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SR-0 (25) RLK: msh C1ty.Council Meeting 09-10-79 Santa Monica, Cal~fornia TO: Mayor and Clty Councll ffCJP-OO?'-03 FROM: City Staff SUBJECT: Airport - Effect of Lower~ng the SENEL Llm~t INTRODUCTION On August 24, 1979, the Honorable Irvlng Hlll, ln the case of Santa MOUlca Alrport Assoclat~on v. Clty of Santa Monica, rendered Judg~ent In favor of the City and upheld the followlng ord~nances: 1. SENEL Llmltatlon - 10105B 2. Hellcopter Tralnlng Ban - lOl05A2 3. Touch-and-Go Restrlctlons - 10111C 4. Nlght Curfew - 10101 At the same tlme, Judge Hlll ordered judgment against the City and struck dmvn the Clty'S "Jet ban" (lOI05A). The court order, by upholdlng the SENEL ordlnance, affirmed the rlght of the City to llmlt alrcraft nOlse by controlllng slngle event llm~ts and also to adopt reasonable regulations to control alrcraft nOlse. Wlth respect to the Jet ban, the eVldence wlthout questlon establlshes that a number of small Jet alrcraft when operated at the Santa Monica Municlpal Alrport would not generate, at the noise monltor statlon, nOlse In excess of 100 SENEL. Nevertheless, openlng up the airport to these jet aircraft, WhlCh were prevlously banned, would result In an overall lncrease ln the amount of hlgh lntensity alrcraft no~se In the enVirons of the airport slmply because lt would add aircraft of the nOlSlest variety permitted at Santa Monica WhlCh aircraft had prevlously been prohlblted. In addition to the adverse effects on the people llvlng near the airport that would ensue from this addltlonal Jet nOlse, It lS known that the nOlse from a number of older, small propeller alrcraft operatlng at the alrport lS a source of annoyance and disturbance to the communlty. Since the tlme of manufacture of many of these "nolsier" KLK:msn C~ty Counc~l Meet~ng 09-10-79 a~rcraft, both propeller and jet, there have been technolog~cal advances ~n the des~gn of a~rcraft engines that have resulted ~n eng~nes that are considerably qu~eter for a g~ven amount of propulsion power than were prevlously avallable. Indeed, s~nce 1974, the FAA has set No~se Compl~ance Limits for both s~all propeller and Jet alrcraft that must be met before a given alrcraft model can be certlflcated and allowed to operate in the Unlted States. These FAA Noise Compl~ance Llmits are conslderably below the equlvalent level of 100 SENEL at the Santa MODlca NOlse Monltor Statlons. Torrance Alrport which is also a munlclpally owned general aVlatlon airport has set a SENEL Ilmit of 88 in order to further noise abatement goals by reducing a~rcraft nOlse impact on the community surroundlng the airport. Parallel w~th the advances made ~n alrcraft and alrcraft oper- at~ons with respect to nOlse reductlon, there has been an lncrease ln knowledge concernlng the adverse effect of aircraft nOlse on people and the establlshment of quantltat~ve, validated relatlons between physlcal measures of the alrcraft nOlse and lts effects on lndivlduals and populat~ons of people. The SENEL (Slngle Event No~se Exposure Level) and the CNEL (average 24-hour Composlte Noise Exposure Level) are reasonably accurate and acceptable methods, among others, of quant~fying a~rcraft no~se ln communitltes and predlctlng from them the effects of the no~se on people. The report to follow prov~des an analysls of the lropact of var~ous SENEL level Ilm1ts upon the tle-down fleet, the number of operat~ons, the nelghbor~ng comnun~ty (CNEL) and other technlcal -2- RLK:msh C~ty Counc~l Meeting 09-10-79 informat~on that would be of ass~stance ~f ~t ~s deemed necessary to prepare an ord~nance whlch would take lnto account the recent developments concern~ng the Santa Mon~ca Alrport and the industry at large. -~- RLK:msh C~ty Cauncll Meetlng 09-10-79 I. IMPACT OF VARIOUS SENEL LIMITS UPON THE EXISTING TIE-DOWN FLEET AT SANTA MONICA AIRPORT A. Purp~?e The purpose of this section 1S to show Wh1Ch a~rcraft, how many of these a1rcraft and what percentage of the ex~sting t~e- down fleet would be