with other nations on a program to
abate aircraft noise. If agreement is not reached, action will be
taken to require that aircraft flown by carriers of other countries
meet FAR Part 36 noise levels at a future specified date which is expected
to be consistent with the requirements established for U.S. flag carriers.
The current U.S. fleet is comprised of some 2100 large jet aircraft.
Of these, 1600 (about three-fourths) do not comply with FAR Part 36
noise standards. It has been estimated by various sources (2, 3, 4, 5)
that between 1,300 and 1,600 of these noncomplying aircraft would
remain in service throughout the 1970s and possibly some 50% would be in
service by 1990 if there was no federal action. Appendix B contains
a detailed listing of the existing fleet and fleet forecasts developed
by the FAA. These data were used in the environmental and inflationary
impact analyses supporting this rule making. While the cost and
benefit analysis (Appendix D) indicates that prolonged retention of
the B-707 and DC-8 fleet would be uneconomical due to increased
maintenance and higher fuel cost differentials, the replacement
policy of individual operators will depend on their capital investment
plans and financial capability.
7
noise levels so that modifications can readily be made to the
previously produced aircraft. British Aircraft Corporation, in
conjunction with Rolls Royce Limited (1971), has evaluated results
for an acoustic modification for the Rolls Royce SPEY engine powering
the BAC-111 airplane (12).
The FAR Part 36 noise standards are shown graphically in Figures I-1,
I-2, and I-3 (13, 14) along with the corresponding values for jet
airplanes in current use. It can be seen that reductions in noise
level at the FAR Part 36 measuring points ranging up to 14 EPNdB
will be achieved for a number of air carrier transport types through
compliance with FAR Part 36 noise levels. (See Section II for a
description of the measuring point geometry.)
FORD & LIBRARY GERALD
APPROACH NOISE
120
B707-320 B/C
CONCORDE
B707-1208
115
DC 8-61
B747-100 ('69 A/C)
Figure I-1 Noise Levels of Aircraft at
FAR Part 36 Approach
B747-100 ('71 A/C)
Measuring Point
DC 10-30
110
B747-200
B747 SR
CF6
JETSTAR I
II 87472008 108
DC 10 RSN
B707- 320 B/C ON
?!
105
FAR-36
B737-200
DC 10-10
B747 RSN
8727-200
DC 10-40
L1011-1
HS 125
102
U
DC 9-50
B747 SP
LEARJET 24
F28-1000
A300B
B707-120B ON
100
+
SABREL'R 80
GRUMMAN II
i
SABREL'R 60
EPNL
DC 9-30
JETSTAR II
95
FALCON 10
:
LEARJET 35/36
90
CORVETTE
CITATION
85
BPR ≤2 BPR> 2
2 ENGINE AIRCRAFT
3 ENGINE AIRCRAFT
80
-
4 ENGINE AIRCRAFT
+
FAR-36 1852 m (1.0 N. MI.)
8
75
(1000 LBS)
10
20
30
40
50
60
70
80
100
200
300
400
500
600
800
1000
TAKEOFF WEIGHT
(METRIC TONS)
5
IO
20
50
100
200
400
SIDELINE NOISE
120
Figure I-2 Noise Levels of Aircraft at
FAR Part 36 Sideline
115
CONCORDE
Measuring Point
110
FAR-36
108
JETSTAR I
B707-320 B/C
DC 8-61
B747-100 ('69 A/C)
105
B707-120 B
HS 125
B737-200
B747-100 ('71 A/C)
it
B707-320 B/C QN
B747 SP
102
GRUMMAN II
II
DC 9-50
8747-200B
B727-200
B747 SR
100
SABREL'R 60
B707-120 B/C QN
B747-200 CF6
EPNL
LEARJET 24
F28-1000
DC 9-30
B747-RSN
DC 10-30
DC 10-RSN
DC 10-10
95
A300 B
LI011-1
DC 10-40
SABREL'R 80
:
JETSTAR II
90
LEARJET 35/36
FALCON 10
85
CORVETTE
CITATION
BPR â 2 BPR > 2
2 ENGINE AIRCRAFT
3 ENGINE AIRCRAFT
80
4 ENGINE AIRCRAFT
450 m (.25 N. MI.)
2 & 3 ENGINE
8a
75
(1000 LBS)
10
20
30
40
50
60
70
80
100
200
300
400
500
600
800
1000
TAKEOFF WEIGHT
(ME TRIC TONS)
5
IO
20
50
100
200
400
4 ENGINE DATA POINTS ADJUSTED TO 450 M.
TAKEOFF NOISE
120
Figure I-3 Noise Levels of Aircraft at
CONCORDE #
FAR Part 36 Takeoff
Measuring Point
B747-100 ('69 A/C)
115
If
DC.8-61
B707-320 B/C
B747-100 (70A/C)
110
If
B747-200B
B707-120 B*
108
B747-100
A/C)
JETSTAR I
B747-200
OF6
105
i
B747 SP
DC 10-30
B707-320 B/C* ON
B747-RSN
DC 10-RSN
DC 10-40
B727-200* QN
100
+
HS 125
B747-200*
B747 SR
CF6
J
DC 10-10
EPNL
DC 50*
L1011-1
FAR-36
B707-120B* QN
DC 9-30*
95
=
SABREL 'R 60
B737-200*
93
JETSTAR TI
0
SABREL'R 80
GRUMMAN II
LEARJET 24
90
F28-1000*
+
A 300B*
85
LEARJET 35/36
BPRS 2 BPR> 2
2 ENGINE AIRCRAFT
CORVETTE
3 ENGINE AIRCRAFT
80
FALCON 10
4 ENGINE AIRCRAFT
I
CITATION
CUTBACK
6500 m (3.5 N. MI.)
8b
75
(1000 LBS)
IO
20
30
40
50
60
70
80
100
200
300
400
500
600
800
1000
TAKEOFF WEIGHT
(METRIC TONS)
5
IO
20
50
100
200
400
9
II. PROBABLE IMPACT OF THE PROPOSED ACTION ON THE ENVIRONMENT
In this section, an examination is made of the expected environmental
benefits to be achieved from implementation of the final rule
prescribing operating noise limits that apply within the United States
to the landing and takeoff of civil subsonic turbojet-powered airplanes
operating under FAR Parts 91, 121, 123, and 135, and that have maximum
certificated takeoff weights of 75,000 pounds or more. In addition,
possible negative effects on other aspects of the environment are
addressed.
NOISE BENEFITS
Before the FAA issued the NPRM's (1), the technological alternative of
modification was examined thoroughly. The FAA determined that the SAM
nacelle treatment would provide meaningful relief, that is, it would
result in a reduction in airplane noise levels which would significantly
reduce annoyance levels for persons living near airports.
The absolute magnitude of the reduction in effective perceived noise
decibels (EPNdB) for the various effected aircraft is shown in Table II-1.
This shows improvements ranging from some 13 EPNdB for JT3D powered
aircraft, 4-6 EPNdB for JT8D powered aircraft, and 3 EPNdB for JT9D
powered aircraft. Discussions of the effects of reductions of noise
on people are contained in Appendix F.
The FAR Part 36 measuring points are locations from which the noise of a
particular aircraft is measured during certification. They result in
noise level measurements of an aircraft at 1 nautical mile from the
10
TABLE II-1
NOISE LEVELS UNDER FAR 36 CERTIFICATION CONDITIONS (EPNdB)
FAR 36
Fully
Aircraft
Condition
Limit
Unmodified
Modified
707-320B
Takeoff
103.7
113.0
102.2
Approach
106.3
116.8
104.0
Sideline
106.3
102.1
99.0
DC-8-61
Takeoff
103.5
114.0
103.5
Approach
106.2
115.0
106.0
Sideline
106.2
103.0
99.0
727-200
Takeoff
99.0
101.2
97.5
Approach
104.4
108.2
102.6
Sideline
104.4
100.4
99.9
737-200
Takeoff
95.8
92.0
92.0
Approach
103.1
109.0
102.2
Sideline
103.1
103.0
103.0
DC-9
Takeoff
96.
96.
95.0
Approach
103.2
107.0
99.1
Sideline
103.2
102.0
101.0
747-100
Takeoff
108.0
115.0
107.0
Approach
108.0
113.6
107.0
Sideline
108.0
101.9
99.0
11
runway threshold under the approach path, 3.5 n. mi. from takeoff
roll under the takeoff path, and .35 n. mi. (4-engine) or .25 n. mi.
(2- and 3-engine) to the side of the runway at the point of maximum
noise during takeoff. Although the FAR Part 36 figures do not provide
projections of total noise impact at an airport, they do provide a
standardized method of measuring aircraft noise for certification
purposes and are very useful in indicating the comparative noise
levels of individual aircraft. (See Appendix E, noise footprints.)
It should be noted that not all aircraft will achieve equal reductions
using the SAM modification packages. Some will benefit more than others,
due to differing aircraft power curves, installation, and operational
characteristics. Additionally, the sound level reductions at all
three measuring points (takeoff, sideline, and approach) will not
be equal, as can be seen from the Table. However, it should be
noted that in optimizing the engine modification materials and
installation, many aircraft will be able to achieve levels at some
measurement points which are below the requirements of FAR Part 36.
In a letter to the FAA, referencing the above reductions in noise
levels, members of the Committee on Hearing and Bioacoustics of the
National Research Council of the National Academy of Sciences and
the National Academy of Engineering stated:
12
"We believe that the above reductions in aircraft noise
level represent significant and beneficial improvements,
which will provide meaningful and perceivable relief to
airport neighbors. Recent research had indicated clearly
that aircraft noise reductions on the order of 6 EPNdB are
quite apparent to residents near airports and result in
substantially less annoyance to those residents."
In its project report (20) dealing with recommended noise standards
for civil subsonic turbojet airplanes, The Environmental Protection
Agency states that nacelles treated with SAM would result in a
meaningful reduction in airport community noise exposure. The
benefits were predominantly attributed to approach operations for
JT8D aircraft and for both takeoff and approach operations for JT3D
aircraft.
A NASA sponsored study conducted by Professor Paul N. Borsky (15) of
the Columbia University's School of Public Health, College of Physicians
and Surgeons, demonstrated that there was a 50 percent reduction in the
number of test subjects who had expressed highest annoyance of the
standard B-727 aircraft as compared to the SAM acoustically treated
B-727. This reduction was perceived in laboratory tests using test
subjects who live in the Kennedy International Airport environment
and was achieved with a difference of 6 EPNdB between the two aircraft.
An additional psychoacoustic study (16) conducted by NASA using
DC-8 noise characteristics has shown that sleeping test subjects have a
markedly lower degree of wakefulness when exposed to the noise spectra
which would be produced by an acoustically treated DC-8 as compared
to spectra from an untreated aircraft.
13
Noise measurements taken by the Port Authority of New York and New
Jersey during routine airline operations at airports in the New York
City area, showed that B-727-200 aircraft which were produced to meet
FAR Part 36 were, on the average, during approach, 6.5 PNdB lower
than the B-727-200 aircraft which were not produced meeting FAR
Part 36. The value relates to a point about 1 mile before landing.
A joint FAA-Boeing Company project, which culminated in May 1973 flyover
demonstrations for members of Congress and the public at Dulles Inter-
national Airport, proved that takeoff noise reductions of 11 EPNdB
and approach noise reductions of 15 EPNdB were achievable using nacelles
quieted with sound absorbing material on a JT3D powered B-707
aircraft and, that the noise reduction was highly significant and
clearly perceivable.
A final indication of the benefit of the FAR Part 36 limits are
established by the relative improvement resulting from the intro-
duction of new widebody aircraft which comply with FAR Part 36.
Letters to the docket in response to the NPRM, letters to Congress
and the FAA, and public sessions with airport neighbors have provided
a limited sample of public opinion which shows that the new wide-
body jets are more acceptable than the older jets not only because
the noise levels are lower but the total spectra content, particularly
on approach, is not as annoying.
14
Table II-1 reflects the noise benefits expected from representative
aircraft based upon noise intensity at specific points. A measured
(or computed) noise level varies with the distance of the aircraft
from the point at which the sound is observed. When the variations
of noise with distance are combined with knowledge of other attenuation
effects, a projection of lines of equal noise level can be prepared
and displayed as "noise footprints." Such noise footprints have
been prepared at various noise levels for aircraft with and without
quiet nacelles. Examples are shown in Appendix E which indicate
the degree of reduction in areas of noise impact achievable through
compliance.
The previous discussion has dealt with the benefits associated with
single events, individual aircraft takeoffs/departures and landings.
The Department of Transportation completed an extensive study
in which it viewed the noise impact that these events would have at
each of 23 major airports, the impact at the aggregate of these 23
airports, and the impact at a representative airport (derived from the
23 airports). The data from the 23 Airport Study have been used by the
FAA to model the effect of compliance and other noise abatement
alternatives on a national basis.
The FAA currently estimates that there are 6 million people residing
on 1500 square miles exposed to cumulative noise levels of NEF 30 or
higher and 1/2 million people residing on 150 square miles exposed to
15
NEF 40 or higher. Compliance with the regulation can, by 1985,
shrink the NEF 30 contours away from some 2.5 million people in the
U.S. providing that replacement of JT3D powered aircraft is extensive.
About .25 million people, or half of those presently within NEF 40
contours, will similarly benefit by shrinkage of the NEF 40 contours.
These environmental benefits will being prior to 1985 and continue
for many years thereafter. Figures II-1 and II-2 indicate the FAA
projections of the percentage reduction in the size of noise impacted
population around all U.S. airports as a result the major alternatives
considered in the benefit and cost analysis. These alternatives
cover the range of possible industry response to the regulation.
Discussions of the meaningfulness of NEF values are found in Appendix
F. NEF 30 annoyance response is cited as 38% of the population
annoyed and 27% seriously annoyed; for NEF 40, the seriously annoyed
population is 69%.
The NEF procedure has been developed over the last decade for land-use
planning around airports as the number of jet aircraft has increased
and their noise has become more of an annoyance. NEF is a cumulative
noise exposure descriptor which is meaningful in measuring the
overall impact that residents around busy airports might experience
from the mix of equipment and time of day and frequency of flights
serving a particular airport. The Environmental Protection Agency has
110
Base Case
100% Modify
100
90
80
Impacted Population as a % of 1976 Baseline (6 million people)
Replace JT3D, Modify JT8D
70
60
Modify/Replace JT3D, Modify JT8D
50
40
30
20
10
0
1976
1980
1985
1990
1995
Year
16
RELATIVE EFFECTIVENESS - IMPACTED POPULATION
(NEF 30)
FIGURE II-1
110
100
/
90
80
Impacted Population as a % of 1976 Baseline (.5 million people)
Base Case
70
100% Modify
60
Modify/Replace JT3D, Modify JT8D
50
40
Replace JT3D, Modify JT8D
30
20
10
0
1976
1980
1985
1990
1995
Year
17
RELATIVE EFFECTIVENESS - IMPACTED POPULATION
(NEF 40)
FIGURE II-2
18
recommended use of a cumulative noise exposure expressed by
a measure called Day/Night Noise Level (Ldn). Equivalent NEF
values can be expressed approximately as:
NEF 30 = Ldn 65; NEF 40 = Ldn 75
A decrease of one NEF unit is equivalent to a reduction of 2 percent
in the number of people highly annoyed and is equal to a reduction of
about 14 percent in the area exposed. (See Appendix F for a more
detailed discussion of noise effects.)
The relationship between NEF reduction and land area reduction is
logarithmic, so that a 50 percent reduction in land area is approxi-
mately equivalent to a 4.5 NEF unit reduction, while a 25 percent
reduction in land area is approximately equal to a 2.0 NEF unit
reduction. While small differences in single event noise exposure
are sometimes not noticable, frequent repetition of the noise can
result in substantial NEF changes.
There are two basically different groups of aircraft which exceed the
FAR Part 36 noise limits--the four-engine Boeing 707 and McDonnell
Douglas DC-8 transports, powered with Pratt and Whitney JT3D engines,
and the two- and three-engine Boeing 727 and 737 and McDonnell
Douglas DC-9 transports, produced before December 1, 1973, powered
with Pratt and Whitney JT8D engines. As of December 31, 1975, the
U.S. fleet contained 508 aircraft in the first group and 1078 in
the latter group. The regulation affects both groups. However,
for purposes of this study, the JT8D equipped aircraft are assumed to
receive the same degree of modification in all cases analyzed while
19
the JT3D aircraft are alternatively viewed as modified, modified
and replaced in combination, and completely replaced. (The baseline
case shown in Figures II-1 and II-2, of course assumes that neither
JT3D or JT8D aircraft are given any acoustic treatment not already
required by FAR Part 36.)
Forecasts of fleet structure show that without this rule more than
60% of the B-707 and DC-8 aircraft would be continued in operation
through 1985 in regular airline service and perhaps indefinitely in
other domestic uses after 1985.
Replacement aircraft available today are the B-727-200, B-747, DC-10
and L-1011. With respect to future needs, aircraft manufacturers
are now considering two types of new "low-noise" aircraft for production.
These include: new technology aircraft such as the Boeing 7X7 and new
technology/derivative aircraft such as the Douglas DC-X-200 designed to
meet the stricter noise standards currently being proposed for modi-
fication to FAR Part 36. Upon receipt of orders, it is estimated
that production could be started on these aircraft within four years.
Insofar as future fleet composition is concerned, a particular replace-
ment program has been forecast, based on air carrier indications of
their plans for updating their fleets, assuming that the government
were to take no action with regard to noise reduction requirements for
aircraft which do not now meet FAR Part 36. In the base case the B-707/DC-8
20
aircraft remain in the fleet with normal attrition and without
acoustical modification. The forecast is based on industry data
through 1984, and trend extrapolation beyond that time. From a
technical standpoint, the B-707/DC-8 life can be extended as required,
but from an economic standpoint the increased cost that occurs in
conjunction with maintaining older aircraft may be a significant force
for airlines to achieve some faster attrition rate than indicated by a
trend extrapolation. This factor, however, is difficult to define with
any degree of certainty since the attrition rate is also dependent on
capital investment capability to finance the acquisition of new aircraft.
Figures II-1 and II-2 consider actions that represent various possible
airline management decisions to modify and/or replace B-707 and DC-8
aircraft in their fleets. The possible alternatives range from 100%
modification to 100% replacement. The JT8D aircraft are assumed to be
modified rather than replaced because they have a longer remaining
useful life. The most likely alternative for the JT3D aircraft
depends on individual airline management decisions. In order to cover
the likely possibilities, therefore, three alternative modification/
replacement scenarios have been selected as presented in Figures II-1
and II-2):
Base Case - No regulation
Case 1 - The modification of 100% of the JT3D and JT8D powered
noncomplying aircraft;
Case 2 - A combination of modification and replacement: modify
100 B-707/DC-8 aircraft and replace the remainder
with new technology aircraft; and modify all
noncomplying JT8D aircraft; and
Case 3 - 100% replacement of the B-707/DC-8 fleet with new
technology aircraft, modify all noncomplying JT8D aircraft.
21
The analysis on which Figures II-1 and II-2 are based incorporates
a detailed breakdown of projected aircraft modification/replacement
as a function of future years. The schedule for the alternatives
considered is included in Appendix B.
FUEL CONSIDERATIONS
As part of their respective noise suppression programs the manufacturers
have performed extensive engine performance tests including the study of
effects upon SFC (Specific Fuel Consumption). Indications from both
Boeing and McDonnell Douglas are that at most, "negligible" fuel
consumption increases would result from modifications required to meet
FAR Part 36 noise standards (21, 22, 23). Conservative estimates for
the B-707-120B, B-707-320B/C and B-720B aircraft range from 1.4% to
2.5% increase in in-flight fuel consumption due to engine modification.
In the case of the B-727-200, ground and flight test results indicated
a penalty of .48% increased SFC relative to an unmodified B-727-200
(22). However, the expected new technology aircraft (7X7) has been
assumed to provide a 30% savings in fuel consumption in comparison
to the consumption of a B-707-300.
22
Using these estimates in conjunction with data on aircraft fuel
usage (1bs/hr) by aircraft type (24), projections for changes in
overall fuel consumption were determined for each of the alternatives.
The following presents the approximate relative change in total
fuel usage per flight hour per aircraft due to each of the three
cases over the years 1976 to 1995:
Change in Fleet Fuel Consumption
Case
from BASE CASE
All modify
Increase less than 1%
Replace/Modify JT3D, Modify JT8D
Decrease of 3%
Replace JT3D, Modify JT8D
Decrease of 4%
The worst of the three alternatives results in an insignificant
deterimental effect upon aircraft fuel consumption. Two cases show
a probable benefit in terms of fuel consumption.
EMISSION CONSIDERATIONS
Since the modifications to meet noise levels do not involve changes
to the engine combustion chambers, no fundamental changes in the
pollutant production process is expected. No changes in thrust are
anticipated during idle and taxi, so pollution emissions from
modified aircraft are expected to be unchanged during ground operations,
the phase of activity that is most critical to the airport impact
on air quality. During the in-flight phase of operation, changes
in emissions of modified aircraft are expected to be proportional
to changes in fuel consumption.
23
Absent compliance with existing EPA aircraft emission standards
(17), new technology aircraft are expected to have greater oxides
of nitrogen emissions than older aircraft, since their propulsions
systems will operate at higher peak combustor temperatures. Based
on the forecasts presented in Appendix B, however, fleet emission
increases (considering the DC-10, L-1011, B-707, DC-8, B-720, B-727
and new technology aircraft as a group, and summing from 1976-1995)
are only of the order of 1 or 2%. On the other hand, decreases of
the same magnitude would be expected for that group's carbon
monoxide and hydrocarbon emissions, owing to the better combustion
efficiency of the new technology engines.
The above considerations of fuel use and emissions are based on an
assumed "static" regulatory environment. However, currently existing
EPA emission standards (17) are expected to require reduced emissions
for all newly manufactured aircraft engines after 1979. The changes
to fleet emissions which will accrue as a result of compliance with
EPA emission standards will far overshadow the minor effects of any
of the modification/replacement programs considered herein; the
same is likely to be true for effects on fleet fuel consumption.
24
III. ALTERNATIVES
A number of alternatives were considered by the FAA. Among the
comments received in response to the NPRM have been suggestions for
alternate approaches ranging from no action on source noise reduction
to more stringent noise level standards. The alternatives considered
are in the following four categories:
(1) No action or defer action.
(2) No aircraft modification - noise reduction solely through operational
procedures.
(3) Modification, but with less stringent standards than proposed
in the NPRM.
higher noise levels
allow tradeoffs and/or compliance with ICAO Annex 16
exemption for international operations
retrofit of JT3D aircraft only
(4) More stringent standards
establish more stringent standards than proposed.
25
1. No Action or Defer Action
One of the arguments advanced for preserving the status quo of JT3D
engine source noise was the concept that natural changes in fleet mix
(i.e., replacement of older design aircraft with quiet wide-body jets)
would eventually provide noise relief equal to that to be obtained
through modification. Figures II-1 and II-2 (Base Case and 100%
modification) show the FAA projection of this phenomenon. The signifi-
cance is not that eventually no-action impact converges with the 100%
modification case, but rather it is the noise improvement to be enjoyed by
millions of citizens over many years as a result of regulatory action now.
It must be noted that the other likely possibilities in the range of
alternatives projected as a result of the regulation result in much
greater noise benefits. Early replacement produces such large and early
benefits that convergence with no-action would not occur until long
after 1995.
The significance of the benefits of the regulation have been discussed
previously. The regulation compliance dates are predicated on technical
feasibility and reasonable costs of compliance considering the benefits.
(See Appendix D for discussions of costs and benefits of the regulation.)
There is no reason to delay or not to act under these circumstances.
2. No Modification - Use Operational or Other Procedures
Under this alternative the operational procedures considered are
those that are employed in the aircraft cockpit to reduce noise on the
ground during takeoff, departure, and approach. These alternatives do
not include preferential runway and routing for noise abatement practiced
26
by personnel responsible for airspace management on the ground.
It should be noted that while operational procedures, where feasible,
can be used to augment the benefits of the regulation, they do not in
themselves provide sufficient noise relief to cease efforts to
reduce the impact of aircraft noise at its source. Operational
techniques are being considered by the FAA as subjects of separate
regulatory efforts as appropriate, but they are not considered by FAA
as alternatives which substitute adequately for source noise reduction
regulations.
Current turbojets are capable of operating within safe, but relatively
narrow ranges of airspeed, deck angle and flap configurations
during the departure phase of flight. These ranges and the attendant
aircraft noise impacts are dependent upon factors such as aircraft
takeoff gross weight, outside air temperature, humidity, airport
elevation, wind direction and velocity, condition of engines, and
pilot technique. Today, turbojet aircraft on takeoff climb rapidly
to 1,500 feet. FAA Advisory Circular 91-39 recommends power cutback
procedures after this rapid climb. Use of a power cutback procedure
provides noise benefits, but the extent of the cutback with the
attendant increase in noise benefits is limited by insuring that
all safety problems posed by routine reduction in power at low
altitude are eliminated.
27
Flap management and interception of the final approach slope at higher
altitudes are two approach techniques which currently reduce aircraft
noise in the approach zones. A combination of these techniques keeps
the aircraft higher (from about 3 miles and beyond from the airport)
and permits the aircraft to approach at a lower thrust setting.
The basic physical principle being applied through this concept is
to increase the separation of the listener from the aircraft thereby
reducing the noise impact which when combined with reduced power
cause the noise levels on the ground to be diminished. The FAA
plans to take final action on these matters by January 1977.
Another technique which has been investigated places the aircraft
higher and reduces the power requirements by the initial utilization
of a higher descent angle for the aircraft to a point on its approach
path where it intersects the normal glide slope. This technique
often is commonly referred to as a two-segment approach. This
approach also provides potential benefits but at significant distances
(beyond 3 miles) from the airport.
There is considerable concern over the safety aspects of the two-segment
approach relating to aircraft performance and the effects of wind
shears, winds, and icing. Of particular concern is the increased
probability of encountering wake turbulence.
FORD LIBRARY & CERALD
28
In any event, the potential benefits of the two-segment approach
can only be realized at those 100 or so runways where the specialized
ground based instrument landing system electronics are installed.
By contrast, the quieting taking place as the result of modification
or replacement of aircraft produces benefits throughout all approaches
at all airports throughout the Nation.
Several commenters raised the issue of land use controls as a means of
relief from aircraft noise impact. Land use is not at issue in this
regulation, but like operational procedures, is a supplementary
means advocated by the FAA to reduce adverse impacts. Land use
controls such as zoning and utility limitations can prevent encroach-
ment on an airport by incompatible land use. Recent Federal legislation
dealing with funding for airports and airways includes provisions for
purchase of land as a means of noise reduction near airports.
29
3. Less Stringent Standards
This group of alternatives includes:
(a) increasing the permissible noise levels.
(b) allowing continuance of tradeoffs and/or permitting certain
classes of aircraft to meet ICAO Annex 16 rather than FAR
Part 36 standards.
(c) excluding foreign operators and/or U.S. flag carriers from
compliance with the planned rule.
(d) retrofitting JT3D aircraft only.
These alternatives are discussed below:
(a) Establishment of higher allowed noise levels at some or all
of the FAR Part 36 measuring points cannot be justified when it
has already been demonstrated that the FAR Part 36 standards
can be met with practicable technology consistent with safety
and economic feasibility.
(b) A similar form of relaxation of the stringency of the regulation
would be the continued inclusion of tradeoff provisions and/or
permitting certain aircraft to meet an alternative standard, ICAO
Annex 16. The inclusion of tradeoffs would permit the standards
to be exceeded at up to two of the measuring points to the extent
30
that the exceedance is offset at the remaining point(s) by
a lower than standard level. The existing FAR Part 36 and
Annex 16 presently contain tradeoff provisions. In accordance
with the intent of the Noise Control Act of 1972, the FAA policy
is to increase the stringency of this rule where it is techno-
logically practicable and economically reasonable. Since, in
general, the existing modification technology will permit aircraft
to meet the FAR Part 36 standards without tradeoffs, the tradeoff
provisions have not been included in the regulation. For the FAA
to act otherwise would be counter to the technological considerations
in the Noise Control Act.
(c) Several commenters raised the issue of the application of standards
to foreign operators, on the grounds that these carriers should be
governed by standards promulgated by the International Civil Aviation
Organization (ICAO). The FAA believes that action can and will
be taken through ICAO to establish international agreements on
operational noise standards. (Reference 25.) However, if
standards are not adopted by ICAO the FAA will proceed with
regulatory action to require foreign carriers to meet FAR
Part 36 noise levels.
The FAA believes that prompt and serious attention should and
will be given to this international issue because of the
important contribution to noise accountable to international
operations at some severely impacted airports throughout the
World. Examples of the international share of operations at
the five airports with over 60% of average daily international
operations in 1972 are as follows:
31
International Operations
Foreign Flag Operations
Portion of
Portion of
Airport
No.
Daily Total
No.
Daily Total
New York (JFK)
284
29.8%
154
16.1%
Miami
119
19.2%
41
6.6%
Chicago O'Hare
63
3.8%
41
2.5%
Los Angeles
52
5.0%
31
3.0%
Boston
41
6.7%
25
4.1%
Because of their longer range and the extra fuel loads required,
international flights tend to operate with higher gross weights
than domestic flights and utilize long range 4-engine aircraft more
frequently than the domestic flights. All these factors tend to
create relatively higher noise levels associated with international
operations as opposed to domestic operations. The following table
provides an indication of the extent to which foreign carriers'
operations would continue to contribute to the airport noise problem.
Additionally, there is presently under consideration a proposal
to expand international operations to additional airports
(19), exposing other communities to these aircraft and their
attendant noise. In any event the regulation will require the
domestic operations of all U.S. flag carriers to meet the FAR
Part 36 noise standards by 1985. Efforts will be expected
through ICAO to bring the foreign international carriers operating
into the U.S. as well as our own U.S. flag carriers which operate
internationally under these same noise standards.
32
IMPACT OF EXCLUDING FOREIGN FLAG CARRIERS FROM THE STANDARDS
(NEF Value at a point one mile from touchdown)
New York
Los
Chicago
(JFK)
Miami
Angeles
O'Hare
No regulation
55
50
55
56
Regulation (all aircraft)
43
40
44
45
Regulation (U.S. aircraft only)
50
44
46
46
Regulation Benefit (all aircraft)
(1 minus 2)
12
10
11
11
Regulation Benefit (U.S. only)
(1 minus 3)
5
6
9
10
Benefit Loss if Foreign Aircraft
Are Not Subject to Standards
(4 minus 5)
7
4
2
1
(d) Another in this group of alternatives less stringent than the
rule is a limited modification rule applying only to the
JT3D powered airplanes. The FAA studied this alternative by
modeling the national impact of regulating JT3D and JT8D powered
aircraft and compared this to the impact of regulating only
JT3D aircraft. A major factor is that the presence of JT8D powered
aircraft is far more widespread than that of JT3D aircraft. They
are much more numerous and operate more frequently at many more
airports throughout the U.S. The analysis pointed out the
predominance of JT8D aircraft noise:
Nationally, JT8D accounts for some 70% of
NEF 30 impacted areas.
At the largest 25 airports JT8D accounts for
between 70% and 90% of impacted area.
33
By requiring both the four-engine and two- and three-engine
aircraft to meet FAR Part 36 noise levels, there will be an
average reduction of 2 NEF units at the 25 largest air carrier
airports at the time compliance is completed, compared to a
reduction of only .5 NEF units if only the four-engine jets
were phased out or required to comply. Additionally, many
more 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 FAR Part 36, 75 percent of
the airports in the country would not receive any noise benefit.
Exemption of the JT8D powered aircraft from the regulation
would have the effect of nullifying much of the environmental
benefit and this exemption was therefore rejected as an alternative.
4. More Stringent Standards
Refan (or reengining) is the only technological approach that
would allow the FAA to establish noise levels below those of
the existing FAR Part 36 for the existing fleet. The refan
design and test program to date has been limited to JT8D
engines and to two aircraft (the B-727 and the DC-9). The SAM
approach is the only one currently available for application
to both the JT8B and JT3D engines.
34
The principles which contribute to noise reductions utilizing
refan are (1) a reduction in jet velocities which reduces the
jet exhaust component of the engine noise, and (2) a simultaneous
reduction in turbomachinery noise through the use of SAM treatment.
The NASA sponsored program with Pratt and Whitney Aircraft, McDonnell
Douglas and the Boeing Company has explored the feasibility of
modifying the JT8D engine to reduce the noise levels of the DC-9 and
B-727 aircraft. To investigate this program objective the design of
the two-stage fan on the JT8D engine was replaced by a single stage
fan of large diameter and higher bypass ratio. This modification was
designed to lower the noise by reducing the jet velocity and also to
increase the static thrust by about 13 percent, to increase the cruise
thrust by 5 percent, and to reduce the uninstalled Specific Fuel
Consumption (SFC) by about 3 percent. The refan SFC reduction would
probably be offset in part by a fuel penalty due to added weight.
(There is an increase in aircraft operating empty weight of approximately
2500 and 3300 pounds, for the DC-9 and B-727-200, respectively.)
This increase is reflected as a range decrease on the order of 85 and
95 nautical miles respectively.
The cost of refanning would be roughly eight to ten times the cost of
using the SAM retrofit in the case of the 3-engine B-727. The overall
program cost of refanning as opposed to SAM, accounting for all aircraft
types, would be an increase by a factor of 5 (4).
35
The noise reduction for the refan configurations should generally
be greater on takeoff than those of the SAM configurations whereas
on approach they are roughly comparable. For the B-727-200 aircraft
the refan noise reduction is projected to be about 5 EPNdB greater
than SAM on takeoff with power cutback. On approach the noise reduc-
tions are projected to be about equal. The refan DC-9 configuration (5)
is expected to be about 8 EPNdB quieter at takeoff with cutback than
the SAM configuration and 3 EPNdB quieter on approach. When these
reductions are incorporated as data into Noise Exposure Forecasts
(NEFs) to assess the impact on the community, the refan of the JT8D
combined with SAM of the JT3D engines would reduce the size of the NEF
40 area by about 90 percent and the NEF 30 by about 71 percent; whereas
SAM alone would reduce the NEF 40 area by approximately 63 percent and
the NEF 30 area by approximately 30 percent. Due to the extraordinary
high cost differential for refanning JT8D engines it is not economically
reasonable at this time to require separate lower noise levels for the
existing fleet equipped with these engines.
35a
The regulation does not affect business jets under 75,000 pounds.
The acoustic modification potential for business jets is very limited.
In exceptional cases, re-engining is possible, but in the general case
this modification requires such extensive redesign (6) that it is
not an economically justifiable alternative.
A final word on alternatives is in order. It can be argued that
alternative schedules for FAR Part 36 compliance should be specifically
addressed as alternatives to the proposed action. The NPRM on fleet
noise requirements established a four-year period for compliance.
In establishing a deadline, the FAA has been concerned with the length
of time needed to develop, certificate, produce, and install the
necessary number of modification kits. The manufacturers have indicated
that it will take six years to complete modification of the B-747s,
B-727, B-737, and DC-9s, six to seven years to complete the B-707s, and
possibly as long as nine years to complete the DC-8s, including kit
production and installation time.
Modification kits are currently certificated and ready for installation
for the two-and three-engine aircraft and the B-747s, and are being
installed on those aircraft that are currently in production. It may
take 28 months and 34 months, respectively, to design and certify kits
35b
for the B-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 routine refurbishment periods for fleet aircraft
must govern the mandatory compliance periods.
Further, providing for an eight-year period for compliance by the
B-707 and DC-8 aircraft will provide more time for airlines to
consider the replacement of these aircraft. There are noise and
fuel benefits of replacement over engine modification. The specific
benefits are not readily predictable, as they would turn on airline
decisions to replace aircraft, available aircraft for purchase and
possible legislation yet in the future which would assist the airlines
in this regard. Accordingly, we have not attempted to quantify these
imponderables at this time, except to point out that replacement would
have additional environmental benefits. These factors limit the
technological feasibility of alternative schedules and assessment
of the impact of alternatives for the purposes of this final
environmental impact statement.
*
From Production Decision
Production Rate in
Airplane
to First Kit Delivery
Ship-Sets Per Month
B-707
2-1/4 yrs
22
DC-8
3 yrs
8.5
B-727
1-1/2 yrs
38
B-737
1-1/2 yrs
10
DC-9
1-3/4 yrs
15
B-747
1 yr
5
36
IV. THE RELATIONSHIP OF THE PROPOSED ACTION TO LAND USE PLANS,
POLICIES AND CONTROLS FOR THE AFFECTED AREAS
The regulation will afford present and future relief to public health
and welfare from aircraft noise by reducing the noise exposure at and
around air carrier airports. These reduced noise levels will result
from extending the FAR Part 36 regulations to subsonic turbojet
aircraft of 75,000 pounds or more.
A noise standard of broad scope, such as this one, will assist local
jurisdictions in quantifying potential noise exposure by assuring
maximum bounds on source noise. Intermediate term (5-10 years) land
use planning will be facilitated by the maximum bounds on source
noise implied in the rule. Since land acquisition costs (and
pressures) to reduce aircraft noise impacts around airports may be
reduced as a result, the regulation may provide greater flexibility
for local development objectives.
V. ANY PROBABLE ADVERSE ENVIRONMENTAL EFFECT WHICH CANNOT BE AVOIDED
When certain aircraft are retrofitted with SAM they may suffer penalties
in fuel consumption and some associated increased in the emission of
air pollutants. On an overall basis these increases in consumption will
increase U.S. energy consumption by a negligible amount. Changes in
emissions have not been measured but since the acoustic modification
does not involve any change to the combustors, increased emissions
are not considered to be sufficient to cause these aircraft to
affect air quality significantly.
37
In terms of a solid waste disposal problem, there may be a slight
increase in the number of airplanes scrapped as a result of the
regulation. The increase in scrappage due solely to the regulation
is not ascertainable because of the number of airline management
options vis a vis modification and replacement. Nevertheless, this
scrappage is probably not significant as a national solid waste
disposal problem, particularly since there is a demand for recycleable
aluminum and other materials found in aircraft.
VI. SHORT-TERM VS LONG-TERM GAINS/LOSSES
The regulation does not involve any tradeoffs between short-term
environmental gains at the expense of long-term losses or vice
versa.
38
VII. ANY IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES THAT
WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED
The regulation will not curtail the range of beneficial uses of the
environment. It is proposed as a method for enhancing these uses.
No irreplaceable ecosystems or natural areas are endangered, nor
are any adverse land use patterns being established. There are known
risks to health and life anticipated. The possible slight degradation
in air quality that has been identified will not be significant in
terms of risk to health and welfare. This action will not preclude
or interfere with the establishment and implementation of air
quality standards for aircraft pursuant to the Clean Air Act. The
small increase in fuel consumption that has been discussed is an
irretrievable use of energy resources.
The material used in the modification kits will probably be irretrievably
committed but at least some may be recyclable. For example, the Boeing
Company estimates that 7185 pounds of raw materials are required to
produce four JT3D modification kits with a total manufactured estimated
weight of 3,450 pounds for a Boeing 707 type aircraft. None of the
materials are currently in such short supply that modification might
cause a significant market impact. Further details concerning
materials usage as a result of the regulation can be found in
Appendix C, Inflationary Impact Statement.
VIII. BENEFITS TO COUNTERBALANCE ADVERSE ENVIRONMENTAL EFFECTS
The adverse effects of the proposed action that have been discussed
are considered minimal in relation to the large measure of noise
relief that will be provided to the public.
39
IX. PUBLIC COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
Comments were received from 55 respondents distributed as follows:
Other Federal Agencies
8
Internal Federal Aviation Administration
7
State and Local Government Agencies
including Airport Authorities
25
Private Citizens
2
Citizen Organizations
6
Foreign Respondents
4
U.S. Industry
2
The public comments are included in Appendix G. Some of the major
issues raised by the respondents were discussed previously in
Section III, Alternatives. The remaining issues are discussed
below.
The Environmental Protection Agency rated the Draft L0-1 (lack of
objections, adequate information) and encouraged early promulgation
of the proposed rule.
The issues of the cost of modification and the impact on airline
finances were raised by several respondents. By direction of the
President, the Secretary of Transportation has scheduled a public
hearing on December 1, 1976, in Washington, D.C., entitled "Financing
of Aircraft Noise Reduction Requirements."
40
Non-capital costs, i.e., change in cash direct operating costs
(fuel, crew, insurance, maintenance), lost productivity (due to
increased weight of nacelles) and down time for installation were
calculated to average, at a maximum, 0.2 percent of annual operating
costs for the industry if a program of modification were accomplished
in four years. For some airlines that increase would have approached
a maximum of 0.3 percent of operating costs, while for most others
the increase in cost will be close to zero percent.
Discussions of the impact of retrofit and replacement on the economy
is contained in the Cost Benefit Analysis (Appendix D) and Inflationary
Impact Statement (Appendix c). In general, there will be no significant
impact on the prices of materials used for modification, or for
fuel. Jet fuel consumption would increase by a maximum of 1 million
barrels per year if all aircraft were modified (approximately 0.5
percent of 1974 consumption).
Several respondents raised the issue of the cost, benefit and effective-
ness criteria employed by FAA in making a decision. In analyzing the
various alternatives, two facts were evident: the more money spent,
(up to a point) the greater the levels of noise reductions attainable;
and, depending upon the alternative, a given level of effectiveness
could be achieved at different costs, or for a given cost, different
levels of effectiveness could be achieved. Two decision rules were:
1. When two alternatives yield the same effectiveness, the
lesser cost alternative is preferred;
41
2. When two alternatives cost the same, the alternative
generating the greater effectiveness is preferred.
Effectiveness was measured in terms of number of people and/or land
area removed from the NEF 30 or NEF 40 noise exposure contour area.
This criterion is based upon years of research by the Federal Government
showing that there is a relationship between subjective response of
individuals to airport noise and the cumulative noise exposure level.
The criteria levels of NEF 30 and NEF 40 have been used by the Federal
Government, particularly the Department of Housing and Urban Development,
Department of Defense, Department of Transportation and the Environmental
Protection Agency, for analyses, regulations and environmental decision
making.
Several respondents questioned the use of the FAR Part 36 certification
levels and/or the NEF analysis as the basis for decision making. These
descriptors were not the sole methods of analysis. Appendix E contains
examples of other types of analyses which are considered during the
decision-making process:
1. Delta dB contours showing plots of equal reductions in EPNdB
between the modified aircraft and unmodified aircraft;
2. 85dBA footprints showing the comparison between modified
and unmodified aircraft;
3.
Noise levels under the flight path for both modified and
unmodified aircraft.
42
Thus, a total of five different types of analyses were performed.
In general, they showed that the magnitude of the noise reductions
which could be achieved varied by aircraft type, operational mode
and location on the receiver on the ground. A significant, sizable
proportion of people currently exposed to airport noise will benefit
from the regulation. While few comments were received from the general
public in response to the DRAFT EIS, several thousand letters from
individuals and communities have expressed support for compliance
with FAR Part 36 in response to the Notice of Proposed Rule Making.
Several respondents indicated that there was no need to modify older
aircraft since most of the candidate aircraft would be removed from
the fleet through attrition and replacement by quieter aircraft
which do meet FAR Part 36. Forecasts of fleet mix show that almost
half of the candidate aircraft will still be flown by airlines in
the 1990 time period. The noise benefit to the public as shown in
Section II is considered to be ample justification for the regulation.
A similar argument was made for excluding foreign aircraft, i.e.,
that quieter wide-body jets would be used for international operations.
Fleet forecasts do not support this contention. The regulation
does not require modification; the method of achieving the regulatory
noise levels includes modification or replacement.
The question of safety was raised with respect to the operational
procedures discussed as alternatives to this regulation. Since this EIS
addresses a modification of Federal Aviation Regulations pertaining
to noise levels to be achieved through aircraft modifications, specific
43
issues with respect to operational procedures need not be
addressed. In general, however, there will be no requirement for
any operational procedures which are determined to be unsafe. Any
modifications to current operational procedures which are adopted,
either through regulation or voluntary action by the airlines, will
be safe and will enhance the benefits to be derived from this
regulation.
Similarly, other technical aspects of the regulation will be addressed
in the preamble to the rule. In general, the analyses of the environ-
mental impact have assumed that available technology, determined through
FAA and industry research and development programs, will be employed.
One respondent indicated that the benefit analysis should take into
account not only the change in number of people exposed to noise within
the NEF 30 and NEF 40 areas but also the relationship between NEF level
and annoyance. Each of the metrics currently in use has advantages,
disadvantages, apologists, and detractors. Historical use of NEF
by the FAA calls for its use in this analysis for purposes of
continuity. The objectivity of noise measures, as opposed to
annoyance measures, is needed to perform comparative analytical
studies. NEF serves well in this regard. See Appendix F for a
discussion of the impact of noise on people.
44
Compliance dates were discussed by several respondents. In general,
earlier compliance dates were desired by those who supported the
regulation while those who opposed indicated that the compliance
dates could not be met. Based upon our analysis of the data provided
by the manufacturers, complete compliance within the schedule
contained in the regulation is technologically feasible and economically
reasonable. Experience with problems of modification will be closely
monitored and, if warranted, adjustments to the completion schedule
can be made. It should be noted that the compliance schedule does allow
sufficient time to achieve the environmentally superior method of
compliance: replacement.
The question of changes in air pollution emissions caused by
modifications to engines was raised by one respondent. As indicated
in the DEIS, test measurements of air pollutant emissions from JT3D
and JT8D engined aircraft modified to meet FAR Part 36 standards
have not been obtained. However, since the modifications do not
involve changes to the engine combustion chambers, no fundamental
changes in the pollutant production processed are expected. Further,
no changes in thrust are anticipated during idle and taxi, and
pollution emissions are expected to be unchanged during ground
operations, the phase of activity that is most critical to the air-
port impact on air quality. During flight phases of operation,
changes in emissions of modified engines are expected to be proportional
to changes in fuel consumption.
Emissions from aircraft modified to comply with the regulation
45
are expected to have a negligible effect on air quality and will
not compromise the EPA aircraft emissions standards that are
applicable today.
The State of Hawaii asked why small and medium hubs were not utilized
in evaluating the alternatives. The data on noise benefits in
the EIS is based on an extrapolation from a study of 23 major airports
to all airports in the Nation. Accordingly, benefits at all airports
have been utilized in assessing the alternatives described in the EIS.
The International Air Transport Association (IATA) questioned the
benefits attainable from SAM modification of engines. This benefit
has been discussed in detail in Section II. The available evidence
strongly shows that the modification is an effective means of achieving
noise relief and worthwhile in terms of economic reasonableness.
The benefits of the SAM modification are noticeable in both the
cumulative unit, NEF, and in the individual event unit, EPNL, at
certification measuring stations. The individual event basis, which
shows a reduction of about 11 EPNdB on takeoff for the JT3D powered
B-707 when certification procedures are used, is meaningful since
reductions of this magnitude could be realized on a day-to-day basis.
The issue of decreased SAM effectiveness with increased distances is
not germane. All aircraft sounds are subject to increased high
frequency absorption with increased distance; however, the SAM is
effective at distances where it is needed.
46
IATA stated that the reductions assumed possible for the DC-8s
are overly optimistic, seemingly based on what has been claimed
possible for the B-707. Experience with the B-747 has shown the
effect on noise of eliminating blow-in doors. Elimination of blow-in
doors is also a feature of the B-707 modification kit. They pointed
out that the DC-8s do not have blow-in doors in their baseline
condition so this particular noise reduction element will not be
available. Further, the DC-8-62s and -63s already have a long duct
nacelle. For these and other reasons, they believe that noise
reductions possible for the DC-8s are unlikely to be nearly as large
as assumed in the draft EIS.
In response, the source noise increment between the B-707 and the
DC-8 aircraft due to the blow-in door feature is approximately 1.5
EPNdB. The noise reductions for the -61 series for the DC-8 aircraft
utilizing available SAM treatment consistent with the no trade-off
requirements should therefore be essentially similar to those of the
B-707. The DC-8s with the long duct nacelles should have an initial
acoustic advantage, and it is therefore expected that these aircraft
could meet the regulatory requirements with a correspondingly reduced
economic impact.
IATA suggested that the FAA's 23 airport study was based on unrealistic
assumptions concerning reapplication of climb thrust. The 23 airport
study did not assume the use of FAR Part 36 certification type thrust
cutback during takeoff. The subject of takeoff operational procedures
47
is supplementary to that of noise source control through the use
of SAM and by replacement with quieter aircraft, and has been
discussed previously in Section III, Alternatives.
The Air Transport Association expressed doubts as to the flight
acceptability of an inlet ring in some of the SAM designs for the
sole purpose of reducing noise. The doubts are raised with respect
to the effect of the ring on safety and reliability of service.
The use of inlet rings on the B-707 configuration has been extensively
investigated from safety and reliability perspectives. There is, in
the opinion of the reviewing FAA airworthiness personnel, no impediment
to the certification of the inlet ring configuration.
ATA alleged that deletion of trade-off provisions would result in
miniscule benefit to airport neighbors. The benefits on a single
event basis would be in the order of three decibels and would
definitely change the quality of the aircraft noise. There would
be a decrease in speech interference from aircraft noise for airport
neighbors, and on a cumulative basis the noise impact areas would
be reduced in the order of 30 to 40 percent. The deletion of the
trade-off requirements is necessary for FAA to comply with legislative
requirements that all technologically feasible noise benefits be
implemented consistent with economic reasonableness.
48
McDonnell Douglas Aircraft Company (DAC) suggested that the
draft EIS implies that if an airport neighbor's noise exposure
goes from NEF 40 to NEF 30, there will no longer be a noise impact.
This is not the intent of the Draft EIS, since it is not alleged
that this regulatory action will be a total solution to the noise
problem. The regulatory action, will, however, upgrade the noise
environment and in concert with other noise control actions should be
expected to provide very meaningful improvements.
DAC maintained that the use of SAM treatment would only provide
minimum relief for airport neighbors. The FAA does not share this
view and believes that a reduction of the fan and compressor noise
of aircraft engines would contribute to the improvement of airport
acoustic environments. These benefits are discussed in Section II.
The National Aeronautics and Space Administration stated that the use
of operational procedures in the impact analysis when such procedures
are not required by FAA for noise certification testing is misleading.
The operational procedure required by the FAA for the noise certification
testing is not intended to be identical to operational procedures
used in day-to-day airline operations which are variable from place
to place and time to time depending on the circumstances. The
procedures are, however, suitable and safe for such operations and
could be required at specific airports to achieve the noise certification
levels at the measurement stations. The primary object of test procedures
49
is to characterize the source noise emissions of the aircraft and
to permit comparisons between aircraft of similar types. The noise
analysis methods used by FAA take into account operational procedures
which are actually used or likely to be used in the future.
The State of Massachusetts asked why compliance by aircraft under
75,000 pounds was not required. The technology for retrofitting
aircraft under 75,000 pounds takeoff gross weight has not been
developed sufficiently to make a determination with respect to
economic reasonableness. In many cases, the modification of these
aircraft requires a reengining to comply with the FAR Part 36 levels.
This in turn implies essentially new aircraft design and development
program which would place an extensive economic burden on the owners
and operators of these aircraft.
Massachusetts also suggested that FAA include flap management and
deck angles in operations analysis. The ancillary nature of operations
controls as a means of achieving noise reudction has led the FAA to
consider these methods as subjects of separate rulemaking.
Citizens against noise suggested that FAA apply the rules to general
aviation and military aircraft. Applicability of the rules is by
weight class, rather than by type of operators. There is no need
for general aviation aircraft to be singled out for special require-
ments since the rules already affect all aircraft in the appropriate
weight class.
50
Modification of military aircraft must be addressed by the
military since the FAA cannot apply noise standards to these aircraft.
The military aircraft in many cases must optimize performance in the
interest of national security at the expense of excessive noise.
51
X. REFERENCES
1. Federal Aviation Administration, 14 CFR Part 91, NPRM Notice
No. 74-14, "Civil Aircraft Fleet Noise Requirements,' Federal
Register, March 27, 1974, and NPRM Notice No. 75-15, "Civil
Subsonic Turbojet Engine Powered Airplanes: Noise Retrofit
Requirements," Federal Register, February 26, 1975
2. L. Simpson, et. al., "Airline Industry Financial Analysis with
Respect to Aircraft Noise Retrofit Programs 1972-1978," R. Dixon
Speas Associates, Department of Transportation Report No.
OST-ONA-73-1, January 1973.
3. "23-Airport Cost Effectiveness Analysis of Noise Abatement
Alternatives," Department of Transportation, Statement for
Subcommittee on Aeronautics and Space Technology, Committee
on Science and Astronautics, House of Representatives,
July 25, 1974.
4. "Airport Noise Reduction Forecast" Volume 1, Summary Report
for 23 airports, Wyle Laboratories, prepared for Department
of Transportation, August 1974 draft.
5. DC-9 Flight Demonstration Program with Refanned JT8D Engines,
Douglas Aircraft Co., Rept. No. NASA CT-134857, July 1975.
6. John 0. Powers, Federal Aviation Administration, "The Conversion
of Aircraft: Acoustic and Performance Benefits," 12th
International Aeronautics Conference, Association Aeronautique
et Astronautique de France, Paris, 29-30 May 1975.
7-9 Not Used.
10. J.E. Mayer, et. al., "FAA JT3D Quiet Nacelle Retrofit Feasibility
Program, Volume III, Lower Goal Flight Testing, Economic Analysis,
and Summary," The Boeing Company, Wichita Division, Federal
Aviation Administration Report No. FAA-RD-73-131, III, February
1974.
11. "FAA JT3D Quiet Nacelle Retrofit Feasibility Program, Volume IV,
Compatibility analysis and Design study for DC-8 Aircraft," The
Boeing Company, Wichita Division, Federal Aviation Administration
Report NO. FAA-RD-73-131, IV, July 1973.
12. "Silencing First Generation Jets," British Aircraft Corporation,
Ltd., Commercial Aircraft Division, TSW 2309, Issue 2,
February 1973.
13. "Noise Source Abatement Technology and Cost Analysis Including
Retrofitting," Environmental Protection Agency, Aircraft/Airport
Noise Study Report, NTID 73-5, July 27, 1973.
52
14. Federal Aviation Administration, Advisory Circular 36-1A,
"Certification Airplane Noise Levels," Department of
Transportation, Federal Aviation Administration, July 21, 1975.
15. P. Borsky and S. Leonard, "Annoyance Judgments of Aircraft
With and Without Acoustically Treated Nacelles," NASA CR-2261,
August 1973.
16. J.S. Lucas, Peeler and Dobbs, "Arousal from Sleep by Noises
from Aircraft With and Without Acoustically Treated Nacelles,
NASA Report CR-2270, July 1973.
17. U.S. Environmental Protection Agency, 40 CFR Part 87,
"Control of Air Pollution from Aircraft and Aircraft Engines,"
July 6, 1973.
18. Public Law 2-574, "Noise Control Act of 1972," enacted by
Congress October 18, 1972; signed by the President,
October 27, 1972.
19. Transatlantic Route Proceeding, CAB Docket No. 25908.
20. U.S. Environmental Protection Agency, "Project Report, Noise
Standards for Civil Subsonic Turbojet Engine-Powered Airplanes."
December 16, 1974.
21 J.E. Mayer, et.al., "FAA JT3D Quiet Nacelle Retrofit Feasibility
Program, Volume I-1, Lower Goal Design Fabrication and Ground
Testing," The Boeing Company, Wichita Division, Federal Aviation
Administration, Report No. FAA-RD-73-131, I-1, June 1973.
22. R.B. Tate, et.al., "727 Noise Retrofit Feasibility, Volume I.
Lower Goal Design, Fabrication, Ground and Flight Testing,"
The Boeing Company, Commercial Airplane Group, Federal Aviation
Administration Report, No. FAA-RD-72-40, I, March 1972.
