3/4/2012 Southflow Arrivals

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11 3/4/2012 Southflow Arrivals

12 Port of Seattle May 2012 Daytime Southflow Arrivals

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14 Dear Medina City Council Members: Below you will find a summary of track efforts from February 2010-present and recommendations. I have also included previously submitted council updates which contain more detail. The History of Aircraft Noise over Medina is available on the City s website. Please let me know if you have any questions. I would be happy to attend the August or September Council Meeting to answer any questions or discuss the recommendations. Sincerely, Allyson Jackson City of Medina- Flight Track Consultant

15 Flight Track Summary of Events for Medina City Council February July 2012 In February 2010, the Port of Seattle and FAA began a Part 150 Noise Compatibility Study at SeaTac airport. These studies normally take 2-3 years to complete and are conducted about every 10 years at Sea-Tac. Their purpose is to develop, in conjunction with the public, airport noise reduction recommendations. The Port s published goals for this Part 150 were to identify existing and future flight corridors, develop aircraft noise exposure maps for current and future conditions, evaluate air traffic control procedures that could be implemented to reduce noise exposure over residential areas, consider land use controls that could be established to reduce future incompatible land uses from being developed within high noise areas, and evaluate means to mitigate noise impacts within high noise exposure areas. The City of Medina hired me to represent and advise the City of Medina for the duration of the FAA Part 150. The goal has been to ensure that Medina s interests are represented throughout the Part 150 process and to use the Part 150 process to improve south flow arrival compliance, encourage increased use of the open water corridor between Medina and Mercer Island for north flow east turn departures and lengthen curfew hours. Additionally, Medina wants to ensure that any future flight track changes will not result in additional aircraft over Medina. Our initial strategy was to attend the Part 150 meetings,communicate Medina s concern and ensure that they were documented.. This was accomplished. Once it was determined that this Part 150 study team was going to focus only on noise issues close to the airport, I adjusted our strategy to utilize relationships developed with the Port and FAA to pursue Medina s concerns directly. I believed our best chance for success was to work locally with the FAA and provide them the opportunity to remedy the situation prior to escalating the issue within the FAA. Although the local FAA management team has to date chosen not to initiate any changes on Medina s behalf, the information that was collected during these meetings is not only vital to our efforts but it also legitimizes Medina s concerns. We are currently waiting for a response from local FAA management to a letter sent by Mayor Luis in June. If we do not receive a satisfactory response, I will recommend that we make a formal request to the FAA Airspace Management Group in Washington DC to review airspace compliance with the Four Post Plan at SeaTac. Depending on the outcome of that request, Medina will need to decide whether they want to retain an aviation attorney to continue to pursue this issue utilizing the data that we have collected. Temple Johnson, retired FAA, former Director of the Northwest Mountain Region and author/implementer of the FAA Four Post Plan, was hired by the City of Medina in early 2011 to provide technical guidance in our efforts. His expertise, guidance and knowledge of SeaTac air space have been significant and irreplaceable. Summary of results and information gathered since Feb 2010: Medina s concerns with regard to south flow arrival non-compliance were successfully documented as part of the Fly Quiet Program evaluation of the Part 150 study. We are currently awaiting the publication of the draft Part 150, scheduled for late Fall. The public and municipalities will have the opportunity to comment at that time. Port of Seattle has agreed to provide the City of Medina with quarterly compliance reports and data. Temple Johnson s random monitoring of the air traffic control frequency has confirmed that generally air traffic controllers issue visual approach procedures not Husky Visual Approach procedures allowing aircraft to cut the corner over Medina. In some meetings, the FAA has insisted that they continue to train air traffic controllers to use the Husky Visual and in other correspondence, they claim that use of a standard visual approach is justified under certain conditions. The City of Medina should continue to pursue this issue and gain written clarification from the FAA to determine specifically which conditions allow for a non-husky visual approach and validate that this is standard practice at other airports. At Medina s request, the FAA completed a study of flight volumes in the hours before and after north flow curfew to determine whether the volumes were low enough to justify increasing the hours of curfew. Initial results showed that it would be possible to start curfew 1 hour earlier on Sat night and end it 1 hour later on Sun morning. The local Tower was asked to review the results and conduct a trial. FAA officials then informed us that it increased the workload of air traffic controllers and that airlines opposed the change because of the inefficiency of the alternate Duwamish routing. Therefore, the FAA decided not to proceed with the longer curfew even though the Four Post Plan states that the Duwamish routing should be utilized whenever volumes are light enough. Flight Track Update for City of Medina September 2011