excluded at the SENEL l~mits of 90, 87, 85 or 80. Note for example, that a 90 SENEL ind1cates that 90 dec1bels 15 the ~aXlrnurn nOlse allowable for a part1cular aircraft. B. Method of Evaluation 1. Comp1latlon of Data The comp11atlon of data necessary to draw stat1stical concluslons concern~ng the impact of the varlOUS SENEL 11mits lS presented 1n Appendix A to thlS report. In order to complle thlS lnformation, each alrcraft tied down at SMa was ldentlfled by a1rcraft number and type, to determlne the n01se emltted by each alrcraft. Flve bas1c sources were relled upon. CAVEAT: These flve sources are the most complete and CUrrent data from all available sources. It 1S current through 5/29/79. Sources of ~Olse Measurement AC 36-1B: Department of Transportatlon Federal AV1atlon Admlnlstratlon Advlsory Circular Number 36-lB dated 12/5/77 regardlng certlfled airplane nOlse levels. AC 36-2A: Department of Transportatlon Federal AVlation Admlnlstration Advlsory Clrcular Number -3- RLK:msh C~ty Counc1l Meet1ng 09-10-79 36-2A dated 2/6/78 regarding measured or estimated (uncertified) a1rplane noise levels. AC 36-3: Department of Transportat1on Federal Aviation Admin1stration Adv1sory C1rcular Number 36-3 dated 5/29/79 regarding est1roated a1rplane n01se levels 1n A-we1ghted dec1bels. EPA: Un1ted States EnV1ronmental Protect1on Agency ProJect Report. N01se Certlfication Rule for Propeller Driven Small Alrplanes dated 11/25/74, Wash1ngton, D.C. BBN (SENEL): Report prepared by Bolt, Beranek, and Newman showlng est1mated nOlse levels In SENEL of propeller dr1ven aircraft at SMO monitor1ng statlons used as Plalnt1ff's Exh1blt 51 in S.M.A.A. v. Clty of Santa Monlca. The figures obtained fron these sources are 11sted In the r1ght hand sect10n of Appendix A under the t1tle ItMeasured/Est1mated Levels. It 2. Rated Fleet There are 415 a1rplanes that compr1se the exist1ng t1e-down fleet at SMO. Of these, 200 alrplanes have been rated (the rated fleet). There are no FAA, EPA, or BBN rat1ngs for the rema1n1ng 215 airplanes comprlslng 51.8% of the total tie-down fleet. (See Appendix B.) In order to determlne which a1rcraft will be arfected at each SENEL level, a two-step process 1S requ1red. F1rst, a conversion must be made from each or1ginal source flgure to an est1mated SMO SENEL ~eter read1ng. The two numbers lD parentheses below the measured/estimated declbel level f1gure represent conversions to SENEL at Santa Monica MOD1tor1ng Stat1ons. The number in parentheses on the left and right lS the SENEL of that a~rplane on approach and takeoff, -4- RLK:msh City Counc11 Meet1ng 09-10-79 respect1vely. The converS1ons are requ1red because d1fferent metrlcs and/or different monitor placement was used in the source data. Once a standard f1gure for SMO SENEL 1S computed, it 1S necessary to rank the source mater1al accordlng to lts rel1ab1lity. ThlS 15 requ1red because in the case where there 15 nore than one f1gure available for a part1cular a1rcraft, a cholce must be made as to WhlCh figure 1S to be used. The ranklng of the original source flgure lS as follows: RANK I: AC 36-3 RANK II: AC 36-lB and AC 36-2A RANK-I:Ll: EPA RANK IV: BBN (SENEL) 3. Rated Pleet Excluslon The exclus10n levels for the rated fleet lS summarized in Appendlx c. The ent1re rated fleet 15 llsted by a1rcraft type and number of each type tled down at S!>10. An "X" 1n the r1ght hand column 1nd1cates the level at whlch that alrcraft would be excluded because the ratlng exceeds the Ilffilt on both takeoff and approach. (T) lndlcates exclusion because of takeoff ratlng only. (A) lndlcates excluslon because of approach rating only. An exclus10n on takeoff or approach counts as an excluslon for all purposes. An exclus10n would eXlst for measured nOlse levels of 90.1 and above, 87.1 and above, 85.1 and above, or 80.1 and above in each category of the same number. An alrcraft would not be excluded for a ratlng of 90.0, 87.0, 85.0, or 80.0 1n the category of the same number. The determlnative numbers used were mandated by