23. "Noise Reduction Programs for DC-8 and DC-9 Airplanes,"
McDonnell-Douglas Corporation, Report No. MDC J4447B, July 24, 1974.
24. "Compilation of Air Pollutant Emissions Factors," U.S.
Environmental Protection Agency, Office of Air and Waste
Management, February 1976.
25. International Air Transportation Policy of the U.S.,
September 8, 1976.
APPENDIX A: NOTICES OF PROPOSED RULE MAKING
desired credit for quieter aircraft; that
14 CFR Part 91 ]
problem. The United States will thus con-
it should be a linear relationship rather
tinue to work through ICAO to establish
[Docket No. 13582; Notice No. 74-14]
than logarithmic; that it did not in-
appropriate international noise stand-
CIVIL AIRCRAFT FLEET NOISE
clude weight factors for day-night opera-
ards.
REQUIREMENTS
tions; that it did not credit a factor for
On the other hand, the FAA does not
community annoyance; and that it did
believe that foreign registered aircraft
Notice of Proposed Rulemaking
not account for effective noise levels at
should be excluded from application of
The Federal Aviation Administration is
different airports. While it is true that
Fleet Noise Level regulations pending
considering amending the Federal Avia-
the proposed mathematical equation
the development of appropriate inter-
tion Regulations to establish additional
would not have satisfied many of the ob-:
national standards. The regulations that
civil aircraft noise requirements. The
jections raised by the commentators, the
would be issued following this Notice
proposed amendments would require that
primary objective of that equation was to
must, under the Noise Control Act of
subsonic turbojet engine-powered air-
assist the fleet operator in evaluating his
1972, be economically reasonable, tech-
planes with maximum weights of 75,000
fleet noise levels in relation to the noise
nologically practicable, and appropriate
pounds or more, and that are operated
limits proposed. The proposal would have
to the type of aircraft to which they ap-
under Parts 91, 121, 123, 129, and
accomplished that objective. However,
ply. To withhold applicability of reason-
135 of the Federal Aviation Regula-
upon review of all the comments re-
able standards to foreign aircraft would
tions, conform to Part 36-"Noise
ceived, including an analysis of alterna-
not be an appropriate response to the
Standards: Aircraft Type and Air-
tive equations submitted in response to
FAA's duty, under that Act, to protect
worthiness Certification."
Notice 73-3, the FAA has determined that
the public from aircraft noise. In addi-
Interested persons are invited to par-
the objective of the fleet noise rule can
tion, excluding foreign aircraft could be
ticipate in the subject rulemaking proc-
be attained without the use of any
unfair to U.S. operators of similar air-
ess by submitting such written data,
mathematical equation.
craft who would be forced to operate (in
views, or arguments as they may desire.
In addition, a large number of com-
the same markets as foreign aircraft)
Communications should identify the reg-
ments expressed strong opposition to the
with an economic burden of noise compli-
ulatory docket or notice number and be
proposed exclusion from the noise re-
ance that is not borne by the foreign op-
submitted in duplicate to: Federal Avia-
quirements in Notice 73-3 of airplanes
erators. On balance, the FAA believes
tion Administration, Office of the Chief
used in overseas, foreign and intrastate
that equal and nondiscriminatory appli-
Counsel, Attention: Rules Docket, AGC-
operations by Part 121 operators. The
cation of economically reasonable noise
24, 800 Independence Ave. SW., Washing-
commentators pointed out that such ex-
standards, to all operators, is an appro-
ton, D.C. 20591. All communications re-
clusion would deprive many of the major
priate noise regulatory policy. Detailed
ceived on or before June 28, 1974, will be
airports in the more noise sensitive areas
comments from foreign operators (as
considered by the Administrator before
of the benefits of the noise reduction pro-
well as U.S. operators) are invited with
taking action on the proposed rule. The
vided by that Notice. In view of the
respect to the technological and economic
proposal contained in this Notice may be
foregoing, and after further considera-
aspects of this proposal. Such comments
changed in the light of comments re-
tion, the FAA now considers it appro-
will be carefully reviewed prior to taking
ceived. All comments submitted will be
priate to cover subsonic turbojet air-
any action.
available both before and after the clos-
planes of U.S. registry weighing 75,000
Since the U.S. aircraft covered by this
ing date for comments, in the rule
pounds or more operated under Part 121,
proposal are limited to those that have
docket for examination by. interested
including in overseas and foreign
U.S. Standard Airworthiness Certificates,
persons. Comments are specifically re-
air commerce. Moreover, this proposal
the only foreign aircraft that would be
quested on the overall environmental
would cover all subsonic turbojet engine-
covered are those that, if registered in
aspects of this proposal.
powered airplanes of U.S. registry weigh-
the U.S., would be required by applicable
This Notice is published after consid-
ing 75,000 pounds or more operated under
Federal Aviation Regulations to have a
eration of the comments received in re-
Parts 91, 123, and 135. As such, it would
U.S. Standard Airworthiness Certificate
sponse to Advance Notice of Proposed
apply to corporate and other general
in order to conduct their intended op-
Rule Making, Notice 73-3, "Civil Air-
aviation operators as well as air carriers,
eration in the United States. Finally,
plane Fleet Noise Requirements" (Docket
certain air taxi and commercial opera-
since the purpose of this proposal is to
No. 12534), published in the FEDERAL
tors, and air travel clubs. However, so far
ensure that the takeoff, sideline, and ap-
REGISTER (38 FR 2769) on January 30,
as U.S. aircraft are concerned, it is pro-
proach noise levels of Part 36 are com-
1973 (hereinafter referred to as Notice
posed to limit the applicability under
plied with, it would serve no useful pur-
73-3).
this Notice to airplanes having standard
pose to apply those standards to foreign
Notice 73-3 proposed to control and
airworthiness certificates. The FAA has
aircraft that merely overfly the United
reduce airplane noise emissions by estab-
not determined that a retrofit to Part 36
States (and thus do not expose airport
lishing a limit on the fleet noise levels of
noise levels for experimentally and pro-
environments to their noise levels). This
each air carrier operating under Part 121
visionally certificated airplanes or air-
planes having a restricted category cer-
proposal, therefore, would only cover
of the Federal Aviation Regulations.
tificate would be technologically prac-
foreign aircraft that land or take off in
Three phases of noise limits were pro-
ticable. It should be noted that there
the United States.
posed to be effective in a progressive
are a number of U.S. registered civil air-
A number of commentators recom-
reduction manner. The first and second
mended that compliance times earlier
planes that are of the type covered by
phases of fleet noise levels were to be
than those proposed in Notice 73-3 be
this proposal but that are operated en-
determined in 1973 and 1976, respectively,
tirely outside the United States. This
established. The FAA does not agree.
The compliance dates proposed were
through the application of a logarithmic
proposal would not apply to those air-
based primarily on the time requirements
equation using the individual noise levels
planes.
associated with the implementation of
and operations of each airplane within
The FAA has given particular atten-
retrofit modifications to the forecast
the carrier's fleet. The third and final
tion to the matter of including foreign
fleet of pre-Part 36 aircraft. Considera-
phase in establishing fleet noise level
civil turbojet engine powered airplanes
tion was given to tooling for retrofit
limits would have required that by July 1,
weighing 75,000 pounds or more. On the
hardware production, the time required
1978, all airplanes in the carrier's fleet
one hand, it is preferable that environ-
in obtaining airworthiness certification
not exceed the Appendix C levels of Part
mental problems affecting international
for engine nacelle-airframe combina-
36 of the Federal Aviation Regulations.
civil aviation, like other aviation prob-
tions, material procurement lead time,
The comments received in response to
lems affecting more than one nation, be
and projected installation time. For these
Notice 73-3 were almost unanimously op-
resolved by the International Civil Avia-
reasons, earlier compliance dates are not
posed to the use, implementation, struc-
tion Organization (ICAO). The United
considered reasonable.
ture, mathematical relationship and
States strongly supports the effort being
Several commentators indicated con-
general concept of the logarithmic equa-
made in ICAO to achieve uniformity in
cerneregarding the availability of retrofit
tion for determining fleet noise levels.
the noise reduction area. Uniform inter-
hardware and doubt that the rule would
The comments suggested that the equa-
national noise standards are viewed as
be economically reasonable. FAA's in-
tion proposed mathematical manipula-
the best ultimate solution to the inter-
tion of noise; that it did not give the
GERALD
vestigation-shows that retrofit designs
national aspects of the aircraft noise
are either available or are being flight
Part 36 by not later than July 1, 1978
91.307 Noise requirements for all airplanes.
tested for many types of airplanes cov-
Most of the Part 01 operators, the air
ared by this proposal and that these types
taxi operators and the air travel clubs
Subpart E-Noise Requirements
constitute most of the fleet. FAA is aware
who have an airplane covered by this
§ 91.301 Applicability.
that this proposal includes the relatively
proposal in their fleet of airplanes gen-
This subpart prescribes noise require-
few pure turbojet engine-powered air-
erally have only one such airplane. Since
ments for the operation, in the United
planes currently in service. No acoustic
the domestic, flag, supplemental air car-
States, of-
modification exists for these aircraft and
riers and commercial operators operat-
(a) U.S. registered civil subsonic tur-
expensive reengining could be required to
ing under Part 121 and foreign air car-
bojet engine-powered airplanes with
achieve conformance with our standards.
riers operating under Part 129 have most
maximum weights of 75,000 pounds or
However, based on the rate at which these
of these airplanes, the impact of the op-
more and having standard airworthiness
airplanes are being retired from service
erations of these operators far exceeds
certificates; and
by U.S. operators, it appears that few,
that of the other classes of users in
(b) foreign civil subsonic turbojet en-
if any, would be in operation by
terms of community noise exposure na-
gine-powered airplanes with maximum
1978. As previously stated, the expected
tionwide. For this reason it might be
weights of 75,000 pounds or more that
retrofit configurations are definable, and
considered appropriate in the public in-
land or take off in the United States and
from these definitions, retrofit cost and
terest to propose that the Part 121 and
that, if registered in the United States,
impact on performance and weight can
Part 129 operators have a significant
would be required by applicable Federal
be estimated so one can assess whether
portion of their airplanes meet the Part
Aviation Regulations to have U.S. stand-
retrofit is economically reasonable. Eco-
36 requirements at an intermediate date.
ard airworthiness certificates in order to
nomic analysis of the cost impact of ret-
But as a consequence of engine/nacelle
conduct the operations intended for the
rofit on the collective operators indicates
intermix problems prior to complete
airplane.
that the proposed program of retrofit is
compliance of a total fleet and con-
economically reasonable, though individ-
siderations of alternate retrofit cost for
§ 91.303 Relation to Part 36.
ual operators may consider the costs to
different compliance options, such a
Unless otherwise specified, all refer-
be a financial burden. The FAA notes
scheme, is impractical. To assure prog-
ences in this subpart to the requirements
that the Civil Aeronautics Board gener-
ress, though, it is now proposed that all
of Part 36 of this chapter, include the
ally allows fare adjustments in the do-
domestic, flag, and supplemental air car-
noise levels of Appendix C of that Part,
mestic air carrier industry to reflect in-
riers and foreign air carriers, and com-
as effective on December 1, 1969, not-
creases in operating costs. However, the
mercial operators holding certificates
withstanding the provisions of that part
impact of retrofit will vary among in-
under Part 121, cannot operate their
excepting certain aircraft from those
dividual carriers, and fare adjustment
subsonic turbojet engine-powered air-
noise levels and notwithstanding the
approvals retain uniformity of fares
planes with maximum weights of 75,000
tradeoff provisions of that part.
among competing carriers. In addition,
pounds or more after July 1, 1976, unless
the rates for flag carriers are established
they can submit evidence that half of
91.305 Interim noise requirements for
by the International Air Transport As-
their inventory of engine/nacelles for
air carriers.
sociation, which has stated that it favors
these airplanes are of a type that has
After June 30, 1976, no domestic, flag,
retrofit by means of public funding
been demonstrated to permit these air-
or supplemental air carrier or commer-
rather than fare adjustments.
craft types to meet the requirements of
cial operator holding a certificate under
In the light of the comments received
Part 36 if the engine/nacelles were de-
Part 121, of this chapter, or foreign air
and after further review within the FAA,
ployed in a full'set.
carrier holding a certificate under Part
it is believed that a phased compliance
Under this proposal, the operators
129 of this chapter may operate, under
with Part 36 of the Federal Aviation Reg-
would have the alternative of modifying
that certificate, any airplane covered by
ulations, including Appendix C, is the
existing airplanes, replacing them with
appropriate means of implementing fleet
other airplanes meeting the Part 36 re-
this subpart and listed on the aircraft
noise requirements. While this proposal
quirements, or a combination of these
record required for domestic and flag air
retains many of the proposed require-
actions.
carriers or on the operations specifica-
ments of Notice 73-3, it is substantially
None of the persons covered by this
tions required for the supplemental air
different in many respects. The signifi-
proposal should have any difficulty in
carriers, commercial operators, and for-
cant comparisons are discussed in some
determining whether an airplane has
eign air carriers, that is not shown to
detail hereinafter.
been shown to meet the Part 36 require-
meet the requirements of Part 36 of this
As proposed in Notice 73-3, this notice
ments since Part 36 requires that an
chapter unless at least one-half of the
applies to turbojet engine-powered air-
entry to that affect be placed in the Air-
engine/nacelles for the airplanes covered
planes with maximum weights of 75,000
plane Flight Manual for the airplane.
by this subpart and listed for the certifi-
pounds or more. Contrary to numerous
As many commentators recommended
cate holder are of a design that has been
comments received in response to No-
with respect to Notice 73-3, this proposal
shown to permit those aircraft types to
tice 73-3, the FAA does not now con-
provides for individual aircraft meeting
meet the requirements of Part 36 if the
sider it appropriate to propose these noise
the prescribed noise levels. However, this
engine/nacelles were deployed in a full
requirements for airplanes weighing less
proposal does not, as suggested by some
set.
than 75,000 pounds. While it has been
commentators, reduce the ultimate noise
§ 91.307 Noise requirements for all air-
demonstrated that the manufacturers of
level for all airplanes to a minus (-)
planes.
some jets of less than 75,000 pounds
10dB from the current Part 36, Appendix
maximum weight can, on a new design
C. The FAA is addressing that matter in
After June 30, 1978, no person may
production basis, meet or better the noise
operate any airplane covered by this sub-
a separate rule-making action.
levels prescribed in Part 36, this in itself
part unless that airplane is shown to
does not justify a retrofit requirement for
(Secs. 313(L), 601, 603, 604, and 611, Federal
meet the requirements of Part 36 of this
Aviation Act of 1958 (49 U.S.C. 1354(a), 1421,
operators of jets in this weight category.
chapter.
1423, 1424, and 1431 as amended by the Noise
The feasibility of potential application of
Control Act of 1972 (P.L. 92-574)) sec.
Issued in Washington, D.C., on March
these advances in small jet engine tech-
6(c), Department of Transportation Act (49
22, 1974.
nology and the related costs in in-service
U.S.C. 1655(c)) Title I, National Environ-
R. P. SKULLY,
retrofit are currently being evaluated.
mental Policy Act of 1969 (42 U.S.C. 4321
Director, Office of
Therefore, jet airplanes with maximum
et seq.); Executive Order 11514, March 5,
weights of less than 75,000 pounds are not
1970).
Environmental Quality.
being included at this time.
[FR Doc. 74-7083 Filed 3-26-74; 8:45 am]
In consideration of the foregoing, it is
All of the airplanes covered by the
proposed to amend Part 91 of the Federal
proposal, including those airplanes op-
Aviation Regulations by adding a new
erated by air taxi operations, air travel
Subpart E to read as follows:
As published in the
clubs and those airplanes operated un-
Subpart E-Noise Requirements
Federal Register (39 F.R.
der Part 91, as well as the flag, domestic
Sec.
and supplemental air carriers and com-
91.301 Applicability.
11302) on March 27, 1974
mercial operators operating under Part
91.303 Relation to Part 36.
121, would have to be in compliance with
91.305 Interim noise requirements for air
carriers.
[ 14 CFR Part 91 ]
later than 60 days after publication of
[Docket No. 14317; Notice No. 75-5]
this document in the FEDERAL REGISTER.
tification," became effective December 1,
CIVIL SUBSONIC TURBOJET ENGINE-
The following EPA opinions, conclu-
1969 (34 FR 18355), prescribing noise
POWERED AIRPLANES: NOISF RETRO-
sions, and proposed regulatory language
measurement, noise evaluation, and noise
FIT REQUIREMENTS
are published verbatim as received by
levels for the type certification, and
Proposed Regulations Submitted to the
the FAA on January 28, 1975.
changes to those certificates, for sub-
FAA by the Environmental Protection
EPA Proposal to FAA. Under the re-
sonic transport category airplanes, and
Agency
quirements of section 7(a) of the Noise
for subsonic turbojet engine-powered air-
Control Act of 1972 (Pub. L. 92-574, 86
planes regardless of category.
This notice of proposed rule making
Stat. 1234), the Administrator of the En-
(2) Part 36, "Noise Standards: Air-
contains proposed regulations submitted
vironmental Protection Agency con-
craft Type Certification" was subse-
by the Environmental Protection Agency
ducted a study of aircraft and airport
quently amended on October 26, 1973 (38
(EPA) to the Federal Aviation Adminis-
noise and submitted a report thereon to
FR 29574), to require new production
tration (FAA), pursuant to section 611
the Congress. (Report on Aircraft/Air-
subsonic transport category and subsonic
(c) (1) of the Federal Aviation Act of
port Noise, Senate Committee on Public
turbojet engine powered airplanes re-
1958, as amended by the Noise Control
Works, Serial No. 93-8, Aug. 1973).
gardless of category to comply with the
Act of 1972 (Pub. L. 92-574). Section 611
Under section 611 of the Federal Aviation
noise requirements of Part 36 irrespective
(c) (1) of the Federal Aviation Act of
Act, as amended by the Noise Control
of the date of the type certification.
1958 provides that EPA shall submit to
Act of 1972, the Administrator of the
(3) Advance notice of proposed rule-
the FAA proposed regulations to provide
EPA is also required, not earlier than the
making 70-44, "Civil Airplane Noise Re-
such control and abatement of aircraft
date of submission of his report to the
duction Retrofit Requirements," pub-
noise and sonic boom as EPA determines
Congress, to submit to the Federal Avia-
lished on November 4, 1970 (35 FR
is necessary to protect the public health
tion Administration proposed regulations
16980), proposed the retrofit of existing
and welfare. That section also provides
to provide such control and abatement of
subsonic turbojet engine powered air-
that the FAA "shall consider such pro-
aircraft noise and sonic boom (including
planes. This proposal has not been
posed regulations submitted by EPA
control and abatement of aircraft noise
adopted as a final rule.
under this paragraph and shall, within
through the exercise of any of the FAA's
(4) Advance notice of proposed rule-
thirty days of its submission to the FAA,
regulatory authority over air commerce
making 73-3, "Civil Airplane Fleet Noise
publish the proposed regulations in a
or transportation or over aircraft or air-
(FNL) Requirements," published on Jan-
port operations) as the Administrator of
uary 30, 1973 (38 FR 2769), proposed
notice of proposed rulemaking." This
notice is published pursuant to this pro-
the EPA determines is necessary to pro-
the establishment of an interim upper
vision of law.
tect the public health and welfare. In ac-
limit on the cumulative noise levels of
The EPA proposals contained herein
cordance with the foregoing requirement,
each fleet operator. Under the FNL con-
would amend Part 91 of the Federal
the EPA published in the FEDERAL REG-
cept there would then be a phased pro-
Aviation Regulations to require civil sub-
ISTER on February 19, 1974 (39 FR 6112)
gressive reduction of those noise levels
a notice of public comment period con-
in accordance with a logarithmic equa-
sonic turbojet engine-powered airplanes
taining a synopsis of the proposed rules
tion until July 1978, when every airplane
to comply with the noise standards of
it is considering to achieve a satisfactory
would be required to meet the noise
Part 36 of the Federal Aviation Regula-
level of aircraft noise control and abate-
standards of Appendix C of Part 36. Al-
tions.
Interested persons are invited to par-
ment for the protection of the public
though the FAA was of the opinion that
health and welfare.
the FNL concept is considered to be the
ticipate in the making of the proposed
rules by submitting such written data,
The proposed rules and the type of
most appropriate course to follow within
control which each rule would implement
current technological capabilities, it ex-
views, or arguments as they may desire.
Communications should identify the
are as follows:
pressly stated in the notice that the FNL
concept did not imply a rejection of the
docket number and be submitted in du-
Flight procedures noise control
retrofit program.
plicate to the Federal Aviation Admin-
(1) Takeoff procedures.
(5) After considering the comments in
istration, Office of the Chief Counsel,
(2) Approach procedures.
response to the foregoing ANPRM 73-3,
Attention: Rules Docket, AGC-24. Com-
(3) Minimum altitudes.
NPRM 74-14-"Civil Aircraft Fleet Noise
ments on the overall environmental as+
Source noise control
Requirements" was published on March
pects of the proposed rules are specifi-
27, 1974 (39 FR 11302). Under the pro-
cally invited. All communications re-
(4) Retrofit/fleet noise level.
ceived by the FAA on or before April 4,
(5) Supersonic civil aircraft noise.
posal civil subsonic turbojet engine-pow-
1975, will be considered by the FAA
(6) Modifications to Part 36 of the Federal
ered airplanes with maximum weights of
Administrator before taking action upon
Aviation Regulations.
75,000 pounds or more would be required
(7) Propeller driven small airplanes.
to conform to Part 36-"Noise Stand-
the proposed rules. The proposals con-
(8) Short haul aircraft.
ards: Aircraft Type and Airworthiness
tained in this notice may be changed
Airport operations noise control
Certification". As distinguished from the
in the light of comments received. All
former ANPRM 73-3, Notice 74-14 would
comments will be available, both be-
(9) Airport goals, mechanisms and proc-
not utilize a logarithmic equation for the
fore and after the closing date for com-
esses by which noise exposure of communities
around airports can be limited to levels con-
determination of fleet noise levels and
ments, in the FAA Rules Docket for
examination by interested persons. EPA
sistent with public health and welfare re-
would apply to all civil subsonic turbojet
quirements.
engine-powered airplanes having stand-
has also indicated that information
ard airworthiness certificates, weighing
copies of public comments may be sent
This proposed rule, identified as the
75,000 pounds or more, and operated un-
to: Director, Standards and Regulations
retrofit portion of item (4) above, is one
der Parts 91, 121, 123, 129 and 135. Al-
Division, Office of Noise Abatement and
of the five whose purpose is to implement
Control (AW-571) U.S. Environmental
engineering noise control at the source.
though the FAA preferred that environ-
Protection Agency, 1921 Jefferson Davis
As proposed herein the EPA believes that
mental problems affecting international
Highway, Arlington, Virginia 20460.
the rule, if adopted, would control and
civil aviation be resolved by ICAO, it did
Pursuant to section 611(c) of the
reduce the noise of civil subsonic turbojet
not believe that foreign registered air-
Federal Aviation Act of 1958, the FAA
engine-powered airplanes to levels as low
craft should be excluded from a fleet
will hold one or more hearings with re-
as is consistent with available safe tech-
noise level rule pending the development
spect to the proposals contained in this
nological capability without imposing
notice. A separate notice of hearing will
unreasonable economic burdens on the
of appropriate international standards.
be published in the FEDERAL REGISTER in
users of those airplanes.
Accordingly, as proposed, the rule was
the near future. As required by section
A. Regulatory background. (1) Part
made applicable to foreign aircraft while
611(c), these hearings will be held no
36, "Noise Standards: Aircraft Type Cer-
operating in the U.S., except in the case
of overflights.
B. References. In the development of
that it is based upon the results of cur-
herein, they would also apply to foreign
this proposed rule, the EPA conducted its
rent, available. and future technology.
registered airplanes, operated within the
own studies and evaluated several per-
Current technology includes "shelf
U.S., except those engaged in overflights.
tinent studies made by other Federal
item" hardware and commonly known
However, since the retront requirements
agencies and private contractors. Those
techniques and procedures that have
contained in this proposal reflect current
studies are listed herein for the informa-
been used effectively by some manufac-
and available SAM technology only. the
tion of all interested persons and are
turers. Available technology represents
EPA believes that the concept of a fleet
available for examination at the FAA
the results of research and development
noise level (FNL) similar to that pro-
Rules Docket Office, GC-24, 800 Inde-
that have not been put into common
posed in NPRM 73-3 should also be con-
pendence Avenue, SW., Washington, D.C.
practice but are available for imple-
sidered to apply the benefits of future
20590, or the EPA Office of Noise Control
mentation. Some performance testing
technology, such as a Refan, Core En-
Programs, Crystal Mall No. 2, 1921 Jef-
may still be necessary, but reliability and
gine, or Quiet Engine retrofit. The EPA
ferson Davis Highway, Arlington, Va.
effectiveness have been demonstrated in
accordingly is proposing a FNL rule to
20460. Copies of these studies prepared
the laboratory and on model and full
the FAA which would provide informa-
by Government Agencies are also for sale
scale tests. Future technology represents
tion that would be of assistance once fu-
by the Superintendent of Documents,
the results of research now in progress
ture technology is determined to be cur-
U.S. Government Printing Office, Wash-
that have not been fully tested but the
rent and available. in determining how
ington, D.C. 20402.
results to date indicate high potential to
and when such future technology should
(1) "Report on Aircraft Airport Noise".
a reasonable degree of confidence.
be applied to existing fleets.
Report of the Administrator of the Environ-
There is no doubt that the most effec-
The NASA Refan program directed to
mental Protection Agency in Compliance
tive use of technology to achieve maxi-
the JT8D powered airplanes indicates
with Pub. L. 92-574, Senate Committee on
mum noise control is the design and de-
Public Works. Serial No. 93-8, August 1973.
that a Refan retrofit for those airplanes
velopment of new aircraft types. Appli-
(2) "Operations Analysis Including Moni-
cations of basic design principles and
may be practicable and perhaps superior
toring, Enforcement. Safety. and Cost", Rc-
acoustical treatment for the control of
to Quiet Nacelles in terms of lower noise
port of Task Group 2. EPA NTID 73.3, July 27,
noise can be exploited optimally when
levels as well as performance benefits.
1973.
(3) "Impact Characterization of Noise
they can be integrated into the overall
If so, a careful consideration should be
aircraft/engine design. Admittedly. mod-
given to a further retrofit or double retro-
Including Implications of Identifying and
ifications such as retrofit hardware are
fit program for those JT8D engine pro-
Achieving Levels of Cumulative Noise Ex-
the least efficient use of that technology.
pelled airplanes previously retrofitted
posure". Report of Task Group 3, EPA NTID
73.4, July 27. 1973.
The EPA believes that regulations for
with Quiet Nacelles. The NASA Refan
(4) "Noise Source Abatement Technology
the control of aircraft noise should be
program. however. will not be completed
and Cost Analysis Including Retrofitting",
constructed to be equally responsive to
before June of 1975. and even then addi-
Report of Task Group 4, EPA NTID 73.5,
July 27. 1973."
all technology. i.e., current, available and
tional performance and airworthiness
(5) "Review and Analysis of Present and
future. and to the extent practicable. be
testing will be required before the results
made applicable to all aircraft, i.e., exist-
of that program can be categorized as
Planned FAA Noise Regulatory Actions and
ing. new production of an older type de-
available technology.
Their Consequences Regarding Aircraft and
Airport Operation", Report of Task Group 5,
sign. and new production aircraft of a
The Air Transport Association (ATA)
EPA NTID 73.6. July 27, 1973.
new type design.
has stated in its comments to NPRM 74-
(6) "Public Health and Welfare Criteria
At the present time, there is a choice
14 that if any technology is to be applied
for Noise". EPA Technical Document 550/9-
between two possible technical retrofits
to an existing machine as complex as a
73-002, July 27, 1973.
for noise reduction. One is known as
transport airplane, it should be fully de-
(7) "Standard Noise/Performance Data for
"Quiet Nacelles" with "SAM", a sound
veloped. its effects should be known. the
Retrofit Studies" Letter from R. E. Russel
(Boeing) to R. P. Skully, FAA, dated Decem-
absorbing material technology and the
cost should be determinable. and the en-
ber 21. 1973.
other is known as "Refan", a replace-
vironmental improvement should be suf-
(8) "727 Noise Retrofit Feasibility. Volume
ment of selected fan and turbine compo-
ficient to justify the expenditure. The
III: Upper Goal Flight Testing and Sum-
nents within the engine, as well as na-
EPA shares this concern. Therefore,
mary", Final Report FAA-RD-72-40, III,
celles with SAM. The Quite Nacelle tech-
pending the results of the NASA Refan
January 1973.
(9) "Refan Design Presentation". NASA
nology is current for JT8D engines and
program the EPA has advised the FAA
Contract NA53-16814. Douglas Aircraft Co.,
available for JT3D engines. while the
that it will withhold the submission of
January 16. 1974.
Refan technology may be available in
any proposal to implement the Refan
(10) "Aircraft Noise Reduction Technol-
the near future.
retrofit of turbojet engine-powered air-
ogy", Report by the National Aeronautics
The noise proposals set forth in NPRM
planes. Should the results of that pro-
and Space Administration to the Environ-
74-14 only apply to available and current
gram indicate that Refan retrofit is prac-
mental Protection Agency for the Aircraft/
technology, i.e., Quiet Nacelles with SAM.
ticable, economically reasonable. and
Airport Noise Study, March 30, 1973.
Applications of future technology. i.e.,
will provide meaningful relief, the EPA
(11) "Allocating the Costs of Alleviating
Refan technology, would not be required
will then submit a recommendation pro-
Subsonic Jet Aircraft Noise", Special Report.
Institute of Transportation and Traffic En-
unless subsequent amendments are
posing to adjust Fleet Noise Level
gineering. University of California, Berkeley,
adopted. Therefore, the EPA has advised
(FNL) requirements consistent with the
February 1967.
the FAA that although it supports the
noise level reductions available from Re-
(12) "Airline Industry Financial Analysis
proposals set forth in NPRM 74-14, some
fan or other programs.
with Respect to Aircraft Noise Retront Pro-
modifications would be necessary to
As previously stated, the EPA strong-
grams". OST-ONA 73-1, January 1973.
bring significant relief to the public
ly supports the noise reduction require-
(13) "Impact of the New Large Jets on the
U.S. Air Transport System, 1970-1975", CAB,
exposed to the airplanes covered by the
ments proposed by the FAA in NPRM
October 1973.
proposed rule.
74-14. Therefore, to the extent that those
(14) "Noise Standards for Civil Subsonic
This new notice of proposed rule mak-
standards are included herein it appears
Turbojet Engine-Powered Airplanes (Retrofit
ing is based upon the requirements pro-
unnecessary to repeat the detailed justi-
and Fleet Noise Level)", EPA Project Report,
posed in NPRM 74-14 as modified by the
fication set forth in that NPRM in sup-
December 16, 1974.
recommendations submitted by the EPA
port of those requirements. However, the
C. Introduction. As applied to aircraft,
pursuant to the mandates of section 611
principal differences between that NPRM
source noise control is the application of
of the Federal Aviation Act. Initially, it
and this proposed rule in regard to its
basic design principles or special hard-
should be noted that these modified pro-
applicability and the required installa-
ware to the engine/airframe combina-
posals apply to all civil subsonic turbo-
tion of engine/nacelles listed by an oper-
tion to minimize the generation and
jet engine-powered airplanes, regardless
ator are discussed herein under separate
radiation of noise. The technology of
headings.
of weight, certificated in the standard
source noise control is time-dependent in
D. Applicability. As proposed in NPRM
airworthiness category. As proposed
74-14 the noise reduction requirements
as those proposed in NPRM 74-14. Com-
with the McDonnell Douglas Corporation
would apply to airplanes having a maxi-
ments received in response to that NPRM
and the Boeing Company to investigate
mum weight of 75,000 pounds or more.
contained estimates for the lead time to
nacelle noise control modifications for
The EPA believes that all turbojet en-
deliver retrofit kits for the various U.S.
operational Douglas and Boeing trans-
gine-powered airplanes having a maxi-
manufactured airplanes which ranged
ports powered by JT3D turbofan engines.
mum weight of less than 75,000 pounds
from 9 to 12 months for the B-747 air-
The NASA program successfully demon-
that do not meet the noise levels pre-
plane, and 10 months for the B-727 air-
strated by flight tests in 1969. conceptual
scribed in Part 36, are capable of meet-
plane. For the DC-8, however, one com-
feasibility of nacelle modifications for
ing those levels by applications of vari-
mentator estimated 30 months.
controlling both approach and takeoff
ous retrofit or reengine options. Since
In response to previous comments re-
noise of JT3D propelled aircraft.
all newly produced airplanes of that type
garding the availability of retrofit hard-
In June 1971, the FAA initiated a
must comply after January 1, 1975 with
ware, an investigation was conducted by
nacelle noise control project directed to
the noise levels prescribed in Part 36
the FAA and it was determined that re-
retrofit of the current fleet of narrow
(§§ 21.183(e) and 36.1(d) of the Federal
trofit designs are either available, or
body aircraft. This project extended the
Aviation Regulations, there appears to
are being flight tested for the many types
NASA program to include research and
be no valid justification to permit those
of airplanes covered by this and previous
development of takeoff and approach
airplanes in the existing fleets to be op-
retrofit proposals. Research and devel-
noise control for both JT3D and JT8D
erated indefinitely at their present noise
opment done to date has demonstrated
propelled aircraft. The purpose of this
levels. Therefore, as proposed herein,
that the basic concepts of noise suppres-
project was to provide test data to as-
§ 91.301 would apply the noise require-
sion of turbofan engines are valid acous-
sist in determining whether certain
ments of the proposed subpart E to all
tically, and materials and fabrication
classes of turbofan propelled airplanes
civil subsonic turbojet engine-powered
technologies can be developed to trans-
in the current fleet could be modified for
airplanes regardless of weight.
late these concepts into hardware that
meaningful noise reduction in a feasible
For the reasons stated in NPRM
could provide an economically reasonable
manner. The research and development
74-14, this proposal would also apply to
and a technologically practicable means
work was directed to providing acoustical
all foreign civil airplanes when operat-
of significantly reducing the noise gen-
treatment for engines/nacelles which
ing in the U.S. except when engaged in
erated by most currently certificated tur-
would permit compliance with specified
overflights. Since such overflights would
bofan engine-powered airplanes. The
noise reduction goals and which would
not involve a takeoff or landing at an
FAA believes that if all persons (manu-
be flight weight, flight worthy, and capa-
airport in the U.S., there is no need to
facturers and operators) make a deter-
ble of being certificated.
include them in this proposal. The rule
mined effort to comply with the retrofit
The FAA project was implemented by
as proposed herein would also except
of the airplanes covered by this proposal
means of three separate contracts with
airplanes not having standard airworth-
it can be accomplished within the com-
appropriate airframe manufacturers. A
iness certificates such as those airplanes
pliance dates specified. The FAA is aware
task force consisting of representatives
having an experimental, provisional, or
that this proposal includes the relative-
from the research and development,
restricted airworthiness certificate. As
ly few pure turbojet engine-powered
regulatory. and airworthiness services of
stated in NPRM 74-14, the FAA has not
airplanes currently in service. Since no
the FAA was also established to monitor
determined that a retrofit to Part 36
acoustic modification exists for these
the progress of those contractors and to
noise levels for those airplanes would be
engines, reengineing may be required to
insure that a judgment of the feasibility
technologically practicable at this time.
achieve conformance with the noise
of noise abatement retrofit modifications
E. Installation of engine/nacelles. As
levels proposed herein by July, 1978.
was based upon production hardware
distinguished from NPRM 74-14, § 91.305
However, based upon the rate which
that would not compromise safety.
(c) of this proposal would require the
these airplanes are being retired from
The results of the foregoing FAA
scheduled installation of each engine/na-
service by U.S. operators it appears that
nacelle retrofit project produced flight
celle on operational airplanes of the
few, if any, would remain in service in
performance and cost data for 707, DC-8,
operator, if he lists such engine/na-
the U.S. by that date.
727, 737, and DC-9 type airplanes
celles as part of his "on-the-shelf" inven-
Retrofit technology is available for all
equipped with acoustical treatment
tory. The EPA believes that a proper
other transports and most of the busi-
which would permit compliance with the
noise reduction for each airplane is not
ness jets. The remainder of the business
FAR 36 noise levels. The acoustical treat-
achieved until all of the engine/na-
jets as subsequently discussed under the
ment investigated included sound ab-
celles for that airplane are retrofitted.
retrofit technology (G), could be in com-
sorption material (SAM) and a combina-
Therefore, proposed § 91.305(a) (2)
pliance with Part 36 noise levels by
tion of SAM and a jet noise reducer
would also require the operator, after
July 1, 1978, by implementation of one of
(JNR). It was found that the least com-
June 30, 1976, to have at least one-half
the reengine options.
plex system consisting of SAM would
of the modified engine/nacelles for those
As proposed in this notice, all airplanes
enable the airplanes to achieve the FAR
airplanes listed by the operator in its air-
covered by the proposal, (including those
36 noise levels or lower in some cases.
craft record or operations specifications.
airplanes operated by air taxi operators,
It was also found that the more complex
But under the proposed § 91.305(c) the
air travel clubs, and by persons in the
systems consisting of SAM+JNR have
remaining engine/nacelles stored in its
furtherance of a business under Part 91)
the capability of decreasing the noise to
warehouse. for example, could not be in-
would be required to be in compliance
levels appreciably lower than those re-
cluded as part of the required number,
with the Part 36 noise standards not
quired by FAR 36.
unless a schedule is established and
later than July 1, 1978. However, since
Quiet Nacelles containing SAM have
maintained for the installation of those
the air carriers (U.S. and foreign) op-
a negligible effect on aircraft perform-
engine/nacelles on operational airplanes
erate most of the flights of the airplanes
ance and provide a practicable means
at the next periodic inspection that will
covered by this proposal, those opera-
for the older narrow bodied transport
permit their installation.
tions far exceed operations by other per-
type airplanes to comply with FAR 36.
As drafted, the provisions of the pro-
sons in terms of community noise ex-
There appears to be no appreciable deg-
posed § 91.305(c) permit the Administra-
posure nationwide. For that reason, the
radation in field length requirements
tor to authorize the installation at a time
intermediate compliance date for one
and direct operating costs but possibly
other than that specified in the opera-
phase of the retrofit was retained in this
a small loss in range for the airplanes so
tor's schedule upon demonstration to the
proposal for airplanes having a maxi-
modified. However, there would be a
Administrator that compliance with the
mum weight of 75,000 pounds or more
meaningful reduction in airport com-
schedule would adversely affect the safety
and operated by the holder of a certifi-
munity noise exposure; mainly for ap-
of the airplane involved due to such in-
cate under Parts 121 or 129 of the Fed-
proach operations for JT8D propelled
termix problems as unbalanced weight,
eral Aviation Regulations.
aircraft and for both takeoff and ap-
thrust, drag, etc.
G. Current and available retrofit tech-
proach operations for JT3D propelled
F. Compliance dates. As proposed here-
nology. In May 1967, NASA contracted
aircraft.
in the compliance dates are the same
Bec.
It was found that quiet nacelles con-
haust nozzle may be all that is necessary
91.307 Noise requirements: all subsonic tur-
taining SAM+JNR, in addition to cost-
to meet the current standard. Such a pro-
bojet engine-powered airplanes.
ing more per shipset, would introduce
gram is being conducted with the poten-
substantial degradation in performance.
tial to certify the Learjet to the FAR 36
Subpart E-Noise Requirements
The performance losses, however, are
noise requirement with a redesigned ex-
§ 91.301 Applicability.
not necessarily irreversible. Uprating the
haust nozzle.
airframe for loading and the engine for
H. Cost/Effectiveness of Retroft. As
This subpart prescribes noise require-
thrust (e.g., JT8D-9 to JT8D-15) will
stated in the preamble to NPRM 74-14
ments for the operation within the
United States of any civil subsonic turbo-
increase the range and reduce the re-
an economic analysis of the cost impact
of a retrofit on the collective operators
jet engine-powered airplane having
quired field length to values approach-
ing those of the baseline production
indicates that it is economically reason-
(a) A U.S. registration certificate and
version. Quiet Nacelles with SAM are
able, although individual operators may
a standard category airworthiness cer-
tificate: or
current and available technology for the
consider the costs to be financially bur-
Boeing family of JT3D and JT8D pro-
densome. With respect to those airplanes
(b) A foreign registration certificate
and lands or takes off in the United
pelled airplanes. For the B-727 and B-
covered by this proposal that are op-
States in the conduct of an operation for
737 airplanes, the treatment is minimal;
erated by U.S. and foreign air carriers
the FAA has noted that the Civil Aero-
which a U.S. registered airplane is re-
the noise reduction benefits are negli-
quired to have a standard category air-
gible for sideline and takeoff but signifi-
nautics Board generally allows fare ad-
worthiness certificate.
cant on approach, and the costs and per-
justments in the domestic air carrier in-
formance losses are so modest that it is
dustry to reflect increases in operating
§ 91.303 Relation to Part 36.
unreasonable not to include such treat-
costs. This adjustment would un-
Unless otherwise specified, all refer-
ment on all new aircraft. For B-707 air-
doubtedly include the impact of retrofit
ences in this subpart to the requirements
planes, the treatment is more extensive:
as it affects the individual carriers. Fare
of Part 36 of this chapter, include the
the noise reduction benefits are substan-
adjustments to reflect increases in the
noise levels of Appendix C of that Part,
tial at all three measuring positions but
operating costs for U.S. or foreign flag
as effective on December 1, 1969, not-
especially dominant at approach; the
carriers should be made in a similar man-
withstanding the provisions of that part
performance losses are small; and
ner by the International Air Transport
excepting certain aircraft from those
the costs are significant but not neces-
Association (IATA). Other means of fl-
noise levels and notwithstanding the
sarily unreasonable from a cost-effec-
nancing may be considered.
tradeoff provisions of that part.
tiveness viewpoint.
For both JT8D and JT3D airplanes,
Quiet Nacelles with SAM are also cur-
the investment cost would be approxi-
§ 91.305 Interim noise requirements:
rent and available for the Douglas family
mately 648 million dollars. Based upon
subsonic turhojet engine-powered
of JT3D and JT8D propelled airplanes.
the projected 1980 fleet of its members,
airplanes having a maximum weight
The QN technology is current and avail-
the ATA estimates the cost of a SAM
of 75,000 pounds or more.
able state of the art and the first nacelles
retrofit to be in excess of one-half bil-
(a) U.S. air carriers and commercial
or retrofit kits for those airplanes covered
lion dollars, including $27,674,000 for in-
operators. After June 30, 1976, no person
by this proposal could be delivered about
creased fuel costs and $2,420,000 for in-
holding a certificate under the provisions
six months after the effective date of a
creased maintenance costs for the B-707
of Part 121 of this chapter may operate,
retrofit regulation.
airplanes. (Comments of the ATA to
under that certificate, an airplane cov-
With respect to those airplanes covered
NPRM 74-14.) The IATA estimates the
ered by this subpart having a maximum
by this proposal which have a maximum
modifications to cost approximately one
weight of 75,000 pounds or more, unless-
weight less than 75,000 pounds, approxi-
million dollars for each 4 engine turbojet
(1) That airplane meets the require-
mately 20 percent of those airplanes (the
airplane. and roughly $250,000 for each
ments of Part 36 of this chapter; or
Falcon 20 and Cessna Citation) are
two and three engine turbojet airplane.
(2) The certificate holder has demon-
powered by moderate bypass ratio turbo-
It estimates the total cost for all its world
strated to the Administrator that at least
fan engines certificated in accordance
wide members to be approximately 1.5
one-half of the engine/nacelles for all
with the noise requirements of Part 36.
billion dollars. (Policy Statement on
the airplanes covered by this subpart
The remaining 80 percent are powered
Noise Retrofit, IATA).
having a maximum weight of 75,000
by turbojet or very low bypass ratio
EPA estimated that the cost of mod-
pounds or more and listed by the cer-
turbofan engines with noise character-
ifying the jet fleet of airplanes having
tificate holder in its aircraft record or
istics similar to that of the straight
a weight of less than 75,000 pounds to
operations specifications, as the case
turbojet. The Gulfstream 2, the largest
comply with FAR 36 levels is approxi-
may be, are of a design that permits
airplane in this class, has a takeoff and
mately 0.3 billion dollars.
those aircraft types to meet the require-
sideline noise level in excess of the FAR
Implementation of the retrofit options
ments of Part 36 if the engine/nacelles
36 requirements. However, Grumman, in
of Quiet Nacelles to the JT3D and JT8D
were deployed in a full set.
concert with Rolls Royce, has defined a
fleet would effect a substantial decrease
(b) Foreign air carriers. After June 30,
program to develop a noise suppression
in the impact of noise on people. Based
1976, no foreign air carrier holding oper-
kit for that airplane utilizing hardware
upon the noise impact methodology of
ations specifications under the provisions
developed for the F28 and BAC111 which
Reference 14, the EPA estimates that
of Part 129 of this chapter may operate,
will meet the FAR 36 requirements.
the equivalent number of persons ex-
under those operations specifications,
The rest of the airplanes in the Gen-
posed to a Day-Night Level (Ldn) of 75
any airplane covered by this subpart hav-
eral Aviation fleet are powered by small
dB will be over 800,000 fewer people,
ing a maximum weight of 75,000 pounds
(3000 to 3500 lbs. thrust) turbojet en-
nationally. This estimate includes, in ad-
or more unless-
gines which are extremely compact en-
dition to Quiet Nacelles, the combined
(1) That airplane meets the require-
gines. Since small engines are less toler-
effects of the introduction of new quieter
ments of Part 36 of this chapter; or
ant of disturbances to the basic thermo-
aircraft into the fleet and the use of a
(2) The air carrier has demonstrated
dynamic cycle, small size in itself can be
two-segment approach procedure.
compliance with the requirements of
a problem with regard to the application
In consideration of the foregoing, it is
paragraph (a) (2) of this section.
of sound absorption materials (SAM) in
proposed to amend Part 91 of the Fed-
(c) Installation of engine/nacelles.
the engine nacelle. There are, however,
eral Aviation Regulations by adding a
Each person authorized to operate an
reengine options available for the air-
new Subpart E to read as follows:
planes that will permit compliance with
airplane under the provisions of para-
Subpart E-Noise Requirements
the FAR 36 requirements before the
graph (a) (2) of this section shall estab-
Sec.
June 30, 1978, compliance date proposed
91.301
lish and maintain a schedule for the in-
Applicability.
herein.
91.303
Relation to Part 36.
stallation of the engine/nacelles required
For those airplanes that are marginally
91.305
Interim noise requirements: subsonic
by that paragraph on airplanes listed
shy of meeting the FAR 36 requirements
turbojet engine-powered airplanes
in its aircraft record or operations speci-
having a maximum weight of 75,-
(Learjet, for example), a modified ex-
000 pounds or more.
fications, as the case may be. Unless
otherwise authorized by the Administra-
tor for reasons of safety, such as un-
balanced weight, thrust, or drag, each
installation shall be scheduled to be per-
formed at the first periodic inspection
of the airplane at which the ground
time is adequate to perform the installa-
tion.
§ 91.307 Noise requirements; all sub-
sonic turbojet engine-powered air-
planes.
After June 30, 1978, no person may op-
erate any airplane covered by this sub-
part unless that airplane meets the re-
quirements of Part 36 of this chapter.
(Secs. 313(a) 601, 603, and 611, Federal Avia-
tion Act of 1958 (49 U.S.C. 1354(a)), 1421,
1423, 1424, and 1431 as amended by the
Noise Control Act of 1972 (Pub. L. 92-574);
sec. 6(c), Department of Transportation Act
(49 U.S.C. 1655(c)).)
Issued in Washington, D.C. on Febru-
ary 20, 1975.
CHARLES R. FOSTER,
Director of Environmental Quality.
[FR Doc.75-5096 Filed 2-25-75;8:45 am]
As published in the
Federal Register (40 F.R.
8218) on February 26, 1975.
APPENDIX B: SUMMARY UNITED STATES AIRCRAFT FLEET FORECAST
PROJECTED U.S. AIR CARRIER FLEET
(at end of indicated year)
BASE CASE
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
45
45
45
45
45
45
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
275
314
354
395
438
472
505
539
572
606
639
939
B-707, DC-8 & B-720
N
487
400
395
391
369
346
314
292
270
248
227
212
o
B-727
C
248
427
436
476
504
542
542
542
542
542
542
542
542
N
572
500
479
459
438
418
397
376
355
335
314
293
8
TOTAL
820
927
915
935
942
960
939
918
897
877
856
835
550
B-737 & DC-9
C
59
303
389
457
508
565
623
686
765
815
866
916
1376
N
480
463
456
448
441
433
426
421
415
410
404
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
0
0
0
0
58
112
165
196
228
259
574
*STATUS CODES:
M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C
= Other aircraft which comply with the noise levels of FAR Part 36.
N
= Aircraft which do not comply with the noise levels of FAR Part 36.
PROJECTED U.S. AIR CARRIER FLEET (continued)
(c.nd of indicated year)
CASE 1: 100: MODIFY
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
37
30
23
17
10
3
0
0
0
0
0
0
M
0
8
15
22
28
35
42
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
275
314
354
395
438
472
505
539
572
606
639
939
B-707, DC-8 & B-720
N
487
390
319
250
173
100
50
22
0
o
0
0
0
M
0
10
76
141
196
246
246
270
270
248
227
212
0
TOTAL
487
400
395
391
369
346
296
292
270
248
227
212
0
B-727
C
248
427
436
476
504
542
542
542
542
542
542
542
542
N
572
295
157
20
0
0
0
0
0
0
0
0
0
M
0
205
322
439
438
418
397
380
358
337
314
293
8
TOTAL
820
927
915
935
942
960
939
918
897
877
856
835
550
B-737 & DC-9
C
59
303
389
457
508
565
623
686
764
815
865
916
1376
N
480
291
154
7
0
0
0
0
0
0
0
0
0
M
0
172
302
441
441
433
426
421
416
410
405
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
0
0
0
0
58
112
165
196
228
259
574
*STATUS CODES:
M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
N = Aircraft which do not comply with the noise levels of FAR Part 36.
NOTE: The above projected schedule indicates airplanes remaining in status category N beyond the 12-31-84 ultimate compliance date.
The difference, however, does not significantly impact the subsequent conclusions concerning the benefits, costs, or the
related analyses predicated on these projections.
PROJECTED U.S. AIR CARRIER FLEET (continued)
(end of indicated year)
CASE 2: RETROFIT/MODIFY JT-3D AND MODIFY JT-8D
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
37
25
14
10
6
3
0
0
0
0
0
0
M
0
8
20
31
35
39
42
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
264
302
341
369
397
421
454
488
521
555
588
888
B-707, DC-8 & B-720
N
498
444
360
270
160
60
30
10
0
0
0
0
0
M
0
10
34
64
84
100
100
100
100
100
100
100
0
TOTAL
498
454
394
334
244
160
130
110
100
100
100
100
0
B-727
C
248
380
386
423
395
334
334
334
334
334
334
334
334
N
572
295
157
20
0
0
0
0
0
0
0
0
0
M
0
205
322
439
438
418
397
380
358
337
314
293
8
TOTAL
820
880
865
872
833
752
731
714
692
671
648
627
342
B-737 & DC-9
C
59
303
389
457
508
565
623
686
764
815
865
916
1376
N
480
291
154
7
0
0
0
0
0
0
0
o
0
M
0
172
302
441
441
433
426
421
416
410
405
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
43
86
183
277
366
422
473
490
516
534
779
*STATUS CODES: M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
N = Aircraft which do not comply with the noise levels of FAR Part 36.
NOTE:
The above projected schedule indicates airplanes remaining in status category N beyond the 12-31-84 ultimate compliance date.
The difference, however, does not significantly impact the subsequent conclusions concerning the benefits, costs, or the
related analyses predicated on these projections.
PROJECTED U.S. AIR CARRIER FLEET (continued)
(end of indicated year)
CASE 3: REPLACE JT-3D AND MODIFY JT-8D
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
37
25
14
10
6
3
0
0
0
0
0
0
M
0
8
20
31
35
39
42
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
264
302
341
369
397
421
454
488
521
555
588
888
B-707, DC-8 & B-720
N
497
454
394
334
244
154
98
10
0
0
0
o
o
B-727
C
248
381
387
424
396
335
334
334
334
334
334
334
334
N
572
295
157
20
0
0
0
0
0
0
0
0
0
M
0
205
322
439
438
418
397
380
358
337
314
293
8
TOTAL
820
881
866
873
834
753
731
714
692
671
648
627
342
B-737 & DC-9
C
59
303
389
457
508
565
623
685
764
815
865
916
1376
N
480
291
154
7
0
0
0
0
0
0
0
0
0
M
0
172
302
441
441
433
426
421
416
410
405
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
43
86
183
281
435
503
545
567
588
606
782
*STATUS CODES: M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
N = Aircraft which do not comply with the noise levels of FAR Part 36.
NOTE:
The above projected schedule indicates airplanes remaining in status category N beyond the 12-31-84 ultimate compliance date.
This difference, however, does not significant impact the subsequent conclusions concerning the benefits, costs, or the
related analyses predicated on these projections.
APPENDIX C: IMPACTS ON NATIONAL ECONOMY:
INFLATIONARY IMPACT STATEMENT
.
THE INFLATIONARY IMPACT
OF THE PROPOSED AIRCRAFT NOISE REGULATION
CONTENTS
EXECUTIVE SUMMARY
1
INTRODUCTION
2
MEASUREMENT OF INFLATIONARY IMPACT
3
UNIT COST ESTIMATES
5
EFFECTS ON SUPPLYING INDUSTRIES
15
THE AIRCRAFT MANUFACTURING INDUSTRY
19
EMPLOYMENT IMPACTS
23
CONCLUSION
28
LIST OF ILLUSTRATIONS
Table 1A
Base Case Number of Airplanes Produced and
Modified, 1977-1986
6
Table 1B
Case 1: One-Hundred Percent Modify -- Difference
in Number of Aircraft Produced and Modified
Between Case 1 and the Base Case
7
Table 1C
Case 2: Modify JT-3D and JT-8D Engines --
Difference in Number of Planes Modified and
Produced Between Case 2 and Base Case
8
Table 1D
Case 3: Replace JT-3D Engines and Modify JT-8D
Engines -- Difference in Number of Planes
Produced and Modified Between Case 3 and
Base Case
9
i
LIST OF ILLUSTRATIONS (Continued)
Table 2A
Cost of Base Case
10
Table 2B
Difference Between Case 1 and Base Case
11
Table 2C
Difference Between Case 2 and Base Case
12
Table 2D
Difference Between Case 3 and Base Case
13
Table 3
Total Cost of Each Case
14
Table 4
Direct and Indirect Demand for Goods and
Services, by Peak Year
16
Table 5
BLS Projected Output of Selected Industries
17
Table 6
World Aircraft Production Forecast
20
Table 7
Aerospace Industry Sales
21
Table 8A
Peak Year Employment Impact
24
Table 8B
Employment Impact, 1977-1986
25
Table 9
Employment in the Aerospace Industry
26
ii
EXECUTIVE SUMMARY
This report examines the question of whether or not inflationary
impacts would result from enactment of the proposed FAR Part 36
Noise Compliance Regulation. Three air carrier industry responses
to the proposed change are postulated, and each is examined to
determine the likely effects on materials and employment within
the aircraft manufacturing industry as well as in key supplying
industries. This analysis is conducted for the peak year in
each case, i.e., the year in which the projected incremental
financial effect of the change in regulations over the baseline
projection is the greatest. Under each of the three cases
examined, it is concluded that the effects of key labor and
material inputs are very small relative to the productive
capacity of supplying industries, and that current and projected
future slack capacity in these industries is sufficiently great
to accommodate the labor and materials requirements created
by the proposed change. As a result, no inflationary pressures
on wages or prices are expected to be created through enactment
of the proposed regulation.