16 The Port provided data that shows the Port of Seattle does not use the FAA Four Post Plan EA parameters to measure flight compliance. They measure compliance to their own noise abatement corridors which are not as strictly defined as the Four Post Plan, nor do the Port s compliance reports track altitude, which is clearly defined within the Four Post Plan. At my request, the Port created a sample report using the Four Post Plan parameters on actual flight track data which demonstrated that more than 30% of flights on south flow arrivals are not complying with the Four Post Plan as written. Because these flights are allowed to join the arrival stream further south than allowed in the Four Post Plan, they are cutting the corner over Medina and increasing the arrivals that fly over Medina. Because the Port of Seattle does not use the Four Post parameters to track compliance, these planes show on their reports as compliant and the FAA then uses these reports to prove they are in good standing. Verbally, the local FAA management team has continued to assert that they are in compliance with the Four Post Plan. (After much questioning, we discovered that the SeaTac TRACON Tower did not even have a copy of the Four Post Plan on-site, nor did the Port of Seattle when we first began conversations with them.) The City of Medina sent a letter requesting an interpretation in writing as to how they could be in compliance when flight tracks show the flights joining the arrival stream further south than allowed in the FAA. The FAA s response carefully avoided addressing our direct inquiry and focused instead on misconstruing information contained in the City s first letter. The City then sent another letter requesting written clarification of how they define compliance. (Copies of letters are in the chronology below.) The FAA has not yet responded. If they do not respond satisfactorily by the end of July, we recommend that the City of Medina request a formal review by the FAA Airspace Management Group in Washington DC. Correspondence with the FAA legal department has confirmed that the FAA considers an EA to be binding until completion of a new EA. To date, there has not been a new EA that supersedes the Four Post Plan EA. With regard to North Flow East Turn, all the FAA officials I have met with have concurred that turning the aircraft as close to the 8 NM marker as possible is preferable in order for aircraft to achieve the open water goal between Medina and Mercer Island.. We have continued to press them on this issue pointing out that the sooner these aircraft initiate their turn, the shorter the distance they fly, thus saving fuel and getting them out of Puget Sound airspace more quickly. Unfortunately, at this time the current FAA management team is unwilling to provide the necessary retraining and focus. Medina should continue to stay involved with the Greener Skies program in order to influence new NexGen procedures that will be written for the East Turn in the future. I have also represented the City of Medina and established a relationship with the consultant running the Greener Skies (NexGen) Environmental Assessment for Sea-Tac. The Greener Skies EA covers changing arrival procedures from the west. There are not any short term plans to work on arrival procedures from the east (the ones that overfly Medina). However, long term all arrival and departure procedures will be reviewed and rewritten as part of the national roll-out of NexGen. I have been told unofficially that the long term goal (which the airlines favor heavily) is to shorten up the arrival procedures from the east just like they are doing on the west. If this is the case, those arrivals will come right over Medina. Given that southflow arrivals occur 65% of the time, it is in Medina s best interest to stay on the FAA s radar and continue to protect our airspace. Medina needs to stop the continued southward migration of the base leg of the south flow arrival flight track over Medina. The Greener Skies Draft EA is scheduled to be published in August, 2012 and public comment will be accepted over a day period. Recommendations: Review the FAA s response to the City of Medina letter dated June 22 nd which asks for specific clarification on the definition of final approach and the conditions upon which a non-husky visual approach can be utilized. If no response or the response is unsatisfactory, Medina should send a request to the FAA Air Space Management Group and ask for a compliance review. The results of this effort will determine whether Medina should consider retaining an aviation attorney to continue to press the matter legally. Review the Draft Part 150 document and provide public comment. Currently scheduled to be completed by year end with a 45 day comment period. Review the Draft Greener Skies EA and provide public comment. Currently scheduled to be released in August with a 30 day comment period. Continue to monitor the Greener Skies Program to ensure that future NexGen flight track changes do not adversely impact Medina. Flight Track Update for City of Medina September 2011