the -5- RLK:msh City Counc~l Meet~ng 09-10-79 rank of rel~ab~l~ty found ~n Section 2 above. c. Analysis 1. Number of A~rcraft Excluded from SMO at Lower SENEL The number of a1rcraft compr~s~ng the rated fleet wh1ch would be excluded~ if the SENEL were lowered is: SENEL 90 19 aircraft excluded SENEL 87 46 aircraft excluded SENEL 85 65 a~rcraft excluded SENEL 80 136 a1rcraft excluded 2. T~pe of A~rcraft Excluded from S~O at Lower SENEL If the SENEL were lowered, the followlng a1rcraft currently a part of the t1e-down fleet would be excluded* from SMO: Excluded at 90 SEUEL Cessna 175 Cessna 185 Cessna 2l0L Cessna 310C Cessna 411 Cessna 421 Piper Cherokee PA 32-260 Beechcraft AGO Beech Bonanza S 35 Beech Debona~re 35A33 Beech Tw1n BCE Baron 95A55 Excluded at 87 SENEL: All planes excluded* at 90 SENEL, plus: *The exclusion 15 based on a close to worst case situation prov~ded for in FAR-36. Many of the excluded planes can be operated at sign1f1cantly lower levels by modifY1ng we1ght and operat1ng condlt1ons to meet nOlse abatement goals. -6- RLK:msh C~ty Council Meet~ng 09-10-79 Cessna 182P Skylane Cessna 320E P~per Cherokee PA 28-180 P~per PA 34-200 Beech Bonanza F33A Beech Bonanza V35B Beech Bonanza A36 Beech Debonaire 35B33 Aero Commander 680 FL Excluded at 85 SENEL: All planes excluded* at 90 and 87 SENEL, plus: Cessna 182H Cessna 210 Cessna T210L Cessna 310Q Cessna T310R P1per Comanche PA 24-250 P1per Comanche PA 24-260 P1per Comanche PA 24-260C P1per Twin COManche PA 30 P1per Cherokee PA 32-300 Excluded at 80 SENEL: All planes excluded* at 90, 87, and 85 SENEL, plus: Cessna 170 Cessna 172M Cessna 172N Cessna 175A Cessna 175B Cessna 177 Cessna 177RG Card1nal Cessna 180 Cessna 182Q Cessna T210M Cessna 404 Cessna 414 Cardlnal Cessna 421B Piper Tri-Pacer PA 22-135 P~per Twin Apache FA 23-160 P1per Twin Aztec FA 23-250 Plper Cherokee PA 28-151 Plper Arrow PA 28R-200 Plper FA 31T Piper FA 34-200T Beech Bonanza 35 Mooney M20E Mooney Executlve M20F Bellanca 17-30 -7- RLK:msh City Counc11 Meet1ng 09-10-79 3. Percentage of Aircraft Excluded from SMO at Lower SENEL The percentages of the rated fleet wh1ch would be excluded from SMO 1f the SENEL were lowered are: SENEL 90 9.5 % SENEL 87 23.0 % SENEL 85 32.5 % SENEL 80 65.0 % These conclusions are accurate for the rated fleet (48.2% of the total fleet). The percentages could be greater or lesser depend1ng on the n01se measurement levels for the 215 unrated a1rcraft. These f1gures apply only to the eX1sting t1e-do\ffi fleet at SMO. The effect on tranS1ent a1rcraft has not been analyzed 1n this part of the report. II. IMPACT OF VARIOUS SENEL LIMITS UPON AIRPORT OPERATION AT SMO A. Impact on Total Operat1on~ According to the Declaration of Colleen J. Clement, 8 May 1979, Santa Monica Airport Associat1on, et. al., v. C1ty of Santa Mon1ca, the following percentages of total aircraft operations (an average of takeoff and land1ng violat1ons) that would be affected at the var10US SENEL l1m1ts are (See also Append1x D) : SENEL 95 0.42 % SENEL 90 3.36 % SENEL 85 6.15 % SENEL 80 14.83 % -8- KLK:msn Clty Councl1 Meeting 09-10-79 B. Impact on Takeoff Operations USlng the ldentical source data (see above) wh~Gh was used ~n determlning the total operation percentages, the followlng evaluation was made for takeoff operatlons only. Slnce the ma]Orlty of nOlse vlolatlons occur on takeoff, and the impact upon the community 15 greater at this locatlon, the follow~ng percentages were determlned: SENEL 95 0.6 % SENEL 90 6.0 % SENEL 85 11.0 % SENEL 80 25.0 % III. IMPACT OF VARIOUS SENEL LIMITS UPON THE C0M11UNITY A. Effect upon the CNEL Appllcatlon of the SENEL and CNEL metrlc to the alrcraft nOlse from present operations, and from future operatlons under varlous posslble noise limltat~ons, at the Santa Monica NOlse Monltor Stat10ns reveals the followlng: 1. Llffilt of 100 SENEL and No Jet Ban. It 1S estimated that In the viclnity of the NOlse Monitor Statlon, about 35% of the people would be hlghly annoyed and about 55% disturbed (speech, TV, radlo, sleep lnterference, and house vlbratlon) on a dally basis by the aircraft noise. CNEL of about 65. 