INTRODUCTION
The proposed regulation being evaluated would mandate noise reductions
on large commercial airplanes by December 1984. this would be accomplished
in various ways: by replacement of existing aircraft with new aircraft
that would meet the noise standards, by modification of engines on existing
aircraft, or by a combination of the two policies.
This report analyzes the effects of the proposed program relative to a
"base case," i.e., a projection of the stock of aircraft (by type) which
would be anticipated in the absence of the proposed noise regulations.
Three alternative cases are considered, one involving modifications only,
and two modification/replacement programs. All of the sets of projections
(including the base case) include some new technology aircraft (NTA),
vehicles designed in part to meet anticipated noise reduction standards.
This study concentrates on the years 1981-1986. While aircraft production
will obviously take place before and after this period, the six years
carry the brunt of change stemming from the modification/replacement
programs. (The fact that the regulation requires total compliance by
December 1984 does not abrogate the findings of this study which was
conducted utilizing a December 1986 compliance schedule.)
2
MEASUREMENT OF INFLATIONARY IMPACT
Inflation is a general increase in prices for the same quality of goods and services; the
typical cause is an increase in demand at a faster rate than the supply of resources or
finished goods. An increase in demand may be monetary -- i.e., generated by an
expansion of the money supply -- or it may be an increase in the real demand for selec-
tive goods and services.
Inflation that is based on monetary causes is likely to be more widespread and can result
in a cycle that feeds upon itself to generate further price increases over a number of
years. Inflation that is based on localized increases in real demand is less likely to lead
to widespread price increases, and, in many cases, the effects are dampened by
offsetting reductions in the demand for goods and services. Dampening is typically the
case if total demand is not increased; if total demand increases, but remains less than
the capacity of a full-employment economy, the spread of price increases is also
limited.
Besides an increase in demand relative to supply, inflation can be caused by an increase
in real costs or decrease in supply. For example, an increase in imported energy prices
or a sudden cutoff in energy imports can trigger inflation.
Increases in real demand for selective goods and services will not be inflationary if this
demand is met by employing previously idle resources; in this case, the supply of the
relevant goods and services at existing prices is increased to keep step with demand
and, as a result, there is no inflationary effect on prices. In practice, specific
imbalances between demand and supply and frictions in making adjustments will lead to
some inflationary impact from demand increases in spite of the existence of idle
resources; however, the inflationary potential is severely limited.
The program being evaluated will not result in monetary expansion but will cause
increases in the demand for selective goods and services and will have some minor
inflationary impact. However, the total program's inflationary impact will tend to be
self-adjusting and short-term in nature, especially in view of the projected less-than-
full-employment economy over the next few years.
3
In view of these conditions, the inflationary impact of the program will be evaluated by
calculating the significance of increases in the demand for the output of specific
industries. Three cases are explored, each corresponding to a particular set of
assumptions concerning industry responses. All estimates developed here are based on
the total cost of a particular case and the deviation of that case from the base case. In
this way we can estimate in the next sections the maximum, incremental impact of the
program.
4
UNIT COST ESTIMATES
The base case and three alternative scenarios are given in the following
tables. Table 1A gives the number of aircraft ("FAR") produced in the
indicated years. Tables 1B, 1C, and 1D give the difference in the number
of aircraft produced between the case in question and the base case, and
the number of aircraft modified ("RTF") in each case.
Table 2A gives the cost (in millions of 1976 dollars) of the base case,
and Tables 2B, 2C, and 2D give the cost of corresponding table entries
of Tables 1B, 1C, and 1D. The following schedule of costs and prices are
used. 1/
Plane price
Modification price (per plane)
NTA
$23 million
727
$0.225 million
L-1011/DC-10
$25.9 million
707
Case 2:
2.6 million
Case 1:
1.9 million
727
$10 million
747
$0.25 million
DC-9/737
$6.5 million
DC-9/737
$0.27 million
707
$14.7 million
747
$32.7 million
A range of prices is shown for the B-707 since the cost of modifying
that equipment is reported to be dependent upon the number of B-707s
being modified.
The total cost for each case (as opposed to the incremental cost above
baseline) are furnished for reference in Table 3.
Based on discussions with industry, the Mitre Corporation, and an
FAA memorandum.
5
TABLE 1A.-BASE CASE NUMBER OF AIRPLANES PRODUCED
AND MODIFIED, 1977-1986
77-80
81
82
83
84
85
86
B747
FAR
26
14
14
14
14
14
14
RTF
0
0
0
0
0
0
0
DC10/ FAR
58
39
40
41
43
34
33
L1011
RTF
0
0
0
0
0
0
0
B707/
FAR
0
0
0
0
0
0
0
DC8
RTF
0
0
0
0
0
0
0
NTA
FAR
0
0
0
0
0
58
54
RTF
0
0
0
0
0
0
0
B727
FAR
179
9
40
28
38
0
0
RTF
0
0
0
0
0
0
0
B737/
FAR
244
86
68
51
57
58
63
DC9
RTF
0
0
0
0
0
0
0
6
TABLE 1B.-CASE 1: ONE-HUNDRED PERCENT MODIFY-
DIFFERENCE IN NUMBER OF AIRCRAFT PRODUCED AND MODIFIED
BETWEEN CASE 1 AND THE BASE CASE
77-80
81
82
83
84
85
86
B747
FAR
-10
0
0
0
0
0
0
RTF
8
7
7
6
7
7
3
DC10/ FAR
0
0
0
0
0
0
0
L1011
RTF
0
0
0
0
0
0
0
B707/
FAR
0
0
0
0
0
0
0
DC8
RTF
10
66
65
55
50
0
0
NTA
FAR
0
0
0
0
0
0
0
RTF
0
0
0
0
0
0
0
B727
FAR
0
0
0
0
0
0
0
RTF
205
117
117
4
4
4
3
B737/
FAR
244
0
0
0
0
0
0
DC9
RTF
227
34
51
50
67
58
54
7
TABLE 1C.-CASE 2: MODIFY JT-3D AND JT-8D ENGINES
DIFFERENCE IN NUMBER OF PLANES MODIFIED AND PRODUCED
BETWEEN CASE 2 AND BASE CASE
77-80
81
82
83
84
85
86
B747
FAR
0
0
0
0
0
0
0
RTF
8
12
11
4
3
3
0
DC10/
FAR
-11
-11
-1
-13
-15
-10
0
L1011
RTF
0
0
0
0
0
0
0
B707/
FAR
0
0
0
0
0
0
0
DC8
RTF
10
14
30
20
16
0
0
NTA
FAR
0
43
43
97
94
31
-7
RTF
0
0
0
0
0
0
0
B727
FAR
-112
-3
-3
-28
-38
0
0
RTF
205
117
117
0
0
0
0
B737/
FAR
0
0
0
0
0
0
0
DC9
RTF
172
130
139
2
2
2
1
8
TABLE 1D.-CASE 3: REPLACE JT-3D ENGINES AND MODIFY JT-8D ENGINES - -
DIFFERENCE IN NUMBER OF PLANES PRODUCED AND MODIFIED
BETWEEN CASE 3 AND BASE CASE
77-80
81
82
83
84
85
86
B747
FAR
0
0
0
0
0
0
0
RTF
8
12
11
4
4
3
3
DC10/
FAR
-11
-11
-1
-13
-15
-10
0
L1011
RTF
0
0
0
0
0
0
0
B707/
FAR
0
0
0
0
0
0
0
DC8
RTF
0
0
0
0
0
0
0
NTA
FAR
0
43
43
97
94
31
2
RTF
0
0
0
0
0
0
0
B727
FAR
-112
-3
-3
-28
-38
0
0
RTF
205
117
117
4
4
4
3
B737/
FAR
0
0
0
0
0
0
0
DC9
RTF
172
30
139
2
2
2
1
9
FORD i LIBRARY 07VH39
TABLE 2A.-COST OF BASE CASE
(Millions of 1976 Dollars)
1977-
1980
1981
1982
1983
1984
1985
1986
B747
FAR
850.2
457.8
457.8
457.8
457.8
457.8
457.8
RTF
00.0
0.0
0.0
0.0
0.0
0.0
0.0
DC10/
FAR
1502.2
1010.1
1036.0
1061.9
1113.7
880.6
854.7
L1011
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B707/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC8
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
NTA
FAR
0.0
0.0
0.0
0.0
0.0
1334.0
1242.0
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B727
FAR
1790.0
90.0
400.0
280.0
380.0
0.0
0.0
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B737/
FAR
409.5
559.0
442.0
331.5
370.5
377.0
409.5
DC9
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL
4551.9
2116.9
2335.8
2131.2
2322.0
3049.4
2964.0
10
TABLE 2B.-DIFFERENCE BETWEEN CASE 1 AND BASE CASE
(Millions of 1976 Dollars)
1977-
1980
1981
1982
1983
1984
1985
1986
B747
FAR
-327.0
0.0
0.0
0.0
0.0
0.0
0.0
RTF
2.0
1.75
1.75
1.50
1.75
1.75
0.75
DC10/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
L1011
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B707/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC8
RTF
19.0
125.4
123.5
104.5
95.0
0.0
0.0
NTA
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B727
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
RTF
46.125
26.325
26.325
0.9
0.9
0.9
0.675
B737/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC9
RTF
61.29
9.18
13.77
13.5
18.09
15.66
14.58
TOTAL
-198.59
162.655
165.345
120.4
115.74
18.31
16.005
11
TABLE 2C.-DIFFERENCE BETWEEN CASE 2 AND BASE CASE
(Millions of 1976 Dollars)
1977-
1980
1981
1982
1983
1984
1985
1986
B747
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
RTF
2.0
3.0
2.75
1.0
0.75
0.75
0.0
DC10/
FAR
-284.9
-284.9
-25.9
-336.7
-388.5
-259.0
0.0
L1011
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B707/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC8
RTF
26.0
36.4
78.0
52.0
41.6
0.0
0.0
NTA
FAR
0.0
989.0
989.0
2231.0
2162.0
713.0
-46.0
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B727
FAR
-1120.0
-30.0
-30.0
-280.0
-380.0
0.0
0.0
RTF
46.125
26.325
26.325
0.9
0.9
0.9
0.675
B737/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC9
RTF
46.44
35.1
37.53
0.54
0.54
0.54
0.27
TOTAL
-1284.34
774.93
1077.71
1668.74
1437.83
456.19
46.945
12
TABLE 2D.-DIFFERENCE BETWEEN CASE 3 AND BASE CASE
(Millions of 1976 Dollars)
1977-
1980
1981
1982
1983
1984
1985
1986
B747
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
RTF
2.0
3.0
2.75
2.0
2.0
1.75
1.75
DC10/
FAR
-284.9
-284.9
-25.9
-336.7
-388.5
-259.0
0.0
L1011
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B707/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC8
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
NTA
FAR
0.0
989.0
989.0
2231.0
2162.0
713.0
46.0
RTF
0.0
0.0
0.0
0.0
0.0
0.0
0.0
B727
FAR
-1120.0
-30.0
-30.0
-280.0
-380.0
0.0
0.0
RTF
46.125
26.325
26.325
0.9
0.9
0.9
0.675
B737/
FAR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
DC9
RTF
46.44
35.1
37.53
0.54
0.54
0.54
0.27
TOTAL
-1310.34
728.53.
999.71
1617.74
1397.48
457.19
48.69
13
TABLE 3.-TOTAL COST OF EACH CASE
(Millions of 1976 Dollars)
1977-
1980
1981
1982
1983
1984
1985
1986
Case 1
4353.3
2279.6
2501.2
2251.6
2437.7
3067.7
2980.0
Case 2
3267.6
2891.8
3413.5
3799.9
3759.8
3505.6
3010.9
Case 3
3241.6
2845.4
3335.5
3748.9
3719.5
3506.6
3012.7
Base
4551.9
2116.9
2335.8
2131.2
2322.0
3049.4
2964.0
14
EFFECTS ON SUPPLYING INDUSTRIES
The impact on industries which supply the aircraft manufacturing industry is examined
in three steps:
1.
the incremental financial impact of each case is computed (see Tables 2B-
2D);
2.
the year with the greatest total financial impact is selected for each case;
and
3.
materials requirements for the peak years thus selected are then projected
and compared to overall production levels.
The first of these steps is detailed in the previous section; the last two are elaborated
below.
For the "peak" years (i.e., those years with the greatest positive difference between a
particular case and the base case), the calculated demand for new aircraft and
modification work, and the difference between peak and base year demand, was
distributed across industries that are major suppliers to the aircraft industry. This was
done by use of the Bureau of Labor Statistics' (BLS) forecast of direct and indirect input
requirements for the aircraft industry in 1985. 2 Table 4 gives the amount that would be
demanded (in 1976 dollars) in each case's peak year. Table 5 gives the BLS projected
3
1980, 1982, and 1983 outputs of the industries, under a slow recovery scenario.
It is immediately evident that the direct and indirect requirements for total demand in
each case, for each commodity, do not exceed one-half of one percent of the forecasted
outputs, except in the aircraft and machine shop industries. The percentages
attributable to the difference between each case and the base are much smaller.
Sample percentages are:
2
U. S. Department of Labor, Bureau of Labor Statistics, The Structure of the
U.S. Economy in 1980 and 1985, Bulletin #1831, 1975.
3
Based on unpublished Bureau of Labor Statistics output.
15
TABLE 4.-DIRECT AND INDIRECT DEMAND
FOR GOODS AND SERVICES, BY PEAK YEAR
(Millions of 1976 Dollars)
Case 1
Case 2
Case 3
Difference
Difference
Difference
Between
Total
Between
Total
Between
Total
Industry
Base and Case
Cost
Base and Case
Cost
Base and Case
Cost
30
.280
4.244
2.832
6.448
2.746
4.665
37
.236
3.580
2.388
5.439
2.316
3.934
43
.283
4.275
2.852
6.495
2.765
4.699
44
1.261
19.071
12.723
28.975
12.335
20.960
48
.188
2.848
1.899
4.327
1.841
3.129
49
1.057
15.998
10.673
24.307
10.347
17.583
50
1.675
25.360
16.919
38.531
16.402
27.873
52
.004
.066
.044
.100
.042
.072
54
.027
.409
.272
.622
.263
.449
55
1.274
19.267
12.854
29.270
12.461
21.174
56
1.301
19.691
13.137
29.915
12.735
21.641
57
1.385
20.959
13.982
31.844
13.557
23.035
61
1.372
20.752
13.846
31.528
13.421
22.807
62
2.283
34.527
23.035
52.454
22.331
37.946
67
3.330
50.382
33.612
76.543
32.585
55.372
69
1.179
17.833
11.898
27.074
11.533
19.600
70
7.694
116.389
77.649
176.827
75.278
127.919
73
.044
.649
.433
.985
.419
.713
77
.112
1.706
1.138
2.593
1.104
1.875
80
5.911
89.419
59.656
135.852
57.833
98.277
82
.360
5.436
3.627
8.258
3.515
5.975
84
22.546
341.115
227.576
518.252
220.623
374.908
88
1.766
26.725
17.830
40.603
17.286
29.373
16
TABLE 5.-BLS PROJECTED OUTPUT OF SELECTED INDUSTRIES
(Millions of 1976 Dollars)
1980
1982
1983
30
Other Furniture
7,108
7,551
7,773
37
Plastic Materials and
Synthetic Rubber
27,067
30,549
32,289
43
Rubber Products
20,247
21,993
22,866
44
Plastic Products
31,659
36,965
39,619
48
Misc. Stone and Clay
Products
9,188
9,688
9,938
49
Blast Furnaces and
Basic Steel Products
55,810
56,298
58,041
50
Iron and Steel Foundries
and Forgings
17,768
18,420
18,746
52
Primary Aluminum
10,129
11,052
11,514
54
Copper Rolling and
Drawing
5,017
5,254
5,367
55
Aluminum Rolling and
Drawing
9,587
10,666
11,206
56
Other Non-Ferrous
Rolling and Drawing
14,056
15,169
15,726
57
Miscellaneous Non-Ferrous
Metal Products
4,554
4,754
4,853
61
Screw Machine Products
16,281
17,115
17,533
62
Other Fabricated Metal
Products
37,068
39,500
40,715
67
Metalworking Machinery
19,190
20,361
20,946
69
General Industrial Machinery
24,808
27,201
28,498
70
Machine Shop Products
11,274
11,972
12,320
73
Service Industry Machines
18,578
20,548
21,534
77
Electric Lighting and
Wiring
13,097
14,488
15,183
80
Radio, TV Transmitting,
Signaling, and Detection
Equipment
17,760
19,181
19,892
82
Miscellaneous Electrical
Machinery
10,349
11,651
12,303
84
Aircraft
40,273
42,959
44,301
88
Professional, Scientific, and
Controlling Equipment
8,915
9,488
19,974
17
Increment
Total Demand
as Percentage
as Percentage
a
c
Case
Industry
of Total Output
of Output
a
1
50
0.009
0.138
1
80
0.031
0.466
1
70
0.064
0.972
b
1
84
0.052
0.794
2
50
0.090
0.206
2
80
0.299
0.683
2
70
0.630
1.435
b
2
84
0.514
1.170
3
50
0.088
0.148
3
80
0.291
0.494
3
70
400
0.611
1.038
b
3
84
0.498
0.846
a
See Table 5 for industry codes.
b
Reflects additional aircraft activity beyond directly demanded levels.
C Derived by dividing the appropriate entry in the "Difference Between Case
and Base" column by projected BLS output in the case's peak year.
d
Derived by dividing the appropriate total cost column entry by the case's
peak year BLS predicted output.
One possible bottleneck is the aluminum industry. High production costs, low profit
margins, and heavy debts have hindered investment in that industry. Should these
conditions persist, an under-supply of domestically refined aluminum might result for
the entire economy. 4 While aluminum's share (in either rolling or primary aluminum) is
small here (at most 0.21% of 1983 output), shortages could put pressure on prices. With
this caveat aside, and the generally favorable outlook for metal producers, 5 no (serious)
bottlenecks are foreseen.
4
Business Week, April 12, 1976, pp. 76-78.
5
Business Week, May 10, 1976, pp. 52-53.
18
THE AIRCRAFT MANUFACTURING INDUSTRY
The existing excess capacity in the aerospace industry is apparent from the picture of
industry production over the past thirteen years as shown in Table 7. In constant
dollars, industry sales peaked in 1968 and have dropped by 37 percent for a thirteen-
year low in 1975. Assuming that most of the industry capacity from the peak period is
still intact, a large amount of slack capacity still exists.
Any significant increases in output between now and 1981 are expected to be in military
sales and general aviation aircraft. The domestic market for transport aircraft is
depressed primarily due to the severe financial problems of the airlines. This condition
is expected to continue until the early 1980s, unless the airlines receive substantial
outside financial help.
The worldwide market is very important to U.S. commercial transport sales and,
currently, about two-thirds of transport production is being exported. The worldwide
market is expected to grow faster than the U.S. market in the future, with a concurrent
increase in competition from foreign manufacturers. As of today, the U.S.
manufacturers are supplying over 90 percent of the worldwide commercial transport
market, excluding the U.S.S.R.; however, significant competition now exists, especially
from the French-German A300-B and the British BAC-11. The Soviet aircraft industry
supplies virtually 100 percent of the Soviet commercial airline fleet.
Current projections by DMS, Inc. indicate relatively low worldwide markets in
commercial aircraft for the next five years, with a sharp increase in the succeeding five
years (1980-84). It is worthy of note that the DMS forecast has been dramatically
revised upwards since a one-year earlier forecast. The latest forecast is compared with
the earlier one in Table 6. The sharp change in these one-year apart projections casts
doubt on their validity and perhaps indicates that the later forecast should be treated as
an upper limit.
If the U.S. keeps its share of this worldwide market (an optimistic assumption), then
U.S. production in the 1980-84 period can be expected to increase approximately 50
percent over current levels. This is probably an upper limit on expected demand on the
19
TABLE 6.-WORLD AIRCRAFT PRODUCTION FORECAST
(Millions of Dollars)
DMS 1975 Forecast
1975-79
1980-84
% Change
Military aircraft
59,611
90,896
+52.5
Commercial aircraft
22,693
31,216
+37.6
Total
82,304
122,112
+48.4
DMS 1974 Forecast
1974-78
1979-83
% Change
Military aircraft
50,044
58,004
+15.9
Commercial aircraft
22,825
21,760
- 4.6
Total
72,869
79,764
+ 9.4
Source: DMS, Inc. World Aircraft Forecast, 1974-83 and 1975-84,
Greenwich, Conn. (copyrighted information purchased by
FAA from DMS).
20
TABLE 7. --AEROSPACE INDUSTRY SALES
Current Dollars
1972 Constant Dollars
Billions
Index
1960=100
1968=100
100
80
1963
20.1
28.1
100
80
1964
20.6
28.3
101
81
1965
20.7
27.9
99
79
1966
24.6
32.0
114
91
1967
27.3
34.5
123
98
1968
29.0
35.1
125
100
1969
26.1
30.1
107
86
1970
24.9
27.3
97
78
1971
22.2
23.1
82
66
1972
22.8
22.8
81
65
1973
24.8
23.4
83
67
1974
26.4
24.9
89
71
1975
28.0
22.2
79
63
Source: Aerospace Industries Association, Aerospace Facts and
Figures 1976-77, pp. 12-13.
21
U.S. acrospace industry for purposes of analyzing industry capacity to meet the added
demand postulated by the program under study. Since production has dropped 37
percent since 1968 (see Table 7) a 50 percent increase over the current base would bring
production back to about 95 percent of its 1968 level in real terms.
In addition to the statistics presented above, the aircraft industry acknowledges that it
6
was operating at about two-thirds of its preferred rate of capacity utilization in 1975.
Production is expected to drop even further in the 1976-80 period. Under the optimistic
assumptions given above, if the U.S. can keep its share of the world market, then U.S.
aircraft production should be fifty percent above current (1976) levels in the 1980-84
period, or at roughly ninety-five percent of its 1968 production capacity. Assuming that
the base case is reflected already in the projected fifty percent increase, then the
highest increment above the base case (that of Case 2 in 1983) would raise capacity
utilization to ninety-nine percent of the 1968 levels. Thus the aircraft industry should
be able to handle the additional orders (over the base case) with little or no increase in
capacity. Since 1975 production was at sixty-three percent of 1968 productions, or
approximately two-thirds of 1968 production, this program should fall at or within the
industry's preferred capacity; new investment should be limited to normal plant and
equipment investment replacement.
This analysis does not take into account the fact that there may be some imbalances in
capacity in the industry and some special tooling would be needed for the new tech-
nology aircraft. Current investment by the industry in equipment is around $800 million
per annum, which is about two-thirds of annual investment levels in the 1960s. In view
of the current slack capacity in producer durable supplying industries, this added
demand can easily be accommodated without expanding the capacity of these industries.
In summary, the proposed noise regulations would not entail any extraordinary invest-
ment outlays by the industry and cannot, in itself, be expected to have an inflationary
impact on the capital equipment-producing industries.
6
Survey of Current Business, March 1976, pg. 18. The results are based on a
survey of manufacturing executives in each industry.
22
EMPLOYMENT IMPACTS
Estimates of aggregate employment impacts of the program are detailed by two
sectors: the aircraft producing industry (direct employment) and the remaining sectors
of the economy (indirect employment). Two principle sources of information were
utilized in deriving these estimates of labor requirements for both new aircraft
purchases and the modifications to existing units. Estimates of the man-years required
to manufacture selected aircraft, which were used to determine the direct labor impact
of new aircraft purchases, were based on information supplied by aircraft producers.
Bureau of Labor Statistics' measures of projected employment per billion dollars of
delivery to final demand by input/output sector, were used to estimate the indirect
employment effect of new aircraft purchases, and both the direct and indirect
7
employment effects due to existing aircraft modifications.
The employment impact was calculated for the peak year for each of the three
scenarios under analysis. As before, the peak year was defined as the year with the
largest difference in estimated total program expenditures (the sum of both new
purchases and retrofits) between the scenario and the baseline forecasts. The
employment impact is shown in Table 8A.
To calculate the direct employment impact as a result of new aircraft purchases, man-
year requirements per unit of 606, 369, 185, and 544 for the B747, NTA, B727, and
DC10/L1011 aircraft, 8 respectively, were applied to the difference in the number of
new aircraft purchased by type between the scenario and baseline forecasts (see
Table 8B for the forecast of new aircraft purchases and existing aircraft modifications
under each scenario and the baseline). The direct employment impact due to the
7
U. S. Department of Labor, Bureau of Labor Statistics, The Structure of the
U.S. Economy in 1980 and 1985, BLS Bulletin #1831, 1975.
8
Employment information pertaining only to the NTA and DC10/L1011 aircraft were
supplied by the aircraft manufacturers. Man-year requirements for the B747 and
B727 were estimated by applying an assumed ratio of man-years/cost to the
respective cost of each aircraft. The assumed man-year/cost ratio was the
simple average of this ratio for the NTA and DC10/L1011 aircraft.
23
aircraft modifications was estimated by applying the BLS ratio (interpolated to the peak
year) of employees per billion dollars of delivery to final demand, 9 to the differential
value of aircraft modifications (converted to 1963 dollars), between the scenario and
the baseline. The sum of these two estimates equals the total direct employment
impact of the program.
Indirect employment impacts were derived by applying the appropriate BLS employ-
ment/final demand ratio to the differential values of both new aircraft purchases and
existing aircraft modifications.
Employment impacts in terms of employee-years were also estimated for the entire
period, 1977 through 1986. The estimation procedure was identical to that described
above except that the BLS employment ratios derived for 1982 (the midpoint of the
time period) were used for the entire period rather than different figures for each year.
The quantitative results are shown in Table 8B.
TABLE 8A.-PEAK YEAR EMPLOYMENT IMPACT
(Number of Employees)
Peak
Direct
Indirect
Year
Employment
Employment
Total
Case 1
1982
2,283
2,344
4,627
Case 2
1983
24,252
22,926.
47,178
Case 3
1983
23,586
22,225
45,811
9
The BLS ratios for 1970 and 1985 are found on pages 255 and 343 of BLS Bulletin
#1831, op. cit. The ratios were linearly interpolated to correspond to the
appropriate peak year, 1982 for Case 1 and 1983 for Cases 2 and 3. The
estimated ratios were as follows:
1982
1983
Direct employment per billion dollars of delivery to final demand 28,046 26,526
Indirect employment per billion dollars of delivery to final demand 28,789 27,903
24
TABLE 8B - EMPLOYMENT IMPACT, 1977-1986
(Number of Employee-Years)
Direct
Indirect
Employment
Employment
Total
Case 1
3,977
5,668
9,645
Case 2
56,620
59,215
112,835
Case 3
50,457
55,969
106,153
Employment in the aerospace industry over the past thirteen years is shown
in Table 9. Overall employment has decreased approximately 37 percent
since the peak in 1968. The decrease for the airframe and aircraft parts
components of the total aerospace industry is even larger than that for
the whole industry, a decline of 46 percent since 1968. Highly skilled
scientists and engineers account for about 7 percent of total employment
in the industry and their number has decreased by 34 percent since 1968.
Scientists and engineers in the aerospace industry now account for only
about 19 percent of the total in all industries, constrated with 27 percent
in 1968. 10/
Employment in the aerospace industry was expected to drop to the 900,000
level by the end of 1976 because of the slackening of demand for commercial
jetliners, the continuing erosion of the high technology manpower base,
and a relatively low level of federal commitment to new or replacement
military aircraft. 11/
It can be seen from Table 9 that the maximum increase in employment in
the aerospace industry, about 24,000 workers, resulting from a combina-
tion of aircraft replacements and modifications (Case 2), amounts to only
a small fraction of the drop of employment in recent years and only
2.5 percent of current total employment. Thus the program, in itself,
would increase demand in the labor market only slightly and therefore
should have virtually no inflationary impact on wages and salaries.
10/ Aerospace Research Center employment survey as quoted in
Aerospace Facts and Figures 76/77, pg. 120.
11/ Ibid., pg. 117.
25
TABLE 9.-EMPLOYMENT IN THE AEROSPACE INDUSTRY
Aircraft and Parts
Total Industry
Scientists & Engineers
Production Workers Only
Index
Index
Index
(000)
1968=100
(000)
1968=100
(000)
1968=100
1968
1,502
100
101
100
506
100
1969
1,402
93
100
99
464
92
1970
1,166
78
93
92
369
73
1971
951
63
78
77
285
56
1972
922
61
71
70
271
54
1973
948
63
72
71
281
56
1974
965
64
71
70
291
58
1975
942
63
67
66
273
54
Source:
Aerospace Industries Association, Aerospace Facts and Figures, 1976-77.
26
The effect of the program when combined with other projected increases in output in
the 1980-85 period should be examined. The most recent BLS projections of industry
12
output
show an expected increase in constant dollar domestic output on the order of
50 and 70 percent for 1980 and 1985, respectively, over the 1972 level. Assuming that
employment increases proportionally with output, this could mean employment of an
additional 140,000-190,000 workers in the aircraft and parts component of the industry.
Even by allocating 100 percent of the direct employment impact of the program (24,000
employees) to the production workers segment of the industry, maximum employment
would total 435,000-485,000 workers -- still below the 1968 peak of over 500,000. The
required skills are not currently in short supply and there is ample time for training new
workers as necessary before increased production would start in the early 1980s.
Therefore, this expansion in employment should easily be accommodated by the labor
market, and no significant inflationary impact on wages and salaries can be expected.
12 U. S. Department of Labor, Bureau of Labor Statistics, unpublished data.
27
CONCLUSION
The proposed regulation to require commercial jets to meet noise standards
by December 1984 should not produce an inflationary impact on the nation's
economy, in the sense of forcing price increases, of supplying industries'
goods, or through large incremental demands for these industries' products.
Based on U.S. Bureau of Labor Statistics' projections of industry outputs
in the 1980s and BLS input/output total direct and indirect relationships,
the difference between each case and the base case will add relatively
little demand (in most cases less than one half of one percent) to the
project supplying industries' output in any year. The total cost of each
case will create additional direct and indirect demands on the supplying
industries of 1.5 percent or less of projected output in any year (outside
of the aircraft industry). It appears that shop industries would experience
the greatest percentage increase in demand.
The modification and replacement programs will, at most, raise industry
output to its peak 1968 levels. Given the current slack in the aircraft
industry, it is not anticipated that inflationary pressures due to any
additional net investment will occur.
Additional employment will amount to at most 112,000 employee-years over
the period 1980-1986. This will be below 1968 peak year employment. It
is anticipated that there will not be an inflationary impact on labor
workers. Also, there should not be pressure on wages in particular
professional or labor occupation groups, given the slackness in the aircraft
industry over the past several years.
28
APPENDIX D: ANALYSIS OF THE COSTS AND BENEFITS OF THE REGULATION
TABLE OF CONTENTS
Page
I. INTRODUCTION
D 1
A. Background
D 1
B.
Analysis Approach
D 3
II. CONCLUSIONS
D 9
III. METHODOLOGY
D 12
A. Scope
D 12
B.
Airline Factors
D 13
IV. IMPACTS OF POLICY ADOPTION
D 15
A. Airlines
D 15
B.
Aerospace Industry
D 18
C.
Noise Benefits
D 22
D.
Fuel Usage
D 26
ATTACHMENTS
1. Environmental Benefits
D 28
2.
Airline Costs, Schedules and Economic
Impacts
D 28
D 1
I. INTRODUCTION
A. Background
This is an analysis of the benefits and costs of
enacting a regulation which requires all civil subsonic
turbojet-engine powered airplanes over over 75,000
pounds maximum weight to comply with the noise levels
in Federal Aviation Regulation Part 36 (FAR 36).
As of December 31, 1975, 77 percent of the U.S. fleet did
not comply with the noise limits of FAR 36. These airplanes
must be either retired, sold or modified to comply with the
noise limits of FAR 36. The B-747, B-727, B-737 and DC-9
airplanes which do not now comply are expected to be modified
except for those which are projected to be retired because
they have reached their economical age limit before their
compliance deadline. The pure jet B-720s, B-707s, CV-990s
and DC-8s are expected to be retired or sold before their
compliance deadlines. The other B-707s and DC-8s (turbofan
powered) may be retired, sold or modified.
D 2
If the turbofan powered DC-8s and B-707s are retired or sold
earlier than is currently projected, then a new generation of
quieter, more efficient airplanes will be introduced in large
quantities as replacements for these B-707s and DC-8s. The
only replacement airplanes available today are the B-727-200,
B-747, DC-10, L-1011 and A-400. With respect to future needs,
manufacturers are now considering two types of new "low noise"
airplanes for production. These include: new technology
aircraft such as the Boeing 7X7 and new technology/derivative
aircraft such as the Douglas DC-X-200 designed to meet the
generally stricter noise standards for NPRM 75-37. Upon
receipt of orders, it is estimated that these aircraft can
be produced within four years.
B.
Analysis Approach
Forecasts of future benefits and costs associated with
the Operating Noise Limits depend on projections of
future fleet composition. Table 1 contains a Base Case.
The Base Case contains projections of the future
composition of the fleet assuming no government action
to require the current fleet to comply with the noise
limits of FAR 36. These projections are the result of
an evaluation of the current intentions of the aerospace
industry and airline managements.
TABLE 1A
PROJECTED U.S. AIR CARRIER FLEET
(at end of indicated year)
BASE CASE
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
45
45
45
45
45
45
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
275
314
354
395
438
472
505
539
572
606
639
939
B-707, DC-8 & B-720
N
487
400
395
391
369
346
314
292
270
248
227
212
0
B-727
C
248
427
436
476
504
542
542
542
542
542
542
542
542
N
572
500
479
459
438
418
397
376
355
335
314
293
8
TOTAL
820
927
915
935
942
960
939
918
897
877
856
835
550
B-737 & DC-9
C
59
303
389
457
508
565
623
686
765
815
866
916
1376
N
480
463
456
448
441
433
426
421
415
410
404
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
o
0
0
0
58
112
165
196
228
259
574
*STATUS CODES: M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
N = Aircraft which do not comply with the noise levels of FAR Part 36.
CI
3
TABLE 1B
PROJECTED U.S. AIR CARRIER FLEET (continued)
(end of indicated year)
CASE 1: 100% MODIFY
Aircraft Type
Status*
1976
1980
1981
1982
1933
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
37
30
23
17
10
3
0
0
0
0
0
0
M
0
8
15
22
28
35
42
45
45
45
45
45
45
TOTAL
104
130
144
158
.172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
275
314
354
395
438
472
505
539
572
606
639
939
B-707, DC-8 & B-720
N
487
390
319
250
173
100
50
22
0
0
0
0
o
M
0
10
76
141
196
246
246
270
270
248
227
212
0
TOTAL
487
400
395
391
369
346
296
292
270
248
227
212
0
B-727
C
248
427
436
476
504
542
542
542
542
542
542
542
542
N
572
295
157
20
0
0
0
0
0
0
0
0
0
M
0
205
322
439
438
418
397
380
358
337
314
293
8
TOTAL
820
927
915
935
942
960
939
918
897
877
856
835
550
59
303
389
457
508
565
623
686
764
815
865
916
1376
B-737 & DC-9
C
N
480
291
154
7
0
0
0
0
0
0
0
0
0
M
0
172
302
441
441
433
426
421
416
410
405
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
0
0
0
0
58
112
165
196
228
259
574
*STATUS CODES:
M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
N = Aircraft which do not comply with the noise levels of FAR Part 36.
D
NOTE:
The above projected schedule indicates airplanes remaining in status category N beyond the 12-31-84 ultimate compliance date.
The difference, however, does not significantly impact the subsequent conclusions concerning the benefits, costs, or the
related analyses predicated on these projections.
TABLE 1C
PROJECTED U.S. AIR CARRIER FLEET (continued)
(end of indicated year)
CASE 2: RETROFIT/MODIFY JT-3D AND MODIFY JT-8D
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
37
25
14
10
6
3
0
O
0
0
0
0
M
0
8
20
31
35
39
42
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
264
302
341
369
397
421
454
488
521
555
588
888
B-707, DC-8 & B-720
N
498
444
360
270
160
60
30
10
0
0
0
0
0
M
0
10
34
64
84
100
100
100
100
100
100
100
0
TOTAL
498
454
394
334
244
160
130
110
100
100
100
100
0
B-727
C
248
380
386
423
395
334
334
334
334
334
334
334
334
N
572
295
157
20
0
0
0
0
0
0
0
0
0
M
0
205
322
439
438
418
397
380
358
337
314
293
8
TOTAL
820
880
865
872
833
752
731
714
692
671
648
627
342
B-737 & DC-9
C
59
303
389
457
508
565
623
686
764
815
865
916
1376
N
480
291
154
7
0
0
0
0
0
0
0
o
0
M
0
172
302
441
441
433
426
421
416
410
405
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
43
86
183
277
366
422
473
490
516
534
779
*STATUS CODES:
M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
D
N = Aircraft which do not comply with the noise levels of FAR Part 36.
5
NOTE:
The above projected schedule indicates airplanes remaining in status category N beyond the 12-31-84 ultimate compliance date.
The difference, however, does not significantly impact the subsequent conclusions concerning the benefits, costs, or the
related analyses predicated on these projections.
TABLE 1D
PROJECTED U.S. AIR CARRIER FLEET (continued)
(end of indicated year)
CASE 3: REPLACE JT-3D AND MODIFY JT-8D
Aircraft Type
Status*
1976
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
B-747
C
59
85
99
113
127
141
155
169
183
197
211
225
400
N
45
37
25
14
10
6
3
0
0
0
0
0
0
M
0
8
20
31
35
39
42
45
45
45
45
45
45
TOTAL
104
130
144
158
172
186
200
214
228
242
256
270
445
DC-10 & L-1011
C
217
264
302
341
369
397
421
454
488
521
555
588
888
B-707, DC-8 & B-720
N
497
454
394
334
244
154
98
10
0
O
o
o
o
B-727
C
248
381
387
424
396
335
334
334
334
334
334
334
334
N
572
295
157
20
0
0
0
0
0
O
0
0
0
M
0
205
322
439
438
418
397
380
358
337
314
293
8
TOTAL
820
881
866
873
834
753
731
714
692
671
648
627
342
B-737 & DC-9
C
59
303
389
457
508
565
623
686
764
815
865
916
1376
N
480
291
154
7
0
0
0
0
0
0
0
0
o
M
0
172
302
441
441
433
426
421
416
410
405
399
269
TOTAL
539
766
845
905
949
998
1049
1107
1180
1225
1270
1315
1645
New Technology
C
0
0
43
86
183
281
435
503
545
567
588
606
782
*STATUS CODES: M = Modified to comply with the noise levels of FAR Part 36 after December 31, 1976.
C = Other aircraft which comply with the noise levels of FAR Part 36.
N = Aircraft which do not comply with the noise levels of FAR Part 36.
NOTE: The above projected schedule indicates airplanes remaining in status category N beyond the 12-31-84 ultimate compliance date.
D
This difference, however, does not significant impact the subsequent conclusions concerning the benefits, costs, or the
related analyses predicated on these projections.
9
D7
Table 1 also displays three possible industry responses
to the Operating Noise Limits. In all three cases, the
two- and three-engine aircraft (powered by JT-8D engines)
together with the B-747s are projected to be modified to
achieve compliances, and the pure jet B-720s, B-707s and
DC-8 are projected to be retired or sold. These three cases
differ in the disposition of turbofan jet B-707s and DC-8s:
Case 1, 100% Modify, assumes they are all modified
to achieve compliance; Case 2, Modify/Replace JT-3D and
Modify JT-8D assumes that 100 of the B-707s and DC-8s
(powered by JT-3D engines) are modified and the remainder
are retired or sold; Case 3, Replace JT-3D and Modify JT-8D,
assumes that none of the JT-3D airplanes are modified.
These three cases span the range of possible industry
reaction to these Fleet Noise Limits.
The introduction of New Technology airplanes in Cases 2
and 3 occurs four years sooner than in the other two
cases. In Cases 2 and 3, it is assumed that the air
carriers decide to replace substantial numbers of
B-707s and DC-8s before 1985. The resulting demand
for new aircraft is anticipated to be adequate to assure
first deliveries of New Technology airplanes in 1981.
In the absence of this demand, these New Technology
D 8
airplanes are not expected to come into service until
1985. As a result, the numbers of New Technology airplanes
projected to be in the fleet in 1995 are much higher in
the two cases in which B-707s and DC-8s are replaced than
in the Base Case and the 100% Modify Case. The numbers
of B-727s from 1981 to 1995 are correspondingly decreased
in the two replacement cases.
It was assumed that passenger demand would be increasing
at an annual rate of six percent. The aircraft that
will be required to serve this increased demand are an
important factor in the fleet projections shown on
Table 1. If government noise reduction action results
in substantial early fleet replacement, it is likely
that the development date of New Technology aircraft
will be accelerated. In these cases, a benefit results
from being able to purchase advanced technology aircraft
at an earlier date as a means of meeting growth in demand.
II. CONCLUSIONS
The Operating Noise Limits will reduce the number of people
residing in areas of significant airplane noise annoyance
by at least 800,000 people in 1985. This number would increase
to over two million people if the airlines elect to replace
D 9
rather than modify their turbofan powered B-707 and DC-8
airplanes. The present value in 1975 of these benefits from
the public prespective is estimated to be $1.2 billion if the
industry rejects the replacement option and $3.7 billion if
the industry elects to replace all but 100 of their turbofan
powered B-707 and DC-8 airplanes.
The estimated costs of the regulation are only one-third as
large as the estimated benefits in the most pessimistic case
considered, Case 1: 100% Modify. In this case the 1975 present
value costs of the Operating Noise Limits are $440 million
from the public prespective (before taxes at a 10% discount
rate after accounting for inflation). However it has not been
possible to predict how the industry will choose to bring
their fleets into compliance. If they elect to replace
rather than modify their JT-3D fleets (Case 3) there will
be a $350 million benefit from the public perspective rather
than a $440 million cost.
The cost of compliance is shown to be less than 10% of the total
fleet costs of the airlines, and possibly less than 5% depending
on the replacement policies adopted by the airlines (using
after tax present value costs with a 15% discount rate).
However, the cost differences between the cases were too small
in this aggregate analysis to predict the replacement policies
of each of the airlines.
D 10
The net present value of incremental sales (relative to the
Base Case at 10% discount rate) to the aerospace industry
were found to be increases of approximately $1.5 billion and
$1.7 billion for Cases 2 and 3 respectively as opposed to a
sales increase of only $0.3 billion for Case 1, 100% Modify.
The increases in sales in Cases 2 and 3 result from the
accelerated purchases of New Technology airplanes. Incremental
direct employment in the aircraft manufacturing industry
resulting from the purchase and modification of airplanes to
comply with the Operating Noise Limits was estimated to be
4,000, 54,000 and 50,000 job years for Cases 1, 2 and 3
respectively between 1977 and 1986. In addition, a significant
amount of indirect employment would be created in industries
providing the inputs to the aerospace industry. This gain
in employment represents only a small percentage of projected
overall employment in the aerospace industry.
Replacement or combination modification/replacement would
provide savings of approximately 5 billion gallons or 3
billion gallons of fuel over a 20 year period. Complete
modification would result in additional fuel consumption of
approximately 0.3 billion gallons of fuel over the period.
These changes in fuel consumption are a small percentage of
the two to three hundred billions of commercial aviation
fuel consumption predicted for this 20 year period. In
addition to the effect on airline operations, some portion
D 11
of the savings associated with replacement can be throught
of as being invested directly into U.S. technology development
rather than lost in foreign exchange by the purchase of mid-
East oil. Additional savings also will result from a currently
unincorporated shadow price associated with regulatory
control and other distortions of free market oil prices.
Although not quantified, replacement can be expected to be
beneficial in terms of U.S. technological leadership, sales
in growth markets, and export sales. New technology is
introduced more quickly into the U.S. fleet and provides
more efficient and less costly air travel. New and derivative
designs can be expected to lead to additional exports.
III. METHODOLOGY
A. Scope
The emphasis of this analysis is on the benefits and
costs that a government-initiated, aircraft modification/
replacement program would have to the airline industry
relative to a normal attrition situation without acoustical
modification (baseline). Capital costs and operating
D 12
costs, in constant dollars, were compared to the baseline
case, for a range of cases. Net present values were
calculated both before and after taxes. This financial
analysis was performed since, aside from the environmental
(noise) benefits which the program is directed at achieving,
the airlines are the most directly impacted parties.
Secondarily, the Operating Noise Limits should lead
the aerospace manufacturing industry to accelerate
development of new technology aircraft, stimulus of
sales, and increased employment. The significance of
the program to the aerospace industry as a whole is
considered to be substantially less than it is to the
airline industry. Accordingly, the analysis simply
compared net sales values for each of the scenarios in
order to achieve better understanding of the impact to
the industry of the possible outcomes resulting from
adoption of the policy. Estimates of added employment
under policy enactment were made for the same purpose
and are discussed in Section IV-B. Finally, estimates
of noise benefits in terms of the effect upon residential
property values and annoyance were made in order to
establish levels of benefits over the range of cases
analyzed.
D 13
B.
Airline Factors
In performing the airline analyses, costs were divided
into capital costs and operating costs. Economic rather
than accounting, cost definitions were used. Capital
costs of aircraft purchase, sale, and modification were
included in the analysis with due regard to progress
payments, investment tax credits, depreciation tax
considerations, and taxes on recaptured depreciation.
The operating cost analysis, which was conducted both
before and after taxes only used out-of-pocket items
such as fuel and direct maintenance. The increased
maintenance costs of B-707/DC-8 aircraft as they approach
their terminal age and increases in fuel prices were
incorporated in these analyses.
The final calculations made no assumptions about the
availability of government financial assistance, assumed
that tax credits could be utilized, and assumed that all
new aircraft would be purchased rather than leased. By
looking only at costs, it was recognized that prediction
of fare/revenue changes associated with the different
cases is impossible.
Sensitivity Analysis
In order to investigate the stability of the conclusions,
several parameters were varied: fuel price, discount
rate, and purchase price of advanced technology aircraft.
D 14
Fuel price was assumed to increase at annual rates of
0%, 6%, and 12% in constant dollars. Inflation adjusted
discount rates ranged from 10% to 25% in 5% increments.
A rate of 10%, which is reflective of the U.S. economy
as a whole, is suggested in OMB Circular A-94. A rate
of 15% is a more appropriate value for the airline
industry. The analyses used purchase prices for advanced
technology aircraft of $20 million, $23 million, and
$26 million in 1975 dollars.
IV. IMPACT OF POLICY ADOPTION
A. Airlines
Since the introduction of DC-10/L-1011 aircraft, the newest
aircraft in U.S. use today, there have been substantial
developments in aircraft design technology. This technology
is capable of producing a new generation of highly produc-
tive and quiet jet transport aircraft. However, the
financial situation of the airline industry is such that
manufacturers are unable to obtain enough purchase
commitments to justify starting production. The
extension of FAR 36 noise limits is expected to accelerate
the orders for a new type of aircraft and, hence, the
implementation of this pending technology.
D 15
There are several examples of pending technology which
are likely to be implemented in new aircraft type designs.
First is the introduction of the high bypass turbofan
technology in the ten-ton engine size category. The high
bypass technology, now in use with the larger family of
aircraft using the twenty-ton engines, has already been
demonstrated to produce 12-15% reductions in fuel comsump-
tion and improved noise levels. Second, new but unused
technology in aerodynamic efficiency (such as the super-
critical wing) offers an opportunity for additional fuel
savings. Third, new "composite" materials technology
offers the promise of reduced airframe weights, lower
production costs, and ease of maintenance. The lower
weight has, of course, an impact on lowering the fuel
required. Thus, improvements in both aerodynamics and
materials are expected to contribute some 10-15% to fuel
reduction in New Technology aircraft.
The fourth significant new technology involves the use of
microelectronics -- another area in which American
technology leads the world. In this case, the savings
in weight is not as significant as the reduction in cost.
D 16
As modern aircraft become increasingly complex, that
fraction of production cost devoted to electronics has
steadily risen. With the new developments now being
demonstrated in various military applications, it is
clear that both capital and maintenance costs can be
reduced to improve return on investment.
Cash flow streams were determined by examining operating
costs and capital costs for vehicle acquisition and/or
modification for each of the scenarios relative to the
baseline. The comparative results are shown in Table 2.
The positive benefit associated with replacement is
the results of the increased efficiency of the New
Technology airplanes. Fuel savings are the dominant
aspect of this increase in efficiency. Maintenance and
crew costs savings are also expected.
In Case 1, 100% Modification, the negative net benefit
to the airlines relative to the baseline is the result
of an approximately 1% increase in out-of-pocket costs.
This increase in out-of-pocket costs is due primarily
to the approximately 15% fuel penalty from the additional
weight added to the aircraft in order to effect the noise
reductions.
D 17
TABLE 2
BEFORE TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
Case
Net Present Value at 10% Discount Rate
100% Modified
439
Modify/Replace JT-3D and Modify JT-8D
228
Replace JT-3D and Modify JT-8D
-352
AFTER TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
Case
Net Present Value at 15% Discount Rate
100% Modified
200
Modify/Replace JT-3D and Modify JT-8D
427
Replace JT-3D and Modify JT-8D
293
Note: All cases presume a purchase price of $23 million for new technology
aircraft and a 6% annual increase in fuel prices after inflation.
Positive net present values represent additional costs relative to the
base case and negative net present values represent benefits relative to
the base case.
D 18
A description of the costs and schedules used to develop the
figures in Table 2 is contained in Attachment 2. This
attachment also contains the results of alternative assumptions
about airplane costs, and discount rates.
B.
Aerospace Industry
This regulation will effect the aerospace industry in sales
and employment. These effects are examined in the following
sections.
1.
Net Present Value of Sales
In each of the cases analyzed, the domestic aircraft purchase
of U.S manufactured aircraft over a 20-year period would be
approximately $6 - 8 billion (in 1975 dollars). The replacement
options would primarily shift purchases of advanced technology
to earlier dates.
The cash flow to the manufacturers is basically equal to the
net cash flow from the airlines for capital expenditures.
They differ to the extent of B-707/DC-8 aircraft sales by
the airlines. This is because these aircraft would presummably
be sold on the open aircraft market and would probably not be
retained by the manufacturers. The following table shows for
D 19
each alternative relative to the baseline case the net present
value (at a 10% discount rate) of the cash flow streams to the
manufacturers based on the fleet mix and modification assumptions
detailed in Table 1 and Table B-1.
Net Present Value of
Case
Sales Increase ($ Millions) *
100% Modify
295
Modify/Replace JT-3D
and Modify JT-8D
1490
Replace JT-3D and Modify JT-8D
1700
The above table shows that under the alternative of 100%
1
modification the industry would be subject to a degraded
cash flow stream, compared to the two other alternatives.
This occurs primarily because replacement of the B-707/DC-8s
is delayed relative to the other cases. The two replacement
options would be beneficial to the manufacturers and would
have substantially positive net present values relative to
the baseline case.
Depending on the case, the modification/replacement programs
in 1981-1986 would add, at a maximum between 0.38% and 3.77%
per year (above the base case) to the forecasted output of the
aircraft industries (assuming the "slow recovery" scenario of
the Bureau of Labor Statistics projectios). The total cost
*Relative to the baseline case
D 20
of each case, at a maximum, would amount to between 5.8%
and 8.46% per year of the projected aircraft industry output.
Should the economy's recovery proceed faster than in the slow
BLS case, these percentages would drop.
The B-707/DC-8 replacement increment plus possible replacement
of JT-8D-powered aircraft with advanced technology aircraft
and foreign sales provides a boost to the industry by increasing
the net present value of their sales. This is important
because the timing would be such that sales would be generated
in a period for which prospects would otherwise be forecast as
poor.
2.
Effect on Employment
Using the Bureau of Labor Statistics' measures of projected
employment per billion dollars of delivery to final demand
by input/output sector, 1/ along with information supplied
by aircraft manufacturers on the labor requirement per unit
for selected aircraft, aggregate employment effects of each
of the three alternative scenarios, (measured as the deriva-
tion from the base case) were estimated. Employment estimates
were derived for the year of peak demand as well as for the
1/ As reported in U.S. Department of Commerce, Bureau of
Labor statistics, The Structure of the American Economy
in 1980 and 1985, Bulletin #1831, 1975.
D 21
entire ten-year period, 1977-1986, and are broken down by
jobs created within the aircraft producing industry (direct
employment) and employment generated elsewhere in the economy
(indirect employment). Nearly 113,000 new employee-years
would be created over the ten-year period 1977 to 1986 as a
result of combination replacement/modification program (Case 2)
with the peak year calling for 24,000 employees above baseline
in the aerospace industry and about 23,000 additional workers
throughout the remainder of the economy. Complete replacement
of the existing B-707/DC-8 fleet with the new technology
aircraft (Case 3) would yield similar results: 106,000 new
employee-years from 1977 through 1986 and a peak demand
representing direct employment of 23,600 and indirect employ-
ment of about 22,000. A program of modifications to the entire
B-707/DC-8 fleet (Case 1) would generate a peak demand of only
2,300 workers in each of the sectors while total employment
over the ten-year period would reach 19,000 employee-years.
C.
Noise Benefits
The noise benefits of the Operating Noise Limits have
been quantified in two ways:
Reduction in number of people exposed to a
given quantity of environmental noise.
Dollar value equivalent of the noise reduction.
D 22
A computer model called the Systems Analysis Model -
Phase I was used to calculate the environmental noise
impact for each case in each of the years: 1980, 1985,
and 1995. The effectiveness of the Operating Noise
Limits for each of three alternative industry responses
relative to the base case are shown in Figures 1 and 2.
Figures 1 and 2 show a substantially better environment
in the cases in which JT-3D aircraft are replaced rather
than modified. This difference is due to a larger number
of New Technology airplanes and a smaller number of B-727s
in the fleet from 1980 to 1995.
In calculating the dollar value equivalent of the noise
reduction, the key parameter was the value placed on the
annoyance, inconvenience, discomfort, mental distress
and emotional distress suffered by the airports' neighbors.
The value selected is $400 per year per person for those
people residing at exposure levels expected to cause
significant annoyance, NEF 30 or higher. This value is
the judgment in a recent court award.
The dollar value equivalent benefits listed below include
both the $400 per person per year value of annoyance
D 23
mentioned above and a value placed on the transient
property value increases which will result from transient
reductions in the environmental noise. The methodology
explained in Attachment 1 led to the following dollar
equivalent benefits of the Operating Noise Limits in
1975 present value dollars:
Case 1: 100% Modify
$1.2 billion
Case 2: Modify/Replace JT-3D and
Modify JT-8D
$3.7 billion
Case 3: Replace JT-3D and
Modify JT-8D
$3.6 billion
D. Fuel Usage
Advanced technology airplanes are estimated to be nearly
30% more fuel efficient than the B-707 and DC-8 airplanes
on a seat mile per gallon basis. The savings and/or
losses in fuel accumulated between 1977 and 1995 for
each alternative are shown in Table 3. The costs or benefits
of these fuel consumption differentials have been incorporated
in the economic analysis in Section IV-A.