17 Chronology of Council Updates: Part 150 Noise Compatibility Study City of Medina Update June 14 th, 2010 Presented by Allyson Jackson Brief Review of Part 150 Process: Structure and Organization (role of the Port, FAA, Landrum and Brown) Timeline Port s goals for this study (65 DNL contour what it means and how it is used) o To address noise issues related to the third runway; o To conduct the process in an open and engaging way; and o To look for opportunities that have not been thought of versus re-visiting old issues. o This study will identify existing and future flight corridors, develop aircraft noise exposure maps for current and future conditions, evaluate air traffic control procedures that could be implemented to reduce noise exposure over residential areas, consider land use controls that could be established to reduce future incompatible land uses from being developed within high noise areas, and evaluate means to mitigate noise impacts within high noise exposure areas. Relevent historical information: (distribute flight track maps) Overview of map, north flow, south flow arrivals, departures.when used etc. Brief discussion of evolution of east turn Four Post Plan: what pertains to Medina: arrivals at 520 bridge, departures at 4000 ft and 8 NM turn over open water corridor Medina s concerns: Continued non compliance on arrivals (especially for nighttime flights) Number of departures over Medina that should be over open water corridor Late night, early morning departures especially on weekends More flights routed over Duwamish Industrial Corridor Actions to date: Presenting City of Medina s concerns to the Port and requesting that our issues be included in the scope of the Part 150 process. o At the public focus meetings o In letter format from the City Council o Directly to the Port staff Working directly with the Port on non-compliance of arriving flights o Port has agreed to send quarterly non-compliance reports to the City Manager o Recommend that the City reviews these reports on a semi annual basis to ensure that non-compliance does not worsen o Port/FAA do not have compliance requirements. Future Action: Continue dialogue with Port Staff and Commissioners and gain their commitment to add our concerns to the scope of the Part 150 City to ensure that review of non-compliance report is reviewed on a regular basis. City could establish their own threshold as to what is acceptable and always notify port when it falls below. City should watch for trends that compliance is getting worse and track is being is being established further south. Flight Track Update for City of Medina September 2011

18 Part 150 Noise Compatibility Study City of Medina Update June - July, 2010 Submitted by Allyson Jackson Activity: Continued correspondence and conversations with Stan Shepherd, Port of Seattle Noise Manager and Rob Adams, Landrum and Brown Consultant Part 150 Study Leader with the following results: 1. Commitment that Medina s concerns will be included in the Fly Quiet Program evaluation portion of the Part 150 study: a. South Flow non-compliance (Is there a way to decrease the number of arriving flights that cut the corner and fly over Medina?) b. Review of current location of North Flow East Turn departure flight track compared to Four Post Plan (Four Post Plan shows the East Turn as predominantly over open water between Mercer Island and Medina but current flight tracks show the track is predominantly over Medina.) c. Increase the number of daytime departure flights that utilize the Duwamish Industrial Corner. Discussion and Action: The Port did not officially respond to Mayor Jordan s May 27 th letter requesting that these issues be included in the Part 150. Even though Stan Shepherd has committed (verbally and via ) that they will be, I have requested an official response from the Port to the City. No City action required at this time. 2. Commitment from Stan Shepherd to hold a working session in late October (tentatively Oct. 27 or 28) with representatives from the Medina City Council and staff, Port of Seattle, FAA and Part 150 consulting team to discuss Medina s concerns (above) and potential solutions. Discussion and Action: The proposed meeting with the Port and FAA provides an unprecedented opportunity to work directly on the noise issues that impact Medina. Although the Port has the responsibility of monitoring and managing noise, the FAA has responsibility and ownership of all flight track implementation. The FAA does not report to the Port. Therefore, when the City complains to the Port, they can track the concerns but they cannot implement any changes nor mandate that the FAA implement changes. Historically it has been difficult to get the FAA to the table to work together with the City and the Port. My recommendation is that we take advantage of this excellent opportunity to enter into a positive working relationship with all parties. Working Session attendance recommendation: Mayor Jordan to establish credibility and convey the appropriate level of importance that this issue carries 2 additional Council Members who have some history with the issue. I can provide a briefing prior to the meeting. City Manager or staff representative myself Bob Rudolph for his historical expertise City of Medina action: Determine availability of council members for tentative Oct 27 th or 28 th meeting date and notify Allyson Jackson as soon as possible. Determine potential locations: The Port has invited the City to their offices at SeaTac because the Part 150 consultants will be in town for Part 150 meetings and they are tightly scheduled. In addition, it is easier to get the appropriate FAA officials to attend at SeaTac. However, the Port is willing to work with the City on an acceptable location. Please notify Allyson Jackson if you can consider a meeting at SeaTac, if the meeting needs to be in Medina, or if you can consider a public facility location (such as a library) between SeaTac and Medina. Flight Track Update for City of Medina September 2011