2. Llmit of 100 SENEL and Jet Ban. (Present Ordinance.) About 30% of the people are highly annoyed and about 45% dlsturbed by the alrcraft no~se. CNEL of about 63. -9- RLK : msh Clty Council Meeting 09-10-79 3. Llm~t of 90 SENEL. About 22% of the people would be highly annoyed and 40% disturbed by the a~rcraft noise. CNEL of about 58. 4. Llmlt of 87 SENEL. About 17% of the people would be h~ghly annoyed and about 30% d~sturbed by the aircraft no~se. CNEL of about 56. B. Recommended CNEL The U.S. EnVlronmental Protection Agency reconmends an Ldn of 55 (wh~ch ~s equ~valent to a CNEL of 56) as a gu~dellne for the maxlmum exposure to nOlse ~n resldentlal areas In order to protect "health and welfare wlth an adequate margin of safety." This recommendation can hardly be ]ustlfled as adequately protect~ve of people exposed to aircraft nOlse lnaswuch as at that level of exposure to a~rcraft nOlse about 17% are highly annoyed and some 30% have var~ous activ~tles disturbed on a da~ly baS1S. Further, ln some communltles group appeals and legal actlons to reduce the aircraft no~se can occur at an Ldn or CNEL of about 55. c. Other Factors. Some non-aircraft nOlses that may occur in residentlal areas generally have less adverse effects on people than might be expected on the bas~s of their composlte no~se levels and ln comparlson to alrcraft noise of the same composlte level. Among the reasonS belng that these noises are: 1. usually from relatively locallzed sources and, hence, unllke a~rcraft noises from a relat~vely far d~stance, are not transm~tted throughout as large a geographlc area and are more -10- KLK:msn Clty Council Meetlng 09-10-79 readlly shielded; 2. the nOlses may not reach peak levels high enough to be above the threshold of annoyance; and 3. the nOlses may be non-regularly recurrlng and even be wanted sounds rather than nOlse. In any event, the presence of other sounds or nOlses In an enVlronment that contalns alrcraft nOlse cannot be expected to reduce the adverse effects, lf any, of the alrcraft nOlse on people. IV. CONCLUSION SENEL REDUCTION REDUCTION OF PEOPLE PEOPLE CNEL OF AIRPORT RATED TIE- HIGHLY DISTURBED OPERATIONS * Dm\N FLEET ANNOYED 90 6% 9% 22% 40% 58 87 9% 23% I 17% 30% 56 85 I 11% 32% I I 1.5% 22% 54 I 80 25% 65% I 12% 18% 52 It is found that a Ilmit of 90 SENEL at the Santa Monlca NOlse Monltorlng Statlons wlll provlde some modest reductlons ln the alrcraft nOlse enVlrOlli~ent at Santa Monlca, and 1S con- slstent wlth nOlse 11ffilts prescrlbed by FAA for the certlflcatlon of small alrcraft licensed to operate in the Unlted States. A lim~t of 87 SENEL at the NOlse Monitor Stations w~ll provide a slgnlflcant reductlon in the alrcraft nOlse envlronment at Santa Monlca and is conslstent wlth recow~endatlons for environmental nOlse in residental areas and also with technology of bUllding qUleter a1rcraft. A few of the new small Jet aircraft will be able to meet elther an 87 or 90 SENEL Ilmlt. * See oage lla. -11- RLK:msh City Cauncll fleeting 09-10-79 * It is presumed in the calculatlon of CNELs wlth the SF.NEL limits set at 87 and 90, that the reduction in operatlons that could ensue 1S only apparent, and that the level of operations would rema1n the same because newer, qUleter alrcraft, including Jets, would replace those alrcraft operatlons now in excess of 87 or 90 SENEL. However, there would be an effective (more or less) long lastlng reduction in 7% of the operations all for alrcraft at SENELs hlgher than 85, and about a 20% reductlon ln the operat1ons of alrcraft at SENELs hlgher than 80, were the SE!IEL linit set at 85 and 80 respectively. Accordingly, the CNELs for the conditlons of an SE~EL limit of 85 and for a limit of 80 SENEL are calculated on the assumption that the nu~er of operations, ln the highest SE~EL ranges, would be reduced by 30 wlth a liolt af 85 SENEL and 62 with a lir.ut of 80 SmJEL. -lla- RLK:msh Clty Councll