110
Base Case
100% Modify
100
90
80
Impacted Population as a % of 1976 Baseline (6 million people)
Replace JT3D, Modify JT8D
70
60
Modify/Replace JT3D, Modify JT8D
50
40
30
20
10
0
1976
1980
1985
1990
1995
Year
D 24
RELATIVE EFFECTIVENESS IMPACTED POPULATION
(NEF 30)
D 25
ATTACHMENT 1
ENVIRONMENTAL BENEFITS
Present Value of Total Benefits
The estimated present values of the reductions in noise in
1975 dollars from the base case for each alternative are:
100% Modify
$1.2 billion
Modify/Replace JT-3D and
Modify JT-3D
$3.7 billion
Replace JT-3D and Modify JT-3D
$3.6 billion
The present value of the total benefits is calculated using
a 10% discount rate and assumes that all benefits vanish in
the year 2000. Note that the combination modify/replace
policy appears higher in benefits than either of the other
scenarios. This is due to the fact that in relation to the
other cases the fleet is quieter in the early program years.
Even though the replace JT-3D case leads to a quieter fleet
over the long run, the effect of determining net present
value over a twenty-year period is that early benefits have
greater apparent weight.
The estimated present value of the reductions in noise is
the sum of two separate benefits:
D 26
The aircraft noise around airports depresses
property values. Lowering the noise levels will
increase the value of these properties. The
predicted increase in revenue generated by these
increased property values is used as the property
value measure for commercial properties. The
property value measure for owner-occupied residential
properties is taken to be the predicted increase
in revenue generating potential of these properties.
In addition to the increases in property values, a
value is placed on the annoyance, inconvenience,
discomfort, mental distress and emotional distress
suffered by the airports' neighbors. The reduction
in noise levels will reduce the number of people
impacted. This value of the noise reduction in
any year is taken to be the number of people
removed from the area of significant noise impact
times a per person dollar evaluation of the impact.
D 27
The values of I and R were diffcult to estimate. The value
of I was selected by reviewing the literature on the effect
of aircraft noise on property values. This literature is
summarized in Table Al. Since the majority of the population
reduction is at the big city airports, value of I selected
reflects the property value sensitivity to noise at big city
airports.
The value of R, the rate of return on real estate investments
was selected by interviewing experts in the field. A value
of 12% per year for apartment houses was judged a reliable
estimate. The rate of return on investments in single
family residents was less easily estimated. Experts agreed
on a range of 0% to 10% in cost flow from lease or rental.
However, they pointed out that property appreciation and tax
shelter were the primary reasons for this type of investment.
Estimates of the historical return due to appreciation
during the past 10 years were on the order of 15% per year
or higher. However, the experts' predictions for the future
were considerably lower. A value of 7% per year was selected
as a conservative value. The 8% per year value used is a
weighted average of the value for apartments and the value
for single family residences. The weighting factors were
determined using 1970 census data given below.
D 28
Present Values of the Property Value Increases
In economic terms, the present values of the property value
increases are:
100% Modify
$ 31 million
Modify/Replace JT-3D and
Modify JT-8D
$299 million
Replace JT-3D and Modify JT-8D
$292 million
These values were computed using a formula which assumes no
benefit before 1979 or after 1999 and that property values
vary linearly over five-year intervals. The formula is:
20
Σ
-k-4
R * I * P (k) * V* N (k) * 1.1
k=0
where:
k = an index indicating the year: year = 1979 + k, e.g.,
= 0 if 1979
= 6 if 1985
= 11 if 1990
= 20 if 1999
P (k) = Reduction in the population residing within the
NEF 30 contour in year k.
N (k) = Average decibel reduction in the NEF level.
V
= per capita 1975 value of residential properties = $8,676.
I
= the fractional increase in property value resulting
from each unit reduction in NEF = .02.
R
= Rate of return on investments in residential
properties per year = .08.
D 29
The per capita property value was primarily determined using
1970 census housing for SMSA's not in central cities. The
rental unit value inflator was derived from the Consumer Price
Index Series. The property value inflator for single
family residences was derived from the National Association
of Realtors, Existing Home Sales Series. The equation used
to determine the per capita property value is:
5
5
MH * NH * (1+rl)
+
MR * NR * (1+r2)
V = PH * (NH+NR)
PR * (NH + NR)
where:
MH = Median Housing Value
= $20,700
PH = People Per Unit
=
3.3
NH = Number of Single Family Residences
=
13.6M
rl = Single Family Residence Property Value
Inflator
=
9.8%
MR = Median Rental Unit Value
(100 X Median Rent)
= $11,300
PR = People Per Rental Unit
=
2.4
NR = Number of Rental Units
II
6.4M
r2 = Rental Unit Value Inflator
=
4.4%
V = Per Capita Property Value (1975 Dollars)
TABLE Al
SUMMARY OF AIRCRAFT NOISE ECONOMIC STUDIES
PERCENT CHANGE IN PROPERTY VALUE PER UNIT NEF CHANGE (AVERAGE)
STUDY
CITY/AIRPORT
NELSON 9/ 12/
OTHERS
McClure 1)
Los Angeles, Cal.
1.5
Colman 2)
Inglewood, Cal. (LAX)
1.5
Paik 3)
N.Y., Los Angeles, Dallas
2.1 -2.6
1.5
Emerson 4)
Minneapolis
0.4
1.2
Dygert & Sanders 5)
San Francisco
1.2 - 1.5
Dygert 6)
San Francisco
0.5
Roskill-Heathrow 7)
Heathrow Environs
2.2
-Gatwick
Gatwick Environs
2.7
Price 8)
Boston
0.4
Nelson 9)
Washington, D.C.
0.5 = 1.0
DeVany 10)
Dallas
.2 - - 2.1
Mieszkowski and Saper 11)
Etobicoke
Mississauga (Toronto)
.8 - 1.8
D 30
D 31
TABLE A1 (continued)
1) McClure, P.T., Some Projected Effects of Jet Noise on Residential
Property Near Los Angeles International Airport by 1970, Santa
Monica, California: Rand Corporation, April 1969
2) Colman, A.H., Aircraft Noise Effects on Property Value, Environmental
Standards Circular, City of Inglewood, California, February 1972
3) Paik, I.K., Measurement of Environmental Externality in Particular
Reference to Noise, Ph.D. Dissertation, Georgetown University, 1972
4)
Emerson, F.C., The Determinants of Residential Value With Special
Reference to the Effects of Aircraft Nuisance and Other Environmental
Features, Ph.D. Dissertation, University of Minnesota, 1969
5) Dygert, P.K., Sanders, D., On Measuring the Cost of Noise From
Subsonic Aircraft, Institute of Transportation and Traffic
Engineering, Monograph (Berkeley, 1972)
6) Dygert, P.K., Estimation of Cost of Aircraft Noise to Residential
Activities, Ph.D. Dissertation, University of Michigan, 1973
7) Roskill Commission, Report of the Commission on the Third London
Airport, (HMSO, 1971)
8) Price, I., The Social Cost of Airport Noise as Measured by Rental
Changes: The Case of Logan Airport, Ph.D. Dissertation, Boston
University, 1974
9) Nelson, Jon, The Effects of Mobile-Source Air and Noise Pollution
on Residential Property Values, Report NO. DOT-TST-75-76, April
1975, Department of Transportation, Washington, D.C.
10) DeVany A., unpublished manuscript
11) Mieszkowski, P., Saper, A., An Estimate of the Effects of Noise
on Property Values, unpublished report
12) Nelson, Jon, Aircraft Noise, Residential Property Values and Public
Policy, January 1976, Draft Monograph
D 32
The reductions in population within the NEF 30 contour and
the average decibel reduction within this contour were
determined for 1980, 1985, 1990 and 1995 using the NEF
System Model - Phase I. These values are shown on Tables A2
and A3. Table A4 shows the increases in revenue predicted
to result from the decrease in noise.
The calculation assumes a 2% increase in residential property
values per unit decrease in the NEF level, and an 8% year
rate of return on residential property investments. Note
that owners of owner occupied residences are assumed to be
receiving revenue from themselves as if they were vesting to
themselves.
The values for years other than those at which the model was
exercised were determined by linear interpolation assuming a
zero benefit in the year 1978 and 2000.
D 33
TABLE A2
NEF 30 Population Reduction (in thousands)
1980
1985
1990
1995
100% Modify
210
810
700
140
Modify/Replace JT-3D
and Modify JT-8D
100
2030
2120
2240
Replace JT-3D and
Modify JT-8D
90
1930
2150
2240
TABLE A3
Reduction in NEF Value
1980
1985
1990
1995
100% Modify
.2
.9
.8
.1
Modify/Replace JT-3D
and Modify JT-8D
.1
2.6
2.6
2.6
Replace JT-3D and
Modify JT-8D
.1
2.5
2.7
2.6
D 34
TABLE A4
Value of Property Value Increases
(1975 dollars in Millions)
Case 2 -
Case 3 -
Case 1 -
Modify/Replace JT-3D
Replace JT-3D
Year
100% Modify
and Modify JT-8D
and Modify JT-8D
1979
.3
.1
.1
1980
.6
.1
.1
1981
2.5
14.8
13.5
1982
4.4
29.4
26.9
1983
6.3
44.1
40.3
1984
8.2
58.7
53.7
1985
10.1
73.4
67.1
1986
9.6
74.0
69.8
1987
9.2
74.7
72.5
1988
8.7
75.3
75.2
1989
8.3
76.0
78.0
1990
7.8
76.6
80.7
1991
6.3
77.5
80.8
1992
4.8
78.4
80.8
1993
3.2
79.2
80.9
1994
1.7
80.1
80.9
1995
.2
81.0
81.0
1996
.2
64.8
64.8
1997
.1
48.6
48.6
1998
.1
32.4
32.4
1999
.0
16.2
16.2
TOTAL
92.6
1155.4
1144.3
Present value
in 1975 at
10% discount
rate
30.7
299.0
292.1
D 35
Present Value of Annoyance Mitigation
In addition to the increases in property values, the annoyance,
inconvenience, discomfort, mental distress, and emotional
distress suffered by the airports' neighbors must be considered.
In a significant decision (Greater Westchester Homeowners'
Association et al V. City of Los Angeles, et al.) one judge
valued these personal injuries at some $400 per person per
year for all residents within the CNR 100 contour. (The
CNR 100 contour is approximately the same as the NEF 30 contour.)
The judge in this case explicitly ruled that these personal
injuries are in addition to the property value losses suffered
by the airports' neighbors.
Using this judge's estimate together with our estimates of the
number of people removed from the NEF 30 contour, the present
values of the reductions in annoyance, inconveniences,
discomfort, mental and emotional distress can be calculated:
100% Modify
$1.2 billion
Replace/Modify JT-3D and
Modify JT-8D
$3.4 billion
Replace JT-3D and Modify JT-8D
$3.3 billion
R.
FORD
GERALD
D 36
The values were determined using the formula:
20
-k-4
Σ
$400/person*P (k) * 1.1
k=0
which is analogous to the formula described in the previous
section.
The value of $400/person as a measure of annoyance was determined
by examining a frequency distribution of the sizes of the judge's
awards. This distribution is shown in Figure Al. A case-by-case
analysis of the amounts of the awards suggests that the judge
varied the size of the award based on individual reactions to
the noise, not on the level of the noise at their residence.
Table A5 shows the values of annoyance mitigation for each
year. For 1980, 1985, 1990 and 1995 the values shown were
computed using the population reductions in the NEF 30 contour
given in Table A2 multiplied by $400/person. For the remaining
years the values were interpolated assuming zero benefits in
1978 and 2000.
D 37
Figure A1
FREQUENCY DISTRIBUTION OF PERSONAL DAMAGE AWARDS
IN GREATER WESTCHESTER HOMEOWNERS' ASSOCIATION ET AL.
V.
CITY OF LOS ANGELES ET AL.
30
20
NUMBER OF PEOPLE
10
$100
200
300
400
500
600
700
1000
AMOUNT OF AWARD PER PERSON PER YEAR IN 1975 DOLLARS
D 38
TABLE A5
Value of Annoyance Mitigation
(1975 dollars in Millions)
Case 2 -
Case 3 -
Case 1 -
Modify/Replace JT-3D
Replace JT-3D
Year
100% Modify
and Modify JT-8D
and Modify JT-8D
1979
42
20
18
1980
84
40
36
1981
132
194
183
1982
180
349
330
1983
228
503
478
1984
276
658
625
1985
324
812
772
1986
315
819
790
1987
306
826
807
1988
298
834
825
1989
289
841
842
1990
280
848
860
1991
235
858
867
1992
190
867
874
1993
146
877
882
1994
101
886
889
1995
56
896
896
1996
45
717
717
1997
34
538
538
1998
22
358
358
1999
11
179
179
TOTAL
3594
12920
12766
Present value
in 1975 at
10% discount
rate
1187
3385
3313
D 39
TABLE B-1
PRICE ASSUMPTIONS FOR CAPITAL ANALYSIS*
a) PRICE OF NEW AIRCRAFT
$20 Million
New Technology
$23 Million
$26 Million
727
$10 Million
DC-10
$27 Million
b) PRICE FOR MODIFICATION (KIT PLUS AIRLINE COSTS)
B-707/DC-8
$1.2 MILLION/VEHICLE - IF 270 AIRCRAFT MODIFIED
B-707/DC-8
$2.6 MILLION/VEHICLE - IF 100 AIRCRAFT MODIFIED
B-727
$0.225 MILLION/VEHICLE
B-737/DC-9
$0.270 MILLION/VEHICLE
B-747
$0.250 MILLION/VEHICLE
c) AVERAGE SALE PRICE OF NON-MODIFIED B-707/DC-8**
1975-1980
1981-1985
1986-1995
NOISE RULE
$2.5 MILLION
$2.0 MILLION
$1.5 MILLION
NO NOISE RULE
$3.0 MILLION
$2.5 MILLION
$2.0 MILLION
*All prices in 1975 dollars.
**Add $.5 million if modified.
D 40
TABLE B-2
BASELINE OPERATING COSTS DATA (OUT-OF-POCKET ITEMS ONLY)
AIRCRAFT
COST PER
NUMBER
ANNUAL COST
TYPE
AIRCRAFT-YEAR
OF SEATS
PER SEAT
(000)
PER AIRCRAFT
(000)
B-707/DC-8
3,800
145
26.2
B-707/DC-8
3,850
145
26.6
w/ ACOUSTIC MODIFICATION
DC-10
5,120
250
20.5
B-727
2,780
125
22.2
New Technology
3,690
200
18.4
D 41
TABLE B-3
NUMBER OF JT-8D AND JT-9D AIRCRAFT
TO BE MODIFIED BY YEAR
YEAR
B-727
B-737/DC-9
B-747
1979
92
86
0
1980
113
86
8
1981
117
130
12
1982
117
139
11
1983
4
2
4
1984
4
2
4
1985
4
2
3
1986
3
1
3
D 42
TABLE B-4
BEFORE TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS
RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
($20 million per New Technology aircraft)
Discount
Capital
Operating
Total
Case
Rate
Costs
Costs
Costs
100% Modified
10%
362
77
439
15%
274
46
320
Modify/Replace JT-3D and
10%
1117
-1284
-167
Modify JT-8D
15%
880
-714
-166
Replace JT-3D and Modify JT-8D
10%
1235
-2030
-794
15%
988
-1182
-194
AFTER TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS
RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
Discount
Capital
Operating
Total
Case
Rate
Costs
Costs
Costs
100% Modified
10%
227
40
267
15%
176
24
200
Modify/Replace JT-3D and
10%
660
-667
-8
Modify JT-8D
15%
594
-372
222
Replace JT-3D and Modify JT-8D
10%
715
-1055
-340
15%
677
-615
63
Note:
All cases presume a purchase price of $20 million for
New Technology aircraft and a 6% annual increase in fuel
prices after inflation. Positive net present values
represent additional costs relative to the base case and
negative net presents values represent benefits relative
to the base case.
D 43
TABLE B-5
BEFORE TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS
RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
($23 million per New Technology aircraft)
Discount
Capital
Operating
Total
Case
Rate
Costs
Costs
Costs
100% Modified
10%
362
77
439
15%
274
46
320
Modify/Replace JT-3D and
10%
1512
-1284
228
Modify JT-8D
15%
1184
-714
469
Replace JT-3D and Modify JT-8D
10%
1678
-2030
-352
15%
1331
-1182
149
AFTER TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS
RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
Discount
Capital
Operating
Total
Case
Rate
Costs
Costs
Costs
100% Modified
10%
227
40
267
15%
176
24
200
Modify/Replace JT-3D and
10%
899
-667
231
Modify JT-8D
15%
799
-372
427
Replace JT-3D and Modify JT-8D
10%
978
-1055
-78
15%
907
-615
293
Note:
All cases presume a purchase price of $23 million for
New Technology aircraft and a 6% annual increase in fuel
prices after inflation. Positive net present values
represent additional costs relative to the base case and
negative net presents values represent benefits relative
to the base case.
D 44
TABLE B-6
BEFORE TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS
RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
($26 million per New Technology aircraft)
Discount
Capital
Operating
Total
Case
Rate
Costs
Costs
Costs
100% Modified
10%
362
77
439
15%
274
46
320
Modify/Replace JT-3D and
10%
1907
-1284
623
Modify JT-8D
15%
1487
-714
773
Replace JT-3D and Modify JT-8D
10%
2120
-2030
91
15%
1674
-1182
492
AFTER TAX NET PRESENT VALUE OF INCREMENTAL CASH FLOWS
RELATIVE TO THE BASE CASE
1975-1995
(Millions of 1975 Dollars)
Discount
Capital
Operating
Total
Case
Rate
Costs
Costs
Costs
100% Modified
10%
227
40
267
15%
176
24
200
Modify/Replace JT-3D and
10%
1137
-667
470
Modify JT-8D
15%
1004
-372
632
Replace JT-3D and Modify JT-8D
10%
1240
-1055
184
15%
1137
-615
523
Note:
All cases presume a purchase price of $26 million for
New Technology aircraft and a 6% annual increase in fuel
prices after inflation. Positive net present values
represent additional costs relative to the base case and
negative net presents values represent benefits relative
to the base case.
APPENDIX E: SINGLE EVENT NOISE REDUCTIONS FOR
AIR CARRIER JET AIRCRAFT
APPENDIX E
SINGLE EVENT NOISE REDUCTIONS FOR AIR CARRIER JET AIRCRAFT
This appendix provides graphic information concerning noise of jet aircraft
in both modified and unmodified configurations. These materials were
developed by the FAA as part of its analytical studies of the effects of
various technological alternatives to reducing aircraft source noise.
The computations for the graphs were determined through the use of air-
craft noise computer models developed by the FAA. The aircraft noise and
performance information used as source data in the models was obtained
from FAA reports prepared through contracts with aircraft manufacturers
(See Appendix E References). Individual aircraft benefits are shown
through the use of three methodologies, as follows:
a. Aircraft noise under the flight path. These graphs demonstrate changes
to the noise environment expected to be perceived by observers located
directly under the approach or departure flight tracks. It can be seen
that a quieter environment is expected for all aircraft types through
modification.
b.
Contours of equal exposure to 85dBA. These graphs depict expected
changes in land areas and shape within the 85dBA contours. Modification
results in area reductions in all cases.
C.
Contours of equal changes in exposure due to engine modification
("Delta dB Contours"). These curves show the locus of points of
equal noise change as a result of modification from a baseline
configuration. These contours outline the noise improved areas
by shape and size.
REFERENCES FOR APPENDIX E
1.
B.G. Williams and R. Yates, "Aircraft Noise Definition - Individual
Aircraft Technical Data - Model 707/727/737/747," The Boeing
Company, Federal Aviation Administration, Report FAA-EQ-7,, II/III/
IV/V, December 1973.
2. J. S. Goodman, et.al., "Aircraft Noise Definition - Analysis of
Existing Data for the DC-8, DC-9 and DC-10 Aircraft," Douglas Aircraft
Company, Federal Aviation Administration, Report No. FAA-EQ-73-5,
August 1973.
APPROACH 3° GLIDESLOPE
120
737-200 JT8D-7 ENGINES
116
98,000 LB. MLW
40° FLAPS
112
SEA LEVEL, 77°F, 70% R.H.
UNTREATED NACELLE
108
QUIET NACELLE
EPNL (EPNdB)
104
100
96
92
88
84
80
0
10
20
30
40
50
60
DISTANCE FROM TOUCHDOWN
(X 1000 FEET)
1/31/75
TC EQ-110
ATA TAKEOFF PROCEDURE
116
114
112
737-200 JT8D-7 ENGINES
110
100,000 LB. BRGW
1° FLAPS
SEA LEVEL, 77°F, 70% R.H.
108
UNTREATED NACELLES
EPNL (EPNdB)
QUIET NACELLES
106
104
102
100
98
96
94
5
10
20
30
40
DISTANCE FROM BRAKE RELEASE
(X 1000 FEET)
1/31/75
TC EQ-110
APPROACH 3° GLIDESLOPE
120
116
727-200 JT8D-9 ENGINES
142,500 LB. MLW
112
40° FLAPS
SEA LEVEL, 77°F, 70% R.H.
108
UNTREATED NACELLE
QUIET NACELLE
104
EPNL (EPNdB)
100
96
92
88
84
80
0
10
20
30
40
50
60
DISTANCE FROM TOUCHDOWN
(X 1000 FEET)
1/31/75
TC EQ-110
ATA TAKEOFF PROCEDURE
116
114
727-200 JT8D-9 ENGINES
155,000 LB. BRGW
15° T.O. FLAPS
112
SEA LEVEL, 77°F, 70% R.H.
110
UNTREATED NACELLE
QUIET NACELLE
108
EPNL (EPNdB)
106
104
102
100
98
96
94
5
10
20
30
40
DISTANCE FROM BRAKE RELEASE
(X 1000 FEET)
1/31/75
TC EQ-110
APPROACH 3° GLIDESLOPE
120
707-300 B/C JT3D-3B ENGINES
116
247,000 LB. MLW
50° FLAPS
112
SEA LEVEL, 77°F, 70% R.H.
UNTREATED NACELLE
108
QUIET NACELLE
104
EPNL (EPNdB)
100
96
92
88
84
80
0
10
20
30
40
50
60
DISTANCE FROM TOUCHDOWN
(X 1000 FEET)
1/31/75
TC EQ-110
ATA TAKEOFF PROCEDURE
116
114
707-300 B/C JT3D-3B ENGINES
299,000 LB. BRGW
112
14° T.O. FLAPS
SEALEVEL, 77°F, 70% R.H.
110
UNTREATED NACELLE
QUIET NACELLE
108
EPNL (EPNdB)
106
104
102
100
98
96
94
5
10
20
30
40
50
DISTANCE FROM BRAKE RELEASE
(X 1000 FEET)
1/31/75
TC EQ-110
APPROACH 3° GLIDESLOPE
120
SEA LEVEL, 77°F, 70% R.H.
116
747-100 B/D JT9D-3W ENGINES
112
564,000 LB. MLW
30° FLAPS
108
747-200 FL JT9D-7W ENGINES
564,000 LB. MLW
30° FLAPS
104
EPNL (EPNdB)
100
96
92
88
84
80
0
10
20
30
40
50
60
DISTANCE FROM TOUCHDOWN
(X 1000 FEET)
1/31/75
TC EQ-110
ATA TAKEOFF PROCEDURE
116
SEA LEVEL, 77°F, 70% R.H.
114
747-100 B/D JT9D-3W ENGINES
662,000 LB. BRGW
112
10° FLAPS
747-200 FL JT9D-7W ENGINES
110
697,500 LB. BRGW
10° FLAPS
108
EPNL (EPNdB)
106
104
102
100
98
96
94
5
10
20
30
40
50
DISTANCE FROM BRAKE RELEASE
(X 1000 FEET)
1/31/75
TC EQ-110
B707 - 300B — LANDING
247,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
10
85 dB(A)
CONTOUR WIDTH ( X 1000 FEET)
5
BASELINE
2287 (3.6 SQ. M.)
0
5
QUIET NACELLE
10
459 ACRES (.7 SQ. M.)
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN ( X 1000 FEET)
TC/EQ-110 2/25/75
B707 - 300B — TAKEOFF
270,000 LBS. (80% MAXIMUM TAKEOFF WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
ATA PROCEDURE
10
85 dB(A)
BASELINE
CONTOUR WIDTH (X 1000 FEET)
2251 (3.5 SQ. M.)
5
0
5
QUIET NACELLE
2103 ACRES (3.3 SQ. M.)
10
0
5
10
15
20
25
30
35
40
45
GERALD FORD ?
DISTANCE FROM BRAKE RELEASE (X 1000 FEET)
TC/EQ-110 2/25/75
B707 - 120B - LANDING
190,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
10
85 dB(A)
BASELINE
CONTOUR WIDTH ( X 1000 FEET)
1873 ACRES (2.9 SQ. M.)
5
0
5
QUIET NACELLE
257 ACRES (.4 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
DC-8 -50/61 — LANDING
207,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
10
85 dB(A)
BASELINE
CONTOUR WIDTH ( X 1000 FEET)
5
2403 ACRES (3.8 SQ. M.)
0
5
QUIET NACELLE
393 ACRES (.6 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
DC-8-62/63 - LANDING
258,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
85 dB(A)
10
BASELINE
CONTOUR WIDTH ( X 1000 FEET)
1763 ACRES (2.8 SQ. M.)
5
0
5
QUIET NACELLE
240 ACRES (.4 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
TC/EQ-110 2/25/75
B727 - 100 JT8D-1/7 - LANDING
142,500 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
85 dB(A)
10
BASELINE
CONTOUR WIDTH ( X 1000 FEET)
673 ACRES (1.1 SQ. M.)
5
0
5
QUIET NACELLE
370 ACRES (.6 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN ( X 1000 FEET)
B727-200 JT8D-9 - LANDING
154,500 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
85 dB(A)
10
BASELINE
CONTOUR WIDTH ( X 1000 FEET)
5
786 ACRES (1.2 SQ. M.)
0
5
QUIET NACELLE
431 ACRES (.7 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
TC/EQ-110 2/25/75
B727-200 JT8D-9 - TAKEOFF
150,000 LBS. (80% MAXIMUM TAKEOFF WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
ATA PROCEDURE
85 dB(A)
10
BASELINE
3569 ACRES (5.6 SQ. M.)
CONTOUR WIDTH (X 1000 FEET)
5
0
5
QUIET NACELLE
3111 ACRES (4.9 SQ. M.)
10
0
5
10
15
20
25
30
35
40
45
DISTANCE FROM BRAKE RELEASE (X 1000 FEET)
TC/EQ-110 2/25/75
DC-9-10 — TAKEOFF
70,000 LBS. (80% MAXIMUM TAKEOFF WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
ATA PROCEDURE
85 dB(A)
10
BASELINE
CONTOUR WIDTH (X 1000 FEET)
5
1593 ACRES (2.5 SQ. M.)
0
5
QUIET NACELLE
1543 ACRES (2.4 SQ. M.)
10
0
5
10
15
20
25
30
35
40
45
DISTANCE FROM BRAKE RELEASE (X 1000 FEET)
TC/EQ-110 2/27/75
DC-9 - 30 — LANDING
99,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
10
85 dB(A)
CONTOUR WIDTH ( X 1000 FEET)
BASELINE
5
767 ACRES (1.2 SQ. M.)
0
5
QUIET NACELLE
430 ACRES (.7 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
TC/EQ-110 2/27/75
DC-9-30 - TAKEOFF
90,000 LBS. (80% MAXIMUM TAKEOFF WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
ATA PROCEDURE
10
85 dB(A)
BASELINE
CONTOUR WIDTH (X 1000 FEET)
2110 ACRES (3.3 SQ. M.)
5
0
5
QUIET NACELLE
2022 ACRES (3.2 SQ. M.)
10
0
5
10
15
20
25
30
35
40
45
DISTANCE FROM BRAKE RELEASE ( X 1000 FEET)
TC/EQ-110 2/27/75
B737-200 JT8D-1/7 LANDING
98,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
85 dB(A)
10
CONTOUR WIDTH ( X 1000 FEET)
BASELINE
5
540 ACRES (.8 SQ. M.)
0
QUIET NACELLE
5
307 ACRES (.5 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
TC/EQ-110 2/27/75
B747 JT9D-7W - LANDING
564,000 LBS. (MAXIMUM LANDING WEIGHT)
SEA LEVEL; 77° F, 70% R.H.
3° GLIDESLOPE
10
85 dB(A)
- 100D
CONTOUR WIDTH ( X 1000 FEET)
749 ACRES (1.2 SQ. M.)
5
0
5
- 200 B
576 ACRES (.9 SQ. M.)
10
0
5
10
15
20
15
30
35
40
45
DISTANCE FROM TOUCHDOWN (X 1000 FEET)
TC/EQ-110 2/26/75
DELTA DB CONTOURS (EPNdb)
BASELINE-QUIET NACELLE
3° APPROACH (1500' INITIAL)
727-200 JT8D -9 40° FLAPS 154,500 LBS MLW
(15° FLAPS GEAR UP DURING LEVEL FLIGHT SEGMENT)
10
2
2
8
6
3
4
CONTOUR WIDTH (X 1000 FEET)
2
3
4
4
O
4
2
3
4
3
6
8
2
10
2
0
2
4
6
8
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
DISTANCE FROM TOUCH DOWN (X 1000 FEET)
DELTA DB CONTOURS (EPNdB)
BASELINE-QUIET NACELLE
3° APPROACH (1500' INITIAL)
707-300 JT3D-3B 50° FLAPS 247,000 LBS. MLW
(25° FLAPS GEAR UP DURING LEVEL FLIGHT SEGMENT)
10
8
6
6
6
4
8
8
CONTOUR WIDTH (X 1000 FEET)
10
2
10
12
12
0
12
12
2
10
10
8
4
8
6
6
8
6
10
0
2
4
6
8
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
DISTANCE FROM TOUCH DOWN (X 1000 FEET)
APPENDIX F: IMPACT OF NOISE ON PEOPLE
1
APPENDIX F
IMPACT OF NOISE ON PEOPLE
How people perceive loudness or noisiness of any given sound
depends on several measurable physical characteristics of
the sound. These factors are:
a.
Intensity - a ten decibel increase in intensity is
considered a doubling of the perceived loudness or
noisiness of a sound;
b.
Frequency content - sounds with concentration of
energy between 2,000 Hertz and 8,000 Hertz are
perceived to be more noisy than sounds of equal
sound pressure level outside this range;
C.
Duration - the perceived loudness of a sound will
increase with its duration. An increase in duration
by a factor of 10 results in a change that is
roughly equivalent to 10 decibels or an increase
in noisiness by a factor of two;
d.
Changes in sound pressure level - sounds that are
increasing in level are judged to be somewhat
louder than those decreasing in level;
2
e.
Rate of increase of sound pressure level - impulsive
sounds, ones reaching a high peak very abruptly,
are usually perceived to be very noisy.
The task of quantifying the environmental impact of noise
associated with any noise source requires the application of
statistics and averages. This approach is necessary because
individual human response to noise is subject to considerable
natural variance. Over the past 25 years researchers have
identified many of the factors which contribute to the
variation in individual human reaction to noise.
Knowledge of the existence of these individual variables
helps to understand why it is not possible to state simply
that a given noise level from a given noise source will
elicit a particular community reaction or have a particular
environmental impact. Research in psychoacoustics has
revealed than an individual's attitudes, beliefs and values
may greatly influence the degree to which a person considers
a given sound annoying. The aggregate emotional response of
an individual has been found to depend on:
a.
Feelings about the necessity or preventability of
the noise. If people feel that their needs and
concerns are being ignored, they are more likely
3
to feel hostility towards the noise. This feeling
of being alienated or of being ignored and abused
is the root of many human annoyance reactions. If
people feel that those creating the noise care
about their welfare and are doing what they can to
mitigate the noise, they are usually more tolerant
of the noise and are willing and able to accommodate
higher noise levels.
b.
Judgment of the importance and of the value of the
primary function of the activity which is producing
the noise.
C.
Activity at the time an individual hears a noise
and the disturbance experienced as a result of the
noise intrusion. An individual's sleep, rest and
relaxation have been found to be more easily
disrupted by noise than his communication and
entertainment activities.
d.
Attitudes about environment. The existence of
undesirable features in a person's residential
environment will influence the way in which he
reacts to a particular intrusion.
e.
Belief concerning the effect of noise on health.
4
f.
General sensitivity to noise. People vary in
their ability to hear sound, their physiological
predisposition to noise and their emotional experience
of annoyance to a given noise.
g.
Feeling of fear associated with the noise. For
instance, the extent to which an individual fears
physical harm from the source of the noise will
affect his attitude toward the noise.
A number of physical factors have also been identified by
researchers as influencing the way in which an individual
may react to a noise. These other factors include:
a.
Type of neighborhood - instances of annoyance,
disturbances and complaint associated with a
particular noise exposure will be greatest in
rural areas, followed by suburban and urban
residential areas, and then commercial and industrial
areas in decreasing order.
b.
Time of day - a number of studies have indicated
that noise intrusions are considered more annoying
at night than during the day.
5
C.
Season - noise is considered more disturbing in the
summer than in the winter. This is understandable
since windows are likely to be open in the summer
and recreational activities take place out of doors.
d.
Predictability of the noise - research has revealed
that individuals exposed to unpredictable noise have
a lower noise tolerance than those exposed to
predictable noise.
e.
Control over the noise source - a person who has no
control over the noise source will be more annoyed
than one who is able to exercise some control.
f.
Length of time an individual is exposed to a noise -
there is little evidence supporting the argument that
annoyance resulting from noise will decrease with
continued exposure, rather, under some circumstances,
annoyance may increase the longer one is exposed.
Aircraft Noise Indices
There are two basic schemes for quantifying the noise associated
with aircraft operations. One method considers the noise
generated by all aircraft over a cumulative twenty-four hour
6
period, while the other quantifies the sound levels of a single
aircraft measured at various points on the ground during the
takeoff and landing. Both methods involve acoustical frequency
and time dependent weightings of the basic sound pressure level
data.
A number of cumulative noise exposure techniques have been
developed in the United States, including a Noise Exposure
Forecast (NEF), Composite Noise Rating (CNR), Day/Night Sound
Level (Ldn), and Aircraft Sound Description System (ASDS) *
The primary noise metric used in the EIS is NEF, based on the
Effective Perceived Noise Levels in units of EPNdB. The NEF
analysis involves construction of contours which link together
points of equal cumulative noise exposure. The contours are
generated by a computer technique based on the following
input data: airport flight patterns, number of daily aircraft
operations by type of aircraft and weight and time of day,
There are equivalencies among the various cumulative noise
indices. Any given NEF is equivalent to LDn minus 35, plus
or minus 3. For example, NEF 30 is approximately equal to
Ldn 65. Between NEF and CNR there is a non-linear relation-
ship. The general equivalencies are shown below (Ref. 1).
NEF 20 = CNR 85 = NNI 22 = Ldn 55
NEF 30 = CNR 100 = NNI 38 = Ldn 65
NEF 40 = CNR 115 = NNI 56 = Ldn 75
7
noise characteristics of each aircraft in terms of EPNL during
takeoff and landing and typical runway utilization patterns
in terms of percentage of use.
It is important to keep in mind the assumptions and limitations
when comparing sound levels of different aircraft at any given
point. The difference in sound levels between two aircraft
under comparison will not usually be the same at different
locations on the ground. This reflects the differences in
their rates of climb, climb gradients, flight paths, thrust
settings, and acoustical spectra.
In order to convey the intensity and relative impact of single
event noise in A-weighted levels, Table I describes typical
dBA values of noise commonly experienced by people.
Quantifying Human Response to Noise
The inherent variability in the way individuals react to noise
makes it impossible to predict accurately how any one individual
will respond to a given noise. However, considering the
community as a whole, trends emerge which relate noise to
annoyance. In this way it is possible to correlate a noise
index (cumulative or single event) with community annoyance.
This index will represent the average annoyance response for
the community.
8
TABLE I
Comparative Noise Levels
Typical decibel (dBA) values encountered in daily life and industry
dBA
Rustling leaves
20
Room in a quiet dwelling at midnight
32
Soft whispers at 5 feet
34
Men's clothing department of large store
53
Window air conditioner
55
Conversational speech
60
Household department of large store
62
Busy restaurant
65
Typing pool (9 typewriters in use)
65
Vacuum cleaner in private residence (at 10 feet)
69
Ringing alarm clock (at 2 feet)
80
Loudly reproduced orchestral music in large room
82
Over 85 dBA, beginning of hearing damage if prolonged
Printing press plant (medium size automatic)
86
Heavy city traffic
92
Heavy diesel-propelled vehicle (about 25 feet away)
92
Air grinder
95
Cut-off saw
97
Home lawn mover
98
Turbine condenser
98
150 cubic foot air compressor
100
Banging of steel plate
104
Air hammer
107
Jet airliner (500 feet overhead)
115
9
In utilizing data relating any given measure of noise level or
exposure to average community annoyance it is important to
note that there will exist a given percentage of the population
highly annoyed, a given percentage mildly annoyed and others
who will not be annoyed at all. The changing percentage of
population within a given response category is the best
indicator of noise annoyance impact. The population tables
contained in the text show the number of people exposed to
various levels of cumulative noise exposure. These levels
are in turn related to percent of population falling within
various response categories.
The ensuing discussion focuses on the results of representative
research concerned with the relationship between annoyance and
noise exposure. A brief examination of these results follows
along with a table summarizing the findings. The references
cited are at the end of this appendix.
Ollerhead (Ref. 1) in analyzing the results of numerous
social surveys conducted at major airports in several countries
has derived the curves shown in Figure 1 relating degree of
annoyance and percent of population affected with noise
exposure expressed in NEF. A survey conducted in the Netherlands
(Ref. 4) investigated the relationship between the CNR (an
approximate conversion of NEF is shown) and the percentage
of those questioned who suffered feelings of fear, disruption
of conversation, sleep or work activities (Figure 2).
100
NOT
80
ANNOYED
PERCENTAGE OF RESIDENTS
60
ANNOYED
40
SERIOUSLY
ANNOYED
20
0
0
20
30
40
NOISE EXPOSURE FORECAST (NEF)
ANNOYANCE CAUSED BY AIRCRAFT NOISE IN
RESIDENTIAL COMMUNITIES NEAR MAJOR AIRPORTS
10
Figure 1
11
100
FEELS AFRAID
80
IS FREQUENTLY
DISTURBED IN
PERCENTAGE INTERROGATED
CONVERSATIONS
60
IS FREQUENTLY
DISTURBED IN
40
SLEEP
IS FREQUENTLY
DISTURBED IN
OCCUPATIONS
20
0
20
30
40
50
NOISE EXPOSURE FORECAST (NEF)
COMMUNITY RESPONSE TO AIRCRAFT NOISE-NETHERLANDS SURVEY
Figure 2
12
In 1960 the "Wilson Committee" was appointed by the British
Government to investigate the nature, sources and effects of
the problem of noise. The final report published in 1963
(Ref. 5) included results of extensive examination of community
response to aircraft operations at London Heathrow Airport.
Figure 3 adapted from that report shows the relationship between
noise and NEF (the approximate conversion of NNI to NEF or Ldn
was given earlier), and percent of population distrubed in
various activities including sleep, relaxation, conversation
and viewing television. Disturbance categories for startle
and house vibration are also included.
The Environmental Protection Agency publication "Information
on Levels of Environmental Noise Requisite to Protect Health
and Welfare with an Adequate Margin of Safety" (Levels
Document, Ref. 6), provides a relationship between the
percent of population highly annoyed and the Day-Night Sound
Level (Ldn). These data are shown in Figure 4 along with the
relationship between annoyance, complaints and community
reaction.
The EPA "Levels Document" describes the relationship between
speech interference and Day-Night Sound Levels as shown in
Figure 5. In going from NEF 30 to NEF 40 there is an increase
in speech interference of nearly 90% outdoors. Indoor
interference does not begin to appear until the NEF 35 level
is reached.
13
70
3
1. STARTLES
2. KEEPS FROM GOING TO SLEEP
1
3. WAKES UP
4. DISTURBS REST OR RELAXATION
2
50
4
1
3
30
4
PERCENTAGE OF PEOPLE DISTURBED
2
10
20
25
30
(NEF)
35
40
80
5
8
6
7
60
6
40
5
5. INTERFERES WITH TV SOUND
7
6. CAUSES TV PICTURE FLICKER
7. HOUSE VIBRATES
8
8. INTERFERES WITH CONVERSATION
20
20
25
30
35
40
NOISE EXPOSURE FORECAST (NEF)
COMMUNITY RESPONSE TO AIRCRAFT OPERATIONS . LONDON HEATHROW AIRPORT
Figure 3
80
PERCENTAGE
COMPLAINANTS
20
COMMUNITY
PERCENTAGE HIGHLY ANNOYED
60
REACTION
15
VIGOROUS
10
ACTION
40
COMPLAINTS &
95% CONFIDENCE
5
THREATS
OF LEGAL
INTERVAL AT MEAN
2
ACTION
20
1
NONE
0
50
60
70
80
90
DAY-NIGHT SOUND LEVEL, (Ldn)
20
30
40
50
NOISE EXPOSURE FORECAST (NEF)
COMPARISON OF VARIOUS MEASURES OF INDIVIDUAL
ANNOYANCE AND COMMUNITY REACTION
AS A FUNCTION OF THE DAY-NIGHT SOUND LEVEL
(Ldn) AND NOISE EXPOSURE FORECAST i (NEF)
Figure 4
14
15
100
80
PERCENTAGE SENTENCE INTERFERENCE
60
OUTDOORS
(NORMAL
40
VOICE LEVEL
AND 2 METERS
SEPARATION)
20
INDOORS
0
50
55
60
65
70
75
80
OUTDOOR DAY-NIGHT SOUND LEVEL, (Ldn)
20
25
30
35
40
45
NOISE EXPOSURE FORECAST (NEF)
MAXIMUM PERCENTAGE INTERFERENCE WITH SENTENCES AS A
FUNCTION OF THE DAY-NIGHT NOISE LEVEL. (PERCENTAGE
INTERFERENCE EQUALS 100 MINUS PERCENTAGE INTELLIGIBIL-
ITY, AND Ldn IS BASED ON Lday + 3)
Figure 5
16
An investigation of attitudes to be expected from non-fear
provoking noise in residential areas led Kryter to develop
the curve shown in Figure 6. Although he expressed his findings
in terms of CNR, the figure is expressed in NEF based on the
approximate conversion of CNR to NEF as shown earlier. The
figure also shows percent of population rating the noise
associated with a given NEF level as acceptable or unacceptable.
The sound level (dBA, EPNdB, PNdB) associated with a single
aircraft operation can be put in perspective by referring to
the list of comparative sound levels for events encountered
in daily life (Table I). In addition, studies have been
conducted in which individuals have been exposed to aircraft
fly-over noise and asked to make judgments with respect to
the noisiness, loudness, annoyance or intrusiveness of the
sound. Figure 7 taken from the "Wilson Report" shows compara-
tive judgements between motor vehicles, aircraft and street
noise. The variability in opinion associated with any sound
level is represented by the vertical extent of the shaded
area. Aircraft noise is apparently considered acceptable by
some segment of the population at higher levels than those
of other noise sources. Other data from the "Wilson Report"
shown in Figures 8 and 9 relate dBA sound levels to ratings
of intrusiveness and noisiness. A summary of that data is
provided in Table II.
ESTIMATED PERCENT OF PEOPLE RATING NOISE
AS UNACCEPTABLE FOR RESIDENTIAL LIVING
0
20
40
60
80
100
10
20
Figure 6
RESIDENTIAL COMMUNITY
ATTITUDES TOWARD AIRCRAFT NOISE IN THE
NOISE EXPOSURE FORECAST (NEF)
30
40
50
100
80
60
40
20
0
ESTIMATED PERCENT OF PEOPLE WHO WILL ACCEPT
NOISE OR ARE NEUTRAL TOWARDS IT
LL
18
EXTREMELY
VERY
NOISY
V
EXTREMELY
NOISY
LOUD
VERY
NOISY
NOISY
LOUD
ACCEPTABLE
MOTOR
MODERATE
FAIRLY
LOUD
QUIET
QUIET
NOT LOUD
AT ALL
20
40
60
80
100
120
20
40
60
80
100
120
SOUND LEVEL (dBA)
SOUND LEVEL (dBA)
COMPARATIVE JUDGMENTS OF DIFFERENT NOISES
Figure 7
10=U
10
DAY 1
DAY 2
OUTDOORS
OUTDOORS
ALL OBSERVERS (60)
ALL OBSERVERS(61)
8=VA
8=VN
SUBJECTIVE RATING (INTRUSIVENESS)
o
oo
6=A
4=1
SUBJECTIVE RATING (NOISINESS)
X
6=N
X
X
4=M
X
X
X
X
X
2=N
2= Q
xx
JET AIRCRAFT
X
JET AIRCRAFT
X
PROPELLER AIRCRAFT
X
PROPELLER AIRCRAFT
X
HELICOPTERS
HELICOPTERS
X
0=NN
0
60
80
100
120
60
80
100
120
SOUND LEVEL (dBA)
SOUND LEVEL (dBA)
OUTDOOR JUDGMENTS ON THE
OUTDOOR JUDGMENTS ON THE
CATEGORY SCALE OF INTRUSIVE-
CATEGORY SCALE OF NOISINESS
NESS PLOTTED AGAINST SOUND
PLOTTED AGAINST SOUND LEVEL A
LEVEL A
Figure 9
Figure 8
19
dBA
EPNdB
PNdB*
FIG. 31
FIG. 32
FIG. 33
120
133
131
EXTREMELY NOISY - VERY NOISY
UNBEARABLE
-
110
123
121
NOISY - VERY NOISY
VERY ANNOYING - ANNOYING
NOISY - VERY NOISY
100
113
111
NOISY
ANNOYING- INTRUSIVE
MODERATE - NOISY
90
103
101
MODERATE/ACCEPTABLE NOISY
INTRUSIVE - NOTICEABLE
MODERATE
80
93
91
QUIET MODERATE/ACCEPTABLE
NOTICEABLE
QUIET - MODERATE
70
83
81
QUIET
NOTICEABLE- - NOT NOTICEABLE
QUIET
60
73
71
NOT NOTICEABLE
# ASSUMING PNdB IS APPROXIMATELY
EPNdB MINUS 2
RELATIONSHIP BETWEEN SINGLE EVENT
AIRCRAFT NOISE LEVEL AND SUBJECTIVE RESPONSE
TABLE II
19a
20
Existing Noise Criteria
Table III summarizes the relationship between various indicators
of community annoyance and several cumulative noise indices.
It also illustrates the point made earlier that a valid
indicator of noise impact is the changing percentage of popula-
tion associated with a given response category.
The Department of Transportation (DOT) has established Noise
Standards and Procedures for use by State highway agencies
and the Federal Highway Administration (FHWA) in the planning
and design of highways (Ref. 7). Table IV shows the L 10 values
(the DBA levels exceeded 10% of the time for a 24 hour period)
considered by FHWA as compatible with various land use categories.
The Department of Housing and Urban Development has published
Noise Abatement and Control Standards (Circular 1390.2,
August 4, 1971 - Ref.8) to encourage land utilization
patterns for housing and other municipal needs. These standards
are intended to separate uncontrollable noise sources from
residential and other noise sensitive areas, and prohibit HUD
ANNOYANCE RESPONSE CATEGORIES
EPA
ELIGIBILITY
LEVELS
FOR HUD
NEF
ASDS
A
B
c
D
E
F
G
H
I
J
K
dn
L
M
N
o
P
Q
R
$
DOCUMENT
SUPPORT
APPROX.
NEF 30
20
55
1 MINUTE
5%
20%
75%
17%
5%
1%
0%
25%
10%
20%
5%
22%
41%
20%
8%
17%
100%
10%
90%
ACCEPTABLE
OUTDOOR
ACTIVITY
30
65
2 MINUTES
27%
38%
35%
55%
21%
8%
4%
45%
25%
44%
28%
45%
61%
45%
33%
90%
30%
70%
NEF 30 NEF 40
39%
INTERFER-
ENCE AND
DISCRETIONARY
ANNOYANCE
POTENTIAL
40
75
APPROX.
NEF 40
69%
25%
6%
80%
43%
22%
16%
60%
56%
69%
50%
79%
78%
78%
79%
54%
0%
60%
40%
HEARING
40 MINUTES
UNACCEPTABLE
LOSS
PERCENT OF POPULATION:
PERCENT OF POPULATION:
P-PER-
R-PERCENT RATING NOISE
CENTAGE
AS UNACCEPTABLE
ASERIOUSLY
D-EXPRESSING FEAR
H-STARTLED
HIGHLY
ANNOYED
S-PERCENT RATING NOISE
E-EXPERIENCING
1. KEPT FROM GOING TO SLEEP
ANNOYED
AS ACCEPTABLE
B- ANNOYED
SPEECH
J- AWAKENED
0% SPEECH
INTERFERENCE
C-NOT
INTELLI-
ANNOYED
F-EXPERIENCING
K-DISTURBED WHILE RESTING OR
GIBILITY
SLEEP
RELAXING
(FIG. 32/REF. 24)
INTERRUPTION
(FIG. 25/
L-INDICATING INTERFERENCE WITH
(FIG. 28/
REF. 21)
G-DISTURBED
TV SOUND
REF. 26)
AT WORK
M-INDICATING PICTURE TUBE FLICKER
*USING EQUIVALENCIES
(FIG. 26/REF. 24)
N- INDICATING HOUSE VIBRATION
NEF 20 = CNR 85
O-EXPERIENCING INTERFERENCE WITH
NEF 30 = CNR 100
CONVERSATION
NEF 40 = CNR 115
(FIG. 27/REF.25)
RELATIONSHIP BETWEEN CUMULATIVE NOISE LEVEL AND INDICATORS OF COMMUNITY ANNOYANCE
TABLE III
21
TABLE IV
22
FHWA
DESIGN NOISE LEVEL/LAND USE RELATIONSHIPS
Design Noise
Level - L
Description of Land Use Category
10
60 dBA
Tracts of lands in which serenity and
(Exterior)
quiet are of extraordinary signifi-
cance and serve an important public
need, and where the preservation of
those qualities is essential if the area
is to continue to serve its intended
purpose. Such areas could include
amphitheaters, particular parks or
portions of parks, or open spaces
which are dedicated or recognized by
appropriate local officials for activities
requiring special qualities of serenity
and quiet.
70 dBA
Residences, motels, hotels, public
(Exterior)
meeting rooms, schools, churches,
libraries, hospitals, picnic areas, recre-
ation areas, playgrounds, active sports
areas, and parks.
75 dBA
Developed lands, properties or activities
(Exterior)
not included in categories A and B above.
55 dBA
Residences, motels, hotels, public
(Interior)
meeting rooms, schools, churches,
libraries, hospitals and auditoriums.
23
support for new construction on sites having unacceptable
noise exposure. Set out below are the HUD criteria for funding
new residential construction.
RATING
DISPOSITION IN HUD
less than 30 NEF
Acceptable
30 to 40 NEF
Discretionary
more than 40 NEF
Unacceptable
The Environmental Protection Agency has also identified noise
levels considered requisite to protect health and welfare with
an adequate margin of safety. Table V summarizes the EPA
findings in terms of Ldn. (As mentioned above, the difference
between Ldn and NEF is approximately 35 - e.g., Ldn 65 equals
NEF 30).
24
TABLE V
SUMMARY OF NOISE LEVELS IDENTIFIED AS REQUISITE TO
PROTECT PUBLIC HEALTH AND WELFARE WITH
AN ADEQUATE MARGIN OF SAFETY
(Ref. 6)
Effect
Level
Area
Hearing Loss
Ldn ≤ 74 dB
All areas
Ldn ≤ 55 dB
Outdoors in residential areas
and farms and other outdoor
areas where people spend widely
Outdoor activity
varying amounts of time and
interference and
other places in which quiet is
annoyance
a basis for use.
Ldn ≤ 59 dB
Outdoor areas where people
spend limited amounts of time,
such as school yards, play-
grounds, etc.
Ldn < 45 dB
Indoor residential areas
Indoor activity
interference and
annoyance
Ldn ≤ 49 dB
Other indoor areas with human
activities such as schools, etc.
NOTE: All Leq values from Reference 6 converted to Ldn for ease
of comparison (Ldn equals Leq (24) + 4 dB)
25
A major complaint raised in conjunction with aircraft noise
is interference with talking and listening. This effect has
been substantiated in numerous studies of noise complaint
data. Figure 10 shows the relationship between speaker-
listener separation and ambient sound level necessary for
speech communication at various noise levels (Ref. 4). The
horizontal axis is calculated in a variety of units, rank-
ordered from best to worst in terms of predicting speech
interference. The PSIL is the average sound pressure level
in the octaves centered at 500, 1000 and 2000 Hertz while
the SIL takes the average over three octaves from 600 to 4800
Hertz. In Figure 11, the EPA provides a similar format for
gauging speech interference. It is important to note that the
dBA and SIL (as well as other indices) are not accurate
measures of the masking of speech by noise containing intense
low frequency components. It has been shown that if a low
frequency noise is sufficiently intense it can mask speech
completely. For example, a sound pressure level of 115 dB
at 50 Hertz will provide a 10 to 30 dB masking effect through
3000 Hertz.
Applying these speech interference criteria (Figures 10 and 11)
to aircraft noise, outdoor communication at a distance of
26
DISTANCE FROM SPEAKER
SHOUT NORMAL RAISED VERY
NOISE-DISTANCE AREA WHERE
16.0
FACE-TO-FACE COMMUNICATIONS
TO LISTENER FT.
8.0
4.0
AREA COMMUNICATIONS NOISE FACE-TO-FACE DISTANCE COMMUNICATING WHERE LOUD EXPECTED VOICE VOICE LEVEL ARE: DIFFICULT
IMPOSSIBLE
2.0
MAX
LIMIT
1.0
ARE POSSIBLE IN
VOCAL
AMPL
"NORMAL VOICE"
EFFORT
SPEECH
0.5
N
R
VL
SH
PSIL
40
50
60
70
80
90
100
110
125
SIL
37
47
57
67
77
87
97
107
122
dB(A)
47
57
67
77
87
97
107
117
132
PNdB
60
70
80
90
100
110
120
130
145
dB(C)
54
64
74
84
94
104
114
124
139
RELATIONSHIP BETWEEN SPEAKER-LISTENER SEPARATION,
AMBIENT SOUND LEVEL AND ABILITY TO COMMUNICATE
Figure 10
27
90
80
A-WEIGHTED SOUND PRESSURE LEVEL IN dB re 20 µ N/m2
70
RAISED VOICE
60
COMPUTER
NORMAL VOICE
50
40
(SENTENCE INTELLIGIBILITY = 99%)
30
20
.3
.4
.6
.8
1
1.5
2
3
4
6
8
10
15
20
COMMUNICATING DISTANCE IN METERS
MAXIMUM DISTANCES OVER WHICH CONVERSATION IS CONSIDERED TO BE
SATISFACTORILY INTELLIGIBLE (SENTENCE INTELLIGIBILITY =
95% EXCEPT AS NOTED)
Figure 11
28
two (2) feet would require shouting for those persons within
the 100 EPNdB single event footprints. This impact would
last for the duration of the noise at this level, up to
30 seconds.
The Occupational Safety and Health Administration of the
Department of Labor has established noise standards to protect
the health and safety of industrial workers (29 CFR 1910.95).
Shown below are the permissible noise exposure times for
sound levels of 90 dBA and greater.
SOUND LEVEL
DURATION PER
dBA
DAY, HOURS
SLOW RESPONSE
8
90
6
92
4
95
3
97
2
100
1 -1/2
102
1
105
1/2
110
1/4 or less
115
29
EPA has recommended that 85 dBA be established as the level
not to be exceded when an individual is exposed to noise for
an eight-hour work day.
Residential structures generally provide 15 to 20 dBA attenuation.