19 3. Commitment by the Port to send the City of Medina quarterly South Flow arrival compliance reports which shows numbers of flight that are flying over Medina outside the noise abatement corridor. Donna Hanson received the first of these reports in early July. Discussion and Action: I recommend that the City track the compliance reports and provide an annual review to the council. The purpose is to monitor whether compliance is worsening and if so, does it appear that the track is being shifted and established over the City of Medina. No City action required at this time. 4. Completed a History of Aircraft Noise over Medina summary that the City can utilize to update and educate citizen s that call in to complain about jet noise. (attached) Discussion and Action: I recommend that the History of Air Traffic over Medina be sent out to citizens that call in requesting information about air traffic or complaining about jet noise. In addition, a link to this document could be added to the City of Medina website. Finally, include a Part 150 update in the next City newsletter and include a link to this document. City Action: Determine the best way to make this information available to the public 5. Attended a Part 150 Technical Review Committee Meeting and noise modeling session. Discussion and Action: No city action required at this time. Flight Track Update for City of Medina September 2011

20 Part 150 Noise Compatibility Study City of Medina Update Summary of Oct 27, 2010 Meeting with FAA and Port Submitted by Allyson Jackson Port, SeaTac and FAA Attendees: Stan Shepherd, Port of Seattle Manager Airport Noise Programs Mark Reis, SeaTac Airport Managing Director Ron Fincher, FAA District Manager Rob Adams, Vice President, Landrum and Brown (Part 150 Lead Consultant) City of Medina Attendees: Bret Jordan, Mayor Shawn Whitney, Deputy Mayor Doug Dicharry, Council Member Donna Hanson, City Manager Robert Rudolph, Former Council Member and Deputy Mayor Allyson Jackson, Consultant Meeting Objective: Enter into a positive working relationship with all the parties that potentially influence flight track operations and compliance: the Port, SeaTac, FAA and the Part 150 team. Reiterate Medina s concerns and gain agreement on the problems Set a course of action on how to resolve Medina s concerns, who is responsible and how to proceed. Gain commitment on whether Medina s concerns will be addressed within the Party 150 Study Summary Bret Jordan introduced city representatives and emphasized that Medina is committed to finding a resolution to their concerns. Mark Reis introduced Port and FAA officials and consultants. Stan Shepherd mentioned that most of Medina s concerns needed to be addressed outside the Part 150 process. Allyson summarized Medina s specific issues as related to the Environmental Assessment Post Plan: South flow arrivals flight track compliance North flow eastern departure flights Duwamish corridor re-routing as the result of new technology Regarding Southflow: Allyson provided documentation of south flow arrival flight track non-compliance and the FAA 4 Post Plan Procedures. She showed a 1991 flight track (a year after the 4 Post Plan was implemented) and a current flight track showing that the bulk of flights had moved south with many flying over Medina. She stated that the City of Medina wants the Port to comply with the Four Post Plan without having to be constantly monitored. Rob Fincher, FAA stated FAA is constantly monitoring and reeducating air traffic controllers but that safety or efficiency are the exceptions. He said that Medina will need to continually monitor the situation just as he does. He said he wasn t sure why the south flow arrival turns had shifted south but assumed that it was due to overall increased volume. (Note: Follow up needed: If current aircraft volumes in/out of SeaTac are close to 1995 volumes (as shown in current Part 150 study data), then volume of flights does not explain the shift of this flight track south. A question was asked whether efficiency is from the airlines or the airport perspective. Ron Fincher answered both. He and Mark Reis described situations during heavy arrival volume when there might be an opening in the arrival stream and that air traffic controllers would direct flights to overfly Medina in order to jump into the arrival stream. Otherwise these flights would have to travel much further north in order to get at the end of the line of the arrivals. Therefore, they do not consider those flights that are Flight Track Update for City of Medina September 2011

