On October 20, 2011, the formal date for the start of Phase 2A of the Airspace Redesign (“the Redesign”), the lives of residents on the Nassau County NY changed forever due to the increase in noise and pollution. With the onerous and confusing language of HR 658 and the increasing use of concentrated and low altitude arrival profiles of NextGen procedures, our environment can only get worse.
The FAA, in their Environmental Impact Statement (EIS) performed for the Redesign, took the position that the Redesign does not increase capacity and therefore did not require detailed environmental studies. However the General Accounting Office (GAO) noted that, even though some NextGen technologies would be available when the redesign was implemented, and that those technologies were known to increase capacity and concentrate noise, the FAA still did not include the impact of those technologies. The EPA, in their review of the Environmental Studies stated that “….we have environmental concerns because of the need for analysis of cumulative impacts to the environment from increasing airspace capacity.”
Now with the acknowledged increase in capacity promised by the NextGen program, and the fact that the Redesign and NextGen programs will be in place at the same time, the airline industry/FAA are taking a different tack to avoid comprehensive studies.
The current argument will likely be based on a need for FAA “streamlining” which will be accomplished by eliminating detailed environmental analysis before a major NextGen rollout. The legal justification will be through the use of the sloppy, confusing and improper Categorical Exclusion language in HR658. While removal of serial tasks may accomplish “streamlining”, there is a better approach. Proper environmental studies can be run in parallel with the design and purchasing of NextGen hardware and software. This approach will allow a proper analysis while not hindering NextGen’s progress. A parallel path will also allow the analysis to be updated as NextGen evolves and permit adjustment of its procedures where necessary.
Please note that FAA environmental experts believe that proper studies must be done [3,4] and, as noted above, the GAO and EPA said they should have already been done. In particular, Dr. Lourdes Q. Maurice, Ph.D., P.E., Executive Director, Office of Environment and Energy (AEE-1) of the FAA stated that: “The National Environmental Policy Act (NEPA) requires projects related in space and/or time be considered together for their cumulative impacts on the environment and not segmented into smaller projects.” Dr. Maurice is warning against doing exactly appears to be happening with the Redesign and NextGen programs.
Please follow the advice of your acknowledged environmental experts and meet the spirit and intent of the Clean Air Act and the National Environmental Protection Act (NEPA) so that the deleterious impacts on our quality of lives are exposed and possibly reduced.