Consequently the indoor noise level shown by the 100 EPNdB
(85 dBA) contours would be in the range of 65 to 70 dBA. At
this level of noise there would be no interference with normal
communication at a distance of three (3) feet. At eight (8)
feet communication would require a raised voice.
Hearing Damage
Studies of the temporary auditory threshold shift or temporary
hearing loss caused by noise exposure have demonstrated several
important facts related to temporary threshold shifts (Ref. 12).
Some of those facts are:
1.
The temporary elevation of auditory threshold which
results from one day of exposure (8 hours) to noise
levels of 100 dBA or more may vary from no shift to
a temporary 40 dB shift depending on individual
susceptibility.
2.
Exposure to typical industrial noise produces the
largest temporary hearing loss at 4000 to 6000 Hertz.
30
3.
Recovery from temporary or transient hearing loss
generally occurs within the first hour or two after
the noise exposure has ended.
4.
Efforts have been made to predict susceptibility to
noise-induced permanent hearing loss on the basis of
the amount of temporary threshold shift. A study of
the various tests for detecting highly susceptible
ears has indicated that there is no test which will
predict susceptibility to noise-induced hearing loss.
Figure 12 shows the relationship between a temporary auditory
threshold shift (TTS) in terms of level of exposure and
exposure time. The "white noise" referred to in Figure 12
is comprised of equal sound pressure levels in each frequency
component.
The EPA "Levels Document" discusses a temporary threshold
shift hypothesis. This hypothesis states that "a temporary
threshold shift measured two minutes after cessation of an
eight hour noise exposure closely approximates the Noise
Induced Permanent Threshold Shift (NIPTS) incurred after a
10 to 20 year exposure to that same level."
40
TEMPORARY THRESHOLD SHIFT (TTS in dB)
30
106 dB (OASPL)
100 dB 100 dB (OASPL)
20
94 dB (OASPL)
10
88 dB (OASPL)
,
0
2
5
10
20
50
100
EXPOSURE TIME (MIN)
31
TEMPORARY THRESHOLD SHIFT (TTS) AS A FUNCTION OF EXPOSURE TO
WHITE NOISE (OASPL - OVERALL SOUND PRESSURE LEVEL)
Figure 12
32
The EPA "Levels Document" also discusses the "Equal Energy
Hypothesis." This hypothesis states "that equal amounts of
sound energy will cause equal amounts of NIPTS regardless of
the distribution of the energy across time." While there is
some experimental confirmation of this hypothesis, certain
types of intermittent sounds limit its application.
Long continued exposure to extensive noise can produce
permanent hearing loss but the process is not well understood.
It does not appear possible to directly equate the deleterious
effects of noise-exposure and the energy content of the
noise. That is to say, doubling the energy content in a
noise does not produce double the hearing loss. It is
assumed that the larger the total energy content of the
noise the smaller the time of exposure required to produce
the same amount of hearing loss, but the exact relation
between time and noise energy is not known.
The total amount of hearing loss produced by noise-exposure
depends on many variables. Hearing loss varies with the
type of exposure and its degree of intermittency, the susceptibility
of the individual exposed, the total duration of the exposure,
and possible induced auditory fatigue generated by the
totality of exposure in terms of type, degree and duration.
33
Other Effects of Noise on Humans
It is important to emphasize that many researchers are not
convinced that noise exposure can be correlated to any real
medical problem. The New York City Mayor's Task Force on
Noise Control (Ref. 9) reported, "To date, virtually no
properly designed formal studies have been published, documenting
the palpable indirect effects of noise pollution upon man.
Although we may again appeal to personal experience, having
been aware of fatigue, distraction, irritation or inefficiency
ostensibly precipitated by or aggravated by noise, the
tangible nature of these effects vanishes as soon as it is
pursued in the laboratory or in formal field studies."
However, there is still considerable debate as to whether
noise can cause health defects of a non-auditory nature.
Many researchers underscore the need for extensive epidemi-
ological noise surveys concerned with the incidences of
acute and chronic ailments in different work groups.
Whatever correlation there may arguably be between noise and
adverse health effects requires far more definite, controlled
tests to demonstrate a cause- effect relationship.
34
Some studies indicate that it is not necessary to be fully
awakened by noise to suffer the consequences in terms of
physiological fatigue. Research by H. R. Richter concluded
that "noise associated with modern civilization and even
natural sounds frequently disturb the rest of sleepers
without their awareness" (Ref. 10).
After protracted periods of exposure to intense noise,
particulary of high frequency, animals have shown marked
depletion of adrenal constituents. This indicates that
their physiological tolerance or ability to adapt to stressful
situations has been exceeded. Under these conditions, gastroduodenal
ulcers and other pathological changes in the liver and
kidneys are possible. It is plausible to expect similar
findings in man, but neither the levels nor the exposure
conditions required to exceed human physiological tolerance
to noise are known.
Noise has been reported to cause vasoconstriction, fluctua-
tions in arterial blood pressure, and even alterations of
some functional properties of cardiac muscle. Vasoconstriction
of the small arterioles of the extremities occurs with noise
exposures of moderate level (about 70 dB) and can become
progressively stronger with increasing noise intensity.
35
N. N. Skatalou, a Russian scientist who studied 589 factory
workers, found effects of noise on cardiovascular systems
varied with the type of exposure. Steady or continuous
noise resulted in "arterial tension, doward trend in venous
pressure and reduced peripheral resistance." Intermittent
noise, on the other hand, caused "hypertension, rising
arterial pressure and frequent capillary spasms" (Ref. 10).
The views of several physicians concerned with the adverse
physiological impact of noise were summarized by Baron (Ref.
2). Dr. G. Jansen found that blood circulation does not
adapt to continuing exposure to noise by a return to its
initial level. Instead, peripheral blood flow continues to
be reduced as a result of continuing vasoconstriction and
increased resistance. This phenomenon begins at 60-70 dB and
becomes more pronounced as sound intensity increases. Dr.
L. E. Farr summarized his views of the effects of noise in
the following way: "In disease states such as anxieties,
duodenal ulcers and other so-called tension ills, the additive,
deleterious effect of noise is real and immediate" (Ref. 2).
36
REFERENCES FOR APPENDIX F
1. Richards, E. J. and J. B. Ollerhead, NOISE BURDEN FACTOR -
NEW WAY OF RATING AIRPORT NOISE. Sound and Vibration,
V. 7, no. 12, Dec. 1973, p. 31-33.
2. Baron, Robert A. THE TYRANNY OF NOISE. New York,
St. Martins Press, 1970, 294 p.
3. Tanner, C. S., R. E. Glass. ANALYSIS OF OPERATIONAL
NOISE MEASUREMENTS IN TERMS OF SELECTED HUMAN
RESPONSE NOISE EVALUATION MEASURES. Hydrospace
Research Corporation, Dec. 1971.
4. Kryter, Karl D. THE EFFECTS OF NOISE ON MAN. New York,
Academic Press, 1970, 633 p.
5. Great Britian. Communittee on the Problem of Noise. NOISE,
FINAL REPORT; presented to Parliament by the Lord Minister
for Science by Command of Her Majesty. London,
H. M. Stationery Office, Jul. 1963, p.
6. U.S. Environmental Protection Agency, Office of Noise
Abatement and Control, Washington, D.C. INFORMATION
ON LEVELS OF ENVIRONMENTAL NOISE REQUISITE TO PROTECT
PUBLIC HEALTH AND WELFARE WITH AN ADEQUATE MARGIN OF
SAFETY, Mar. 1974. Various paging. EPA 550/9-74-004.
PB 239 429/4GA. GPO: EP1.2;N69/26
7. Department of Transportation Policy and Procedures Memorandum
90-2, Feb. 8, 1973
8. Department of Housing and Urban Development, Circular 1390.2,
Aug. 4, 1971
9. New York (City), Mayor's Task Force on Noise Control. TOWARD
A QUIETER CITY. 1970, 56 p.
10. Newman, J. S. SUBJECTIVE COMMUNITY REACTIONS TO CONSTRUCTION
NOISE. Presented at NOISExpo Convention, Chicago, Ill.,
Oct. 1973
11. U.S. Environmental Protection Agency, Washington, D.C.
NATIONAL PRIMARY AND SECONDARY AMBIENT AIR QUALITY
STANDARDS. Federal Register, V. 36, no. 84,
Apr. 30, 1971, p. 8186-8201
12. Glorig, Aram. HEARING CONSERVATION IN INDUSTRY. Maico
Audiological Library Series, V. II, Report 3, 5p.
APPENDIX G: COMMENTS ON DRAFT
ENVIRONMENTAL IMPACT STATEMENT
UNITED PROTECTION STATES 1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JAN 24 1975
OFFICE OF THE
ADMINISTRATOR
Mr. Charles R. Foster
Director, Office of Environmental
Quality
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
Dear Mr. Foster:
We have reviewed your draft environmental impact
statement (EIS) for Civil Airplane Fleet Noise Recuirements,
and are in agreement with the proposed action. Accordingly,
we have assigned the EIS a rating of LO-1 lack of objections,
adequate information).
We encourage the Federal Aviation Administration to
promptly complete their deliberations on the various details
of the proposed regulation and promulgate the rule as soon
as possible.
Sincerely yours,
Sheldon Meyers
Sheldon Meyers
Director
Office of Federal Activities
Form DOT F 1320.1 (1-67)
UNITED STATES GOVERNMENT
DEPARTMENT OF TRANSPORTA
Memorandum
OFFICE OF THE SECRETARY
DATE: January 20, 1975
In reply
SUBJECT: Draft Environmental Impact Statement: FAA -
refer to:
Civil Airplane Fleet Noise Requirements
FROM : Director, Office of Environmental Affairs
TES-70
TO
:
Director of Environmental Quality
FAA/AEQ-1
We appreciate the opportunity to review and comment on this draft
environmental impact statement. We have no specific comments to
offer on the statement.
We look forward to receiving the final environmental impact state-
ment, including the comments received from other public agencies
and the general public on the draft statement.
Twanty Martin Convisser
DEPARTMENT OF COMMISCE
U.S. DEPARTMENT OF COMMERCE
National Bureau of Standards
UNITED STATES OF AMERICA
Washington, D.C. 20234
December 23, 1974
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
Dear Chuck:
I have reviewed the Draft Environmental Impact Statement for a proposed
Federal Aviation Regulation which would establish noise standards for
all turbojet aircraft with takeoff gross weight of 75,000 pounds, or
greater and have no comments.
Sincerely,
W. W.A.Linson Leasure,
Acting Chief
Applied Acoustics Section
Mechanics Division, IBS
DEPARTMENT OF
MOUSING
*
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
C
WASHINGTON, D.C. 20410
JAN 24 1975
OFFICE OF THE ASSISTANT SECRETARY
FOR COMMUNITY PLANNING AND DEVELOPMENT
IN REPLY REFER TO:
CSP
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
This is in response to your request for comments on the draft Environmental
Impact Statement (EIS) for the proposed rule on "Civil Airplane Fleet
Noise Requirements. 11 We commend your office on the completeness of the
cost/benefit analysis of the sound absorption material (SAM) treatment
program for subsonic turbojet aircraft over 75,000 pounds. We ask,
however, if the same treatment and improvement would be achieved if
applied to aircraft less than 75,000 pounds. These lighter aircraft,
often operating from general aviation airports, are contributing to
aircraft noise exposure in many of our suburban and rural areas.
It appears that the proposed strategy, coupled with operation procedure
alternatives, will substantially reduce the noise impact around air
carrier airports. It also appears that the refan program when applied
to certain aircraft would provide additional benefits, and we would urge
that work continue to develop this retrofit strategy.
The SAM retrofit program and rule will have its greatest benefit in most
densely settled urban areas where land use measures to reduce aircraft
noise-community conflicts can be achieved only at a large cost and com-
munity disruption. As stated in the EIS (page 42) compatible land use
planning and development should be enhanced by the fleet noise rule. In
our densely settled urban areas, reduced noise at the source will pro-
vide a large measure of relief for residents now living around airports
as well as making available needed housing sites which are now considered
unacceptable because of aircraft noise.
This Department endorses the proposed aircraft fleet noise requirements
and believes that the EIS considers adequately the environmental impact
of promulgating a retrofit rule.
Sincerely
David O. Meeker, Jr. FAIA
Assistant Secretary
CIVIL AERONAUTICS BOARD
WASHINGTON, D.C. 20428
IN REFER REPLY TO: B-1-68
January 23, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D. C. 20591
Dear Mr. Foster:
With regard to your request for comment on the Draft Environmental
Impact Statement of a proposed Federal Aviation Regulation to establish
aircraft noise standards, the Board suggests that adoption of the pro-
posed regulation be deferred until a comprehensive analysis of the
economic impact on the airlines is made to determine whether or not a
retrofit program to accomplish the objectives of the proposed regulation
is economically feasible.
Aside from the initial expense of an estimated 650 to 750 million
dollars for SAM retrofit kit installation, the means of payment for which
has yet to be determined, other economic aspects of the proposed program
must be considered.
The President's proposal to impose a $3.00 per barrel import tariff
on imported crude oil, and a $3.00 per barrel excise tax on domestic crude
oil production equates to 7.5 cents per gallon increase in the price of
aircraft jet fuel. Based on the certificated airline fuel consumption of
about 9 billion gallons per year, airline fuel costs would increase by
675 million dollars yearly. It has also been proposed that all domestic
crude oil production be decontrolled, which would allow "old" crude oil
now selling at $5.25 per barrel to rise to equal the price of "new" crude
oil production priced at about $10.25 per barrel. About 59 percent of
the total domestic crude oil production is from "old" wells. A $5.00
increase per barrel in the price of old crude equates to a 12.5 cents per
gallon increase in the price of jet fuel, which, when applied to 59 per-
cent of the 9.0 billion gallon airline industry consumption, creates a
further added fuel cost of over 678.5 million dollars per year.
If, as estimated in the draft proposal, the retrofit program would
result in an increase in air carrier fuel consumption of 4,000 barrels
per day, a further increase in cost of about 21.6 million dollars per
year, based on the current jet fuel price of 23.8 cents per gallon and
the 7.5 cents per gallon increase resulting from the proposed tax and
tariff, would be incurred.
is
FORD
GURALD
- 2 -
Additionally, direct operating costs are estimated to increase by
an amount ranging from 9.0 to 12 percent per year upon completion of the
retrofit program. In the 12-month period ended September 30, 1974, the
direct operating costs of the U.S. certificated air carriers were 6.858
billion dollars. A 9.0 percent increase in direct operating costs applied
to the 67 percent of the airline fleet aircraft considered to be candidates
for retrofit would result in an increased cost to the airlines of over
413.5 million dollars yearly, which would prevail each year throughout the
remaining life of each aircraft after retrofit.
Further, the economics of a decrease in productivity resulting from
a weight or range penalty inherent in the retrofit program is a prime con-
sideration, as is evidenced by the B707-300B aircraft which would gain
about 3,450 pounds in weight for a loss of 17 passenger seats with a
probable 9.0 percent increase in direct operating costs and a potential
for over a 10 percent loss in revenue.
Under the Federal Aviation Act of 1958, the Federal Aviation Adminis-
tration is charged with the responsibility to assure that any proposed
regulation or standard must be economically reasonable. The Civil
Aeronautics Board is also subject to the same requirement, and for that
reason proposes that operational procedures and normal airline aircraft
attrition be continued as the principal means of aircraft noise abatement
until a full analysis of the economic impact on the airlines of the pro-
posed retrofit program is completed. In view of the recent developments
in fuel cost and conservation as outlined in the President's addresses to
the nation on January 13 and 15, 1975, such an analysis is of paramount
importance.
The potential adverse economic impact on the U.S. airline industry of
the contemplated actions as delineated herein is of such magnitude that
the Board's staff has been directed to analyze the economic effects on the
U.S. certificated air carrier industry on an expedited basis.
Sincerely,
Richard Olivelia
Richard J. O'Melia
Acting Chairman
United States Department of the Interior
RIOR
OFFICE OF THE SECRETARY
March
1849
WASHINGTON, D.C. 20240
PEP ER 75/4
JAN 27 1975
Dear Mr. Foster:
Thank you for your letter of December 9, 1974, transmitting
copies of the Federal Aviation Administration's draft
environmental statement for civil airplane fleet noise
requirements.
Our comments are presented according to the format of the
statement or by subject.
We believe the draft statement is well done. The discussion
under II. Probable Impact of the Proposed Action on the
Environment Dealing with "Noise Benefits" and "Fuel Consump-
tion" is objective, quantitative, and rigorous. The con-
clusions reached from the discussion represent a balanced view.
We suggest a statement be added to the final statement
indicating biotic natural resources were considered in the
establishment of the proposed regulations. Noise levels are
often critical to certain pressure-sensitive wildlife species
on a local basis.
We note that on page 13, the draft statement indicates
11
possible negative effects on other aspects of the
environment are addressed." We suggest all significant
environmental impacts should be discussed, as the quotation
from the draft statement appears to make a value judgment
about effects.
Also, the discussion and analysis of "Emissions" are sketchy
and the conclusions reached on air pollution levels are not
supported by a rigorous analysis of data. While we do not
take issue with the conclusions reached on air pollution
emissions, we suggest these conclusions are not supported
by analysis of presented facts.
CONSERVE
AMERICA'S
ENERGY
Save Energy and You Serve America!
2
We hope these comments will be helpful to you in the
preparation of a final statement.
Sincerely yours,
Deputy Assistant Secretary of the Interior
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Department of Transportation
Washington, D. C. 20591
REVOLUTION
AFROND
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
WASHINGTON, D.C. 20546
AMERICAN
POLENTE
NATIONAL
USA
JAN 24 1975
1776-1976
REPLY TO
ATTN CF
RL
Mr. Charles R. Foster
Director
Office of Environmental Quality
Federal Aviation Administration
Washington, DC 20591
Dear Chuck:
We have reviewed the Draft Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements dated December
1974. Our comments follow.
1. The section "Alternatives to the Proposed Action"
should state the criteria used to make the determination of
economic reasonableness of the various technological options
for noise reduction. Economic reasonableness is a key
issue to decision making in this area. We think this
section should include the values of such factors as maximum
acceptable cost, minimum acceptable number of people bene-
fited by a selected amount of noise reduction, acceptable
values of cost effectiveness, etc., that were used in the
decision making process, and the rationale for selecting
the values.
2. Figures III-1 and III-2 in this section may be
misleading in an environmental impact statement on retrofit.
The inclusion of operational procedures has a substantial
impact on the areas removed from any given level of noise
exposure. Therefore, since these procedures are not re-
quired by the FAA, the results obtained using them may be
misleading. In particular the points through which the
curves are drawn in Figures III-1 and III-2 are not points
corresponding to the options of interest in this impact
statement.
Sincerely,
Jany
Harry W. Johnson
cc:
H. Safeer/FAA, Office of Environmental
Quality
FEDERAL
ENERGY
FEDERAL ENERGY ADMINISTRATION
WASHINGTON, D.C. 20461
ADMINISTRATION
1975
OFFICE OF THE ASSISTANT ADMINISTRATOR
FEA 74-115
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
Dear Mr. Foster:
This is in response to your request for our review and comment on the
draft environmental impact statement for Civil Airplane Fleet Noise
Requirements. Our comments are presented according to subject.
Fuel Consumption
During the next decade or SO the 727 will be the mainstay of the
industry due to its versatility. Also during the next decade airlines
will probably be replacing most of the B 707's and the D.C. 8's in
their fleet. This is due to the high operating costs, limited routes
and relatively small number of seats. These two planes are also. the
worst noise offenders in the fleet and would incur the highest fuel
increase after retrofit, 1.4% and 1.0%, respectively. The 727 by
comparison would incur a 0.2% fuel increase. The 727, 737, and D.C. 9
cambined make up 77% of the fleet.
Consideration should be given to relaxing the proposed standards to
exclude all presently operating 3 engine jets (727, 737, and D.C. 9).
A comparison of the FAR limits in table II on page 15 shows that the
727, 737, and D.C. 9 either meet or approach all FAR limits on take-
off, sidelines, and landing.
Because the greatest noise offenders are the jets with four engines
(D.C. 8 and 707), a retrofit program for only 4 engine jets in
operation after June 30, 1979, would be appropriate. This would have
the effect of speeding up their retirement from fleets and thus
avoiding the increased installation cost and fuel consumption
2
associated with the muffler system for most of these planes. Only the
4 engine jets still in use after June 30, 1969 would be required to
install the muffler system. This would result in the elimination of
the worse noise offenders within a reasonable period of time.
We hope that our comments will be helpful to you in the preparation of
the final impact statement and in your future consideration of the
proposal.
Sincerely,
Mudast
Roger W. Sant
Assistant Administrator
Energy Conservation and Environment
GFORGE R. ARIYOSHI
E ALVEY WRIGHT
GOVERNOR
DIRECTOR
LAWRENCE F.
HUN
DEPUTY DIRECTOR
MUNNY Y. M. LEE
DEPUTY DIRECTOR
DOUGLAS S. SAKAMOTO
STATE OF hawaii
DEPUTY DIRECTOR
DEPARTMENT OF TRANSPORTATION
IN REPLY REFER TO:
AIRPORTS DIVISION
HONOLULU INTERNATIONAL AIRPORT
HONOLULU. HAWAII 96819
AIR 9784
January 20, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
This is in reply to your letter of December 9, 1974
transmitting for comments the Draft Environmental Impact
Statement for Civil Airplane Fleet Noise Requirements which
would amend Part 36 of the Federal Aviation Regulations.
In general, we are in agreement with the analysis of
the effect on the environment that would result from the
proposed rule for nacelle treatment to reduce engine noise.
To the best of our knowledge, the acoustic treatment of
engine nacelles with sound absorbent materials appears to
represent the best immediate solution to the urgent need to
reduce aircraft noise at airports.
We are concerned with the reliance the impact statement
places on the 23-airport analysis in Appendix C. In terms
of total fleet cost, it is apparent that the refan retrofit
program will be substantially more than SAM retrofit. However,
23 airports and the representative airport model of the analysis
are principally large hubs with a greater number of JT3D equipped
aircraft. We wonder whether a complete investigation including
medium and small hub airports served by JT8D equipped aircraft
might not show that the cost-benefit ratio would favor early
implementation of a JT8D refan program.
Mr. Charles R. Foster
Page 2
January 20, 1975
We suggest additional clarification be provided in the
EIS for Figures III-1 and III-2. An explanation is needed
for the abbreviations used in the code column and the source
of the data for the figure should be provided for reference
purposes.
Thank you for the opportunity to review the draft
environmental impact statement.
Very truly yours,
Own OWEN MIYAMOTO Migarts
Chief, Airports Division
TVASNAC
TOWN-VILLAGE AIRCRAFT SAFETY & NOISE ABATEMENT COMMITTEE
196 CENTRAL AVENUE
LAWRENCE, NEW YORK 11559
(516)371-2330
TOWN OF HEMPSTEAD
CLIFFORD A. DEEDS
Director
Villages of
ATLANTIC BEACH
CEDARHURST
EAST ROCKAWAY
January 13th, 1975
FLORAL PARK
GARDEN CITY
HEMPSTEAD
Mr. Charles R. Foster
HEWLETT BAY PARK
Director of Environmental Quality
Federal Aviation Administration
HEWLETT HARBOR
Washington, D. C.,
20591
HEWLETT NECK
ISLAND PARK
Dear Mr. Foster:
LAWRENCE
Re: Environmental Impact Statement
LYNBROOK
Civil Airplane Fleet Noise
NEW HYDE PARK
Requirements
RUSSELL GARDENS
We thank you for your transmittal letter of 9 December 1974,
STEWART MANOR
together with draft Environmental Impact Statement noted
VALLEY STREAM
above.
WOODSBURGH
We have studied the E.I.S. and find ourselves in agreement
City of
with it. On the basis of this E.I.S. we see no reason for
LONG BEACH
further delay in instituting immediately the Civil Airplane
Fleet Noise Requirements regulation.
Very truly yours,
CanDeed
Clifford A. Deeds
Director
CAD:dt
100% Recycled Fiber
30803
1778
Department of Transportation
State of Georgia
DOWNING MUSGROVE
No.2 Capitol Square
THOMAS D. MORELAND
COMMISSIONER
STATE HIGHWAY ENGINEER
EMORY C. PARRISH
DEPUTY COMMISSIONER
Atlanta, Georgia 30334
W. M. WILLIAMS
SECRETARY. TREASURER
December 27, 1974
File No. 270
Mr. Charles R. Foster, AEO-1
Director of Environmental Quality
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
Subject: Draft Environmental Impact Statement, Noise
Thank you for the opportunity to comment on the draft environmental
impact statement regarding civil airplane fleet noise requirements
We strongly agree with your suggestion of retrofitting nacelles and
fan ducts with sound absorbing materials. This is of special im-
portance as airlines strive to extend the useful life of their fleets.
We look forward to the many benefits resulting from quieter aircraft
operations.
Very truly yours,
Floyd E. Hardy, P. E., Chief,
Environmental Analysis Bureau
it
RRB/ch
INCORPORATED
VILLAGE OF HEWLETT NECK
NASSAU COUNTY, N. Y.
30 PIERMONT AVE., HEWLETT, N. Y. 11557
SHELDON SHANE, TRUSTEE
TELEPHONE: (516) 295-1400
MARVIN ROSS, ATTORNEY
BERTRAM KALISHER. TRUSTEE
-
NORMAN L. WAX, BUILDING INSPECTOR
FROHMAN HOLLAND. MAYOR
LAWRENCE FELDMAN. TRUSTEE
PATRICK J. KING, JR.. CLERK
MARVIN SCHACHER, TRUSTEE
January 14, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
I am familiar with the Environmental Impact Study
recently issued by the FAA.
Our Village along with many others have suffered
much from aircraft noise.
The implementation of retrofit rules should go far in
giving our residents the relief they have long sought.
An early enforcement of such regulations would be most
welcome and appreciated.
Sincerely,
Alcound
FROHMAN HOLLAND
Mayor
FH/dw
Inc. Village of Hewlett Neck
HEWLEY OF VILLAGE BAY PARK CNI 1828 MASSAU
COUNTY.N.
Village of Hewlett Bay Park
30 PIERMONT AVENUE, HEWLETT, L.I., NEW YORK 11557
TELEPHONE (516) 295-1400
MILTON S. RINZLER, MAYOR
WILLIAM V. LURIE, TRUSTEE
JACK NORDEN, JR., COUNSEL
RONALD ROSS, TRUSTEE
PATRICK J. KING. JR., CLERK
BRUCE GODT. TRUSTEE
ALLEN FRANK, TREASURER
ROSLYN T. LEA. TRUSTEE
January 14, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
I am familiar with the Environmental Impact Study recently
issued by the FAA.
Our Village along with many others have suffered much from
aircraft noise.
The implementation of retrofit rules should go far in giving
our residents the relief they have long sought.
An early enforcement of such regulations would be most welcome
and appreciated.
Sincerely,
My
MILTON S. RINZLER
Mayor
MSR/dw
Inc. Village of Hewlett Bay Park
HERE INTERPORATED 1925 # SEAL
OFFICE OF THE MAYOR
W TOM WARD
(516) 825.4200
VALLEY STREAM.
VILLAGE HALL
NEW YORK 11580
ON THE VILLAGE GREEN
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D.C. 20591
Re: Environmental Impact
Statement Civil Airplane
Fleet Noise Requirements
Dear Mr. Foster:
In keeping with sentiments expressed by
Nassau County Villages, via TVASNAC and in
separate expressions from the Villages in-
volved, Valley Stream wishes to add evi-
dence of its concern.
The contents of the Environmental Impact
Statement on Civil Airplane Fleet Noise Re-
quirements conforms with the convictions of
this Village. This communication is to re-
quest immediate application of the Fleet
Noise regulation.
Respectfully submitted,
Whom Ward
W Tom Ward
14 January 1975: sas
MILLBRED SEPTEMBER
INCORPORATED VILLAGE OF CEDARHURST
CEDARHURST. NEW YORK 11516
OFFICE OF THE MAYOR
TELEPHONE
NICHOLAS A. FARINA
295-5770
January 20, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D.C. 20591
Dear Mr. Foster:
With respect to your statement concerning Civil
Airplane Fleet Noise Requirements (E.I.S.), I as the
Mayor of the Village of Cedarhurst and the Board of
Trustees are in total agreement with your study, and
wish to see this Civil Airplane Fleet Noise Require-
ment Regulation implemented immediately.
We commend you for your action and insight.
Very truly yours,
nick
Nicholas A. Farina
Mayor of Cedarhurst
NAF/db
NEW YORK STATE
DEPARTMENT OF TRANSPORTATION
Raymond T. Schuler, Commissioner
1220 Washington Avenue, State Campus, Albany, New York 12226
January 15, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
Re: Draft Environmental Impact Statement
Civil Airplane Fleet Noise Requirements
Dear Mr. Foster:
We have reviewed the draft Environmental Impact Statement for Civil
Airplane Fleet Noise Requirements and concur with the intent of the
proposed Statement.
We cannot concur, however, with the proposed schedule of compliance.
Prior to any schedule being established, it must be determined whether
or not the manufacturer has the ability to supply sufficient retrofit
kits within the allotted time frame. The retrofit schedule should be
established based on the availability of material.
We cannot accept the Statement that there is a negligible increase in
emissions from the retrofitted engines, until test results proving this
fact are released. The Environmental Statement indicates emission tests
are underway only on the JT3D and JT8D engines. Consideration must also
be given to the Rolls Royce Spey and the early JT9D engines.
The BAC-1-11, currently in use by Allegheny Airlines, overflies a major
portion of the northeast as a result of the Allegheny route structure.
The high population density along these Allegheny routes make it
extremely important that while noise is reduced, the emissions are not
increased.
It is our understanding that a "hush kit" currently exists for the BAC-1-11.
However, we have no information to indicate if this kit conforms to FAR
Part 36 requirements. If the requirements are met, then consideration
should be given to using the existing kit rather than a new retrofit
package.
Mr. Charles R. Foster
January 15, 1975
Page #2
We strongly concur with the regulation of International Carriers. Since
noise regulations are being imposed on United States carriers, it seems
completely justified to apply the same controls to the competition. To
do otherwise would defeat the purpose of the retrofit program.
Thank you for giving us an opportunity to review this draft Environmental
Impact Statement.
Sincerely
Millah
-CLARENCE M. COOK, Supervisor
Airport Development Section
CMC/JR/CM
MEMPHIS SHELBY COUNTY AIRPORT AUTHORITY
COMMISSIONERS
E W (NED) COOK
Charrisn
JOSEPHH JOHNSO'
Vice-chairman
GEORGEE CATES
BETTY FOLEY
JOHNM HEISKELL
LAWRENCE THUGHES
DANIEL WARD
LOUIS CARRUTHERS
HonoraryCharman
January 23, 1975
ROBERT WOOD.
President
Council on Environmental Quality
722 Jackson Place, N. W.
Washington, D. C. 20006
Dear Sirs:
The Draft Environmental Impact Statement for Civil Airplane
Fleet Noise Requirements prepared by the Federal Aviation
Administration, dated December 1974, has been reviewed.
We are in agreement with the conclusions reached in the
impact statement. However, the retrofit compliance schedule
provides a very slow ti : frame for relief to the airport
communities which are E Sected. More expeditious relief
is desirable, but if this is impractical, there is no stren-
uous objection to the draft proposal.
Another area of concern in the proposal is that foreign
manufactured four engine aircraft will not be required to
meet FAR 36 standards, only Annex 16 requirements. It
seems inconsistent to require two and three engine foreign
aircraft to be retrofitted, but not four engine foreign
aircraft.
It is our desire to see final adoption of the proposed
rule 74-14 as a major step toward solving the noise pollution
problem around airports.
We appreciate the opportunity to comment on the Draft En-
vironmental Impact Statement.
Sincerely,
W. M. Fletcher, Secretary
Memphis-Shelby County
Airport Authority
WMF/TMS/mr
cc: Mr. Chuck Foster
Mr. Don Reilly
VILLAGE OF LAWRENCE
NASSAU COUNTY, NEW YORK
WILLIAM D. DENSON
MAYOR
ACTING CLERK-TREASURER
TRUSTEES
PETER W. OVERS
MARTIN ROSEN
HERBERT WARSHAVSKY
196 CENTRAL AVENUE
c. PAYSON COLEMAN
LAWRENCE. NEW YORK 11559
M. ALBERT BENDES
516 - 239.4600
January 22, 1975
Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D.C. 20591
Dear Mr. Foster:
The Village of Lawrence would like to go on record as being in
complete accord with the findings of your Environmental Impact Study.
After examining this study, it becomes quite evident that it
justifies the need to make a ruling on civil airplane fleet noise
requirements (retrofit rules) effective immediately.
We urge you to bend every effort in creating early enforcement
of such regulations to reduce the jet noise impact and hopefully bring
some much needed relief to our community.
Jallian Very William truly D. D. yours, Denson Dearn
Mayor
WDD;jc
The Commonwealth of Massachusetts
Aeronautics Commission
Boston - Logan Airport. Boston 02128
January 21, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
800 Constitution Avenue
Washington, D.C.
Dear Mr. Foster:
Thanks for the opportunity to comment on the draft EIS of the proposed
SAM retrofit requirement. Overall, it's a thorough and intelligent treatment
of the subject.
The Aviation Advisory Commission, in its January 1973 report, also
supported the nacelle retrofit program and recommended immediate implementa- -
tion. Page 74 of the AAC Summary Report has a concise statement of this position.
I was a bit surprised to notice that the alternative of more stringent standards
didn't consider making the retrofit rule applicable to aircraft with gross weights
under 75, 000 lbs. While the total noise contribution of Lear jets, Sabreliners and
the like may be relatively small, as individual events they can and do raise hell.
Your office is to be especially commended for the excellent treatment of the
cost/effectiveness of the proposed rule and related noise abatement possibilities,
even though you left out one of the best bets. While a two-segment approach is cost/
effective (as your report shows) increasing existing glideslope angles to somewhere
between 3½¹₂ and 4 degrees is 727 times MORE cost/effective. See the attached for
the details.
By the way, the two similar cost/effectiveness charts on pages 30 and C-32
don't quite agree. The option of "SAM-3D+2SEG+C/B" produces a 62% reduction in
impacted area on p. 30 but only a 53% reduction on p. C-32. There are similar
discrepancies in the "SAM 3D/8D+2SEG+C/B" and the "SAM 3D-RFN8D+2SEG"
options.
Just as a matter of reader convenience, you might consider moving your
excellent "capsule comparison" of SAM VS. Refan on p. 38 to a more prominent
location. You might also like to more clearly emphasize the fact that the benefits
of refanning the JT-8D remain theoretical while the SAM nacelle retrofit has been
demonstrated.
2
Lastly, I thoroughly agree with your idea of figuring operational
techniques into the overall noise abatement results, but I'm afraid you
missed a few that at least deserve consideration. For instance, flap manage- -
ment (mentioned briefly) and increased takeoff deck angles have been shown to
reduce noise significantly. Similarly, the possible diversion of some air
traffic to less noise-sensitive fields deserves consideration and, while they're
a last resort, curfews and quotas may be expected to have an effect on the
noise abatement formulae.
I look forward to seeing the final version of the EIS on the nacelle retrofit
program.
Yours,
Columbur
{
Crocker Snow
Director of Aeronautics
RK/ep
January 24, 1975
Council on Environment:1 Quality
722 Jackson Place, N. W.
Washington, D. C. 20006
Gentlemen:
We have been in correspondence with the Airport Operators
Council International concerning draft of Environment 1
Impact Statement for special airpl ne fleet noise requirements,
and we would like to be included in the record as being in
complete support of the position urged by the Council.
The Council's position is set forth in f irly good detail
in its letter of Jenuary 14, 1975 addressed to your office.
Very truly yours,
William T. Burns
Deputy Director of
WTB:g
Commerce for Aviation
cc: Chuck Foster, Director
Office of Environmental Quality
J. Donald Reilly, AOCI
CITY OF PHILADELPHIA
ALIENS MUST REPORT
DEPARTMENT OF COMMERCE
DIVISION OF AVIATION
Philadelphia, Pa. 19153
PHIL
JANP-1 1913 JRN73'75
-PM
THEIRCADORESSES
7975
DURING JANUARY
Mr. Chuck Foster, Director
Office of Environmental Quality
Federal Aviation Administration
800 Independance Avenue, S.W.
Washington, D. C. 20591
THE
One World Trade Center
New York, NY. 10043
Aviation Department
Caesar B Patterini, Director
(212) 466-7453
(201) 622-6600 x7453
Morns Sicane. Deputy Director
January 27, 1975
(212) 466-7455
(201) 622-6600 x7455
Council on Environmental Quality
722 Jackson Place, N.W.
Washington, D.C. 20006
Gentlemen:
We have recently reviewed the Draft Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements prepared by the Federal
Aviation Administration of the U.S. Department of Transportation
dated December, 1974.
The Port Authority of New York and New Jersey is basically in
agreement with the concept and content of the proposed Statement,
subject to a few minor comments, as follows:
1. Compliance Date
The proposed targets of 36 months for intermediate compliance
and 48 months for full compliance (from the effective date of
the regulation) seem reasonable. In view of past slippage, we
feel that it is essential that the new regulation be issued at
the earliest possible date with an early effective date in
order that the public may receive the benefit of the retrofit
treatment.
2. Refan Noise Reductions
The discussion on Page 40 of noise reduction for Refan VS. SAM
indicates that the DC-9 with refan will be "3 EPNdB quieter on
approach". It is our understanding that FAA testimony before
the House Subcommittee on Aeronautics and Space Technology showed
a difference of 0.3 EPNdB, which in the absence of flight test
data, is meaningless. It is suggested that the quoted language
be deleted from the Draft Statement.
3. Benefits of Retrofit
Section VIII on Page 47 should be expanded to emphasize some
of the points made in the text and some of the points raised
in the legislative history of the Noise Control Act.
Council on
Environmental Quality
-2-
January 27, 1975
In conclusion, we strongly recommend the earliest possible adoption
of FAA's proposed Fleet Noise Level Rule in order that the public
can receive the benefit of the significant noise reductions without
further delay.
Sincerely
BPattarimi
c. B. Patterini
Director of Aviation
CC: Mr. C. R. Foster, DOT
INCORPORATED
Hillage of Moodsburgh
WALTER BRECHER, TRUSTEE
NASSAU COUNTY. LONG ISLAND. N. Y.
JACK NORDEN. JR., ATTORNEY
ROBERT B. KULLMAN. TRUSTEE
30 PIERMONT AVENUE, HEWLETT, NEW YORK 11557
FRED WEINSTOCK,
RICHARD NEIMETH, TRUSTEE
TELEPHONE: 295-1400
BUILDING INSPECTOR
IRVING E. HOLLAND. TREASURER
PATRICK J. KING. JR.
ROBERT TOMCHIN, TRUSTEE
-
CLERK AND REGISTRAR
DONALD S. RUTH, MAYOR
January 16, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
I am familiar with the Environmental Impact Study recently
issued by the FAA.
Our Village along with many others have suffered much from
aircraft noise.
The implementation of retrofit rules should go far in giving
our residents the relief they have long sought.
An early enforcement of such regulations would be most
welcome and appreciated.
Deputy Mayor
RBK/dw
Inc. Village of Woodsburgh
AERONAUTICS COMMISSION
STATE OF MICHIGAN
AERONAUTICS COMMISSION
CAPITAL CITY AIRPORT
MARIO FONTANA,
LANSING, MICHIGAN 48906
CHAIRMAN
NALD C. HEINLEIN,
517-373-0576
VICE CHAIRMAN
LYNN D. ALLEN, O.D.
PETER H. BURGHER
BRITTON L. GORDON
WILLIAM G. MILLIKEN, GOVERNOR
E. V. ERICKSON
COL. GEORGE L. HALVERSON
DEPARTMENT OF STATE HIGHWAYS AND TRANSPORTATION
HOW. RD A. TANNER, Ph. D.
JOHN P. WOODFORD, DIRECTOR
JAMES D. RAMSEY,
DIRECTOR
January 22, 1975
Subject: Draft Environmental Impact
Statement for Civil Airplane
Fleet Noise Requirements dated
December, 1974
Review and Comment
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D.C. 20591
Gentlemen:
This is in response to your request for comments concerning the subject
Draft Environmental Impact Statement.
We believe that the expected reduction in noise levels which would
result from compliance with FAR Part 36 noise standards would represent a
significant improvement to the environmental quality of land surrounding
major airports. The small increases in fuel consumption and air pollution
from aircraft emissions that would result from implementation of the pro-
posed extension of Part 36 are worth the beneficial effects of this pro-
gram.
We were unable to assess the cost benefit aspects mentioned in the state-
ment due to time factors and staff limitations.
Very truly yours,
L. C. Andrews, Chief Engineer
MICHIGAN AERONAUTICS COMMISSION
gc
MICHIGAN
THE
GREAT
LAKE
STATE
VILLAGE OF LAWRENCE
NASSAU COUNTY, NEW YORK
WILLIAM D. DENSON
MAYOR
ACTING CLERK-TREASURER
TRUSTEES
PETER W. OVERS
MARTIN ROSEN
HERBERT WARSHAVSKY
196 CENTRAL AVENUE
C. PAYSON COLEMAN
LAWRENCE, NEW YORK 11559
M. ALBERT BENDES
516 239-4600
January 27, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
Dear Mr. Foster:
Thank you for the opportunity of reviewing the Draft Environmental
Impact Statement for Civil Airplane Fleet Noise Requirements. I was
pleased to note that the statement contains strong and convincing argu-
ments from every standpoint - environmental, technological and economic -
for proceeding with the prompt issuance of a final rule.
I was, however, greatly disturbed to find that "the FAA is consider-
ing revising the intermediate compliance date to be 36 months from the
effective date of the amended regulation with full compliance required
48 months from the effective date." As is noted, the time frame is cer-
tainly "different from that given in the NPRM (June 30, 1976 and June 30,
1978) On two separate occasions I have written to the FAA on this
issue, the last to Rule Docket AGC-24 on June 7, 1974. I said at that
time "We wish also to express our concern that the compliance dates set
forth in the NPRM, mid-1976 and mid-1978, may be extended in view of the
time that has elasped since the proposal was first made. Any slippage
in these dates is unacceptable to the communities which have already
endured the noise problem too many years." The same sentiment was ex-
pressed earlier. These warnings have gone unheeded.
Now we find that these already too distant dates are to be pushed
back further. The communities near Kennedy International Airport and
the nation's other major airports must not be penalized because of the
slow pace of the FAA's rule making. Certainly, a priority program could
be initiated that would make the original dates feasible.
I urge you to retain the original dates in the final environmental
impact statement and in the final rule, which we hope will be issued at
2.
Mr. Foster - continued
January 27, 1975
the earliest possible moment. Such action must be taken in fairness
to the Village of Lawrence and to other noise-impacted communities
across the nation.
Very truly yours,
reched variliancy
Herbert Warshavsky
Trustee
HW;jc
Locust Grove Civic Association
OF QUEENS COUNTY, INC.
135-45 Lefferts Boulevard
So. Ozone Park, N. Y. 11420
Alfred Maggiore, President
MICHAEL CAMPAIOLA
114-10 - 150th Avenue
Vice-President
So. Ozone Park, N.Y. 11420
MAE D. COTTRELL
Secretary
February 6, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
800 Independence Avenue SW
Washington, D.C. 20591
Dear Sir:
We recommend that the Retrofit Program, as proposed in the Environ-
mental Impact Statement, to lower noise levels, be put into effect
immediately.
Residents in our area and those in areas surrounding Kennedy Airport
are in favor of anything that will help reduce noise, and hope that
some relief can be obtained through this program.
Sincerely,
alfred Alfred Maggiore mag maggiore
President
AM-mdc
LOCUST GROVE CIVIC ASSOCIATION
Alfred Maggiore, President
VALLEY FE87 FREAM 1975 NY
114-10 - 150th Avenue
11580
So. Ozone Park, N.Y. 11420
Mr. Charles R. Foster
Director of Environmental Qualit
Federal Aviation Administration
800 Independence Avenue SW
Washington, D.C. 20591
METRO OLITAN DADE COUNTY FLORIDA
P. O. BOX 592075 AMF
AVIATION DEPARTMENT
MIAMI, FLORIDA 33159
TEL: 526-2000
January 29, 1975
Council on Environmental Quality
722 Jackson Place, N.
Washington, D. C. 20006
Gentlemen:
Miami International Airport is situated SO as to be adjacent to or near
a number of residential areas some of which contain significant population
density. Consequently, the citizens of our area and numerous agencies
of city, county, state, and federal government are all very sensitive to
any action which will have an effect on noise pollution in our community.
The Environmental Impact Statement for Civil Airplane Fleet Noise
Requirements prepared by the Federal Aviation Administration dated
December, 1974, reaches a number of conclusions in which the Dade
County Aviation Department is in agreement.
In particular, we strongly favor requiring all foreign manufactured
aircraft to meet FAR 36 standards without exclusion, which would in-
clude four engine aircraft as well as two and three engine aircraft.
Any compromise from this position would cause the Dade County
Aviation Department to totally withdraw our approval from NPRM 74-
14.
Last year thirty-four percent of the passengers traveling to and from
our airport had origins or destinations outside the continental U. S.
limits. Sixty-six percent of the freight and express processed through
MIA also originated or was destined to points outside the continental
U. S. Experience shows that both foreign passengers and freight are
increasing as a percent of the total traffic processed at MIA.
Consequently, foreign aircraft are having an increasing influence on
the noise profile which affect our community. We feel that it is im-
perative that these aircraft adhere to the noise abatement procedures
embodied in FAR 36 as originally proposed.
LIBRARY GERALD ? FO-RO
MIAMI INTERNATIONAL AIRPORT
Council on Environmental Quality
Page 2
January 29, 1975
Your consideration of our position on these matters is appreciated.
Very truly yours,
J.K.Can H. Can
I. H. Carr
Planning Section Head
IHC:mcp
cc: Mr. Chuck Foster, Director
Office of Environmental Quality
Federal Aviation Administration
800 Independence Ave., S. W.
Washington, D. C. 20591
INCORPORATED
RAYMOND L.REGAN
MAYOR
VILLAGE OF GARDEN CITY
TRUSTEES
JAMES F. DOOLEY
NASSAU COUNTY, N.Y.
WARREN WYTZKA
351 STEWART AVENUE
AMOS B. SHARRETTS
GARDEN CITY, L.I.,N. Y. 11530
FRANK R. LIEBERT
ALFRED DE SALVO
OF GARDEN CITY
DANIEL V. DUFF
TEL. PIONEER 2-5800
E. TREVERTON CLARK
FIELDSTONE 7-5800
SEAL
GEORGE L. HUBBELL. JR. COUNSEL
EARL P. SANDQUIST. VILLAGE ADMINISTRATOR
8 CLERK TREASURER
February 10, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D.C. 20591
Dear Mr. Foster:
The Garden City Board of Trustees and I have studied the
draft Environmental Impact Statement for "Civil Airplane Fleet
Noise Requirements" and wish to express to you our support of this
statement.
We likewise wish to register with you our support of the
proposed rule to change the size and location of aircraft registra-
tion markings to require aircraft to have an identifying number on
the underside of the wing.
Thank you for your consideration.
Very truly yours,
Reymond L. Regan
Raymond L. Regan
Mayor
RLR:rr
PRIVATE CITIZENS
William D. Daugherty
8336 Chase Avenue
Los Angeles, Calif. 90045
January 15, 1975
Department of Transportation
Federal Aviation Administration
Washington, D. C., 20591
Reference: Draft Environmental Impact Statement for
Civil Airplane Fleet Noise Requirements
Gentlemen:
As a resident near Los Angeles International Airport I urge you to approve
the Sound Absorbing Material (SAM) Program to quiet the jet aircraft which
do not meet Part 36 of the Federal Air Regulation.
This and future aircraft noise attenuation techniques are essential to
restoration of property values and the physical and mental well-being of
residents in such noise impacted areas. Because of the present high noise
levels in and around airport installations a considerable amount of
property has been condemned and removed from the tax rolls. With every
reduction of consequence in dB level, parcels could be recovered and put
into private and productive use.
Sincerely yours,
William D. Daugherty
WDD:db
a
deea
10. wepan ment 01 reaeral
Aviation Administration
RE: "Draft Environmental Impact Statement
for Gvil Airplane Fleet Noise Requirements"
Gentlemen,
I am in Favour of approval of Sound Abserbing
Material (SAM) Program to quiet the present
noisy fleet of jets which do not meet Part 36
of the Federal Air Regulation.
We are living in the area of has Angeles
International Airport where two hundred thousand
people are subjected to excessive naise levels.
The Airport expansion Foreid condinination -t
3000 homes and 2 major schools and displaciont
of over 10,000 people.
Many communities around the country suffer
from similar problems: Loss of residential
property value, defereara of educational
standards diw. to noise interruptions, loss of
sleep and hearing, nervores disorder property
condemnation pig costs oF litigation.
100,000 people on the ground should desire
the same consideration as 100 people inanoisy
plane. Some reasonable compromise be the
conflicting rights of people should be reached.
SAM program would substantially reduce
the untokrable naise levels and preserve binding
residential communities From Further determation e
which we cannot afterd.
The costs of implementation could be received
by witon ling the unnecessary flights. Many
planes take off with only 50% of passengers
or less aboard. Some coordination between Airlins
and streamlining of waste Ful procedures could
sowe money to help SAM Program.
A speedy approval is urged.
sincerely
ANDREW F. STEFANSKI
7296 W. 85th St.
1-14-75
Los Angeles, Cal. 90045
C. A. N. citizens against noise
2729 W. Lunt Ave.
Chicago, Illinois 60645
(312) 274-0980
23 January 1975
Dear Mr. Foster
We are responding to your Draft Environmental
Impact Statement for Civil Airplane Fleet Noise Requirements.
We find serious shortcomings in three areas, which we hereby
detail.
1. We find mention but no intent to regulate land
use around airports. While we agree that retrofitting and
other mechanical restrictions on aircraft are essential to
the control of airport noise, regulations must also take into
consideration the areas on which noise impacts. Since the
local governments have abdicated this responsibility of re-
stricting residences to reasonable distances from the areas
of airports, it falls upon the Federal Government to do so.
We would suggest that the immediate ring around airports be
restricted to heavy and noisy industries, and that at in-
creasing distances from airports, lighter manufacturing be
allowed, then office buildings and residences, farthest away.
2. We can find in these documents no mention of
supersonic transports or the control of noise from aircraft
at supersonic speeds. We feel this is a serious omission
which needs correction.
3. We wonder why these regulations are restricted
to civil fleets. While commercial jetliners create the most
noise in the broader area of airports, general aviation is
responsible for much noise closer to airports. Furthermore,
there is no military advantage to noise--nay, some real tac-
tical advantages to quiet. In addition, civilian areas
around military airfields are impacted more heavily in some
cases by aircraft noise than are like areas around civilian
airports. We therefore request that these or similar re-
gulations apply equally to noise from military aircraft.
Sincerely,
Bernd
THEODORE BERLAND, President
Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
TB:hj
CC: Dr. Alvin Meyers, ONAC, EPA, Sen. Stevenson, Sen. Percy,
Cong. Yates
COMMUNITY PLANS, INC.
Westchester - Playa del Rey
Post Office Box 90632 - Los Angeles, California 90009 - Telephone (213) 823-2628
Office of the Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
Ref: Draft Environmental Impact Statement for
Civil Airplane Fleet Noise Requirements
Gentlemen:
Community Plans Incorporated urges adoption of the "Sound Absorbing
Material" (SAM) retrofit program to bring the noise levels of all "narrow
body" commercial aircraft within the standards of FAR Part 36 as soon
as possible. Our preference for the SAM retrofit program over the "Refan"
proposals for near-term improvements in the acoustic environment around air-
ports throughout the nation are based on the following facts.
1. SAM retrofit will provide earlier relief than Refan.
2. SAM would apply the noisiest aircraft, e.g., 707s, and
DC-8s, as well as 727s, 737s, and DC-9s, whereas the
refan program would apply only to the latter group.
3. SAM would be less costly than Refan.
Our preference for the SAM program should not be construed as implying
opposition to the Refan proposal per se. We believe airport neighbors should
be able to enjoy some relief from aircraft noise as soon as possible; and we
believe as many aircraft as possible should be included in any retrofit program.
CPI would also enthusiastically support a more comprehensive two phase
program of retrofitting all aircraft with SAM now, and followed by a second
phase later to include refanning those aircraft which could benefit from
additional noise reduction.
If, contrary to our recommendation, you should choose the Refan
program for 727s, 737s and DC-9s, we would strongly urge that the SAM
program be made mandatory for 707s, DC-8s and other aircraft not covered by
the Refan program.
We further believe that any noise reduction rule adopted should
apply equally to foreign and domestic airlines operating in the United States.
COMMUNITY PLANS, INC.
Westchester - Playa del Rey
Post Office Box 90632 - Los Angeles, California 90009 - Telephone (213) 823-2628
Community Plans Incorporated is a citizen planning organization
made-up of residents and business people in the Westchester-Playa del Rey
area adjacent to the north side of Los Angeles International Airport.
Over the past eight years we have repeatedly supported measures aimed
at reducing noise impact on airport neighbors; eg quiet engine/nacelle
retrofit, compatible land use, federal noise standards, preferential run-
way useage, two-segment approach, and California state noise standards in
the absence federal noise standards.
We trust you will give our views due consideration in reaching a
decision which will bring some measure of relief, as soon as possible, to
the multitude of people who have suffered for years from excessive air-
craft noise.
Very truly yours,
morgan
Normand E. Morgan, President
Community Plans Inc.
Indianapolis Airport Authority Weir Cook Municipal Airport
EXECUTIVE DIRECTOR
DANIEL C. CRCUTT
INDIANAPOLIS, INDIANA 46241
(317 747-527:
January 24, 1975
Council on Environmental Quality
722 Jackson Place, N.W.
Washington, D.C. 20006
Re: Draft EIS for Civil Airplane Fleet Noise Requirements
Prepared by F.A.A./D.O.T December 1974
Gentlemen:
The Indianapolis Airport Authority operates a medium-hub air
carrier airport serving the metropolitan Indianapolis area.
The Authority, in developing its Airport Master Plan, has
examined the noise impact area around Weir Cook Airport. Be-
cause the airport is only 6½ miles from the center of the city,
its noise footprint encompasses a major portion of the metro-
politan area.
Because of the significance of noise impact on our community,
the Airport Authority has been very active in its support of
reduction of noise at its source. We have examined and evaluated
sound absorption material programs VS. refan programs. We've
waited patiently for more than ten years for effective noise
relief. Because of three close-in residential areas, which are
subjected to continual aircraft noise from airplanes on their
approach to Weir Cook Airport, we have been subject to a great
deal of criticism and complaint from the general public.
In examining our alternatives of the Airport Master Plan, it
was determined that the airport could remain in its present
location only if there was significant relief from aircraft
noise at its source, and a corresponding land acquisition pro-
gram with vicinity land-use planning and zoning to complement
an aircraft noise reduction program. In order to be effective,
the aircraft noise reduction program must meet FAR Part 36
immediately, with future reductions by 1980.
The Airport Authority has responded to the ANPRM (Civil Airplane
Fleet Noise Level), participated in the EPA study analysis impact
of aircraft/airport noise, and reviewed more than twenty docu-
ments and reports issued by EPA and Congress on this problem.
We are convinced and support 100 per cent the SAM program. We
-Cont. on page 2--
BOARD MEMBERS: Arthor 5 hearn
Michael G. Schaeter
Milton H. Slosson
Robert L. Dawson
Pies dent
Vice President
Secretary
Member
Council on Environmental Quality
January 24, 1975
-2-
are disappointed in two points now contained in the EIS that
were not contained in the original NPRM. One, is the compliance
schedule; and the second, to omit foreign-manufactured, 4-engine
aircraft. Although at the present time we do not have any
foreign 4-engine aircraft operating from our airport on a regu-
larly scheduled basis, we do have an occasional charter aircraft
which would be exempt under the NPRM considered by the EIS.