Meetlng 09-10-79 The requlrements of FAA Regulatlon FAR 36, Part 36, related rAA Advlsory Circulars AC 36-, the FAA Integrated N01se Model, and procedures glven in thlS report prov1de bases for the determlnatlon or estlmatlon by ill 1 lnterested part1es of the SENEL values to be expected atthe Santa Monlca NOlse Moultor statlons for most, lf not all, alrcraft certlfled to operate lU the Unlted States slnce 1 January 1974. It 15 noted that all models of small (less than 12,500 pounds) and Jet (less than about 20,000 pounds) a1rcraft must be FAA certlf1ed after 1 January 1975 to not exceed a nOlse level equlvalent to an SEKEL of 90 at the Santa Mon1ca NOlse Monltor Stat1ons. New technology perm1ts, or may permlt, thlS maXlffium noise Ilffilt for type cert1f1catlon to be reduced by 3dB or so, as a n1nlmum (l.e. to an equlva1ent SENEL of 87.) V. PROPOSED ORDINANCE A. EIR Requlrement The Clty Attorney has determlned that an In1tia1 Study shall be immedlately undertaken pursuant to the requ1rements of the Callforn1a Env1ronmental Quallty Act, PubllC Resources Code 21000 et seq. ThlS shall be carrled out In order to determlne If the ordlnance may have a slgnif1cant effect on the enVlronment. Thereafter, elther a Negatlve Declarat10n or an EIR shall be prepared. B. Ordlnance - Draft Pursuant to the f1nd1ngs in thlS report, studles belng conducted, and the outcome of 8.M.A.A. v. Clty of Santa Monica, -12- RLK:rrsh Clty COUDCll r~etlng 09-10-79 an ordlnance has been drafted to cover the SENEL Ilmltatlon, the authorlty of the Alrport Director to promulgate rules and regulatlons, and a prohlbltion on tralnlng for hlgh performance a1rcraft. The SENEL Ordinance has been amended to take lnto account the recent actions by government agencies to standardize the criter1a for controlllng alrcraft noise. In order to further these government goals, several pre- sumptions will apply to those aircraft that have been ass1gned a ~easured or estimated nOlse level rating by the FAA, FPA, aircraft manufacturers or independent consultants. Flrst, as to any person ownlng, operatlng or permlttlng the use of any alrcraft W!llCh ex- ceeds the acceptable n01se level Ilmit at Santa ~IDnica as deter~1ned under Subsectlor. (9) of the proposed amendment to Sectlon lOlOSB, lt 15 concluslvely presumed that that person intends to violate the Santa Monlca nOlse limit. Secondly, as to any aircraft operator who exceeds the acceptable nOlse level ll~lt whlle flYlng an alrplane that has been determlned under Subsectlon (9) of the proposed amend- ment to lOl05B to fall wlthln the acceptable noise group, lt 1S re- buttably presumed that such alrcraft operator is guilty of an In- tentional violatlon or a crlmlnally negllgent vlolation based on In- approprlate pilot operating procedures. This presumptlon may be rebutted by clear and convlncing eVldence to establ1sh condlt1ons wholly beyond the control of the pilot. Third, as to any aircraft which lS not rated as prov1ded for In Subsect10n (9) of the amencment to lOlOSB, there lS a rebuttable presu0ption that such a1rcraft exceeds the nOlse IlMits at Santa Monlca A1rport untll such t1me as sufflC- ient techn1cal data is furnlshed to establ1sh that the part1cular -13- RLK:msh Clty CounCl1 f~etlng 09-10-79 aircraft wl11 meet the nOlse Ilmlt set by the Clty. The rule-maklng authorlty 15 added to set a standard for the Airport Dlrector to follow In adoptlng rules and regulatlons. The prohlbit1on on h1gh performance aircraft traln1ng 1S des1gned to reduce repetltlve operatlons and to curtail the m1X of numerous h1gh performance tralnlnq flights wlth the fllghts of other aircraft. RECO~~~NDATION It 15 staff's recommendation that the attached ordlnance be lntroduced for flrst readlng and that the Clty Councll set the SENEL limlt at that amount It deems approprlate to Meet the comwunlty needs. Prepared by: Rlchard L. Knickerbocker, Clty Attorney Sandra Henry, Deputy City Attorney Colleen J. Clement, Legal psslstant Karl Kryter, Ph.D., Psycho-Acoustlclan -14- ~