This is a comment on the proposed Grand Canyon National Park Quiet Aircraft Technology Incentive: Seasonal Relief From Allocations in the Dragon and Zuni Point Corridors ([Federal Register Volume 79, Number 217 -- Docket No. FAA-2014-0782). To Comment go to: regulations.gov and search FAA-2014-0782 The effort to achieve soundscape improvements originates from the National Parks Overflights Act of 1987. This effort has continued despite a series of lawsuits by the air-tour industry, and various political efforts to undermine the Act. From 2005 through 2009, I participated in the Grand Canyon Overflights Working Group as representing recreational interests, specifically hikers. Despite the failure to reach an agreement, I learned a great deal about the technical aspects of the Grand Canyon soundscape, and about the political, economic, and agency dynamics. One of the things I learned is that Quiet Technology (QT) qualified helicopters now increasingly in service with the air-tour operators are actually effective in reducing the aircraft noise footprint, and I favor converting all operating aircraft at Grand Canyon to this standard. But I am dismayed by this new proposal, and I find three serious flaws in the proposed plan, each serious enough alone to call implementation into question. Firstly, the proposed adoption of an average annual noise metric is a serious step backward. This specific application was originally given by the Federal Aviation Administration (FAA) in contrast to the natural quiet definition established by the National Park Service (NPS), and offered as a metric to favor air-tours. In litigation resolved in Federal Court in 2002 the NPS standard of “each and every day” was upheld and ruled appropriate. It is shocking that NPS would now accept this metric which embodies “statistical quiet” not actual quiet, and is an invalidated standard. The test of whether any QT program is effective must be based on a metric founded on the “each and every day” standard which remains the appropriate and legal soundscape definition at Grand Canyon National Park. Secondly, the proposal for the Dragon and Zuni flight corridors defines success based on noise not quiet. A noise-based metric restricted to scheduled air-tour operations has no valid statistical correlation to quiet in Grand Canyon as a whole. The appropriate standard would measure the noise propagation in the Park for a full day on the peak operating day and including all low-altitude flights of any type -- the same method that was applied to assessments during the NPOAG Working Group process (and was supported by all participants). This modeling would measure quiet periods in areas surrounding the flight corridor. If the quiet zone or duration is increased the program is effective, otherwise not. Such a metric need not wait for the elapsed program duration either. If the peak operating day of the program fails the test the program would be (should be) immediately terminated. Thirdly, the proposal allows air-tours to accumulate QT allocation credits on off-season QT flights, but then allows air-tours to expend those credits with non QT flights during peak periods. Not only does this clearly go against the “each and every day” standard by allowing more flights on peak days, but also fails to achieve the objective of giving an incentive for conversion to QT equipment, by giving an economic incentive to retain and operate nosier helicopters at a lower cost-basis. For any effective incentive program all flights must require QT aircraft for every operation under the program, or fail to meet this basic test. All operational air-tour aircraft at Grand Canyon should be required to meet QT qualifications as well as being more compliant (less noisy) than the aircraft they replace. And incentives may aid in attaining this objective. But this requirement alone cannot deliver soundscape controls without rational and appropriate NPS regulatory management. This incentive proposal should not be implemented and any future incentive proposal must make a realistic effort to offer results that would overcome the deficiencies in this proposal.
Posted on: Mon, 08 Dec 2014 04:56:47 +0000
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