Since we had commented on the original NPRM and this feature was
not included, we do not feel that an EIS is an appropriate place
to make a change and the agency should be required to publish
a proposed change.
The second change from the original proposal is of a much greater
concern. We have already waited more than ten years for a meaning-
ful noise relief. The citizens around our airport and airports
across the country are entitled to responsive Federal action with
a firm date. F.A.A.'s proposal to now change the dates from
June 30, 1976, for retrofit on one-half the fleet, and June 30,
178, for retrofit on the balance, is unacceptable. The previous
published dates should stand.
Subject to these two comments, we urge the immediate approval
of the EIS and implementation of the sound absorption material
program.
Sincerely,
DailDraiss
Daniel C. Orcutt
Executive Director
DCO/ca
CC: Mr. Chuck Foster
Director
Office of Environmental Quality
FAA - 800 Independence Ave. S.W.
Wash. D. C. 20591
METROPOLITAN NASHVILLE AIRPORT AUTHORITY
METROPOLITAN AIRPORT
P.O. BOX 17208
NASHVILLE. TENNESSEE 37217
COMMISSIONERS
ALBERT J. HUBER. A.A.E.
EXECUTIVE DIRECTOR
HAROLD J. BLACK, P.E., CHAIRMAN
JAMES L. HARPER, VICE CHAIRMAN
FRANKLIN JARMAN
TELEPHONE (615) 259-3801
WHITNEY STEGALL
JOHN C. TUNE
C. D. WALLING, JR.
DAVID K. WILSON
January 28, 1975
Council on Environmental Quality
722 Jackson Place, N.W.
Washington, D. C. 20006
Gentlemen:
I am in receipt of a January 14, 1975 letter written to you by J. Donald
Reilly, Executive Vice President of Airport Operators Council International,
expressing AOCI's position as favoring the Draft Environmental Impact
Statement for Civil Airplane Fleet Noise Requirements (SAM).
The Metropolitan Nashville Airport Authority is a member of the AOCI, and I
wish to state our support of subject Environmental Impact Statement. We did
go on record by letter of June 17, 1974 (attached) favoring the Sound
Absorbing Material (SAM) method as an effective means of reducing aircraft
noise levels. From an airport operating standpoint, expeditious rule making
enforcement procedures will be very helpful in presenting plans and programs
for expansion and development of airport facilities. Issuance of a final
Environmental Impact Statement on SAM will fulfill FAA responsibilities under
the National Environmental Policy Act of 1969.
While AOCI in representing its member airports has already provided you with
an Association position, we wish to go on record as supporting the drafted
Environmental Impact Statement.
Yours very truly,
OH
Albert J. Huber, A.A.E.
Executive Director
AJH:KM
cc: Mr. Chuck Foster
Office of Environmental Quality - FAA
Mr. J. Donald Reilly
Executive Vice President - AOCI
Mr. Herbert Banks, Airport Manager, Chattanooga, Tennessee
Mr. William K. Hart, Airport Manager, Johnson City, Tennessee
Mr. Robert H. Wood, President, Memphis-Shelty County Airport Authority, Memphi
Mr. Henry A. Willis, Director of Aviation, Knoxville, Tennessee
Tennessee
NASHVILLE METROPOLITAN SMYRNA
MEMBER: AOCI
AAAE
TAACA
-
METROPOLITAN NASHVILLE AIRPORT AUTHORITY
METROPOLITAN AIRPORT
P O. BCX 17208
NASHVILLE TENNESSEE 37217
COMMISSIONERS
ALBERT J. HUBER. A.A.E.
EXECUTIVE DIRECTOR
HAROLD J. BLACK, P.E., CHAIRMAN
JAMES L. HARPER, VICE CHAIRMAN
TELEPHONE (615) 259-3801
franklin JARMAN
WHITNEY STEGALL
JOHN C. TUNE
June 17, 1974
C. D. WALLING, JR.
DAVID K. WILSON
The Honorable Howard H. Baker, Jr.
United States Senator
2107 new Senate Office Building
Washington, D. C. 20515
Dear Senator Baker:
We have received a copy of Mr. Rellly's June 7. 1974 letter to you
outlining reasons the Airport Operators Council international Is
strongly orging that the Federal Aviation Administration issue its
proposed regulations covering aircraft noise abatement. As Indi-
coted In Nr. Reilly's letter, the Metropolitan Hashville Airport
Authority is a member of AOCI and supports the Council's position
with respect to this long standing Item of business.
We are of the opinion that if Industry and government do not earnestly
and sincerely address themselves to the business at hand, community
renstion to unregulated aircraft noise will continue to cause oppos!-
tion to further development of the nation's system of airports.
Economics and technology set cut in the packet of material attached
to Mr. Rellly's letter clearly Indicates that a reasonable objective
type "retrofit" aircraft noise abatement program can be mutually
supported at this time by both Industry and government. Speaking as
an airport operator, we are continually aware of what can happen on
the local scene with respect to recolving community support for
continued airport expansion and development programs. Presently the
Metropolitan Nashville Airport Authority is In the process of
developing plans and construction programs covering building a
rellever airport in the western sector of Davidson County. One of
the first things residents in the proposed construction area
expressed was concern with aircraft noise. The Airport Authority
presently operates three other airports, and understandably so, noise
emission is always a point of concern and contention any time public
hearings are held.
NASHVILLE METROPOLITAN- SMYRNA
MEMBER: AOCI
AAAE
TAACA
The Honorable Howard H. Baker, Jr.
June 17. 1974
Page 2 --
While appropriate regulating agencies of government have been moving-
ahead with review of their respective activities In this area, we
are at a point where something concrete can be done now to comply
with original Intent of Public Law 90-411, passed by Congress in 1968.
Proven application of sound absorption material (SAM) as an Interim
measure for full retrofit and introduction of the "two-segment"
approach procedure for keeping aircraft noise away from populated
areas as fully discussed In Mr. Reilly's letter offer an acceptable
solution to providing a meaningful aircraft noise abatement program.
We would like to take this opportunity to endorse AOCI's stated air-
craft noise abatement position, joining other concerned airports in
urging your favorable consideration for Implementation of a meaningful
program, encouraging the Federal Aviation Administration to issue its
proposed rule making covering one of civil aviation's most pressing
problems.
Sincerely,
DH
Albert J. Huber, A.A.E.
Executive Director
AJH/h
CC: Mr. J. Don Rellly, AOC1
Mr. Herbert Banks, Chattanooga Airport
Mr. Norman Helinski, Director of Public
Service, Knoxville
Mr. Robert H. Wood, Memphis Airport
Mr. William K. Hart, Tri-City Airport
STARTS
COMMONWEALTH Of PUERTO RICO
G.P.O. BOX 2829, SAN JUAN, PUERTO RICO 00936
JUL 10 MAYMI PAGAN
Executive Director
January 23, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D. C. 20591
Dear Mr. Foster:
In response to your letter of December 9, 1974, below please note
our comments on the Draft Environmental Impact Statement for Civil Air-
plane Flight Noise Requirements.
The Puerto Rico Ports Authority, as operator of the public airports
of the Commonwealth of Puerto Rico, has a vested interest in the pursuit of
positive and meaningful action that will result in the amelioration of aircraft
noise. We are not different from many mainland U. S. airports where serious
environmental noise problems exist. In particular, the urban areas of Puerto
Rico are subjected to high-noise levels resulting from many sources including
the noise associated with aircraft landing or departing from the many airports
within the Commonwealth. Therefore, the Ports Authority believes that it
must address to some of the topics discussed within this Draft Environmental
Impact Statement.
The noise certification standards and procedures established under
FAR Part 36 were indeed welcome to the airport operators as they indicated
that quieter aircraft would be available in the very near future. In Puerto
Rico, we have seen the direct results of these regulations at the Puerto Rico
International Airport, located east of San Juan. In the last four years this
airport has seen a dramatic change in equipment, from the noisier B-707 and
DC-8 series aircraft to the more quiet B-747, L-1011, and DC-10 aircraft.
This is primarily because San Juan is a long-haul, high-density market, and
the carriers could operate more efficiently and profitably by using the wide-
bodied aircraft in this market.
Mr. Charles R. Foster
-2-
January 23, 1975
The Puerto Rico International Airport is by no means free from the
noise attributed to the older series aircraft. We have numerous foreign and
domestic supplemental air carriers operating from the airport which utilize
the older, noisier U. S. -manufactured equipment. Therefore, the Puerto
Rico Ports Authority is vitally interested in any program that will substantially
effect the replacement or modification of these older aircraft.
The Ports Authority encourages and agrees. to any proposed action
that will provide meaningful relief to the general public. The action outlined
in subject Environmental Impact Statement will definitely reduce the noise
impact associated with aircraft operations and is, therefore, of importance
to the Authority.
Since the International Airport is served by many foreign carriers,
with U. S. -manufactured equipment, the Ports Authority believes that the
provisions outlined for foreign or overseas commerce are appropriate. Some
of the foreign operators are already utilizing wide-bodied aircraft on their
high-density, long-haul routes, and the provisions of the Environmental Impact
Statement would insure that they continue to operate this equipment.
The Draft Environmental Impact Statement states that financial aspects
of the retrofit program should not be considered a subject for comment. How-
ever, when weighing the cost/benefits of the retrofit program, we must consider
financing. The Federal Aviation Administration must give consideration to
financing methods which will insure that the air carriers will not further in-
crease the passenger fares in order to recover their retrofit costs.
The noise benefits derived from the proposed action will provide
meaningful relief by significantly reducing annoyance levels in the vicinity
of airports. However, the potential penalty of increased fuel consumption
must be closely scrutinized. The Draft Environmental Impact Statement in
its present form, considers the increased fuel consumption as a negligible
result far worth the benefits derived from the proposed action. This is
evident in the statement that "retrofit would change total energy use by no
more than 013%". (Page 23 of the drafted document). However, in the
same paragraph it indicates that the air carrier fuel use would be increased
by 4, 000 barrels per day, or on an annual basis, 1, 460, 000 barrels of addi-
tional fuel consumed. We believe that this increased consumption of aviation
fuel cannot be dismissed lightly. The increased demand for aviation fuel,
coupled with the dwindling world supply of petroleum products, clearly calls
for positive action to retain our natural resources where possible. Therefore,
the Ports Authority urges the Federal Aviation Administration, in preparing
Mr. Charles R. Foster
-3-
January 23, 1975
its final Environmental Impact Statement, to more thoroughly consider the
total impact of this additional fuel consumption versus the noise benefits
derived from the proposed action.
In summary, the Ports Authority endorses and agrees to the retrofit
program. But at this moment our main concern is the matter of getting some
assurances that any of the costs of the retrofit program be not passed on to
the air traveller. In addition, the Federal Aviation Administration should
give thorough consideration to the matter of changes in fuel consumption versus
the benefit derived from the proposed rule.
Finally, we concur with the AOCI's position in that the retrofit com-
pliance schedule set forth in the draft outlines timing which may prove to be
very slow in providing relief to the affected communities. We favor expedi-
tious relief.
Many thanks for the opportunity to express our views on this important
matter.
Sincerely,
Maymf Pagan
Executive Director
AIRPORT AUTHORITY
BOX 80407, LINCOLN, NEBRASKA 68501
Mr. Chuck Foster, Director
Office of Environmental Quality
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
LINCOLN
MANN
...a short distance from anywhere
January 23, 1978
Council on Environmental Quality
722 Jackson Place, N.W.
Washington, D.C. 20006
Dear Sir:
We would like to go on record as fully agreeing with the letter
submitted by the Airport Operators Council International on January
14, 1975 in reference to the Draft Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements prepared by the Federal
Aviation Administration dated December, 1974.
Airport noise is a major problem which we feel must be tackled
at the source as soon as possible. Since the EIS is the next step
in the process, we recommend its approval so the Proposed Rule can
become established law and the problem of noise can be met head on.
Sincerely,
AIRPORT AUTHORITY
Joseph H. Hills
Administrative Assistant
JHH:pw
CC: Chuck Foster, Director
Office of Environmental Quality
City of 100 Angeles
1 World Way
Los Angeles
Depart ant of Aliports
Los Annutos, California 90009
Ortano
V3
Tom Brade i. Mayor
213/043-5252 Telex 65.3013
Paimidate
ird of
loft Commissioners
January 6, 1975
Amounts
Pape
Ref: Docket No. 13582; Notice No. 74-14
Benefit
Civil Aircraft Fleet Noise Requirements
for A. Moore
Draft Environmental SmpasunStatement
viral Manager
for Civil Airplane Fleet Noise
Requirements
Federal Aviation Administration
Office of the Chief Counsel
Rules Docket, AGC-24
800 Independence Avenue, S.W.
Washington, D.C. 20591
Dear
Sir:
The City of Los Angeles, Department of Airports has carefully
reviewed the referenced Draft Invironmental Impact Statement.
This draft was submitted in support of Docket No. 13582. The
following comments are intended to supplement our letter of
April 5, 1974 concerning this docket.
In studying this EIS, we note in Item 5 of the summary sheet
that comments have been requested from various entities. We
are very concerned in looking at this list that there is not
one airport or airport association listed. It is obvious that
the airports and their neighboring communities have long
received the major brunt of the aviation noise problem. As
a consequence, items such as this EIS associated with noise
reduction regulations are of great interest to the airports.
For the good of the air transportation industry and the
interest of the airports that act as the ground base of their
operations, the airports must become involved,
In general after studying the EIS, we agree that the sound
absorbant material (SAM) retrofit program, coupled with all
safe sound abatement flight procedures, is a proper approach
to the noise problem. The airports cannot wait for the refan
program, nor can they exist without severe operational
restrictions if nothing is done. The SAM program, with flight
procedures, will provide noise relief within a proper time
frame with the greatest cost benefit.
Federal Aviation
-2-
January 6, 1975
Administration
On Page 23 of the EIS, we note the statement that it might be
possible for sound abatement flight routings to be eliminated with
retrofit. The reverse traffic "over-water procedures" at LAX is
cited as an example. It must be pointed out here that aircraft
operating to Part 36 levels are still noisy. This category, by
any impact methodology, will still require large compatible land
use zones under the airport flight paths. As a result, sound
abatement routings will still be required to reduce the noise
impact to its lowest denominator.
In considering the timing of retrofit presented in the EIS, we
would completely support the change from that shown in NPRM 74-14.
The EIS proposed scheduling of 50 percent compliance in 36 months,
with 100 percent compliance in 48 months from the date of the
regulation, appears reasonable. The entire project should go
forward with the utmost speed.
We appreciate the opportunity to comment on this EIS.
Very truly,
Clifton A. Moore
General Manager
CAM: BJL: jb
CC: Don Reilly, AOCI
Russ Hoyt, AAAE
METRO SUBURRAN
ASSOCIATION INC.I
Jeris
10
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O. BOX 88
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Jada Inwood, L. I., N. Y. 11696
vd Titue
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213 gift ni January 22, 1975 nI
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BE 02 to
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
800 Independence Avenue SWiemmoo
Washington, DC 20591
VISV
RE: Environmental Impact Statement
Civil Airplane Fleet Noise Requirements
.A
Dear Sir:
The recent Environmental Impact Statement on retrofit indicates
the need for such a program to lower the noise residents around airports are STATE
jected to.
We recommend the retrofit program be put into effect immediately.
Yours for quieter skies,
Josh Joseph R. R. Lewis 1
President, METRO
January 24, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Washington, D. C. 20591
Reference: Comments on the "Draft Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements" dated
December 1974
Dear Mr. Foster:
A very high priority should be assigned to the implementation of
the Federal Aviation Administration program to reduce jet aircraft
noise in the communities which surround airports. The airport area
have subsidized the airline industry far too long by putting up
with the excessive and unnecessary noise generated by the low flying
aircraft. It is time for the airline industry to start acting the
part of a good neighbor, if not voluntarily then involuntarily.
On page 5 of the draft it is noted that "a safe and practicable
application of acoustic technology has been developed and tested
that would allow aircraft certification prior to the effective date
of FAR Part 36 to be modified to meet the noise level certification
standards while maintaining compliance with appropriate airworthiness
safety standards."
On page 14 the National Research Council of the National Academy of
Sciences and the National Academy of Engineering is quoted. "We
believe that the above reductions in aircraft noise level represent
significant and beneficial improvements, which will provide meaning-
ful and perceivable relief to airport neighbors. Recent research
had indicated clearly that aircraft noise reductions on the order of
6 EPNdB are quite apparent to residents near airports and result in
substantially less annoyance to those residents."
The Supreme Court, this past week, has put the airport operators on
notice that it is going to be very expensive for them to operate the
airports in a noisy manner. The court has let stand a $650,000
damage claim against the Los Angeles International Airport. It
appears this is only the beginning of law suits against irrespon-
sible airport operators.
All technical, safety and economic barriers have been overcome
towards making the commercial jet aircraft using U.S. airports to
comply with at least FAR Part 36 noise levels. It is the FAA's
responsibility to eliminate any further delay and institute an
accelerated SAM retrofit program to provide relief to the airport
area residents.
2.
C. R. Foster, FAA
Jan. 24, 1975
The airline industry has demonstrated their lack of concern by
failing to voluntarily install SAM retrofit kits to quiet their
existing jet aircraft. The airport operators now face costly court
suits and damage claims because of inadequate planning and of
excessive noise around airports. The alternative open the the
airport operators is to acquire the noise impacted land. Both
options are far more costly than the cost of the SAM program.
The FAA should adopt an effective noise abatement program by:
1) A SAM retrofit of all jet aircraft, both foreign and domestic
which use U.S. airports, which currently do not meet FAR Part 36
noise levels.
a) One-half of all the aircraft by Jan. 1, 1977.
b) All aircraft by July 1, 1978.
2) All aircraft which have been SAM retrofited will be exempt from
any refan (high by-pass ratio engine) retrofit program.
3) All newly manufactured current model aircraft will use high
by-pass ratio type engines.
4) Eliminate all noise trade-offs such as those described on page
10 of the draft.
5) Establish an absolute fleet noise level rating and institute
a non-degradation standard.
6) Immediately institute operational procedures which willgive
releif now and even more so with SAM engines.
a) Power cut-back on takeoff as proposed by the Air Line
Pilots Association.
b) Flap management technique on approach.
c) Two-segment approach fully implemented by Jan. 1, 1978.
7) Set up an Aircraft Noise Abatement Trust Fund to pay for the SAM
retrofit program and the adoption of the two-segment approach.
The Fund should be funded by:
a) $0.50 to $1.00 surtax on all tickets.
b) One per cent surcharge on all freight way bills.
The charges should be clearly identified as to their purpose
just as the security surcharge is identified.
8) On Jan. 1, 1980, the FAR Part 36 noise levels for all newly
manufactured aircraft should be reduced by 15 EPNdB.
9) Supersonic transport (SST) aircraft will no longer be exempt
from FAR Part 36 noise levels.
Sincerely yours,
Stemy J Frimme
Henry J. Grimme, Secretary
O'Hare Area N.O.I.S.E. Chapter
National Organization to Insure a
Sound-Controlled Environment
7735 West Norwood Street
Chicago, Illinois, 60631
CITY INTERNATIONAL AIRPORT
BIRTH
20101
M LANE CITY, UTAM 64122
A. STUAR MANAGER
January 23, 1975
Council on Environmental Quality
722 Jackson Place, H. W.
Washington, D. C. 20006
Gentlemen:
Salt Lake City International Airport is in favor
of the final adoption of Notice of Proposed Rule Making 74-14.
We feel that retrofit of all aircraft under FAR 36
be completed on the original time schedule and that all foreign
aircraft meet the same requirements as domestic aircraft.
While Salt Lake City has been fortunate with regard
to noise due to its location, there are many airports and their
surrounding communities which need relief immediately or in the near
future.
If we can be of additional assistance in this
important matter, kindly let us know.
Cordially,
Original Signed by
MURRAY A. BYWATER
MURRAY A. BYWATER, A.A.E.
Airport Manager
GHB/fr
CC: Mr. Chuck Foster, Director
Office of Environmental Quality
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D. C. 20591
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800 Independence Avenue, S. W.
Federal Aviation Administration
Office of Environmental Quality
Mr. Chuck Foster, Director
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BLESS
AECMA
ASSOCIATION EUROPEENNE DES CONSTRUCTEURS DE MATERIEL AEROSPATIAL
88 Bd Malesherbes 75008 PAR'S
Téléphone 2922550
Télegr.: ASINCOMA PARIS Ext 037
Telex: SYSTELE PARIS 21550 Ext 31
JH/GEP.
21st January, 1975.
Mr. Charles R. Foster,
Director of Environmental Quality,
Department of Transportation,
Federal Aviation Administration,
Washington DC 20591.
U.S.A.
Dear Mr. Foster,
AECMA Comments on Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements
AECMA, representing European aircraft and engine constructors has
examined FAA Draft Environmental Impact Statement for Civil Airplane
Fleet Noise Requirements and welcomes the opportunity to submit the
following comments.
AECMA is totally opposed to the rule being applied to foreign
operators and considers that such requirements affecting International
commerce must be agreed on an International basis such as would be
provided through ICAO. The number of movements by foreign operators
at the very small number of United States airports apart from New York
(JFK) and possibly Miami given in the draft Environmental Statement is
small compared with the total number of movements at these airports.
It is expected that even at those airports taking the majority of
foreign operated aircraft a higher proportion will be of the newer
technology type and aircraft already certified on the US register with
lower noise levels.
Furthermore we don't consider that the operation of foreign
manufactured and registered aircraft should be subject todifferent
regulations depending on number of engines nor that aircraft which may
be designed to meet the internationally agreed environmental
requirements of ICAO should then be subjected to more severe
requirements when operated into the United States.
The removal of the trade-off allowance for retrofitted aircraft
is considered to be thoroughly anomalous in that it applies a more
stringent requirement for the older type of aircraft than is currently
applicable for new aircraft.
Continued.
ALLEMAGNE BELGIQUE ESPAGNE FRANCE ITALIE PAYS-BAS ROYAUME-UNI SUEDE SUISSE EUROSPACE
- 2 -
AMO3A
Further production of older types are now required to meet FAR
Part 36 levels with trade-offs and will as soon as they enter service
with airline fleets be required to meet the proposed Fleet Noise Rule
which stipulates FAR Part 36 levels with no trade-offs. The issue of
the Fleet Noise Requirement as it now stands will therefore lead to
conflicting legislation.
As stated in the AECMA response to the NPRM No. 74-14, the noise
levels of the older engines may not be well matched to the prescribed
levels at the three measuring points. Engines in service to-day fall
into two categories of low bypass jet engines and turbofans which
present very different problems in achieving the specified noise
levels. This leads us to believe it may be economically practical
to ensure compliance with the noise levels with some margin at two
or the three measuring points but the noise level at the third point
may be difficult to achieve. It is imperative therefore, that the
impact of this should be eased by retaining the trade-off margins
for the retrofitted aircraft and there is a strong case for
increasing the margins to a total exceedance of 4 EPNdB with any
single point not exceeding 3 EPNdB. This suggested modification of
the trade-off margins for retrofitted aircraft would also provide a
noise trade-off standard consistent with that developed by ICAO in
Annex 16 for new aircraft.
Yours faithfully,
J.
A.
HAY.
ip
J.A.Hay
Chairman AECMA Noise Group
From: Mr.J.A.Hay, British Aircraft Corporation Ltd, Brooklands Road,
Weybridge, Surrey KT13 ORN. England.
to
10
Airport Cities Action Committee
8129 Calabar Avenue
GREATER WESTCHESTER HOMEOWNERS ASSGC ATION
Playa del Rey, CA 90291
CITY OF INGLEWOOD
January 14, 1975
PLAYA DEL REY CIVIC UNION
PLAYA DEL REY WOMEN'S CLUB
COMMUNITY PLANS INC.
PALISADES DEL REY PROPERTY OWNERS ASSOCIATION
THE WATCHFUL EYE
NORTH RUNWAY RESIDENTS
Office of the Department of Transportation
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
Subject: Draft Environmental Impact Statement, Pursuant to Section 102(2) (c),
P.L. 91-190
Dear Sir:
We strongly support the use of Sound Absorbing Material as a means to reduce the
noise emitted by air carrier fleets which do not now meet Federal Aviation Regu-
lation Part 36, and we urge approval of the SAM program by the FAA at the earliest
possible date.
Three areas of concern to us, however, are:
1) Page 7, Draft Environmental Impact Statement - "At this time, the FAA is con-
sidering revising the intermediate compliance date to be 36 months from the
effective date of the amended regulation with full compliance required 48 months
from the effective date. This time frame is different from that given in the NPRM
(June 30, 1976 and June 30, 1978)."
The technology is available; a further extension of time is unnecessary. It's
taken our government 17 years to recognize the fact that a severe noise problem
exists. The public should not have to continue suffering for the convenience of
airlines. In this case, the benefit to the public should be the deciding priority.
2) Page 15, Table II-1, Draft EIS - the testing and certification estimates for
takeoff noise reduction (including retrofit) were obtained with a cutback in
engine power.
We believe this should be a built-in regulation within the Civil Airplane Fleet
Noise Requirements, so that engine cutback will be used at all times except in
situations when safety precludes such use.
3) Page 35, Draft EIS - "Another subset of this alternative is the exemption of all
or part of the carriers engaged in international operations (foreign and overseas
air commerce), an exemption considered in the ANPRM."
The abating of noise inflicted on airport neighbors is the basis for the SAM
Retrofit Program. With this purpose in mind, we feel the exclusion of any specific
Page two
Office of the Department of Transportation
Federal Aviation Administration
Draft Environmental Impact Statement
air carriers will certainly not be in the best interests of the public.
Noisy aircraft also damage people and property in other parts of the world.
In conclusion, we believe the SAM Retrofit Program is a beneficial one, and that
it should get underway as quickly as possible.
There is, however, an urgency about tightening up the regulations for the pro-
tection of the public. Aircraft noise is damaging; the reaction of people to it
has caused unending problems to the operation and growth of airports. Therefore,
no further delays should be allowed the airlines in meeting the compliance schedule.
Reduced takeoff noise, gained by engine cutback along with retrofit, should be a re-
quirement stipulated in the Noise Regulations, except when the cutback is considerei
to be unsafe. International carriers make noise too; their exclusion seems to defeat
the whole purpose of the retrofit program.
Seventeen years is a long time to wait for an "improvement". But it is a big step
in the right direction, and worthwhile as long as it remains undiluted by needless
delays and exclusions.
Yours truly,
(Mrs.) Sallie Davison, Chairman
Airport Cities Action Committee
SD:me
CITIZENS FOR A QUIETER CITY, INC.
Box 7777, Ansonia Station, New York, N.Y., 10023 (212)362-4942
F rt Alex Baron, Executive Vice President
February 7, 1975
Mr. Charles R. Foster
Director of Environmental Quality
Department of Transportation
Federal Aviation Administration
Washington, D.C. 20591
Dear Mr. Foster:
CQC cannot undertake at this time to analyze
the technical aspects of the Draft Environmental
Impact Statement for a proposed Federal Aviation
Regulation which would establish standards for
all turbojet aircraft with takeof gross weight
of 75,000 poiunds or greater.
However, COC does recognize that the proposed
regulation is a progressive stop to amcliorate
the airport noise problem. In one sense the
environment is better protected noise-wise if
noise abatement features are built into the
plane itself with secondary reliance on flight
procedures.
It is heartening to see the FAA's apparent new
attitude towards aircraft noise as exemplified
by this proposed regulation. If we have any
quarrel with the regulation, it would be, under-
standably primarily with questions of degree
of a atement and expansion of coverage to all
significant airplane noise sources.
The ideal, of course, is not only the reduction
of the impact of jet noise on sleep awakenings
but on sleep stages, and going even further,
on the quality of the airport/residential
environment using as indices speech interference,
rest, and comfort.
Cordially,
Cabert ale Ban
NEW TOKYO INTERNATIONAL AIRPORT AUTHORITY
2, Akasaka Aoicho. Minato-ku.
TOKYO 107, JAPAN
,T
Mr. Charles R. Foster
Director of Environmental Quality
Federal Aviation Administration
Department of Transportation
Washington, D.C. 20591
U. S. A.
to
February 3, 1975
Dear Sir,
to
Thank you very much for sending me a copy of "Draft Environmental
Impact Statement" which I think will be helpful for us to work
out an appropriate environmental planning for the surrounding
area of our airport.
6 at
ti
Sincerely yours,
ogni
of
yas 11 Bunta Okina
to
IIE 6
Bunta Okino
Consulting Staff
Corporate Planning Office
no 20 10
no
odt to no
86
,JOST
todal
Telegrams: Britair Weybridge Telex Cablegrams: Britair Weybridge Telex: 27111
British Aircraft Corporation Limited
BROOKLANDS ROAD WEYBRIDGE SURREY KT13 OSF
TELEPHONE WEYBRIDGE 45522
E.E. Marshall
Director of Engineering
Commercial Aircraft Division
DE. 4078
27th January, 1975.
Mr. E. R. Foster,
Director of Environmental Quality,
Department of Transportation,
Federal Aviation Administration,
Washington, DC 20591,
U.S.A.
Dear Sir,
We have read with interest the Draft
Environmental Statement for a proposed Federal
Aviation Regulation which would establish noise
standards in the United States for all turbo-jet
aircraft with a take-off gross weight greater than
75,000 lb.. Our general comments on the document
have been incorporated into an A.E.C.M.A. paper
which you will shortly receive.
I should like- to clarify, however, the
retrofit position for the BAC One-Eleven, which is
reported on page 6 of the draft E.I.S..
The hushkits now being developed will allow
the BAC One-Eleven series of aircraft to meet current
I.C.A.O. Annex 16 requirements and tests are expected
to demonstrate that F.A.R. part 36 can be met by the
200 Series One-Eleven. The production kits will be
available twenty months from receipt of orders.
To
date no orders have been received.
Contd
Place of Registration: LONDON Registered Number: 774349 Registered Office: 100 PALL MALL LONDON SWIY 5HR
2.
betimil AsmiA daith
120 КОИАДХООЛЯ
Further development work is being studied
aimed at allowing other versions of the BAC One-
Eleven to conform with FAR Part 36 although currently
no date can be given on the availability of any such
kits. .2501 days
8504.30
If there is any further information on this
topic which you require, I shall be pleased to furnish
it.
To
Issebe?
Yours faithfully,
19810 and 12
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/
U.S.A.
FAA,
Washington DC 20591,
7
Department of Transportation,
Director of Environmental Quality,
MR. C. R. Foster,
WELDWINE
FLY BAC ONE to ELEVEN
SURRE
TO 0175 I 75
WE TDRIDGE
15
1
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bill
IN
POSTAGE
International Air Transport Association
3/4
ACTION AOA#: ORMATION: AEQ-1
26th February 1975
DUE DATE
FOR SIGNATURE OF:
COURDINATION WITH/THRU:
INFORMATION COPY: AIA-1/AFD-1
4426
The Administrator
Fedeal Aviation Administration
800 Independence Avenue S.W
Washington, D.C. 20591
USA
Draft Environmental Impact Statement for
Civil Airplane Fleet Noise Level
Requirements
Sir,
Late last year we were invited to comment on the FAA's "Draft Environmental
Impact Statement for Civil Airplane Fleet Noise Level Requirements", We
reviewed the draft EIS with great interest and it raised many questions and
points in our minds. Because of the short time between receipt of the draft
EIS and the beginning of the fourth meeting of the ICAO Committee on Aircraft
Noise (CAN/4), and because of our desire to study and comment on the draft
EIS in depth, I regret it was impossible to let you have our views by 27th
January. However, they have now been put together and are enclosed. I trust
you will be able to take them into account.
2. Our review has identified a number of assumptions which we feel to be
invalid. In addition, we question some of the philosophies adopted and make
suggestions intended to remove some of our doubts about the validity of any
conclusions which may be drawn in the final EIS.
3. We very much appreciate the opportunity to review the draft and hope our
comments will be useful.
Yours very truly,
nnh
RECEIVED
R.R. Shaw
Asst. Director General - Technical
Encl:
MAR w 81 AM 75
cc: C. Foster, FAA
J. Rudolph, FAA
Administrator, EPA
M. Kane, CEQ
Feb/75
IATA COMMENTS ON DRAFT ENVIRONMENTAL
IMPACT STATEMENT FOR CIVIL AIRPLANE FLEET NOISE
LEVEL REQUIREMENTS
International aspect
1.
At the outset, there is one point of principle we would wish to make most
strongly and that concerns the international nature of the subject in
question. It is stated quite clearly that, in respect of retrofit, all
aircraft, U.S.- and foreign-registered, operating at U.S. airports would be
required to meet FAR 36 without trade-offs, with the sole exception of
foreign-manufactured four-engined aircraft. There exists, as you are well
aware, an internationally agreed set of noise Standards, ICAO Annex 16, and
regardless of whether any State's certification rules are more stringent
than those of Annex 16, all ICAO States are obliged to accept foreign-
registered aircraft at their airports if they comply with Annex 16 Standards.
Although there are no ICAO Standards dealing specifically with "retrofit
candidate" aircraft, it would in our opinion be clearly in contravention
of the spirit of ICAO if the United States attempted to require foreign-
registered aircraft to comply with stricter standards th in those applicable
to noise-certificated aircraft. Further, we consider it totally illogical
to attempt to apply stricter standards to in-service aircraft than those
applicable to future production of identical models. We therefore suggest
that, whatever the U.S. decides ultimately in respect of U.S.-registered
aircraft, no assumption should be made in the EIS that any foreign-registered
aircraft would have to meet the Standards of FAR 36 without trade-offs.
2.
On this general point, it is relevant to review the outcome of the fourth
meeting of the ICAO Committee on Aircraft Noise (CAN/4). The Committee
to all intents and purposes reiterated its Recommendation of nearly two
years ago that "ICAO recommend and encourage " retrofit " of all subsonic
jet aeroplanes
as are regarded by
State of Registry to be
sufficiently effective and economically reasonable". During the discussion
it was clearly stated by one member that his interpretation of this
Recommendation was that, regardless of what it decided to do about the aircraft
on its own Register, no State should try to impose a retrofit requirement on
aircraft on the Register of other States. Indeed, CAN recognised that the
Council of ICAO had already urged States not to take unilateral action on
retrofit until ICAO had completed its study of the question and an inter-
national agreement applicable to all Contracting States had been reached
through ICAO. In this respect, unilateral action has been defined in
the report of CAN/4 as referring to the "imposition of retrofit requirement
by a State on foreign-registered aeroplanes operating into its territory".
The report also indicates that the Committee considered that severe operational
restrictions (such as a total ban on non-noise-certificated aircraft) on
aircraft on the Register of other States would be equivalert to imposing
unilateral retrofit action against the aircraft of those States. For this
reason, we question the principle of assuming that any foreign flag operation
should be required by the United States to be retrofitted. However, as we
point out later in this comment, we doubt whether it would make much
difference to the noise exposure either way.
- 2 -
Public health
3. A second point of principle we would wish to make concerns the oit-repeated
reference to health as well as welfare. The ICAO Special Meeting on Noise
in the Vicinity of Aerodromes (1969) reached the following Recommendation
which IATA completely supports:
"RECOMHENDATION 2/1 - RESEARCH ON THE EFFECTS ON HUMAN HEALTH OF
AIRCRAFT NOISE EXPOSURE IN THE VICINITY OF
AERODROMES
"That
a) it be acknowledged that aircraft noise exposure in the vicinity
of aerodromes has not been demonstrated as being harmful to
health or hearing and that evidence which might so identify it
would be unlikely to come from other than long-range studies
which, to the knowledge of the Meeting, have not yet been
conducted; and therefore
b) selected States and International Organizations, including the
World Health Organization, should be requested to actively
pursue, and collaborate in, medical and psychological esearch
on the effects on man of long-term exposure to noise such as
occurs in the vicinity of aerodromes".
We are not aware of any evidence brought to light since then which would
alter the conclusion of Recommendation 2/1a) above. Because of this we
strongly disagree with the statement in the first paragraph of the intro-
duction of the draft EIS, and repeated elsewhere, to the effect that the
proposed regulation would "provide relief and protection to the public health".
We wouldhope that the final EIS would be free of such contentious statements.
Land use planning and controls
4. As a third general point, we are very concerned by the thought expressed in
the last sentence on p. 42 which we read as admitting that retrofit may
reduce the need for land use planning and controls. We concede that it
may reduce the amount of land for which use planning and controls are required,
but utterly reject any suggestion that land use planning and controls will be
less necessary if retrofit is implemented. In this respect, the 8th ICAO
Air Navigation Conference, 1974, commented in its report that, if further
encroachment of residential areas towards older aerodromes continued, it was
likely that the benefits offered by aircraft noise certification, retrofit,
and operational techniques might be negated. The Conference noted that the
problems of the environment around aerodromes made it necessary for efforts
to be pursued in every field to reduce their magnitude, placing particular
emphasis on planning of urban development, and developed the following
recommendation:
"RECOMMENDATION 11/2 - LAND USE PLANNING AROUND AERODROMES
"That States not already doing so should, to the extent practicable,
take action to develop programmes for compatible land use adminis-
tration and planning around aerodromes, in order to avoid incompatible
development in critical noise areas, both around new aerodromes and
in respect of still undeveloped areas in the vicinity of existing
aerodromes".
- 3 -
Purpose of EIS
5.
It is our understanding that the purpose of the EIS is to demonstrate
whether or not SAM retrofit would provide meaningful relief to a
significantly greater number of airport neighbours presently exposed to
aircraft noise than would be achieved in the absence of a retrofit
programme. In our comments on NPRM 74-14 we suggested that this would not
be the case and nothing in the draft EIS causes us to change our opinion.
In fact, all our comments on NPRM 74-14 generally remain valid.
Use of NEF
6.
The entire study on which the draft EIS has been based has used the NEF
as the noise unit for comparison of various noise reduction strategies.
It anpears that a certain amount of faith has been placed in the calculated
absolute number of people/land area within the NEF 30 and NEF 40 contours.
The concept of adding up the noise energy from a number of single events
into a cumulative unit is accepted. However, the assumptions made in
estimating cumulative noise exposure, especially when forecasting for some
point in the future, are such that the calculated number may not be more
accurate than within ±3 to 5 NEF of what would actually be the exposure in
practice. Some of the factors which lead to this comparative inaccuracy
are variability in actual operating weights, flight procedures, and atmospheric
conditions, as well as the difficulty of accurately forecasting fleet mix
and traffic growth. Thus, while the population within the NEF 30 contour
in 1972 was calculated to be approximately five million (see P. C-26, Fig. 5)
that number could be inaccurate by a factor of up to two. Past calculation
methods have recently been found to have overestimated sideline noise by
up to 15 or more EPNdB. It is suggested that estimations of people/land
area within a given NEF contour as performed in the 23-airport study are
likely to be significantly higher than would be the case if the contours
were based on actual measurement of day-to-day operations. This in itself
would tend to overstate the magnitude of the problem. We would suggest
that the above points be brought out in a strong statement cautioning
against too much faith in the absolute number of people/land area within the
NEF 30 and NEF 40 contours.
Presentation of cumulative noise reductions
7.
The only method used in the EIS to present the benefits from the various
strategies is the reduction of number of people/land area within the NEF 30
and NEF 40 contours. While this method of presentation may not be without
some uses, it does offer serious shortcomings and presents only part of the
story. The main disadvantage is that it greatly over-exaggerates the apparent
significance of any noise reduction. For example, a 15% reduction in land
area, which to the layman would seem to be not insignificant, would probably
be achieved by an overall reduction in noise exposure of about 1 NEF which,
in actual fact, could not even be perceived.
8.
In order to avoid the danger of a wrong decision being taken by people who
may not fully appreciate this relationship, we suggest that an additional
means of quantitatively presenting the results should also be included.
The method we suggest is not a new one; in fact, it was used by Working
Group A of the ICAO Committee on Aircraft Noise (CAN) in its report to the
- 4 -
third meeting of CAN in March 1973. It would involve counting up the
number of people/land area within a given baseline area (say, the baseline
NEF 30 contour) percieving greater than "X" NEF, and X could have a series
of values such as 0, 2, 4, 6, 8, 10, etc. The results could be presented
both airport by airport and as a total of all airports studied. Attachment
1 shows a format which might be used and which is extracted from the report
of CAN/3. This information was derived simply from output data developed
for a six-airport study by the United States in its activity supporting the
work of CAN Working Group A.
9. We have also found it useful to present the same data in a graphical form
and an example is shown at Attachment 2 which shows the way the data in
Attachment 1 were presented to CAN Working Group A prior to CAN/3. The
reason we believe that these additional means of presenting the results
should be included in the EIS is that the people who are affected by
aircraft noise will not really care whether a particular strategy moves them
from just inside a contour to just outside that contour. What will really
concern them is how much noise reduction they will receive if a particular
strategy is adopted. Only if that reduction is large enough to be readily
noticed and appreciated will they be convinced that the stretegy was worth
adopting and only if a significant proportion of those affects are so
convinced will the strategy be worthy of serious considerati
Effect of length of time required to complete retrofit
10. The draft EIS attempts to reach conclusions concerning the significance
of noise reductions resulting from completion of a retrofit programme
compared with the noise exposure in the absence of a retrofit programme.
Whether the conclusions reached are valid or not, the fact that any such
programme would be time-phased over a period of the order of five years,
and the fact that any noise improvements would be only in small increments,
could result in a lack of any perception of improvement by the public.
Airport neighbours would certainly lose the contrast of a before/a :I change
and, as a result, acoustic improvement would be even less likely to be
perceived.
The effect if not applied to foreign flag carriers
11. Considerable emphasis is placed in the draft EIS on the assertion that the
cumulative noise reductions would be significantly decreased if foreig
flag operations were not required to comply with a retrofit rule. In
support of this, the Table at the bottom of page 35 shows the number of
foreign flag operations at a number of U.S. airports and their proportion
of the daily total. However, it is not brought out that, especially at JFK
New York (the airport at which both the absolute number and its proportion
of the daily total are the highest) a significant number of foreign flag
operations are conducted with aircraft which already meet Annex 16/FAR 36 and
are therefore not retrofit candidates. If this Table (and argument) is to
remain in the EIS then it should show just those numbers appropriate to
retrofit candidate aircraft in the columns headed totals of international
and foreign flag operations.
- 5 -
12. The point is made just above the Table that the numbers are appropriate
to 1972. It is strongly proposed that a realistic forecast be made of
similar numbers for the other benchmark years considered in the analysis,
particularly 1980 and 1985. It is suggested that, by that time, the
number of foreign flag operations using retrofit candidate aircraft might
be an insignificant proportion of the total.
13. The Table on p. 36 purports to show the magnitude of the benefit lost if
foreign aircraft are not retrofitted but does so at only one point under
the approach path, being that for which SAM retrofit benefits are generally
greatest. Contrary to what is suggested in the note to that Table, we
believe a more exhaustive analysis is warranted, especially for the take-
off case. Even for the approach we note the lost benefits at Los Angeles
and Chicago are only 2 and 1 NEF respectively, which is hardly significant.
Timing
14. Various assumptions have been made in the draft EIS about the date by which
complete retrofit would be possible. Most of these assumptions are, however,
unrealistic in that they presume that only the U.S.-registered fleet would
have to be provided for but, at the same time, base the noise reductions
on the assumption that foreign flag operations will also be affected - the
intention stated by the FAA both in NPRM 74-14 and in the introductory part
of the EIS. If compliance by foreign flag operations is to be required, then
the compliance date proposed is totally unrealistic. It may not be achiev-
able even if confined to the U.S-registered fleet only, but we have not
studied this problem within IATA. In this respect, the Table on P. B-3
certainly takes no account of kits required for foreign aircraft and may not
take into account the capability of the airlines to install the kits.
15. It is also pertinent here to remark that, if a decision is taken to publish
a retrofit rule within the United States, and if it is decided to make
compliance with such a rule mandatory (by whatever means) for foreign flag
operations, and if it is decided to have a 50% compliance date for such a
rule as proposed, then the severity of such a provision will probably be a
good deal stronger on foreign flag carreirs than on U.S. carriers. In such
a case, we would have to protest most strongly against the competitive
disadvantages of such a proposal.
Noise reductions for individual aircraft types
16. Although the method used for presenting benefits is based on the cumulative
NEF unit, in certain parts of the draft EIS, particularly at the bottom of
p.13/top of p.14, great emphasis is laid on the noise reductions for individual
aircraft claimed to be possible from incorporation of SAM retrofit. We
believe this emphasis is misplaced for two reasons. Firstly, certification
take-off procedures assumed are themselves of academic interest only since
they are not typical of those used in day-to-day operations. Secondly, the
emphasis is laid on the reductions claimed to be achieved at the noise certi-
fication measurement points, but we would point out that the effectiveness
of SAM modifications decreases with increasing distance from the aircraft to
the ground. This reduction in effectiveness was demonstrated in the response
of McDonnell Douglas to NPRM 74-14. The aircraft for which the largest
reductions are claimed is the B.707 series and presentation of the reductions
- 6 -
in the McDonnell Douglas format would show this reduction in effe tiveness
to be a significant factor. Assessment of the B.707 would lead to a
picture much like that shown at Attachment 3 for the take-off case.
17. In that part of the analysis concerning the noise reductions achieved
through the use of FAR 36 type thrust cutback during take-off, no mention is
made of the point at which climb thrust was assumed to be re-applied In order
to enable the aircraft to accelerate and clean up. In the current IATA
take-off procedure (which is similar to that developed by the FAA and ATA),
acceleration and clean-up is commenced at 3000 ft AGL. Informally, we have
understood that the 23-airport study did not assume re-application of climb
thrust until 6000 ft AGL. The safety aspects of such an assumption
are addressed in para. 23 below and we therefore suggest the assumption 1S
unrealistic. For this reason, we believe that the study should, in fact,
consider re-application of climb thrust at 3000 ft and we suggest that this
would substantially change the conclusions concerning noise reductions.
Indeed, it is pertinent to note that according to a calculation carried out
by this Association a SAM-treated 707 at typical take-off weights, using
the FAR 36 type thrust cutback at 700 ft and re-applying climb thrust
at 3000 ft, would in fact make some 4 or 5 EPNdB more at distances greater
than 70,000 ft from brake release than an untreated 707 at the same weight
using the IATA take-off procedures.
18. In para. 24 below we raise doubts as to the flight acceptability of an inlet
ring in some of the SAM designs for the sole purpose of reducing noise,
The doubts are raised in respect of the effect of the ring on safety and
reliability of service. If indeed it should be agreed that the ring should
not be permitted, then the reductions due to SAM on the 707 in the approach
might look very much as shown in Attachment 4. We would like to suggest
that information for individual aircraft types should be shown in this format
rather than in Table II-1 on P. 15.
19. While we are aware that final agreement has not yet been reached 1 tween the
FAA and Douglas on the baseline noise levels of DC-8 series aircraft, we
feel that the reductions assumed possible for the DC-8s, as shown in Table
II-1, are overly optimistic. The reductions assumed by the FAA seem to
have been based on what has been claimed possible for the B. 707. Experience
with the B.747 has shown the effect on noise of eliminating blow-in doors.
Elimination of blow-in doors is also a feature of the B. 707 retrofit kit.
However, the DC-8s do not have blow-in doors in their baseline condition so
that particular noise reduction element will not be available. Further,
the DC-8-62s and -63s already have a long duct nacelle. For these and
other reasons, we believe that noise reductions possible for the DC-8s are
unlikely to be nearly as large as assumed in the draft EIS and suggest a
re-work using more realistic values.
Flight operational procedures
20. As mentioned in para. 16 above, the noise certification take-off procedure
will not be typical of day-to-day operations; nevertheless, the draft EIS
appears to suggest that such a procedure should be used routinely in order
to get maximum efficiency from SAM retrofit. In para. 23 below, a number
of comments are presented which question the wisdom of adopting such a
procedure on safety grounds. Until such time as all of the points raised
- 7 -
there have been examined, we do not believe that use of such a take-off
procedure should be considered acceptable. We therefore suggest that the
relevant sections should be deleted from the draft EIS and we note in
passing that the benefits of SAM retrofit would therefore be much less than
claimed to be readily achievable.
21. IATA has commented already on two-segment approach suggested in ANPRM 74-12
and, for much the same reasons as outlined above in respect of large thrust
cutbacks on take-off, we would suggest that adoption of the two-segment
approach as a possible strategy should not be addressed in the EIS.
22. The effect of removing both large thrust cutbacks on take-off and two-
segment approach as potential strategies would delete from Figures I and II,
PP. 23-30, all points except 1, 5, 9, 13 and 17. If this were done, we
believe a totally different picture would be presented.
Take-off procedure
23. Much of the benefit claimed for SAM retrofit comes from the assumed use of a
FAR 36 type thrust cutback during take-off. Considerable efforts have been
made by the industry in recent years to standardize take-off procedures to
the greatest extent possible. Elimination of variations in some of the
parameters has, it is felt, contributed to an increase in safety levels in
the take-off phase and for this reason the airlines are strongly opposed to
any reduction in the degree of standardization. The current procedure being
used by IATA Member Airlines (which is similar to that developed by the FAA
and ATA) was developed taking into account many factors, one of which was the
desire to minimise the noise exposure on the ground. If this procedure is to
be changed to one using essentially a FAR 36 type thrust cutback, firstly this
would have to be done for all aircraft types and on all occasions, and
secondly the effects of all the factors (including but not limited to noise
exposure) must be taken into account. In this respect we would comment as
follows:
i) since FAR 36 type thrust cutback will virtually amount to the
loss of one engine, it would be necessary to re-examine all
existing departure routes (minimum noise routes, SIDs) to ensure
adequate terrain clearance under these conditions;
ii) due to reduced altitude after cut-back, early turns (for example,
for minimum noise routes) may be ruled out;
iii) current SID procedures, and the associated workload, favour use
of the standardized take-off technique now in use, whereas
revised take-off procedures would undoubtedly aggravate the
workload problem;
iv) an encounter with a severe tail windshear during initial climb
would usually require reduction of rate of climb to permit com-
pensating acceleration. The available margin would be consider-
ably reduced with a large power reduction. There is significant
evidence of the occurrence of severe tail windshear which there-
fore raises questions about the safety of routine large power
reductions during take-off while still close to the ground;
- 8 -
v) in busy terminal areas the reduced rate of climb resulting from
a large power cutback shortly after take-off could be expected
to generate additional ATC problems;
vi) there would be a risk of degradation of safety in adverse
weather such as icing conditions or turbulence;
vii) the aircraft would be kept in a hostile traffic environment
longer, increasing the exposure to collision or near-miss with
other low altitude aircraft;
viii) unless climb thrust were to be re-applied upon reaching 3000 ft
AGL, the time spent with a margin of only 10 kt above V₂ would be
considerably lengthened. This might increase the presently
acceptable small probability of stall to the point where it was
unacceptable.
As mentioned in para. 20 above, until such time as all of the above factors
have been examined, we do not believe consideration should be given to the
effect of the FAR 36 type thrust cutback on the noise exposure we suggest
the relevant parts should be deleted from the draft EIS.
Ring in the inlet of JT3D nacelle
4. Much of the noise reduction claimed for the B.707 (and perhaps also the DC-8?)
on approach is due to the inclusion of a ring in the inlet of the treated
nacelle. While it may be possible to design and install a ring in such a way
as to meet basic airworthiness requirements, it is suggested that there are
potential effects on safety and operating reliability which would make it highly
undesirable to have any hardware mounted in the inlet in this way. Certainly
the proposed location of the ring would increase the work required for certain
maintenance tasks on the engine and we believe that a much greater analysis
of its acceptability should be undertaken before credit is given it noise
reduction in the EIS. As mentioned above in para. 18, the noise reductions
for SAM modification of the B.707 would be substantially less than those
claimed if the ring were not included.
Cost/benefit analysis
5. The draft EIS contains much detail on the estimated costs of a retrofit
programme and then relates these costs to the benefits. The costs assumed
are those relevant only to the U.S. carrier fleet. However, if the U.S.
were to require compliance by all foreign carriers operating into U.S. airports,
the total costs would be significantly greater. While it is true that
theoretically not all of the aircraft of the affected types on the fleets of
foreign carriers concerned would need to be retrofiteed, in order to retain
their essential operating flexibility it is probable that in practice the
entire foreign fleets of affected carriers would have to be retrofitted.
This would probably make the total costs about double those for the U.S. fleet
alone.
6. At the fourth meeting of CAN, recently concluded, the U.S. member presented a
working paper (CAN/4-WP/56) explaining, among other things, the concept of
ratio of marginal benefit to marginal cost. While we do not completely
- 9 -
understand how the marginal benefits were assigned dollar values, it is
quite clear that if the marginal costs were doubled, the ratio of marginal
benefits/marginal costs would be halved. The paper makes the contention
that any strategy having a marginal benefit/marginal cost ratio greater
than unity is cost beneficial. In para. 4.5 of the paper, the ratio for
SAM 3D/8D is shown as 1.4 However, if the total cost is taken into
account, this might be reduced as low as 0.7 which would clearly not be
cost beneficial according to the assumed criterion.
Attachment Li
Estimated number of people within the selected
baseline total noise exposure contour perceiving
greater than a given noise exposure level reduction
МЕСЬИГ
Number of people within Baseline 78 WECPNL
Retro-
Max.
18 МЕСЬИГ
AIRPORT
fit
contour perceiving reduction
WECPNL
Ontion
>0 WECPNL
>5 WECPNL
>10 WECPNL
15 WFCPNL
Reduction
NJS
^
NFF
NJS
546,000
42,000
-
-
5.3
B
NFF
NJS
712,000
-
-
-
4.7
C
NFF
712,000
712,000
-
-
8.6
NJS
115,000
-
-
-
4.2
D
NFF
115,000
3,000
-
-
5.6
NJS
177,000
116,000
77,000
-
11.4
E
NFF
177,000
157,000
107,000
52,000
16.4
NJS
39,000
1,000
-
-
5.4
F
NFF
39,000
25,000
-
-
8.0
NOTE: WECPNL is the ICAO unit of cumulative noise exposure comparable
to NEF; NJS stands for nacelle and jet suppression which is
roughly comparable to SAM plus an exhaust ejector; NFF stands
for new front fan which is comparable to the refan alternative.
Attachment 2=
Number of people within the selected baseline total noise
exposure contour perceiving greater than a given noise exposure level reduction
100%
100%
NJS
% people peoplewithin within baseline 78 WECPNL
ontour perceiving reduction> a WECPNL
NFF
75%
50%
25%
AIRPORT AIRPORT
% people within basline 78 WECPNL
contour perceiving reduction > 4 WECPNL
75%
50%
AIRPORT
a AIRPORT
AIRPORT
AIRPORT E
AIRPORT
&
25%
D
F
0
5
10
0
15
5
10
15
WECPNL
WECPNL
Number of people within Baseline 78 WECPNL
Retro-
Max.
AIRPORT
fit
contour perceiving reduction
WECPNL
Option
>0 WECPNL
75 WECPNL
>10 WECPNL
>15 WECPNL
Reduction
NJS
A
NFF
NJS
B
NFF
NJS
712,000
-
4.7
C
NFF
712,000
712,000
-
-
8.6
NJS
115,000
-
-
-
4.2
D
NFF
115,000
3,000
-
-
5.6
NJS
177,000
116,000
77,000
-
11.4
E
NFF
177,000
157,000
107,000
52,000
16.4
NJS
39,000
1,000
-
-
5.4
F
NFF
39,000
25,000
-
-
8.0
KE
10 X 10 TO THE INCH. 7 X 10 INCHES
KEUFFEL & ESSER CO. MADE IR USA
46 0700
DISTANCE and
SIDELINE
1m G FROM STOR CFT
4
10,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
20,000
100,000
10,000
CONTOURS OF EQUAL
6 EPNAB
NOISE REDUCTION
SEPNIB
O
-10,000
B, 707-320-B/c : JT3D-3B ENGINES
FLAPS
COMPARISON of UNTREATED NACELLE
RETRACTED
HEIGHT
AFL (FT)
WITH 1- RING NLST QN (TREATED)
+
~ FLIGHT PROFILE E
c 11.
Ano
SEA LEVEL:,77 F: 70%R.H.
RELIMINE
START FLAP
RETRACTION
START
ACCELERATION
3000
UNTREATED
TREATED
AIRCRAFT
AIRCRAFT
Tow x/329,450.10
TOW2333,60018
2000
REACH
CLIMB THRUST
START THRUST
REDUCTION
Attachment 3
1000
0
10,000
20,000
30,000
42,000
50,000
60,000
70,000
80,000
90,000
100,000
DISTANCE STOR (PT)
SIDELINE
DISTANCE (FT)
DISTANCE To TOUCHDOWN (FT)
90,000
80,000
70,000
60,000
50,000
40,000
50,000
20,000
.,0000
o
10,000
SEPNAL
EST MATED CONTOURS OF
o
6
EQUAL NOISE REDUCTION
7
/
-10,800
ELTMINARY
HEIGHT
AFL(A)
FLAPS UP
GRAR UP
1
200 KIAS
4" FLAPS
25 FLAPS
86 KIAS
" KIAS
GEAR DOWN
3000
INCREASE THRUS
EXTEND FLAPS
EXTEND FLAPS
REDUCE speed
INCREASE
REJUCE SPEND
INCREASE
Reduce THRUST
THRUST
REDUCE THRUST
THRUST
146 KIAS
START DESCENT
EXTEND GEAR
REDUCE SPEED
2000
REDUCE THRUST
8.707 - 320-6/C JT3D-38 ENGINES
COMPARISON OH UNTREATED NACELLE
WITH NO-RING INLET QN (TREATED)
50°FLAPS
INCREASE TARUST
1000
~ FLIGHT PROFILE E NOISE REDUCTION
SEA LEYEL, 70% RH. ZERO WIND
EXTEND FLAPS
REDUCE SPEE3
REJUCE
THRUST
Veer
WEIGHT
AT
TOUCHDOWN 1.11.NTREATED AC
243,350.6
141 KIAS
TREATED A/C
247,000 lb
O/D Attachment
o
100,000
90,000
80,000
70,000
60,000
50,000
40,000
30,000
20,000
10,000
-
DISTANCE To TOUCHDOWN (FT)
Air Transport Association
OF AMERICA
1709 New York Avenue, N.W.
Washington, D. C. 20006
Phone (202) 872-4000
CLIFTON F. VON KANN
Senior Vice President
Operations and Airports
January 27, 1975
Honorable Alexander P. Butterfield
ACTION:
AEQ-1
The Administrator
INFO: APD-1
Federal Aviation Administration
1/28/75
800 Independence Avenue, S. W.
Washington, D. C. 20591
Dear Mr. Butterfield:
The FAA forwarded a "Draft Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements" to the Council on
Environmental Quality on December 6, 1974. The Draft deals with
Notice of Proposed Rulemaking 74-14, which would require within a
small period of time a large number of jet transport aircraft to be
retrofitted to meet the noise certification requirements of FAR
Part 36 - without the use of existing "trade-off" allowances.
The Air Transport Association submitted to the FAA on June 28,
1974 the comments of its members relative to NPRM 74-14. We re-
affirm the position expressed at that time, as much of those comments
go to the heart of the Draft Environmental Impact Statement. In addition,
we are providing in this letter, and its attachment, the comments of
our members on that Draft.
Basically much of which is set forth in the Draft is unsupported
as the cost to retrofit the airline fleet has not as yet been determined,
the case has not been made that the small noise reduction be efit
justifies the large expenditures indicated, the technology to retrofit is
not fully developed and important safety issues have not been solved or
even considered.
1. Noise Reduction Benefits
The portions of the Draft Statement that attempt to quantify
noise reduction benefits for the proposed retrofit action utilize various
superficial indicators that are misleading with regard to the scope of
their applicability and their suitability as to the noise reduction which
- 2 -
will actually be achieved. This consequently results in inferred
benefits that are grossly exaggerated.
As we have pointed out in the past to the FAA, use of the
FAR Part 36 aircraft certification methodology as a measure of
merit for quantifying noise reduction benefits is faulty and mis-
leading, especially when the claimed reductions are predicated on
faulty information used to represent present noise levels of non-
noise certificated aircraft (such as that contained in FAA Advisory
Circular 36-1 dated May 31, 1973 and Figure I-1 of the Draft State-
ment). Table II-1 labeled "Noise Levels Under FAR 36 Certification
Conditions, uses for baseline data values which are at odds with
similar data available from other sources. What makes this signifi-
cant, is the fact that the comparison, i.e., the benefit, for takeoff,
is made at maximum gross weight, with the use of a "cutback"
technique not compatible with present operating rules and practice.
If the takeoff comparison is made under conditions corresponding to
the existing operating rules and cutback procedures, the benefits
become small or non-existent, because the procedure used in the
comparison is different and because the baseline values shown are
not representative of present levels.
For approach, the comparison is heavily sensitive to the flap
setting chosen. Moreover, the data presented is really applicable to
only certain configurations and submodels of the aircraft types identified.
It is not revealed, for example, that a retrofitted B-737 approach value
is obtained with a restricted landing flap setting of 30°. Several of
these topics are discussed in the section herein dealing with applicability
and availability of modification hardware to various aircraft subtypes
as related to the use of "trade-off."
An even greater fault in using FAR Part 36 style data, as repre-
senting the benefits achieved is that the comparisons made at the FAR
36 measuring points are generally not representative of the reductions
achieved at other locations within the influence of the aircraft flight
path.
While an attempt is made to assess the benefit at other locations
in a general way by the use of noise exposure contours, that approach
also contains serious flaws. Among these are (a) the entire set of
empirical routines used for extrapolating benefits to extended distances
(especially to the side of the flight path), (b) the inability to account
adequately for natural meteorological attenuating factors and (c) the
flight procedure and airplane operating configuration assumed for the
- 3 -
comparison. On the last of these points, for example, it appears
that the exposure contours used for illustration in the Draft Environ-
mental Impact Statement, and in the 23 airport studies used as a
principal foundation for the Draft, do not reflect the use of reduced
flap approach procedures already in use. The present contour
plotting methodologies produce a product which does not truly have
the sophistication that it implies. Perhaps the most deceptive
aspect of the contour methodology, however, is the application of
the area relationship "before" and "after" as an indicator of merit.
This practice has the characteristic of making any, even small,
change in source noise level look impressive. It has been demon-
strated that a 1 dB reduction in noise reduces the so-called "impact
area" by 15% or more; a modest 3 dB reduction results in about a
50% reduction in "impact area"; (a 3 dB reduction can barely be
identified, if at all). The inference that the noise exposure, popu-
lation annoyed, or the extent of the problem, is reduced by this same
amount is not recognized as erroneous by the reader, otherwise
knowledgeable, who does not have the detailed technical experience.
Other methods are available which, we believe, give a much
less distorted pictorialization of the extent of the noise level reductions
expected to be obtained by the retrofit options being considered under
realistic operating conditions. The approach used by the Douglas
Aircraft Company in response to Notice of Proposed Rulemaking 74-14
is particularly noteworthy. The use of the Douglas formula would show
the realistic but small noise exposure area where actual improvement
would exist.
Pursuing some points a little further in the case of the B-727-
200 airplane, the Draft Environmental Impact Statement claims a 3.7
EPNdB reduction for takeoff (see Table II-1), again relying on the
certification takeoff procedure which is not applicable to actual
operation, as the FAA clearly points out in the preamble to its recent
revision to FAR 36 concerning "acoustic changes." After citing a 5.6
EPNdB improvement on approach (for full flaps, also currently not
used), a statement is made that such changes "will be perceivable to
most observers." The choice of words is "perceivable to most", not
"significant to most. The change is not significant to most, nor is
it even perceivable to all. Indeed there exists no evidence that the
benefits provided by the proposed SAM retrofit which is already in-
stalled on many newly produced B-727 airplanes now in operation,
are in fact detected or appreciated by residents or that these newer
airplanes are distinguishable in this respect.
- 4 -
The quotation from the National Research Council on page 14
of the Draft relies upon the Borsky Report cited directly beneath it.
The Environmental Impact Statement leaves the reader with the im-
pression that real aircraft were used in the tests by stating "This
reduction was perceived by test subjects who live in the Kennedy
International Airport environment and was achieved with a difference
of 6 EPNdB between the two aircraft. 11 The facts are that the tests
were in a simulated living room with noise tapes synthesized to repre-
sent the B-727 with SAM. We do not fault the Borsky Study, but the
FAA citation that "there was a 50% reduction in the number of test
subjects who had expressed highest annoyance, while technically
correct, leaves the wrong impression of the annoyance reduction
achieved. The average annoyance was, in fact, reduced by a value
less than the difference between annoyance scale units used. In the
construction of the tests, the scale units chosen and the deliberate
exposure of subjects to levels higher and lower than, as well as
their own location levels, forced shifts in scale ratings. Finally
the Draft neglects to identify these tests as applicable only to the
approach noise of B-727. Dr. Borsky has made it very clear that
the conclusion of this study only applies to the B-727 during the
approach configuration. His conclusion applies to no other airplanes.
2. FAA Proposed Compliance Schedule
Based on current information furnished by the manufacturers
regarding lead times to begin delivery of SAM retrofit kits and based
on the fundamental assumption (accepted by the FAA) that installation
will occur during routine extended periods of maintenance, such as
overhaul which for some aircraft models occur at intervals greater
than the 5 year for each individual aircraft, the airlines point out that
the compliance schedule proposed by the FAA -- even the revised
schedule of 36 months to intermediate compliance and 48 months to
complete compliance -- cannot possibly be met, short of prematurely
retiring or grounding a sizeable portion of their fleets, thus greatly
increasing the cost of a retrofit program.
The manufacturers are currently quoting the following lead
times to commence delivery of SAM retrofit kits for their respective
aircraft:
B-707-120B
33 Mos.
B-747
12 Mos.
B-707-320B/C
26 Mos.
DC-8-51/61
31 Mos.
B-720B
34 Mos.
DC-8-62/63
31 Mos.
B-727
18 Mos.
DC-9
22 Mos.
B-737
18 Mos.
BAC-111
20 Mos.
- 5 -
Further, it should be recognized that a period of 2 to 3 months
will elapse from the date of rule effectivity to the date that the airplane
manufacturers issue a "go-ahead" for their respective programs, during
which time the individual affected airlines decide how they will comply
with the rule, make the financial arrangements and carry out contract
negotiations with the individual manufacturers. On the other hand, the
manufacturers may not issue a "go-ahead" until after they are certain
of air carrier needs.
Deducting the manufacturers' lead times together with the
period between rule effectivity and manufacturer "go-ahead" from the
36 months for intermediate compliance and from the 48 months for full
compliance, clearly will leave insufficient time for the airlines to
carry out the required installations.
As a consequence of the FAA's unrealistic proposed compliance
schedule the rule, which is the basis of this study, clearly does not
satisfy the criterion of technical practicability.
Basic questions arise on the practicability of application of
SAM as demonstrated only on four basic airplane types out of a total
of ten. While we are aware of studies applying a prototype B-707
SAM installation to the DC-8 series, actual production hardware has
not been built or tested for any JT3D powered aircraft to verify
theoretical analyses of fully-modified aircraft. Thus, no accurate
data are available regarding performance degradation, reliability
deterioration and effect upon inherent safety characteristics. Further
it has not been demonstrated that proposed retrofit designs for JT3D
powered aircraft will meet FAR Part 36 levels.
It should also be pointed out that while certain specific models
of the B-727 and DC-9 have SAM configurations which have been certifi-
cated and are in production, application of these SAM configurations to
other models of the same aircraft will not permit compliance with
FAR 36 without "trade-off" allowances. Furthermore, the B-737
with a quiet nacelle installation, which is identical to its proposed
SAM retrofit configuration cannot comply with FAR 36 without "trade-
off."
In short, since the technical aspects of retrofit of many affected
aircraft types are still vague and tenuous and have not been demonstrated,
we are certain that the FAA's proposed compliance schedule is im-
possible to meet. Thus, the FAA's sweeping conclusions concerning
the amount of noise reductions and that there will thus be meaningful
relief is greatly in error.
- 6 -
3. Trade-Off Allowance
Throughout the Draft Environmental Impact Statement, the FAA
indicates that the retrofit of aircraft owned by U. S. airlines must be
made to comply with FAR Part 36 without the "trade-off" permitted by
Part 36 as now written.
As we understand the Notice of Proposed Rule Making (NPRM)
on which the Draft Environmental Impact Statement is based, this means
that if an aircraft as a series were certificated as meeting Part 36 (with
or without trade-offs) prior to March 27, 1974, the date on which the
Notice appeared in the Federal Register, that series of aircraft could
continue to be manufactured, delivered and operated using trade-offs.
Older individual aircraft retrofitted and certificated as meeting Part
36 (with or without trade-offs) prior to March 27, 1974 would be
similarly treated and could continue to be operated using trade-offs.
Those individual aircraft which were not certificated to meet Part 36
noise levels prior to March 27, 1974 would have to be retrofitted. To
be certificated the retrofit kits for these individual aircraft would have
to meet the Part 36 noise levels without using trade-offs.
The result would be two categories of the same model aircraft
each with a different noise level. One category would be those that
meet Part 36 because they were certificated before the date of the
Notice and therefore were allowed to use trade-offs. These aircraft,
some of which would be identical in all respects with those subject to
retrofit, would be noisier than the latter since trade-offs could not be
used in certificating retrofit kits installed on aircraft subsequent to
the date of the Notice.
Trade-offs are of miniscule benefit to the airport neighbor.
But they are essential if manufacturers are expected to produce and
warrant that the hardware they deliver to the airlines will do what it
is supposed to do. Technology is just not that precise. Anyway, a
trade-off is not a license to make more noise across the board, an
excess at one point has to be made up at another.
To the airlines trade-offs are needed for many reasons de-
pending on the type of operation involved. One of the reasons they
are needed is to avoid an unnecessary inventory of spare engines.
Although it is conceded that most retrofitted engines/nacelles can
be intermixed with untreated ones on the same aircraft without
technical difficulty, FAA will not allow an engine to be substituted,
even in an emergency, on an aircraft if the installation of that engine
- 7 -
will increase the noise level of the aircraft (FAR 21. 93(b)). A letter
dated August 27, 1971 from the Director, Flight Standards Service to
ATA's Director of Engineering emphasized the fact. Thus, a third
category of aircraft is introduced --i.e., an aircraft certificated to
meet Part 36 prior to March 27, 1974 with the use of trade-offs but
fitted with one or more engines/nacelles taken from an aircraft of
the same model which has been retrofitted and which met Part 36
without trade-offs. In view of the aforesaid FAA ruling that a quieter
airplane cannot be made noisier, the converse would not be permitted --
i.e., an engine/nacelle from an aircraft certificated with trade-offs
could not be installed on an aircraft certificated without trade-offs.
It is easy to see the logistical burden and cost increase an
airline must incur if trade-offs are deleted. Many of their spare
engines would cease to be usable on all aircraft of the same type.
The alternative to acquiring more spare engines, amounting in some
cases to duplicating spare parts, is to hold an aircraft at a given
station until an engine, comparable noise-wise to the one experiencing
mechanical difficulty, arrives from another station. Such an impinge-
ment on public service cannot be justified by the negligible noise re-
ductions achievable by eliminating the trade-offs.
Another example of the importance of trade-offs to the airlines
is the effect that abolishing them will have on some of the cargo air-
craft. The cargo version of the DC-9-33 aircraft is equipped with
JT8D-9 or JT8D-11 engines. Elimination of trade-offs will place a
special burden on operators of this aircraft. The manufacturer ad-
vises that without trade-offs a retrofit meeting the specified noise
levels with the available kit is out of the question. This being the
case the only way compliance can be achieved would be modifying
the engine to a JT8D-15 configuration. Such a requirement is surely
impracticable, unnecessarily costly, and outright unreasonable when
it is noted that the failure of this model DC-9 to qualify is due entirely
to its inability to achieve truly insignificant reductions in the take-off
noise level. Not only is the noise reduction to be achieved meager at
best, in those cases where nearly all take-offs are over water, as in
the Hawaiian Islands, there would be no benefit at all from engine
modification. In a word, the investment will achieve nothing.
A more disturbing result of deleting the trade-off provision
is illustrated by focusing on what would have to be done to comply with
the rule in the case of the B-737 which cannot meet the noise levels
using SAM retrofit kits unless trade-offs are permitted. There are
no additional hardware options available to the manufacturer that
- 8 -
would bring this aircraft into compliance without trades, even when
retrofitted with the most extensive SAM available. The only way it
could qualify would be by accepting operating limitations. On landing
,it would have to utilize no more than a 30 degree flap setting rather
than maximum landing flap setting. When operated into some airports
this would be coupled with a severe reduction in landing weight. For
example, such an aircraft equipped with a JT8D-7 engine would have
its landing weight reduced by some 14 to 17 thousand pounds. The
service penalty to the public in this case should be apparent. But that
is not all. B-737s are used extensively in remote, mountainous areas
of the U.S. where runway lengths, of necessity, are relatively short,
thus requiring a full landing flap setting. No one knows better than
FAA the safety considerations arguing against such operations with
reduced flap setting. To put it another way - the level of safety of
operations in the B-737 will be reduced.
Deletion of trades therefore will decimate service to the hinter-
lands where there are no serious noise problems and unnecessarily re-
duce the safety margin of such operations without, in practical terms,
reducing noise by a decibel.
FAA has not stated the basis for proposing the deletion of trade-
off, perhaps out of recognition that it would be hard put to justify the
proposal especially when the requirements of Section 7 of the Noise Act
are taken into account. But even if there were an ostensibly rational
basis for the proposal, there is no way that such minute noise reductions
could weigh heavily against the penalties portended for airline operations
and thus public service. It follows that if the rule is adopted the trade-
off provisions of Appendix "C" to Part 36 must be retained. And even
more important with respect to the Draft Environmental Impact State-
ment and the alleged "benefit" calculation contained in the Draft, the
noise levels "with trade" used in calculating the land areas and persons
within such areas must be redone. The Draft indicates on page 35 that
"the FAA will consider on a case-by-case basis, any specific aircraft
or configurations of aircraft that must use trade-off
Experience
on such matters in the past have indicated this is not practical. On the
other hand - if the FAA sincerely means to provide relief and permit
the use of trade-off for safety or other reasons, again the calculation
of land areas and persons within certain noise level contours has to be
redone.
4. Safety of Proposed Takeoff and Landing
Noise Abatement Procedures
The Draft Environmental Impact Statement makes a number of
references to reducing noise by requiring two types of operational
- 9 -
procedures: (1) the 2-segment approach and (2) a takeoff using "cutback".
The airlines, with FAA's concurrence, have been using a noise
abatement takeoff procedure with "cutback" at 1500' since August 1, 1972,
and a reduced flap approach procedure since September 1972 - both of
which reduce noise levels received on the ground near the airports.
However, the airlines are deeply concerned about the safety aspects of
the 2-segment approach advocated by FAA in Advance Notice of Proposed
Rule Making (ANPRM) 74-12 and any takeoff procedure that would require
"cutback" below 1500' above the airport elevation.
We find the ANPRM on 2-segment approach deficient in the flight
safety area on a number of counts. Some of these are:
(a)
With several aircraft types, notably the DC-8, B-747
and DC-10, flight idle thrust is required to remain on
the profile, thus greatly reducing or negating anti-
icing capability.
(b) As given in the previous example, excessively high
sink rates and accelerating airspeeds are encountered
with some aircraft. This needs much more evaluation.
(c) Other aircraft types not now in evaluation need to be
examined, particularly with regard to the upper segment
definition, which the airlines feel will vary by aircraft
type.
(d) Well over one half of all air carrier jet losses and fatalities
have occurred in the approach and landing phase of flight.
For this reason, the airlines are extremely cautious about
adding any degree of complexity or complication to this
phase of flight. Proponents of two-segment approaches
argue that providing DME in conjunction with ILS and/or
adding RNAV equipment to the aircraft will result in a
level of safety for two-segment approaches at least
equivalent to that for conventional ILS approaches with
current equipment. This reasoning is extremely specu-
lative in view of the limited testing done to date. More-
over, one could very logically argue that installation of
this same equipment, without the complication of the
two-segment transition maneuver, would significantly
improve the reliability and safety of conventional, one-
segment ILS approaches. The interrelationship of
- 10 -
electronics, safety, and approach complexity must be
thoroughly explored to accurately determine the actual
flight safety implications of two-segment approaches.
(e)
Two problems dealing with weather and safety are
important. The first deals with wind shear. A tail
wind at altitude will reduce thrust requirements on
the upper segment. Couple this with an icing problem,
the resultant power required may not be adequate to
operate anti-icing systems even though the auto-coupler
can maintain the glide slope.
(f)
There is a serious safety problem involved with respect
to the wake turbulence caused by the aircraft on the
first segment of a two-segment approach as that turbu-
lence relates to non-airline aircraft using the 3° glide
slope. We are aware of the FAA/NASA program re-
garding this matter but it needs further pursuing and
checking out in order to assure safety of all operations.
There have been various proposals for a takeoff "cutback"
procedure to be used in day-to-day operations, including cutback at
700' for 4-engine jets and 1, 000' for 2-and-3-engine jets, as permitted
under Part 36 for meeting the noise certification test requirements.
What all of the various proposals fail to take into account are the safety
of the aircraft, crew, passengers and those residing under the flight path.
Here are some of the considerations.
First and foremost, a single standardized takeoff procedure is
needed for safety reasons.
As far as performance requirements are concerned there are
four basic types of takeoffs. There is: (1) the all engines, obstacle
limited takeoff, (2) the all engines, non-obstacle limited takeoff, (3)
the engine out, obstacle limited takeoff, and (4) the engine out, non-
obstacle limited takeoff. If a single procedure is to work it must take
care of all of the above kinds of takeoffs, and it must provide:
- adequate stall margins
- adequate controllability margins
- adequate maneuvering margins
- adequate gust and wind shear margins
- comply with anti-noise requirements
- be economically feasible and practical from a fuel
consumption and engine performance viewpoint.
- 11 -
Such a procedure is not developed overnight. It requires
hard work and study of each airplane type regarding climb gradient
curves, stall and maneuvering speeds, regulatory performance re-
quirements, etc. Then flight test work has to be done, followed by
a good shake down in actual practice. A good procedure cannot be
derived without such preparation.
Our point in bringing these safety matters to the FAA's
attention is to be certain that everyone is aware that the two-segment
approach, and a "cutback" procedure on takeoff, different than that
now used by nearly all of the airline members of ATA, will not be
forthcoming in the near future, if at all, because of very serious
safety considerations and decisions that must be made. Therefore,
we feel it is far too premature to set forth in the Environmental
Impact Statement any indication of how noise on the ground may be
reduced by such procedures. Thus, the various Tables and Figures
in the Draft Environmental Impact Statement showing the cumulative
noise reduction using these procedures should be deleted.
In summary, all the noise reductions assumed to be the result
of the use of such procedures is still pure theory and far, far from
ever becoming fact.
5. "Public Health and Welfare"
In several places in the Draft Environmental Impact Statement,
reference is made to aircraft noise levels as related to "public health
and welfare. The prime document allegedly dealing with noise levels
as related to public health and welfare is EPA's document, 550/9-74-004,
"Information on Levels of Environmental Noise Requisite to Protect
Public Health and Welfare with an Adequate Margin of Safety.' We do
not believe that the basis for the maximum acceptable dB levels set
forth in that document is sound. Even the document itself refers to
assumptions, extrapolations and interpolations which had to be made
to arrive at the levels set forth (i.e., 70 Leq re hearing loss, and
55 Ldn re annoyance). We recommend, therefore, that any reference
to "health and welfare" in the Environmental Impact Statement be
deleted until there is an agreed upon, scientifically proven, and fully
recognized basis for establishing any noise levels associated with the
phrase "public health and welfare."
- 12 -
6. Fuel
The Draft Environmental Impact Statement contains a section
on fuel consumption which tries to show that only a small increase in
fuel consumption would occur with the installation of the SAM treat-
ment to the existing non-Part 36 jet transport fleet. Using the FAA
figure of 4, 000 barrels a day of added fuel required with the SAM
installations (see Page 23, line 6 of the Draft Environmental Impact
Statement) we are of the opinion that such increased fuel consumption
is quite alarming. 4, 000 barrels a day means 1, 460, 000 barrels, or
61, 320, 000 gallons, of jet fuel per year.
The President's program is to reduce U. S. petroleum product
consumption so as to reduce the import of 1, 000, 000 barrels a day
from foreign sources in 1975. The 1, 460, 000 barrels a year required
because of SAM would be about 1-1/2 times that amount. Instead of
helping the President's program, a SAM requirement would hinder it
considerably.
Further, 61, 320, 000 gallons of jet fuel is approximately the
amount of fuel needed (a) to operate either of two of our larger local
service air carriers for one year and (b) the same amount would be
more than enough for the combined operation for a complete year of
three of the smaller members of the Association.
An ineffective and costly retrofit program which will also
increase fuel consumption is indefensible.
7. Safety
The Draft Environmental Impact Statement gives little, if any,
recognition to several serious safety problems which have to be taken
into consideration and solved before certain operating procedures and
certificated hardware features can be used in calculating noise benefits.
We refer to:
(a)
The need to use 30° landing flap instead of "full flap"
with a B-737 to meet Part 36 without trade-off, thus,
causing a reduction in the landing runway length safety
factor. (See comment 3. Trade-Off Allowance.)
(b) The proposal to use "cutback" below 1500' above air-
port elevation during takeoff. (See comment 4. Safety
of Proposed Takeoff and Landing Noise Abatement
Procedures.)
- 13 -
(c) The proposal to require a two-segment approach.
(See comment 4. Safety of Proposed Takeoff and
Landing Noise Abatement Procedures.)
(d) The SAM retrofit proposal for the B-707-320B/C,
the B-707-120B and the B-720B requires an acoustical
"ring" in the engine inlet. The airlines feel that these
are inherently unsafe from an airworthiness point of
view.
Safety is most important to the airlines. It is necessary for
the FAA to assure the safety of noise abatement hardware and procedures.
The airlines are of the impression that this has not been done as yet and
thus indicated alleged noise reduction benefits to the public as set forth
in the Draft are misleading.
Some additional page-by-page detailed comments are attached.
Most of these refer to comments contained above. Others are set forth
for the first time in the attached.
The airlines appreciate the opportunity to comment on this
Draft Environmental Impact Statement, and hope our comments will be
of value to the Agency.
Sincerely,
Weren
for
Clifton F. von Kann
Senior Vice President
Operations & Airports
Attachment
RECEIVED
JAN 28 8 51 AH 75
ON
Attachment
ATA Detailed Comments on Draft Environmental Impact
Statement for Civil Airplane Fleet Noise Requirements
1.
Page 2 in the last sentence including the Table of Airplanes and
Certification Dates - the word "initial" should be inserted before
the word "certification." This suggested change need not be made
if the table at the end of the page would include the certification
dates for the various subsequent models of the airplanes listed.
Listing the certification date of the later models would be
preferable.
2.
Page 3, third line. It is indicated here that the "open circles
signify estimates' in Figure I-1. New data is available which
would indicate many of the levels indicated on Figure I-1 are
incorrectly high.
3.
Page 3, the second sentence indicates that Figure I-1 shows that
appropriate reductions to meet Part 36 noise levels are achievable.
The point is that the retrofits being assumed are not technical
available now for six of the basic aircraft models.
4.
Pages 2 and 3. The FAA statements that 1, 969 of 2, 419 (page 2)
currently operating aircraft do not meet FAR 36 noise levels and
the estimate that 1300 to 1600 (page 3) of these will still be operating
"through the '70s" is essentially irrelevant to the case for SAM
retrofit. Even though SAM retrofit could allow most of these air-
craft to meet FAR 36 noise levels, the fact remains that, even
with this retrofit, the aircraft which make in excess of 85% of all
U.S. takeoffs and landings (JT8D-powered aircraft) would still
not offer noise relief detectable by the public.
5.
Page 3, fifth last line. To our knowledge, there is no basis for
the assumption made in this sentence.
6.
Page 5. The first sentence in the first full paragraph indicates
"a safe and practicable application of acoustic technolgy has been
developed
" The airlines question the safety of the SAM
retrofit developed for the 707 series of aircraft. In addition,
there is no "practicable application" developed and tested for the
two basic DC-8 models.
- 2 -
7.
Page 5. In the middle of the page, it is indicated that SAM
treatment has been demonstrated as technically feasible to
retrofit engines/nacelles to meet FAR Part 36 noise levels.
Your attention is called to the fact that the SAM retrofit pro-
posals are not available however for six of the basic aircraft
types involved. In that same paragraph the point is made that
the JT3D powered B-707, with SAM treatment, have been
demonstrated to meet Part 36 levels. Only a "two ring" inlet
prototype has been used. The airlines question the safety of
this arrangement. It is further noted that the work done on
the B-707 is not applicable to either of the basic models of
the DC-8s. The FAA indicates in the second last line the
"general manner" in which the 707 acoustic treatment as
used in 707 could be used in the DC-8. It fails to point out
that absolutely no SAM retrofit hardware has been developed,
or either ground or flight tested for the DC-8 aircraft.
8.
Page 5, paragraph at the bottom of the page. This paragraph
fails to indicate that one DC-9 model and the B-737s can not
be certificated to meet Part 36 levels without trade-off
allowances. We also understand the B-727 furnished with
JT8D-7 and -1 engines can not meet Part 36 levels without
trade-off.
9.
Page 6, paragraph in the middle of the page. This paragraph
would indicate that retrofits can be made during routine over-
hauls and that engine intermix is possible (that is one aircraft
could be equipped with both non-retrofitted engines and retro-
fitted engines and used in airline operations). Reference is
made to the retrofitting of JT8D with burner-can for emissions.
In the case of the SAM retrofit this would be prohibited from an
aircraft certification point of view as well as unsafe from an
operational point of view.
10.
Page 7. This page deals primarily with compliance dates.
FAA is still indicating that questions of manufacturing capacity
and logistics are still under review. We, therefore, find it
difficult to see how the compliance dates of 36 months and 48
months from the effective date of the regulation were determined
if these points are still "under review. " The information we
received from the manufacturers and set forth in our comments
entitled FAA Proposed Compliance Schedule indicates that a
final compliance date of 1982 or later may be in order.
- 3 -
11.
Page 9, paragraph in the middle of the page. The FAA indicates
that its proposed retrofit rule would only apply to aircraft operated
by foreign carriers into and out of the United States. Such a rule
would place U.S. Flag carriers in a bad competitive position inso-
far as those routes between foreign terminals are concerned. For
example, between Rome and Bombay where foreign Flag carriers
using aircraft that do not enter the U.S. are competing with U.S.
Flag carriers which would have to use aircraft which are retrofitted.
12.
Page 9, paragraph B at the bottom of the page. Again we point out
that the B-737, certain models of DC-9 and B-727 cannot meet
Part 36 without trade-offs.
13.
Page 10, paragraph D. If foreign manufactured 4-engine air-
planes need not comply with Part 36 but only meet ICAO Annex
16, U.S. carriers operating 4-engine aircraft are being discrimi-
nated against by the regulation. This is true because Annex 16 is
less strict than Part 36. In addition, Annex 16 permits trade-off
where the proposed rule would not permit the use of trade-off
provided in Part 36 for U.S. 4-engine aircraft.
14.
Page 13, second full paragraph. The phrase "meaningful relief"
appears twice in this paragraph. As noted in our comments en-
titled, Noise Reduction Benefits, we do not concur that "meaningful
relief" will be provided by the SAM treatment.
15.
Page 13, last paragraph. The statement here indicates that there
is an 11 EPNdB reduction on takeoff for JT3D powered aircraft.
This is true only for the B-707 type aircraft when flown with
"cutback." It is not true when flown in accordance with FAA
recommended noise abatement takeoff procedures. The Dulles
tests showed that when the B-707 took off without "cutback", the
difference is on the order of 2.8 to 3 EPNdB reduction. Further,
the 11 EPNdB reduction is not true for DC-8 aircraft which are
equipped with the JT3D engines. For the JT8D powered air-
planes on takeoff, when they are flown in accordance with recom-
mended noise abatement takeoff procedures, the reduction for
some models is zero.
16.
Page 14. In our comments entitled, Noise Reduction Benefits,
we have discussed the validity of Dr. Borsky's tests and their
meaning.
17.
Page 15, Table II-1. With regard to the column entitled,
"Present (Baseline), the data listed appears to be old data.
It should be updated.
- 4 -
The column entitled "Retrofit" is misleading for some airplanes,
as the numbers indicated are "estimated" because hardware is
not developed, much less having been flight tested. For example,
in the case of the DC-8, there are no actual retrofit noise levels
available. The B-737 data for landing is with a 30° flap and for
safety reasons we need to use a 40° flap.
The asterisk along side of the word "takeoff" in the first column
deals with a "cutback" procedure, which the airlines feel is
inappropriate.
18.
Page 16, first full paragraph. A reduction of 3. 7 EPNdB on
takeoff for the B-727-200 can only be accomplished with "cutback"
which the airlines do not use, thus the statement here is mis-
leading. The last sentence of that paragraph gives the impression
that with retrofit the improvement in magnitude of noise and the
quality of the frequency spectra will be perceivable to most
observers. It is interesting to note that there are a fair number
of 727-200 series aircraft which meet Part 36 operating in the
scheduled airline fleet today, yet no recognizable difference or
improvement has been noted by the public. As far as the public
is aware all the B-727s are alike from a noise standpoint.
19.
Page 16, second full paragraph. The Dulles demonstrations
showed that when flown using FAA recommended takeoff proce-
dures, the difference between retrofitted and non-retrofitted
B-707 was between 2.8 and 3 EPNdB and not 11 EPNdB.
20.
Page 16, last sentence beginning on the page. This sentence
leaves the impression that new wide-body jets, such as DC-10
and L-1011, provide lower noise levels at the noise certification
measuring points than the smaller 2-and-3-engine jets such as
B-727, DC-9 and B-737. The B-727 noise levels without SAM
at some measuring points are lower than the L-1011 and DC-10,
and at others are so close to wide-body levels the difference is
imperceivable.
21.
Page 17, last sentence of the first full paragraph. As we point
out in our comments entitled Noise Reduction Benefits, it is the
reduction in the noise level which the person on the ground
actually perceives that is important; not the reduction in the
so-called area of noise impact achievable through retrofit.
22.
Page 18 and 19. It is noted that "power cutback" as permitted
by FAR Part 36 provisions is used in Figures II-1 and II-2. Our
comment entitled Safety is appropriate here. Noise certification
- 5 -
test "cutback" altitudes should not be used in preparing these
charts. The airlines do not use "cutback" permitted during
certification.
23.
Page 23, beginning with the sentence commencing at the bottom
of the previous page and continuing on to the top of this page, it
should be noted that the existing Los Angeles International Airport
procedure for night operations makes no differentiation between
those aircraft that meet Part 36 and those which not not meet
Part 36. Since April of 1974 all aircraft, whether they meet
Part 36 or not, follow the same procedure. Thus, this sentence
should be eliminated.
24.
Page 23, first full paragraph. This paragraph should be eliminated
at this time for the reasons set forth in our comment entitled
Safety of Proposed Takeoff and Landing Noise Abatement Procedures.
25.
Page 28, first full paragraph, last sentence. We are encouraged
by this sentence because it indicates that safety and efficiency will
have to be considered along with noise benefits. On the other hand,
until safety has been assured for takeoff with "cutback" and using
a two-segment approach through the rulemaking process, as we
indicated in our comments in the basic letter, supposition of
noise benefits should not be made through the use of takeoff or
approach procedures that have not yet been agreed upon. In
other words, the Environmental Impact Statement should be
limited to the matter of noise reduction expected through retrofit.
26.
Pages 29 and 30. These charts should be deleted as we indicated
in the second paragraph on pages 9, 10 and 11 of our commenting
letter. Safety is our prime concern. However, the use of NEF
40 and 30 in these two charts are misleading units as well.
27.
Page 31, paragraph beginning on page 28. Here again much is
made of the fact that additional benefits through power cutback
will be provided. Safety is involved here and has not been taken
into account.
28.
On Page 34. In the first full paragraph which continues onto the
next page, it is indicated that the FAA has a policy to increase
the stringency of Part 36 where it is technologically practicable
and economically reasonable and then it refers to the fact that
this can be done in the retrofit situation by eliminating the trade-
off provisions of Part 36. As indicated in our comment on
- 6 -
"Trade-Off Allowances, eliminating trade-off is not technologically
practicable and economically reasonable.
29.
Page 39, first full paragraph. We merely restate the fact that SAM
modifications do not provide meaningful relief.
30.
Page 42, second paragraph. It is indicated here that the retrofit
rule would assist local jurisdictions in quantifying potential noise
exposure by assuring maximum bounds on source noise. This
simply is not true as the use of NEF contour and single event foot-
prints give completely erroneous and misleading information to
land use planners. Until the NEF formula is appropriately cor-
rected, it will mislead anyone that uses it, or counts on its use.
We understand that the aircraft manufacturers and airport operators
generally concur with this viewpoint.
31.
Page 43. See our comment entitled "Fuel."
32.
Page 44. The FAA expresses an opinion here that the proposed
retrofit does not involve any trade-offs between short-term
environmental gains at the expense of long-term losses. Such
a statement in view of the airlines is simply not true. Any money
committed now to retrofit is capital made unavailable to buy new
truly quieter and more fuel-efficient aircraft. This is true regard-
less of where the financing comes from; capital is capital, and it
is scarce. Omission of this realization would have a long-term
negative economic impact upon the aircraft manufacturing industry,
as well as the air transport industry. Commitment to retrofit
represents therefore, at best, a modest short-term environ-
mental gain at the expense of potential long-term gains, both
environmental and economic.
33.
Page 45. The first paragraph on this page states that there are
no adverse land use patterns being established as related to the
proposed retrofit rule. We challenge this statement, using as
an example for rebuttal the situation involving the Port of
Oakland, the City of Alameda, California, and the developer
of Harbor Bay Island, a major development immediately adjacent
to the principal air carrier runway at Oakland International Air-
port. A principal justification for continuing this obviously in-
compatible land usage is reliance of its proponents on the
probability of retrofit and its ability to make the area compatible.
- 7 -
34.
Page 45. The third sentence indicates "There are no known risks
to health and life anticipated" through the adoption of the proposed
rule. As we have indicated in several places in this attachment
as well as under the "Safety" paragraph in our covering letter,
there are several safety matters and therefore "risks to life"
which have not been solved as yet.
35.
Page 46. The Table set forth on this page relates to part of the
FAA's argument that raw materials for use in retrofit are currently
not in short supply. We call your attention to "polyimides" which
is a petrochemical and thus is in short supply. Other items listed,
though they may not be in short supply, are difficult to obtain and
this is one reason why the airframe manufacturers have indicated
that the time element in preparing the first retrofit kits and sub-
sequent kits has been lengthening over the past two years, and
will probably do so in the future.
36.
Page 47. The first paragraph indicates again that there will be
"large measure of noise relief. As we have indicated earlier,
this simply is not true.
37.
Page 47, second paragraph. There is no question but that the
aircraft noise is a major problem in impeding the orderly develop-
ment and operation of air transport industry. We wish to make it
clear, however, that the proposed NPRM 74-14 will in no way
rectify this situation.
DOUGLA AIRCRAFT
3855 Lakewood Boulevard Long Beach, California 90846
24 January 1975
Mr. Charles R. Foster
Director, Office of Environmental Quality
Federal Aviation Administration, AEQ-1
800 Independence Ave., S. W.
Washington, D. C. 20591
Dear Chuck:
We have reviewed the Draft Environmental Impact Statement
for Civil Airplane Fleet Noise Requirements dated December 1975 and
wish to take this opportunity to comment on it.
The results of our assessment of the potential benefits of a
SAM retrofit have indicated much smaller benefits than indicated in this
draft EIS. The greatest difficulty we have with the report is the assump-
tion throughout that if an airport neighbor's exposure goes from above
NEF 30 (or 40) to below NEF 30 (or 40), he will experience a meaningful
reduction in noise and will no longer be impacted by noise.
Figures 7, 8 and 12 of Appendix C of the EIS contain the only
data in which the benefits of the SAM retrofit are isolated. Figure 7
indicates that SAM treatment of the JT3D and JT8D powered aircraft by
1978 would result in a 25% reduction in the population exposed to NEF 30
or above. Earlier reports on this study have shown that for NEF 30 the
reduction in population exposed and reduction in contour area are comparable.
It has been generally accepted that aircraft noise contours are cut roughly
in half by each 4 dB reduction in noise. Thus a 25% reduction is roughly
the equivalent of a reduction of 2 dB for the people exposed to an NEF of
30. There is a tendency to consider that this 25% of the exposed population
will go from an impacted condition to a non-impacted condition, and this
is a quarter of the way toward a solution to the noise problem. This is
not a proper interpretation of this result. We would not expect that an
average reduction of 2 dB would have any significant effect on those people
exposed to NEF 30. It seems that on average the people exposed to NEF 31
before retrofit would be exposed to NEF 29 after retrofit, and certainly
2 dB is difficult to detect even under laboratory conditions.
MCDONNELL DOUGLAS
C. R. Foster
Page 2
The reduction in population of those exposed to NEF 40 is between
45 and 50%. Again the impression that the problem is half solved, but in
actuality people in that general category would probably experience a reduc-
tion of about 4 dB. Again a reduction from NEF 42 to NEF 38 could hardly
be expected to result in a very meaningful improvement.
This same reasoning could be applied to the data in Figure 8, and
the indication is that the improvement is even less both before and after
1978. Figure 12 breaks this information out by airport for the reduction
in population exposed to NEF 30 or above. Our analysis would show the
equivalent reduction is only 1 to 4 dB for any given airport with most being
2 dB or less.
Based on this analysis we believe a reassessment of the results
of this study will provide very convincing evidence that a SAM retrofit
program will not provide meaningful benefits for most airport neighbors.
We have found contours of equal noise reduction resulting from
a noise reduction option to be a very informative tool in the evaluation of
airport noise. It would appear that the necessary data are available in
the DOT's Twenty Three Airport Study to develop contours of equal reduc-
tion in NEF, which would result from the various options. We believe
this would provide a much clearer picture of the benefits that might be
expected from a SAM retrofit program. We urge the FAA to consider an
examination of such contours.
We also have considerable concern about some of the input data
used in the study. We have attached a copy of our response to NPRM 74-14
which provides data which we believe more nearly reflects the kinds of
reductions that might be expected from the application of SAM suppression
to DC-8 and DC-9 aircraft. This document also provides additional infor-
mation on our assessment of the SAM retrofit option.
Considering the enormous costs that would be associated with a
SAM retrofit program and all the implications of such a program, we believe
the FAA should explore every reasonable avenue to help in understanding
the community benefits of such a program before establishing any regulation.
We would be pleased to cooperate with the FAA in such an endeavor.
Sincerely,
azmPla
A. L. McPike
Director
Industry Association Activities
ALM:mlg
DOUGLAS AIRCRAFT COMPANY
3855 Lakewood Boulevard Long Beach, California 90846
26 June 1974
C1-CMF-80
CHARLES M. FORSYTH
EXECUTIVE VICE PRESIDENT
Federal Aviation Administration
Office of the General Counsel
800 Independence Avenue, S.W.
Washington, D.C. 20590
Attention:
Rules Docket CFR-91
Subject:
Civil Aircraft Fleet Noise (FNL) Requirements
Notice of Proposed Rulemaking
Reference:
Docket No. 13582; Notice No. 74-14
Gentlemen:
The Douglas Aircraft Company has studied NPRM 74-14 - Civil Aircraft Fleet
Noise Requirements and is pleased to have the opportunity to submit the following
comments for your consideration.
Our analysis of the NPRM and of the overall question of a sound absorbent
material (SAM) retrofit program has led us to the following conclusions:
1.
The benefits of conducting such a program to reduce the whine without
also reducing the jet roar of the JT3D and JT8D engine powered aircraft in the fleet would
be minimal and therefore disappointing to most airport neighbors seeking meaningful relief.
2.
While the SAM technology has been demonstrated, SAM retrofit kits
for all JT3D and JT8D powered aircraft are not available. Considering the lock of
production design and tooling for JT3D kits, long material lead times and production
capacity limitations, a SAM retrofit program if undertaken could not be completed until
early in the next decade.
3.
While we are uncertain of the intended applicability of the deletion
of the tradeoff provisions of FAR Part 36, we find that deletion of these provisions is
indefensible for any application and urge the FAA to reconsider any such action.
GERALD FORD
MCDONNELL DOUGLAS
R
CHARLES M. FORSYTH
EXECUTIVE VICE PRESIDENT
26 June 1974
C1-CMF-80
Page 2
4.
The FAA should develop an acceptable and approved means of paying
for any retrofit program before establishing a requirement for it.
These conclusions are supported by the more detailed comments included in Attach-
ment 1. Additionally, the conclusion concerning the minimal benefits of the proposed
program is further supported by the extensive analysis provided for your information in
Attachment 2. This analysis includes some new methodology which permits a specific
estimation of the noise reduction that would be expected by any airport community from
installing a SAM noise suppressor on an aircraft. As an example, it indicates that the
residents of Georgetown near Washington National Airport would experience reductions
of only 1 dBA resulting from the DC-9 SAM treatment if outdoors, even less if indoors.
We believe this analysis method is the first to offer a realistic assessment of the benefits
of SAM suppression.
Based on the above conclusions we recommend that the FAA cancel NPRM 74-14
and pursue more meaningful approaches to the airport community noise problem. We will
be happy to cooperate with the FAA in this pursuit.
On the other hand, if the FAA continues to pursue a SAM retrofit program, we
would urge careful consideration of the information supplied herein with respect to costs,
schedules and the specific requirement. If there is to be a SAM retrofit program, it should
be accomplished on an international basis to international noise standards on a realistic
schedule and with some approved approach to paying for it.
In closing we would like to point out that our attitude toward a SAM noise retrofit
program should not be construed to imply that we fail to take the airport neighborhood
noise problem seriously. On the contrary we view this problem as a very serious threat
to the future of our air transportation system. It is for this reason that we are apprehensive
about a program which would direct our resources toward technology which in our opinion
would not offer significant relief for most airport neighbors.
Sincerely,
Fougth
Charles M. Forsyth
Attachment 1
COMMENTS ON NPRM 74-14
CIVIL AIRCRAFT FLEET NOISE REQUIREMENTS
1.
The Benefits - The NPRM specifically requested comments on the overall environ-
mental aspects of this proposal. Basically the NPRM is proposing a SAM (Sound Absorbent
Material) nacelle retrofit program for the current fleet of low bypass ratio turbofan powered
aircraft. This would consist of applying SAM technology to these aircraft to bring the
turbomachinery noise of their engines roughly to the same level as their jet exhaust noise.
It would provide no reduction in the jet exhaust noise of these engines. Our analyses
indicate that while application of this technology to DC-9's and DC-8's would provide
maximum reductions of from 4 to 10 dB for a few people under certain conditions, most
neighbors would experience levels which are much smaller. In fact many, perhaps most,
of the airport neighbors who are annoyed by aircraft noise would experience no detectable
change in that noise as a result of such a program. These analyses are described in some
detail in Attachment 2. Our conclusion is that the proposed program would have only a
small impact on the overall airport community noise environment.
2.
The Schedules - The NPRM would require that all aircraft in the fleet be in com-
pliance with the proposed requirement by mid-1978 and that half of an operator's fleet of
a given aircraft type be in compliance by mid-1976. Assuming for the moment that the
DC-9's would require a SAM retrofit kit installation to comply with the proposal, meeting
the intermediate date of mid-1976 would not be possible. As paced by material supply
limitations, the DC-9 nacelle treatment as a retrofit kit is currently available 22 months
from date of order. Assuming further that the earliest a rule might be promulgated would
be at the end of this year and that orders for kits were placed immediately thereafter, the
first kit would not be available until late in 1976.
A retrofit of the complete world fleet of DC-9's would of course involve the devel-
opment and installation of up to 700 ship sets of SAM kits. At a rate of 15 ship sets per
month, this would require up to about 4 years after the first kit became available before
Page 2
Attachment 1
retrofit could be completed. This of course assumes that the airlines could install them
as fast as they became available. This would indicate a date of late 1980 for completion
of a retrofit on the DC-9.
The time from go ahead to the first kit for the DC-8 is 28 to 36 months depending
on the model. Again assuming a go ahead at the end of the year, the first kits would not
be available until 1977. At a rate of one aircraft kit per week each for the long duct and
short duct pod DC-8's, it would be about 1981 before the program could be completed.
We would suggest that if there is to be a nacelle retrofit program, its scheduling
must be modified to reflect this information.
3.
Applicability and the Specific Requirements of the Proposal - In general the NPRM
appears to be addressing the subject of a nacelle retrofit program for the JT3D and JT8D
powered aircraft. However, in paragraph 91.303 of proposed subpart E, it appears that
the tradeoff provisions of Part 36 will not be permitted. As stated, it would appear that
all aircraft must meet Part 36 without the possibility of using tradeoffs after mid-1978. We
are not certain if it was the FAA's intent to apply this to all aircraft, or just those segments
of the fleet which do not comply with Part 36. However, in any event we must strongly
object to the whole idea of deleting tradeoff provisions. There are aircraft of both the
narrow bodied and wide bodied type, both in production and previously delivered, which
are in compliance with Part 36 but which do require the use of the tradeoff provisions.
To suddenly delete the tradeoff provisions for all aircraft would result in utter chaos.
On the other hand, to suggest that aircraft designed more than ten years ago must
suddenly meet requirements which are more stringent than those for newer aircraft is com-
pletely unsupportable. We understand that the FAA's intent may be to delete the tradeoff
provisions only for those aircraft/configurations which were not certified to Part 36 prior
to the date of the notice. If true, this would constitute an unfair and discriminatory
provision unprecedented in aircraft regulatory history.
We thus urge the FAA to drop any consideration of deleting the tradeoff provision
of Part 36. In fact, we would urge the FAA to go even further. If there is to be a retrofit
rule, it would be sensible only if the entire world fleet were retrofitted. Otherwise for
some aircraft types the kit cost per airplane would be much higher. Thus, if there is to be
a rule, it should be done on an international basis to international standards. This would
Page 3
Attachment 1
mean that for any retrofit the requirement should be to Annex 16. The difference in per-
ceived noise between aircraft meeting Annex 16 and meeting Part 36 could hardly be.
detectable. However, the cost differences between retrofitting to these two requirements
could be enormous as illustrated by the attached data. We therefore urge the FAA to
adopt ICAO Annex 16 as a requirement if it pursues any SAM retrofit program.
4.
Costs - The firm price of the SAM kit for the DC-9 is $140,000 including Pratt and
Whitney treated fan ducts. This price does not include installation costs; spares costs would
have to be added also. The price is for 1974 orders and is subject to escalation. The kit
has been designed, tested and certified.
The situation for the DC-8 is quite different. Because there are no kits in existence
for this aircraft and because it is impossible to be sure what, if any, requirement will
eventually be established for such kits, costs can only be roughly estimated. These estimated
kit costs for the DC-8 vary from $450,000 to $900,000 depending on the requirement and
on the type fan discharge duct included on the JT3D engine (long or short duct). These
estimates of course assume that the kit development costs can be spread over a significant
number of aircraft. If it were necessary to spread these development costs over a limited
portion of the fleet, the costs per aircraft could climb much higher. Cost estimates for a
number of specific kits for the various models of the DC-8 and DC-9 are discussed below
in the section called "Possible DC-8 and DC-9 Nacelle Retrofit Kits". It should be clearly
understood, however, that these costs are supplied purely for general planning purposes
and are not commitments on either price or availability for the DC-8.
The data we as manufacturers can supply of course deals with only one portion of
the costs of any retrofit program. While the costs of the kits for a fleet retrofit program
would probably exceed one billion dollars, the additional costs associated with installation,
spares financing, maintenance and increased operating costs would probably amount to
even more than that. We would urge the FAA to develop an acceptable means for paying
for such a program before establishing a requirement for it.
5.
Possible Nacelle Retrofit Kits for DC-8 and DC-9 Aircraft - Attached is a set of
charts which provide nacelle retrofit kit data for the several versions of the DC-8 and DC-9
aircraft. On pages 1 through 3 there is a listing of the various models of the DC-8 and -9
Page 4
Attachment 1
for which a kit is available (DC-9) or under consideration (DC-8). In each case the specific
engine is listed below the model number. This is followed by a column which provides the
MTOGW (Maximum Takeoff Gross Weight) and MLW (Maximum Landing Weight) of the air-
craft, which except as noted are the maximum design weights for the aircraft. The next
column indicates the landing flap setting assumed. In the last three columns are listed a
particular SAM suppressor kit which when installed on the airplane should bring it into
compliance with the noted possible requirement. Part 36 with the tradeoff provisions,
Part 36 without the tradeoff provisions and Annex 16 are the three possible requirements.
The treatment code is quite simple. TJP refers to turbojet pod and the -1 is a sequence of
devices considered. SDP refers to the short duct pod, which is on all JT3D powered DC-8
Series 50 and 61 aircraft. SDP-5 and SDP-7 are the two configurations currently under
consideration for this pod. LD refers to the long duct pod which is used on DC-8-62 and -63
series with JT3D engines. The LD-2A and LD-2C are the two configurations currently under
consideration for the long duct pod.
The remaining pages provide for each suppression kit a sketch showing where the
treatment is added and a table showing the noise levels required and predicted with that
kit at the noted weights. Following each table there are estimates of the change in specific
range, change in airplane weight, kit costs, kit availability and retrofit down time asso-
ciated with installation of the kit. In the case of the DC-9, information is presented for
the hardwall case because with it almost all DC-9's are in compliance with both Part 36
and Annex 16.
DC-C/DC-9 NACELLE RETROFIT KITS
JULY 19 - 1974
The enclosed information is furnished for planning
purposes only. It is based on the best available
nominal data but should not be construed as a
guarantee nor as a commitment to manufacture or
deliver the subject treatment. Exceptions
are noted for aircraft FAA certified at the
specified noise levels.
DC-8/DC-9 NACELLE RETROFIT
KIT REQUIREMENTS
TREATMENT REQUIRED TO MEET
(FAR PART 36)
(ANNEX 16)
AIRPLANE
MTOGW/MLW (KLBS)
FLAPS
WITH TRADE
WITHOUT TRADE
WITH TRADE
*DC8-20/30
*272/*180
50°
TJP-1 (Pg. 5)
TJP-1 (Pg. 5)
TJP-1 (Pg. 5)
(JT4A-9/12)
*DC8-20/30
*270/199.5
50°
TJP-1 (Pg. 5)
Will not comply
TJP-1 (Pg. 5)
(JT4A-9/12)
DC8-51
286/199.5
50°
SDP-5 (Pg. 8)
SDP-7 (Pg. 10)
SDP-5 (Pg. 8)
(JT3D-3B)
DC8-51
286/199.5
50°
SDP-5 (Pg. 8)
SDP-7 (Pg. 10)
SDP-5 (Pg. 8)
(JT3D-1)
*DC8-51
286/*192
50°
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
(JT3D-3B)
DC8-52
305/207
50°
SDP-5 (Pg. 8)
SDP-7 (Pg. 10)
SDP-5 (Pg. 8)
(JT3D-3B)
*DC8-52
305/*195
50°
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
(JT3D-3B)
*DC8-52
305/207
*35°
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
(JT3D-3B)
DC8-53
315/207
50°
SDP-5 (Pg. 8)
SDP-7 (Pg. 10)
SDP-5 (Pg. 8)
(JT3D-3B)
*DC8-53
315/*197
50°
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
(JT3D-3B)
*Reduced Operating Weight and/or Flap Alternatives
1
DC-8/DC-9 NACELLE RETROFIT
KIT REQUIREMENTS
(FAR PART 36)
(ANNEX 16)
AIRPLANE
MTOGW/MLW (KLBS)
FLAPS
WITH TRADE
WITHOUT TRADE
WITH TRADE
DC8-54
315/240
50°
SDP-5 (Pg. 8)
SDP-7 (Pg. 10)
SDP-5 (Pg. 8)
(JT3D-3B)
*DC8-54
315/240
*35°
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
SDP-5 (Pg. 8)
(JT3D-3B)
DC8-55/61
325/240
50°
SDP-5 (Pg. 9)
SDP-7 (Pg. 10)
SDP-5 (Pg. 9)
(JT3D-3B)
*DC8-55/61
*320/240
*35°
SDP-5 (Pg. 9)
SDP-5 (Pg. 9)
SDP-5 (Pg. 9)
(JT3D-3B)
*DC8-61F
328/258
*35°
SDP-5 (Pg. 9)
SDP-7 (Pg. 10)
SDP-5 (Pg. 9)
(JT3D-3B)
*DC8-61F
*320/258
*35°
SDP-5 (Pg. 9)
SDP-5 (Pg. 9)
SDP-5 (Pg. 9)
(JT3D-3B)
DC8-62
335/240
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-7)
DC8-62
335/240
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-3B)
DC8-62
350/240
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-7)
DC8-62
335/250
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-7)
*DC8-62
335/250
*35°
LD-2A (Pg. 12)
LD-2A (Pg. 12)
LD-2A (Pg. 12)
(JT3D-7)
*Reduced Operating Weight and/or Flap Alternatives
2
DC-8/DC-9 NACELLE RETROFIT
KIT REQUIREMENTS
(FAR PART 36)
(ANNEX 16)
AIRPLANE
MTOGW/MLW (KLBS)
FLAPS
WITH TRADE
WITHOUT TRADE
WITH TRADE
DC8-63
350/245
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-7)
DC8-63
355/258
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-7)
DC8-63
355/275
50°
LD-2A (Pg. 12)
LD-2C (Pg. 13)
LD-2A (Pg. 12)
(JT3D-7)
DC9-14 & -15
90.7/81.7
50°
None (Pg. 14)
None (Pg. 14)
None (Pg. 14)
(JT8D-7)
DC9-20
98/93.4
50°
None (Pg. 14)
None (Pg. 14)
None (Pg. 14)
(JT8D-9)
DC9-20
98/93.4
50°
None (Pg. 14)
None (Pg. 14)
None (Pg. 14)
(JT8D-11)
DC9-31
105/98.1
50°
None (Pg. 14)
P-36 (Pg. 15)
None (Pg. 14)
(JT8D-7)
DC9-31
103/98.1
50°
None (Pg. 14)
P-36 (Pg. 15)
None (Pg. 14)
(JT8D-9)
DC9-32
108/99
50°
None (Pg. 14)
P-36 (Pg. 15)
None (Pg. 14)
(JT8D-7)
DC9-32
108/99
50°
None (pg. 14)
P-36 (Pg. 15)
None (Pg. 14)
(JT8D-9
DC9-33, -41
114/102
50°
P-36 (Pg. 15)
P-36 + re-engine
None (Pg. 14
(JT8D-9)
to JT8D-15 (Pg. 15)
DC9-33, -41
114/102
50°
P-36 (Pg. 15)
P-36 + re-engine
None (Pg. 14)
(JT8D-11)
to JT8D-15 (Pg. 15)
DC9-33, -41
114/102
50°
None (Pg. 14)
P-36 (Pg. 15 )
None (Pg. 14)
(JT8D-15)
*Reduced Operating Weight and/or Flap Alternatives
3
DC-8-20/30 JT4A-9/12
NO ACOUSTIC TREATMENT
©
NOISE LEVELS
(Requirement/Predicted)
OPERATING WEIGHTS
TO
TO/CB
SL
APPROACH
MODEL
MTOGW/MLW KLBS (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
-20/30
*272/*180
(50°)
102.3/113
102.3/102
105.7/105
105.7/111
105.7/110
(JT4A-9/12)
-20/30
*279/199.5
(50°)
102.2/113
102.2/102
105.7/105
105.7/111
105.7/110
(JT4A-9/12)
*Reduced Operating Weight and/or Flap Alternatives
4
TJP-1 TREATMENT FOR
DC-8-20 AND DC-8-30
NOISE LEVELS
(Requirement/Predicted)
OPERATING WEIGHTS
MODEL
MTOGW/MLW KLBS. (FLAPS)
TO
TO/CR
SL
APPROACH
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
-20/30
*272/*180
(50°)
102.3/113
102.3/102
105.7/105
105.7/106
105.7/105
(JT4A-9/12)
-20/30
*270/199.5
(50°)
102.2/113
102.2/102
105.7/105
104.7/106
105.7/105
(JT4A-9/12)
DC8-20 and -30 at certified MTOGW and MLW will not meet FAR Part 36 or ICAO Annex 16
ASPECIFIC RANGE (%)
AWT. (AIRPLANE)
SHIP SET
AVAILABILITY
RETROFIT
KIT COST $
DOUN TIME
0
60 lbs.
**
**
**
*Reduced Operating Weight and/or Flap Alternatives
5
DC-8-51/61 JT3D-3B (EXCEPT AS NOTED)
NO ACOUSTIC TREATMENT
NOISE LEVELS
(Requirement/Predicted)
OPERATING WEIGHTS
TO
TO/CR
SL
APPROACH
HODEL
MTOGH/MLW KLBS. (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
**51
286/199.5
(50°)
102.7/107
102.7/106
105.9/102
105.9/111
105.9/110
51
286/199.5
(50°)
102.7/107
102.7/102
105.9/102
105.9/111
105.9/110
*51
286/*192
(50°)
102.7/107
102.7/102
105.9/102
105.9/111
105.9/110
52
305/207
(50°)
103.1/109
103.1/105
106/102
106/111
106/110
*52
305/*195
(50°)
103.1/109
103.1/105
106/102
106/111
106/110
*52
305/207
(35°)*
103.1/109
103.1/105
106/102
106/109
106/108
53
315/207
(50°)
103.4/110
103.4/107
106.1/101
106.1/111
106.1/110
*53
315/*197
(50°)
103.4/110
103.4/107
106.1/101
106.1/111
106.1/110
*53
315/207
(35°)*
103.4/110
103.4/107
106.1/101
106.1/109
106.1/108
54
315/240
(508)
103.4/110
103.4/107
106.1/101
106.1/112
106.1/112
*54
315/240
(35°)*
103.4/110
103.4/107
106.1/101
106.1/110
106.1/109
*Reduced Operating Weight and/or Flap Alternatives
**JT3
Engine
6
DC-8-51/61 JT3D-3B (EXCEPT AS NOTED)
NO ACOUSTIC TREATMENT
NOISE LEVELS
(Requirement/Predicted)
OPERATING WEIGHTS
TO
TO/CB
SI.
APPROACH
MODEL
MTOGW/MLW KLBS. (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
55/61
325/240
(50°)
103.6/110
103.6/108
106.2/101
106.2/112
106.2/112
*55/61
*320/*240
(35°)
103.5/110
103.5/107
106.2/101
106.2/110
106.2/109
*61F
328/258
(35°)
103.6/111
103.6/109
106.3/101
106.3/110
106.3/110
*61F
*320/258
(35°)*
103.5/110
103.5/107
106.3/191
106.3/110
106.3/110
*Reduced Operating Weight and/or Flap Alternatives
7
SDP-5
EATMENT FOR
DC-8-50 AND DC-8-61
JT3D-3B Engine (except as noted)
NOISE LEVELS
(Requirement/Predicted)
OPERATING WEIGHTS
TO
TO/CB
SL
APPROACH
MODEL
MTOGW/MLW KLBS. (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
**51
286/199.5
(50°)
102.7/107
102.7/101
105.9/102
105.9/106
105.9/106
51
286/199.5
(50°)
102.7/107
102.7/98
105.9/102
105.9/106
105.9/106
*51
286/*192
(50°)
102.7/107
102.7/98
105.9/102
105.9/106
105.9/105
52
305/207
(50°)
103.1/108
103.1/101
106/102
106/106
106/106
*52
305/*195
(50°)
103.1/108
103.1/101
106/102
106/106
106/105
*52
305/207
(35°) *
103.1/108
103.1/101
106/102
106/104
106/103
53
315/207
(50°)
103.4/109
103.4/102
106.1/101
106.1/106
106.1/106
*53
315/*197
(50°)
103.4/109
103.4/102
106.1/101
106.1/106
106.1/105
*53
315/207
(35°)*
103.4/109
103.4/102
106.1/101
106.1/104
106.1/103
54
315/240
(50°)
103.4/109
103.4/102
106.1/101
106.1/108
106.1/107
*54
315/240
(35°) *
103.4/109
103.4/102
106.1/101
106.1/105
106.1/105
*Reduced Operating Weight and/or Flap Alternatives
Cont. Pq. 9
**JT3D-1 Engine
8
SDP-5 TREATMENT FOR
(continued)
DC8-50 AND DC9-61
OPERATING WEIGHTS
TO
TO/CB
SL
APPROACH
MODEL
MTOGW/MLW KLBS. (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
55/€1
325/240
(50°)
103.6/109
103.6/104
106.2/101
106.2/108
106.2/107
*55/61
*320/*240
(35°)
103.5/109
103.5/103
106.2/101
106.2/105
106.2/105
*61F
328/258
(35°)*
103.6/110
103.6/104
106.3/101
106.3/106
106.3/105
*61F
*320/258
(35°) *
103.5/109
103.5/103
106.2/101
106.2/106
106.2/105
ASPECIFIC RANGE (%)
AWT. (AIRPLANE)
SHIP SET
RETROFIT DOWN
TOTAL REWORK
KIT COST $
AVAILABILITY
TIME
PER AIRCRAFT-MN/HRS
0
93 lbs.
$450,000
ATP + 28
24 hours elapsed
1350
months
*Reduced Operating Weight and/or Flap Alternatives
9
SDP-7 TREATMENT FOR
DC-3-50 AND DC-8-61
NOISE LEVELS
(Pequirement/Predicted)
TO
TO/CB
SL
APPROACH
OPERATING WEIGHTS
MODEL
MTOLGW/HLW KLBS (FLAPS)
(FAR PART 36 0, ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
-51
286/199.5
(50°)
102.7/107
102.7/100
105.9/102
105.9/105
105.9/104
(JT3D-1)
-50/61
325/240
(50°)
103.6/109
103.6/103
106.2/101
106.2/106
106.2/106
(JT3D-3D)
-61F
328/258
(35°)
103.6/110
103.6/103
107.3/101
106.3/104
106.3/104
(JT3D-3D)
SPECIFIC RANGE (%)
WT. (AIRPLANE)
SHIP SET
AVAILABILITY
RETROFIT
TOTAL REWORK
KIT COST $
DOWN TIME
PER AIRCRAFT - MJ/HRS
+1
449 lbs.
$900,000
ATP + 30
72 hours
1880
months
elapsed
*Reduced Operating Weight and/or Flap Alternatives
10
DC-8-62/63 JT3D-7 (EXCEPT AS NOTED)
NO ACOUSTIC TREATMENT
NOISE LEVELS
(Requirement/Predicted)
OPEAATING WEIGHTS
TO
TO/CB
SL
APPROACH
MODEL
MTOGW/MLW KLBS. (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
62
**335/240
(50°)
103.8/111
103.8/110
106.3/100
106.3/113
106.3/113
335/240
(50°)
103.8/110
103.8/109
106.3/100
106.3/113
106.3/113
350/240
(50°)
104.1/112
104.1/111
106.4/100
106.4/113
106.4/113
335/250
(50°)
103.8/110
103.8/109
106.3/100
106.3/114
106.3/113
335/250
(35°)
103.8/110
103.8/109
106.3/100
106.3/112
106.3/112
63
350/245
(50°)
104.1/112
104.1/111
106.4/100
106.4/114
106.4/113
355/258
(50°)
104.2/112
104.2/112
106.5/100
106.5/114
106.5/113
355/275
104.2/112
104.2/112
106.5/100
106.5/114
106.5/113
(50°)
*Reduced Operating Weight and/or Flap Alternatives
**JT3D-3B Engine
11
LD-2A TREATMENT FOR
DC-8-62 AND DC-8-63
JT3D-7 Engine (except as noted)
NOISE LEVELS
(Requirement/Predicted)
OPERATING WEIGHTS
TO
TO/CB
SL
APPROACH
MODEL
MTOGW/MLW KLBS (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
62
**335/240
(50°)
103.8/110
103.8/105
106.3/97
106.3/107
106.3/107
335/240
(50°)
103.8/108
103.8/104
106.3/97
106.3/107
106.3/107
350/240
(50°)
104.1/109
104.1/105
106.4/97
106.4/107
106.4/107
335/250
(50°)
103.8/108
103.8/104
106.3/97
106.3/107
106.3/107
335/250
(35°)*
103.8/108
103.8/104
106.3/97
106.3/106
106.3/105
63
350/245
(50°)
104.1/109
104.1/105
106.4/97
106.4/107
106.4/107
355/258
(50°)
104.2/109
104,2/106
106.5/97
106.5/107
106.5/107
355/275
(50°)
104.2/100
104.2/106
106.5/97
106.5/108
106.5/107
SPECIFIC RANGE (%)
0 WT. (AIRPLANE)
SHIP SET
AVAILABILITY
RETROFIT
TOTAL REWORK
KIT COST $
DOWN TIME
PER AIRCRAFT - MN
0
304 lbs.
$600,000
ATP + 36
24 hours
120
months
elansed
12
*Reduced Operating Weight and/or Flap Alernatives
**JT3D-3D Engine
LD-2C TREATMENT FOR
DC-8-62 AND DC-8-63
NOISE LEVELS
(Pequirement/Predicted)
OPERATING WEIGHTS
TO
TO/CB
SL
APPROACH
MODEL
MTOGW/MLW KLBS (FLAPS)
(FAR PART 36 & ICAO ANNEX 16)
(FAR PART 36)
(ICAO ANNEX 16)
62/63
355/275
(50°)
104.2/109
104.2/104
106.5/97
106.5/105
106.5/105
(JT3D-7)
62
335/240
(50°)
103.8/110
103.8/104
106.3/97
106.3/105
106.3/104
(JT3D-36)
ASPECIFIC RANGE (%)
AWT. (AIRPLANE)
SHIP SET
AVAILABILITY
RETROFIT
PER AIRCRAFT - NO
KIT COST $
DOWN TIME
0
916 lbs
$650.00
ATP + 36
24 hours
120
months
elapsed
13
DC-9 110DELS !'ITHOUT
RETROFIT TREATMENT
NOISE LEVELS
(Pequirement/Predicted)
FAR PART 36
ICAO ANNEX 16
OPERATING WEIGHTS
MODEL
INTOGN/MLM KLBS.
TO
TO/CB
SL
APPROACH
TO
TO/CB
SL
APPROACH
-14 & -15
90.7/81.7
94.4/93
94.4/92
102.5/99
102.5/101
94.4/93
94.4/05
102.5/96
102.5/100
(JTBD-7)
-20 (JT&D-9)
98/03.4
94.9/99
94.9/93
102.8/100
102.8/103
04.9/99
94.9/87
102.8/97
102.8/102
-20 (JTSD-11)
98/93.4
94.9/100
94.0/93
102.8/98
102.8/103
04.9/100
04.9/96
102.8/103
102.8/102
-31 (JTSD-9)
103/98.1
95.3/100
95.3/96
102.9/100
102.9/103
95.3/100
95.3/89
102.9/97
102.9/102
-31 (JT&D-7)
105/98.1
95.4/101
95.4/05
103/98
103/101
95.4/101
95.4/89
103/95
103/101
-32 (JT8D-7)
108/99
95.6/101
95.6/97
103.1/98
103.1/101
95.6/101
95.6/90
103.1/05
103.1/101
-32 (JTSD-9)
108/99
95.6/102
95.6/97
103.1/100
103.1/103
95.6/102
95.6/90
103.1/97
103.1/102
-33, -41
114/102
96/103
96/99
103.2/100
103.2/103
96/103
20/92
103.2/97
103.2/103
(JT8D-9)
-33, -41
114/102
96/102
96/99
103.2/101
103.2/103
96/102
96/92
103.2/98
103.2/103
(JTSD-11)
-33, -41
114/102
96/102
96/97
103.2/101
103.2/103
96/102
00/90
103.2/90
103.2/103
(JTBD-15)
14
p-36 TREATMENT FOR
DC-9-31, -32, -33, -44
KCN 215
0
NOISE LEVELS
(Requirement/Predicted or FAA Certificated)
FAR PART 36
ICAO ANNEX 16
OPERATING WEIGHTS
MODEL
MTOGW/MLW KLBS.
TO
TO/CB
SL
APPROACH
TO
TO/CB
SL
APPROACH
-31 (JT8D-9)
103/98.1
95.3/100
95.3/94
102.9/99
102.9/99
95.3/100
95.3/87
102.0/96
102.9/98
-31 (JT8D-7)
105/98.1
95.4/100
95.4/94
103/97
103/97
95.4/100
95.4/87
103/94
103/97
-32 (JTBD-7)
108/99
95.6/100
95.6/95.2*
103.1/97.3*
103.1/97.3*
95.6/100
95.6/88
103.1/94
103.1/97
-32 (JTSD-9)
108/99
95.6/102
95.6/95.6*
103.1/98.9*
103.1/99.1*
95.6/102
95.6/89
103.1/96
103.1/98
-33, -41
114/102
96.0/102
96.0/97
103.2/99
103.2/99
96.0/102
96.0/00
103.2/96
103.2/09
(JT8D-9)
-33, -41
114/102
96.0/101
96.0/96.8* 103.2/99.9* 103.2/99.4*
06.0/101
96.0/90
103.2/97
103.2/09
(JTSD-11)
-33, -41
114/102
96.0/102
96.0/95.8* 103.2/100.5*103.2/99.4*
96.0/102
96.0/88
103.2/97
103.2/99
(JTSD-15)
SHIP SET
RETROFIT
TOTAL REWORK
ASPECIFIC RANGE (%)
AWEIGHT (AIRPLANE)
KIT COST $
AVAILABILITY
DOWN TIME
PER AIRCRAFT : - IT/HRS
0
330 lbs.
$99,774 DACO Kit ATP + 22
? lirs.
032
+$43,500 P&WA
months
elapsed
"Ilush Kit"
*FAA Certificated
15
Attachment 2
AN ASSESSMENT OF THE BENEFITS OF A
NACELLE RETROFIT PROGRAM
Problems with Existing Assessment Methods
Quite a number of rating methods have been used to compare the community noises
of different aircraft types, different operating conditions, and different kinds
of noise suppressors. The two primary methods have consisted of establishing the
difference in noise levels at the FAR Part 36 noise measurement locations, or
establishing the difference in areas of some particular noise level contour.
Both these methods are highly questionable when it comes to evaluating the
benefits of applying sound absorbent materials (SAM) to the existing fleet of JT3D
and JT8D powered aircraft. The primary difficulty lies in the fact that the amount
of noise reduction achieved by the SAM treatment varies considerably with engine
type, with engine thrust, with distance from the engine and with other conditions
which may influence the propagation path between the engine source and the receiver
of the noise.
In the case of the Part 36 locations, the approach noise reduction is rated at
only one point at a distance of 370 feet from the aircraft. For takeoff there are
two points if the sideline is included as a part of takeoff, but the use of a major
thrust reduction which is not currently a normal operating procedure certainly clouds
the issue. There is a tendency to use only the takeoff point and for four engine
aircraft, this involves an evaluation at a distance of only about 800 feet from the
aircraft.
In the case of contour areas there are three major problems. One is the
selection of the appropriate contour value. The projected benefits of suppression
vary considerably with the value selected, and there is no value which is universally
accepted as the most significant. The second problem is that no one can yet attach
any particular significance to a given reduction in contour area. For example, a
1
reduction in contour area of 50% sounds impressive, but it can be accomplished
with a reduction of only 4 dB, which is not very impressive. Contour areas are
highly sensitive to small changes in noise level, and caution must be exercised
in attaching a particular significance to given reductions in contour areas. The
third problem is, of course, the accuracy of the contour. Again because the contour
areas are sensitive to small changes in noise level, gross inaccuracies in contour
areas are not unusual. Our ability to predict noise levels at considerable distances
from an aircraft and to account for wind and temperature gradients and terrain
effects on propagation is quite limited. As a result there are no universally
accepted means of developing contours.
The following sections evaluate the SAM treatment for DC-8 and DC-9 aircraft
under new alternate evaluation systems. It is considered that in light of the
difficulties of the more conventional systems, these evaluations will help sub-
stantially to put the benefits of the SAM treatment for JT3D and JT8D powered aircraft
into a more proper perspective.
2
Contours of Equal Reduction in Noise Level
One proposed assessment method which should overcome at least most of the
objections to existing methods is that of contours of equal reduction in noise
level. This method would not be suitable for noise reduction features which achieve
the same noise reduction for all frequencies but is especially suitable for something
like the SAM suppression which reduces high frequency noise while leaving low
frequency noise unchanged.
To develop such a contour for a given sound suppressor one could develop a series
of contours for the unsuppressed case and for the suppressed case and then develop
a new contour based on the differences between them. However, if the flight path of
the aircraft is the same in both cases, there can be a much more direct approach.
One need only know the flight path of the aircraft, the thrust setting for each
segment of that flight path and the noise reduction achieved by the suppressor at
each thrust setting as a function of the distance from the aircraft.
Figure 1 presents the noise reduction achieved by the P-36 sound suppressor
for the JT8D powered DC-9 aircraft. The noise reductions are plotted as a function of
distance from the aircraft for the three different thrust conditions which correspond
to the takeoff, cutback and approach thrust of FAR Part 36. The noise reductions are
plotted in terms of dB(A). The unit was selected primarily for reasons of simplicity.
Extrapolation of EPNL's measured at one distance to various other distances is far
more complex and uncertain than extrapolation of a simple unit such as PNL or dBA.
In any event it is expected that using either PNL or EPNL would lead to the same
general conclusions.
For all these thrusts the amount of noise reduction decreases as distance from
the aircraft increases. This is of course because the high frequency noise which is
attenuated by the suppressor is attenuated in any event by atmospheric absorption
so that this type suppression does not affect the total noise at greater distances.
3
Noted on the curves are the three points which are representative of the three
Part 36 evaluation points of approach, takeoff (with cutback) and sideline.
Even this plot provides a much greater insight into the benefits of the
suppressor than the limited Part 36 values. However, utilizing these data to develop
the contour provides an even more revealing analysis.
Figure 2 shows the contour of equal reduction in noise level for the P-36
suppressor for this airplane when flown under the FAR Part 36 conditions of weight,
weather, operating procedures, etc. The aircraft is landing from the left and taking
off toward the right. For approach Part 36 rates the suppressor only at the single
point 1 nautical mile from touchdown as shown. However, only a small percentage of
the airport neighbors would experience that reduction. Rather the airport neighbors
would experience the reductions as shown in the Figure. For many airports of course a
large part of the area experiencing the largest reduction in approach noise is a part of
the clear zone or is at least not residential property. The amount of reduction
decreases with increasing distance from the runway and of course decreases rapidly as
one goes out towards the side from directly beneath the approach flight path of the
aircraft.
As the aircraft begins its roll for takeoff there is a small reduction in noise.
A reduction of 1 dBA could be expected out to a side distance of about 1000 feet.
This narrows slightly as the aircraft gains altitude after liftoff. However, if the
thrust is cut back at the 3 1/2 nautical mile point, the contour expands because the
suppressor is more effective at the lower thrust. Actually the expansion starts
well before the 3 1/2 nautical mile point. This takeoff procedure was developed to
achieve a minimum noise level at the 3 1/2 mile point and requires that the thrust
reduction be made more than 2000 feet prior to that point.
With this technique one can see that the reductions of the suppressor are too
small to be detectable by most airport neighbors. However even this analysis is
optimistic for the suppressor. Just as the atmosphere absorbs the high frequency noise
4
more efficiently than low frequency noise so do the walls and roof of a house. For
this reason the reductions resulting from a high frequency noise suppressor like
SAM will be less indoors than outdoors. The average house attenuation from Society
of Automotive Engineers Aerospace Information Report No. 1081 was applied to the
suppressed and unsuppressed noise data for the DC-9 and the noise reduction was then
recalculated for an indoor case. The results are plotted in Figure 3.
The results are similar to those of Figure 1 except that the reductions are
even smaller. For the takeoff thrust case they have essentially dissappeared. The
reduction is less than 2 dBA even for the approach case at 370 ft altitude. It is
obvious from this curve that the typical indoor noise reductions achieved by the
suppressor are too small to even be considered measurable. Figure 4 again presents
the contours of equal noise reduction achieved by this suppressor but this time for
the indoor case. There is a tiny island of 2 dBA reduction at the end of the runway
and a narrow island of 1 dBA reduction extending out to 15,000 feet. There is nothing
for takeoff.
All our studies show that the vast majority of the disturbances resulting from
aircraft operational noise occur to people when they are in their homes. In light
of this fact and of the data presented we find it extremely difficult to see that
application of this suppressor would provide any meaningful relief to the community
noise problem. Based on the data we have seen for SAM suppression applied to the
727 and 737 powered by the same engine we would expect slightly different numbers
but the same general conclusions as for the DC-9.
One further extension of this analysis procedure is perhaps appropriate.
That is to lay these contours over a map to establish the reductions which may be
expected by any specific community at a specific airport. Figures 5 and 6 present
an example of this application for Washington National Airport. The landings and
takeoffs are toward the south with the aircraft following the path of the river.
5
The data indicate that for the Georgetown area the reduction expected would be
about one dBA outdoors and zero indoors. For this airport the noise reduction at the
FAR Part 36 location is certainly a meaningless number. Similar analysis can, of
course, be conducted for noise sensitive communities at any airport.
The situation for the DC-8 is somewhat different but not radically. Figures 7
and 8 show the estimated noise reductions of the SDP-7 suppressor installed on the
short duct pod version of the JT3D powered DC-8 as a function of distance for the
indoor and outdoor case. While the reductions get fairly large outdoors and close to
the airplane at approach and cutback thrust these reductions fade away rather quickly
with distance or altitude (slant range).
Figure 9 shows the data for this suppressor in contour form. Data are provided
for the outdoor case in the upper contours and for the indoor case in the lower
contours. Again a Part 36 thrust cutback procedure was assumed, This is, of course,
not the way these aircraft are flown. As they are flown the small takeoff contour
reductions would just not occur. In either event the reductions are very limited in
both magnitude and extent. Yet this is the suppressor projected to bring this aircraft
into compliance with FAR Part 36 without the need of tradeoffs.
Figure 10 presents similar information for the DC-8-63 with the long duct pod
and the LD2A suppressor. While the reductions are somewhat greater they are still
quite limited.
The JT3D powered 707 would show still greater reductions with its SAM treatment.
This is believed to be because the blow-in doors on the nacelle inlet result in a
higher level of turbomachinery noise than is present or the DC-8. As a result
removing these blown-in doors and adding SAM provides a greater reduction in noise
level. However, the reduction is still primarily just applicable to the high
frequency noise and the same kinds of limitations in the extent of the reductions
achieved with distance from the aircraft would be expected.
6
The Concept of People Annoyed
The Noise Exposure Forecast (NEF) is the airport noise rating system which is
used most extensively in this country. It suffers from all the problems of accuracy
associated with contours and with predictions of human response to a complex series
of noises even a long period of time. However, if viewed as a general guidance
tool for estimating the reaction of communities to some future noise exposure it is
of considerable value.
On the other hand there are no technical data to support the selection of any
single NEF value (such as NEF 30 or NEF 40) as an index for use in estimating the
change in noise disturbance resulting from changes in noise source strength. Even
for a suppressor which reduces noise at all frequencies this would be questionable.
NEF areas experience the same halving for each 4 dB of noise reduction as do the
single event noise contours and thus tend to strongly overestimate improvement
effects.
For the SAM type suppression, however, using such an evaluation procedure can be
especially optimistic because the noise reductions decrease at the lower NEF values.
It has been suggested that this is perhaps not important because there is nc noise
problem at the lower NEF values. Our analyses do not agree with this conclusion.
In fact our analyses show that the majority of the people who are highly annoyed
by aircraft noise lie outside the NEF 30 exposure area. The reasons for this conclusion
are illustrated in an Appendix to this note. The analysis is based on the SAGA
concept which has been studied by quite a number of investigators. Rather than
assuming any single exposure value and assuming all people exposed to higher levels
are annoyed and those exposed to lower levels are not annoyed it assumes that the
higher the noise exposure the higher the percentage of people who are annoyed. Quite
a number of curves have been developed to show this relationship. While there are
some major variations between them, the general conclusions to be drawn from using
7
any one of them tends to be the same. This point is illustrated in the appendix.
It is believed that adding this type analysis to any NEF data developed to rate
suppressors is essential before any meaningful conclusions can be reached.
A Simple Single Numbered Evaluation
Our studies have shown that using some sort of average or summation of the three FAR
Part 36 values for an airplane can be very misleading. Locations and conditions vary for
different aircraft types. Some use thrust reductions and some do not, and in any event each
single value does not necessarily offer a fair representation of the noise of the aircraft.
At least some of these objections are not applicable to the evaluation of a noise suppressor.
A simple system follows which may help to put the effects of SAM suppressors into a more proper
perspective.
As a first step one could assume that very roughly each of the three Part 36 points is repre-
sentative of one third of the problem: i.e., approach, takeoff up to the point of thrust cutback
(sideline) and takeoff beyond the point of thrust cutback. For the takeoff case, actual takeoff
operating procedures lie between the cutback and the non-cutback case. In the case of the
DC-9-30 with the P-36 SAM suppressor, the approved data show differences between baseline
hardwall and P-36 treatment as 4.0 EPNdB for approach, 1.1 EPNdB for sideline and 1.8 EPNdB
for takeoff with cutback. If we assume the 1.1 EPNdB for takeoff without cutback and average
between cutback and no cutback, we would obtain a 1.4 EPNdB value for the takeoff point.
Averaging this value with the approach and sideline, we get a single valued average suppression
of 2.2 EPNdB at the Part 36 locations. Recognizing that this evaluation applies only to
locations very near the airport and outdoors, and that it is the most optimistic evaluation of the
suppressor, it is easy to reach the conclusion that most neighbors would be highly disappointed
with the results of a SAM retrofit program on this aircraft.
8
A similar analysis has been performed for other Douglas Aircraft and for several Boeing
aircraft based on published data. It is shown in Figure 11.
The data for JT8D powered aircraft cluster very closely with an average reduction of from
2.0 to 2.3 EPNdB. It would thus seem reasonable to conclude that the lack of meaningful benefits
demonstrated by the contours of equal noise reduction for SAM treatment on the DC-9 would also
be true for the 727 and 737 aircraft.
In the case of the DC-8 the average reduction varies from about 3 to 6 EPNdB depending on
the pod type and the particular suppressor. The 707 shows an average reduction of 8EPNdB,
which is a little higher than for the DC-8. Again, this is thought to be attributable to deletion
of the blow-in doors in addition to the SAM treatment on the 707.
Perhaps a fair summary of this evaluation would be to conclude that SAM provides an average
reduction of 2 EPNdB for JT8D powered aircraft and 3 to 6 EPNdB for JT3D powered aircraft.
It should be emphasized, however, that these values refer only to locations outdoors and very
near the airport. The bulk of the reductions experienced by airport neighbors would be well
below these due to the loss in effectiveness of SAM suppression indoors and at greater distances.
Even so, they are hardly the kinds of reductions which would make the difference between an
unacceptable and an acceptable environment for airport neighbors.
The Question of Timing
If a nacelle retrofit program could be accomplished overnight, it is expected that those people
near the airport and directly below the approach path whose disturbance is dominated by JT3D
approach noise would appreciate the effects of a SAM suppression program. However, those
people represent only a small part of the people bothered by aircraft noise. In addition, any
actual retrofit program would be spread out over a period from about 1977 to 1982. During that
9
time period the JT3D powered aircraft will represent an increasingly small portion of the total
jet aircraft operations. ATA has estimated that JT3D powered aircraft will account for less
than 10% of the commercial jet operations in the U.S. in the 1980's. As only half those
operations are approaches less than 5% of the total operation would reflect the kinds of reduc-
tions achieved for the JT3D on approach. Under these circumstances it is not expected that a
SAM retrofit would make a significant contribution to the solution of the airport community
noise problem.
General Conclusions
Based on the foregoing data and analyses we can only conclude that the benefits of conducting
a SAM retrofit without also reducing the low frequency jet exhaust noise would be minimal and
would lead to disappointment on the part of most airport neighbors. It is recognized that most
airport neighbors would be pleased to hear that anything was being done and thus could become
more tolerant of aircraft noise. However, it is suggested that this would be only temporary.
When people realize that in most cases they have the same noise problem that was present before
the retrofit, that tolerance may well backfire into a strong resentment which will make airport
operations and expansion more difficult than ever.
10
46 4973
1
2
3
5
6
7
8
6
10
2
3
4
5
6
7
8
9
MODEL DC-9-30
JT8D-7
OUTDOOR NOISE REDUCTION
HARDWALL - P-36
3
6
NOISE REDUCTION, dBA
Part 36 Approach Value
APPROACH
4
CUTBACK
TAKEOFF
Part 36 Takeoff Value (with Cutback)
Part 36 Sideline Value
2.
Part 36 Takeoff Value (without Cutback
250
500
1000
2000
4000
0403
SLANT RANGE, Ft.
++++++++
FIGURE 1
DOUGLAS
ESTIMATED CONTOURS OF EQUAL NOISE REDUCTION RESULTING FROM P-36 TREATMENT
DC-9-30
JT8D-7A ENGINES
108,000 LB. TAKEOFF AND 99,000 LB. LANDING GROSS WEIGHTS
TAKEOFF WITH CUTBACK
10000 FT
OUTDOOR
1 dBA
2 dBA
3 dBA
4 dBA
LANDING
TAKEOFF
FIGURE 2
46 4973
I
2
3
4
5
6
7
8
6
10
1
2
3
4
5
6
7
8
6
MODEL DC-9-30
JT8D-7
INDOOR NOISE REDUCTION
0
HARDWALL - P-36
8
NOISE REDUCTION, dBA
6
Part 36 Approach Value
Part 36 Takeoff Value (with Cutback)
CUTBACK
APPROACH
of
Part 36 Sideline Value
Part 36 Takeoff Value (without Cutback)
250
500
1000
2000
4000
EDD
SLANT RANGE, Ft.
FIGURE 3
DOUGLAS
ESTIMATED CONTOURS OF EQUAL NOISE REDUCTION RESULTING FROM P-36 TREATMENT
DC-9-30
JT8D-7A ENGINES
108,000 LB. TAKEOFF AND 99,000 LB. LANDING GROSS WEIGHTS
TAKEOFF WITH CUTBACK
INDOOR
10000 FT
1 dBA
2 dBA
LANDING
TAKEOFF
FIGURE 4
his
ESTIMATED CONTOURS OF EQUAL NOISE
REDUCTION FROM SAM TREATMENT
OFCOLUMBIA
OUTDOORS
06-9-30
JTCD-7A ENGINES
B
P-35 TREATMENT
108,000 lbs TOG!
I
29,000 lbs LGH
M
TAKEOFF 11TH CUTRACK
WEST
I
Similar
II80
SUMILITARY
RIVER
Tidel
Run
ABLICATION
ER
ington
CEMETER
Washington
WASHINGT
un
Channel
PARK
Greenlest
YINDS
1dBA
STATION
and
2dBA
CHAIL
3dBA
4dBA
BOLLING
AIR FOTCE
BASE
lete Island
FIGURE 5
ESTIMATED CONTOURS OF EQUAL NOISE
90
REDUCTION FROM SAM TREATMENT
The Three Sisters
OF
COLUMBIA
INDOORS
0C-9-30
Highlands
JT20-7A ENGINES
Theodore
little
B
B
P-35 TREATMENT
22
108,000 lbs TOGU
Raose
99,000 lbs LGW
TAKE OFF VITH CUTRACK
WESP
UMAC
I
MILITARY
JITTLE
II80
EIVER
Tidel Hasin
DIO
ARLINOTION
X
NATIONAL
st
CEMETERY
DISTRICT
Laron
Washington
WASHINGT
Greentest
Continue
Helne
Point
1dBA
STATION
98
THE
2dBA
?
BOLLING
AIR FORCE
BASE
reld Island
FIGURE 6
1
2
3
4
5
6
7
8
6
10
2
3
4
5
6
7
8
6
MODEL DC-8-61
INDOOR NOISE REDUCTION
HARDWALL - SDP-7
10
8
Part 36 Approach Value
NOISE REDUCTION, dBA
APPROACH
Part 36 Takeoff Value (with Cutback)
Part 36 Takeoff Value (without Cutback)
2
CUTBACK
TAKEOFF
Part 36 Sideline Value
250
1000
2000
SLANT RANGE, Ft.
FIGURE 7
1
2
3
4
5
9
L
8
6
10
1
2
3
4
5
6
7
8
9
MODEL DC-8-61
OUTDOOR NOISE REDUCTION
HARDWALL - SDP-7
10
&
Part 36 Approach Value
NOISE REDUCTION, dBA
APPROACH
4
Part 36 Takeoff Value (with Cutback)
Part 36 Takeoff Value (without Cutback)
CUTBACK
12
Part 36 Sideline Value
TAKEOFF
250
500
1000
2000
4000
END
SLANT RANGE, Ft.
FIGURE 8
DOUGLAS
ESTIMATED CONTOURS OF EQUAL NOISE REDUCTION RESULTING FROM SDP-7 TREATMENT
DC-8-61
JT3D-3B ENGINES
325,000 LB. TAKEOFF AND 240,000 IB LANDING GROSS WEIGHTS
TAKEOFF WITH ct BACK
10000 FT
1 dBA
2 dBA
1 dBA
3 dBA
2 dBA
OUTDOOR
4 dBA
LANDING
TAKEOFF
1 dBA
1 dBA
2 dBA
INDOOR
3 dBA
LANDING
TAKEOFF
FIGURE 9
DOUGL
ESTIMATED CONTOURS OF EQUAL NOISE REDUCTION RESULTING FROM
LD-2A
TREATMENT
DC-8-63
JT3D-7 ENGINES
355,000 LB. TAKEOFF AND 275,000 LB LANDING GROSS WEIGHTS
TAKEOFF WITH CUTBACK
10000 FT
1 dBA
2 dBA
3 dBA
4 dBA
5 dBA
1 dBA
6 dBA
OUTDOOR
2 dBA
7 dBA
3 dBA
LANDING
TAKEOFF
FIGURE 10
OUTDOOR SUPPRESSION BASED SIMPLE RATING METHOD
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APPENDIX
IMPORTANCE OF THE MINIMUM NEF VALUE USED IN STUDIES OF
VARIOUS AIRCRAFT NOISE REDUCTION ALTERNATIVES
The following analysis was prepared to demonstrate the importance of selecting
the minimum NEF to be used in studies of various aircraft noise reduction
alternatives. While the analysis does not offer a specific minimum NEF value it
indicates that too high a minimum value can omit from consideration the major part
of the people highly annoyed by aircraft noise.
Figure 1 is a sample set of computer printed NEF contours from values 25 to 40.
It is taken directly from a report prepared by Bolt, Beranek and Newman. It is
actually only a portion of the contours but if one neglects the airport property the
relative areas enclosed by the different contours are somewhat representative of
those in a typical airport situation. The approximate areas of each contour value
were measured with a plamimeter and are plotted on semilog paper in Figure 2 as a
function of the NEF value. The circles are points measured on Figure 1. The line is
a visual fit extrapolated down to an NEF value of 20. The relationship of increasing
area with decreasing NEF value from this figure has been used in the analysis that
follows.
Table la lists the area enclosed by each contour value and Table 1B the contour
area between NEF values of 5 NEF intervals from NEF 20 to NEF 40. Table 1c lists the
total population for each of the contour intervals based on an assumption of ?500
people per square mile.
Figure 3 relates the percentage of people highly annoyed to the NEF value to
which they are exposed. The lower curve is taken directly from DOT information.
The upper curve is from Figure 238a of Karl Kryter's book. Kryter's curve uses the
terminology "Estimated percent of people rating noise as unacceptable for residential
living."
a
Table 2 shows the steps to determine the number of people within each of the
contour intervals who are highly annoyed. This was a simple numerical integration
and the percentage people annoyed value for each interval was selected as that at
the midpoint of the interval.
Table 3 is similar to Table 2 except that Kryter's curve was used rather than
the DOT curve.
With either the DOT curve or the Kryter curve the general conclusion would be
about the same. Most of the people who are highly annoyed live beyond the NEF
30 contour. In fact, for this particular set of assumptions there are about five
times as many people highly annoyed in the NEF 20 to 30 interval as there are in the
NEF 30 to 40 interval. This kind of analysis needs to be made for other situations
but this one is probably representative of the situation at many airports. When
one is examining the relative benefits of noise reduction alternatives which might
vary in there relative effectiveness between an NEF 20 and an NEF 30 area reduction,
selecting NEF 30 as a minimum value for the analysis could lead to the wrong
conclusions.
b
25
30
35
40
40
35
30
25
DTW 1985 NEF 25-40 CONTOURS
10000-29864 FT.
DETROIT. MICHIGAN
3R-B
SCALE 1: 24000 (1" =2000')
I 2000 FT.
BOLT BERANCK I NEWMAN INC.
JOB 118992
DATE 05/08/72
EXAMPLE OF COMPUTER PRINTED NEF CONTOURS FOR ONE FLIGHT SEGMENT
FIGURE 1
3
2
9
AREA ENCLOSED BY CONTOUR AS A
FUNCTION OF NEF VALUE
50
40
NEF
30
20
0.1
0.2
0.5
1.0
2.0
5.0
10.0
AREA ENCLOSED BY
CONTOUR (Mi)2
FIGURE 2
PERCENT PEOPLE HIGHLY ANNOYED BY AIRCRAFT NOISE
AS A FUNCTION OF THE NEF TO WHICH THEY ARE EXPOSED
100
80
% People
Highly
KRYTER
Annoyed
60
DOT
40
20
0
0
10
20
30
40
50
60
NEF
FIGURE 3
NEF
CONTOUR AREA
NEF INTERVAL
CONTOUR INTERVAL
(MI)²
2
AREA (MI)
20
10.000
20 to 25
5.980
25
4.020
25 to 30
2.685
30
1.335
30 to 35
0.976
35
0.359
40
0.065
35 to 40
0.294
la Contour Areas
1b Contour Interval Areas
NEF INTERVAL
CONTOUR INTERVAL
TOTAL POPULATION
AREA (MI)²
IN AREA
20 to 25
5.980
14,950
25 to 30
2.685
6,720
30 to 35
0.976
2,440
35 to 40
0.294
735
lc Population in Each Contour Interval Area Assuming 2500 People per (MI) 2
TABLE 1
HIGHLY ANNOYED PEOPLE BASED ON DOT CURVE
NEF INTERVAL
POPULATION
PERCENT
PEOPLE
PERCENT OF
HIGHL Y
HIGHLY
TOTAL HIGHLY
ANNOYED
ANNOYED
ANNOYED PEOPLE
20 to 25
14,950
15
2245
45.6
25 to 30
6,720
23.7
1593
32.3
30 to 35
2,440
32.3
788
16.0
35 to 40
735
41
301
6.1
20 to 30
21,670
-
3838
77.9
30 to 40
3,175
-
1089
22.1
20 to 40
24,845
-
4927
100
TABL
HIGHLY ANNOYED PEOPLE BASED ON KRYTER CURVE
NEF INTERVAL
POPULATION
PERCENT
PEOPLE
PERCENT OF
HIGHLY
HIGHLY
TOTAL HIGHLY
ANNOYED
ANNOYED
ANNOYED PEOPLE
20 to 25
14,950
25.3
3785
49.4
25 to 30
6,720
35
2350
30.7
30 to 35
2,440
45.3
1106
14.5
35 to 40
735
55.8
410
5.4
20 to 30
21,670
-
6135
80.1
30 to 40
3,175
-
1516
19.9
20 to 40
24,845
-
7651
100
GERALD
R.
TIGRAMY
FORD
TABLE 3
APPENDIX H: BIBLIOGRAPHY
APPENDIX H: BIBLIOGRAPHY
1. AIR POLLUTION AND POLITICS OF CONTROL. Papers by Elliot Goldstein,
Charles A. Cohen, Yves Alarie, and others. New York, MSS
Information Corp., 1973, 182 p.
2. Air Pollution Control Association and National Air Pollution Control
Conference, Pittsburgh, Pa., 1970.
3. Baron, Robert A. THE TYRANNY OF NOISE. New York, St. Martins
Press, 1970, 294.p.
4. Beranek, Leo L., ed. NOISES AND VIBRATION CONTROL. New York,
McGraw-Hill, 1971, 650 p.
5. Bolt, Beranek and Newman, Inc., Cambridge, Mass. HANDBOOK OF
ACOUSTIC NOISE CONTROL. V. II. Noise and Man. Prepared for
U.S. Air Force, Wright Air Development Center, Wright-
Patterson AFB, Ohio. Jun. 1953, 262 p. WADC TR 52-204
Cf. Chapt. 17 Effects of noise on human behavior, p. 139
6. Bolt, Beranek and Newman, Inc., Cambridge, Mass. REACTION TO
AIRCRAFT NOISE. Prepared for U.S. Air Force, Aeronautical
Systems Division, Wright-Patterson AFB, Ohio. Nov. 1961,
138 p. ASD TR 61-610 AD 278 622
7. Bolt, Beranek and Newman, Inc., Canoga Park, Calif. COMMUNITY
NOISE EXPOSURE RESULTING FROM AIRCRAFT OPERATIONS: TECHNICAL
REVIEW. Final report. Prepared for Aerospace Medical Research
Laboratory, Wright-Patterson AFB, Ohio. 237 p. AMRL-TR-73-106
8. Budyko, Mikhail, I. CLIMATE AND LIFE. English ed. edited by
David H. Miller. New York, Academic Press, 1974, 508 p.
Cf. p. 299
9. Clayton, George D. AIR POLLUTION. In Industrial Hygiene and
Toxicology. 2d rev. ed. V. I. New York, Interscience
Publishers, Inc., 1958, p. 413-441
10. Environmental Acoustics and U.S. National Institute for Occupational
Safety and Health. EVALUATION OF HEARING LEVELS OF RESIDENTS
LIVING NEAR A MAJOR AIRPORT. Final Report, Jun. 1972, 99 p.
FAA-RD-72-72 AD 747 129
2
11. Forney, A. K. SUMMARY OF ENGINE MODIFICATION COSTS. In
Propulsion Effluents in the Stratosphere. J. M. English,
(ed.), CIAP Monograph 2 (in press)
12. FIFTH ANNUAL REPORT OF THE COUNCIL ON ENVIRONMENTAL QUALITY
Washington, D.C., U.S. Government Printing Office, 1974.
GPO Stock No. 4000-00327
13. Glorig, Aram. HEARING CONSERVATION IN INDUSTRY. Maico
Audiological Library Series, V. II, Report 3, 5 p.
14. Grant, S. M. and P. A. Broyose. AIRCRAFT NOISE INDUCED VIBRATION
IN FIFTEEN RESIDENCES NEAR SEATTLE-TACOMA INTERNATIONAL
AIRPORT. University of Washington, Oct. 1973
15. Great Britain. Committee on the Problem of Noise. NOISE, FINAL
REPORT. Presented to Parliament by the Lord President of the
Council and Minister for Science by Command of her Majesty.
London, H. M. Stationery Office, Jul. 1963, 235 p.
16. *Habercom, Guy E. AIRPORT NOISE (A BIBLIOGRAPHY WITH ABSTRACTS).
Spirngfield, Virginia, National Technical Information Service,
Aug., 1976
17. Heimman, Harry. EFFECTS OF AIR POLLUTION ON HUMAN HEALTH. In Air
Pollution. New York, Columbia University Press, 1961, p.
159-220
Cf. Carbon Monoxide, P. 194-196
18. Hermann, Edward P. EAR ANATOMY AND EFFECTS OF NOISE ON MAN.
National Safety News, V. 99, No. 2, Feb. 1969, p. 64-73
19. International Civil Aviation Organization, Committee on Aircraft
Noise. REPORT. Third meeting, Montreal, 5-23 Mar. 1973.
Varying paging. ICAO Doc. 9063, CAN/3
20 International Civil Aviation Organization, Committee on Aircraft
Noise. REPORT. Fourth meeting, Montreal, 27 Jun - 14 Feb.
1975. Various paging. ICAO Doc. 9133, CAN/4
*
This is a new publication containing 172 abstracts of which 34 are
new entries to the previous edition.
3
21. Johnston, Harold. REDUCTION OF STRATOSPHERIC OZONE BY NITROGEN
OXIDE CATALYSTS FROM SUPERSONIC TRANSPORT EXHAUST. Science
V. 173, 6 Aug. 1971, p. 517-522
22. Kryter, Karl D. THE EFFECTS OF NOISE ON MAN. New York, Academic
Press, 1970, 633 p.
23. Loughborough University of Technology, Department of Transport
Technology, Loughborough, England. ESTIMATING COMMUNITY
ANNOYANCE DUE TO AIRPORT NOISE. Feb. 1972, 111 p. TT 7203
24. National Opinion Research Center, University of Chicago, Chicago,
Ill. COMMUNITY REACTIONS TO AIR FORCE NOISE. Part II.
Data on community studies and their interpretation. Prepared
for U.S. Air Force, Wright Air Development Division, Wright-
Patterson AFB, Ohio. Mar. 1961, 171 p. WADD TR 60-689 (II)
AD 267 057
25. Newman, J. Steven. SUBJECTIVE COMMUNITY REACTIONS TO CONSTRUCTION
NOISE. Masters Thesis, Northwestern University, 1973.
Presented to NOISEXPO Convention, Chicago, Ill., Oct. 1973
26. New York (City), Mayors Task Force on Noise Control. TOWARD A
QUIETER CITY. 1970, 56 p.
27. Peterson, Arnold P.G. and Ervin E. Gross, Jr. HANDBOOK OF NOISE
MEASUREMENTS. 6th ed. West Concord, Mass., General Radio
Company, 1967, 282 p.
28. Richards, E.J. and J.B. Ollerhead. NOISE BURDEN FACTOR - NEW WAY
OF RATING AIRPORT NOISE. Sound and Vibration, V. 7, No. 12,
Dec. 1973, p. 31-33
29. Starr, Edward A. MEASURING NOISE POLLUTION. IEEE Spectrum, V. 9,
No. 6, Jun. 1972, p. 18-25
30. Tanner, C. S., R. E. Glass. ANALYSIS OF OPERATIONAL NOISE MEASUREMENTS
IN TERMS OF SELECTED HUMAN RESPONSE NOISE EVALUATION MEASURES.
Hydrospace Research Corporation, Dec. 1971
31. U.S. Department of Housing and Urban Development, Circular 1390.2,
Aug. 4, 1971
32. U.S. Department of Labor. WALSH-HEALY PUBLIC CONTRACTS ACT.
Federal Register, V. 34, No. 96, Part II, May 20, 1969,
p. 7946-7954
4
33. U.S. Department of Labor, Occupational Safety and Health
Administration, Washington, D.C. GUIDELINES TO THE DEPARTMENT
OF LABOR'S OCCUPATIONAL NOISE STANDARDS. Bulletin 334, rev.
1971, 16 p.
34. U.S. Department of Transportation, Office of Noise Abatement,
Washington, D.C. SINGLE-EVENT AIRCRAFT NOISE EXPOSURE
CONTOURS FOR CONCORDE AND CONVENTIONAL SUBSONIC AIRCRAFT.
Information brief. Jul. 23, 1975, 13 p.
35. U.S. Environmental Protection Agency, Washington, D.C., IMPACT
CHARACTERIZATION OF NOISE INCLUDING IMPLICATIONS OF IDENTIFYING
AND ACHIEVING LEVELS OF CUMULATIVE NOISE EXPOSURE. Aircraft/
airport noise study report. Jul. 27, 1973. Various paging.
EPA NTID 73.4 PB 224 408/5
36. U.S. Environmental Protection Agency, Office of Noise Abatement
and Control, Washington, D.C. INFORMATION ON LEVELS OF
ENVIRONMENTAL NOISE REQUISITE TO PROTECT PUBLIC HEALTH AND
WELFARE WITH AN ADEQUATE MARGIN OF SAFETY. Mar. 1974. Various
paging. EPA 550/9-74-004 PB 239 429/4GA GPO: EP1.2:n69/26
37. U.S. Federal Aviation Administration, Washington, D.C. CERTI-
FICATED AIRPLANE NOISE LEVELS. Advisory Circular, Jul. 21,
1975. AC No. 36-1A
38. U.S. Federal Aviation Administration, Washington, D.C. NOISE
STANDARDS: AIRCRAFT TYPE AND AIRWORTHINESS CERTIFICATION.
Federal Aviation Regulations, Part 36, Jun. 1974, 36 p.
39. U.S. Panel on Noise Abatement. THE NOISE AROUND US: INCLUDING
TECHNICAL BACKUP. Washington, D.C., U.S. Department of
Commerce, 1970, 294 p.
40. Webster, J. C. and R. S. Gales. NOISE RATING METHODS FOR
PREDICTING SPEECH COMMUNICATION EFFECTIVENES. In Evaluating
the Noises of Transportation, Proceedings of a Symposium on
Acceptability for Transportation Noise, University of Washington,
Mar. 26-28, 1969. Apr. 1970, p. 105-123. OST-ONA-70-2
PB 191 117
41 Wyle Research, E1 Segundo, Calif. AIRPORT NOISE REDUCTION FORECAST.
V. 1. Summary report for 23 airports. Final report. Oct. 1974,
222p. DOT-TST-75-3 PB 239 387/4GA
42. Wyle Research, E1 Segundo, Calif. NATIONAL MEASURE OF AIRCRAFT
NOISE IMPACT THROUGH THE YEAR 2000. Report WCR 74-13
APPENDIX I: FAR PART 36 COMPLIANCE REGULATION SUMMARY
APPENDIX I: SUMMARY OF FAR PART 36 COMPLIANCE REGULATION
I. Effective Date of Regulation: January 1, 1977
II. Regulation Application: U.S. civil aircraft operating under
FAR Parts 91, 121, 123, and 135.
III. Standards: FAR Part 36 Levels
IV. Phasing or Scheduling of Application:
TIME SCHEDULE
Aircraft Class Impacted
Before 1/1/81
Before 1/1/83
Before 1/1/85
o
4-engine airplanes with
25% Compliance
50% Compliance
100% Compliance
bypass ratio less than 2
including pure jets
(B-707, DC-8).
o
4-engine airplanes with
50% Compliance
100% Compliance
I
bypass ratio greater
than 2
(B-747).
o 2- and 3-engine airplanes 50% Compliance 100% Compliance
-