21 given the go ahead by air traffic control to overfly Medina and join the arrival stream as violating the Four Post Plan. Note: Follow up: Can the FAA legally violate its own Environmental Assessment of the Four Post Plan for the basis of improving efficiency? Stan Shepherd stated that the Port has monthly meetings with FAA and sends a non-compliance letter from Port to airlines chief pilot if they see any patterns. They also reward/recognize carriers that have high compliance. Shawn Whitney talked about multiple flights over her house and how she can regularly see non-complying arrivals. Allyson noted patterns on the Port s Compliance Monitoring reports: Nighttime South flow Arrivals from the East consistently have the worst compliance of any routes that are monitored South flow arrivals from east are consistently 5-8 times worse than south flow arrivals from the west Fincher/Reis stated that this was because the South flow from the west turn was further south and to cut that corner was unnatural for pilots. Bret Jordan expressed frustration that the Port was just trying to give more excuses instead of working on ideas to improve compliance. Rob Adams, Part 150 consultant offered to take a look at ways to get higher compliance in these areas. Stan Shepherd stated that he would look into what the Port could do reinforce compliance. Port of Seattle and Ron Fincher stated that they would be open to working with Rob Adams on these ideas. Mark Reis, SeaTac Airport Director, wanted to make sure that Medina was not asking for the Four Post Plan flight tracks to be changed. Allyson reiterated that Medina is looking for strict compliance to the Four Post Plan procedures. Rob Adams stated that the airports with the highest level of compliance are those with the most communications between the airlines, airport, and FAA. Regarding North Flow East Turn Departures: Allyson talked about the North flow east turn departures. She presented the schematic map from the Four Post Plan document which shows the flight path as over the open water between Medina and Mercer Island, just touching the tip of Medina. She discussed the documented conversations and letters between the City of Medina and the FAA, which show the FAA s intent over many years to put the flights over the open water. She stated that the FAA had committed to Medina in the mid 90 s that when FMS was implemented, then most of the flights would move into the open water corridor. She showed flight tracks with most of the planes not initiating their turns until North of the I90 bridge, well past the 8 NM marker, and that these are the planes going over central Medina. She also showed some flight tracks from selected days where a majority of the flights were actually successfully flying the open water corridor. The FAA and Port did not provide an explanation for this. Allyson also pointed out that the Port of Seattle Staff report at the conclusion of the Part 150 study describes the east turn as going over the open water corridor between Medina and Mercer Island. Ron Fincher, FAA stated that FMS (also known as R-Nav) was not currently being utilized on the East Turn but it is being used for departures turning west and going out the Duwamish Corridor. He did not say why it was not being used on the East Turn. The turn is dependent on the aircrafts destination. He thought that aircraft were waiting to make their turn so that they would be at a higher elevation when they cross an arrival stream further East. (Note: this information needs to be confirmed. It is not consistent with the Four Post Plan). He thought that flights were not turning at the 8 NM marker because they had not achieved 4000 feet of elevation. (Note: Data we have from the Port would suggest that almost all flights are at 4000 feet of elevation when they cross the 8 mile marker.) He said that air traffic controllers tell the pilots when to begin their east turn. (Note: This information may be incorrect.my understanding is that the planes initiate the turns themselves and then are given one of 2 headings and perhaps 090. These are SIDS or Standard Instrument Departure procedures. If they are only given these 2 headings, then that would explain more flights over Medina.) Allyson mentioned a conversation with a local retired pilot who recommended that to achieve the open water goal, flights on the east turn could travel a little slowly once off the runway which would allow them to achieve a higher elevation faster (therefore be less noisy to people on the ground more quickly) and then easily initiate their turns at the 8 NM marker. The FAA did not comment on this suggestion. Flight Track Update for City of Medina September 2011

22 Allyson asked what is precluding the FAA from utilizing the open water corridor between Medina and Mercer Island and Fincher stated, nothing prevented him from getting the flights over the open water. Allyson asked what it would take to make the change to get the flights over the open water. Fincher said an 18 month process. Allyson asked who at the FAA needed to authorize it. Fincher said it was his decision. Allyson asked Fincher if he would get the process started and Ron said he would be willing to look into it. Neither the FAA or Port expressed an opinion on whether they consider North Flow flights over Medina as non-compliant. Duwamish Corridor: Allyson asked why when historically almost all parties agreed, there were not more planes sent over the Duwamish corridor when it is an industrial area and the east is residential? In addition, air traffic volume is significantly less and more planes are equipped with improved navigational technology than when the Duwamish Corridor capacity study was done in 2000 Mark Reis stated that the Duwamish is used for flights with certain destinations and that all flights going to those destinations are already on the Duwamish. Fincher stated that they would not reconsider flights with other destinations using the Duwamish Corridor because it creates a crossover problem in southern Oregon. Note: Southern Oregon is not crowded airspace and there is plenty of vertical space to separate the highways in the sky. Think about how many crossovers occur in the crowded East Coast air space. Williams Aviation Consulting hired by the City of Medina showed how this could be done safely and efficiently in their 2002 report that was submitted to the FAA. Allyson asked if the FAA would be willing to adjust curfew hours currently from10 pm to 6 am. Ron Fincher said he would look into curfew alternatives. Flight Track Update for City of Medina September 2011

23 Part 150 Noise Compatibility Study City of Medina Update Feb 8, 2011 Submitted by Allyson Jackson Recent Activity: Met with Temple Johnson, retired FAA Northwest Mountain Region Director and author/implementer of the Four Post Plan. Reviewed Medina s concerns with North Flow East Turn and non-compliant South Flow arrivals. After discussion and reviewing current flight tracks, he concurs that many of the North Flow East Turn flights could safely and efficiently flow the open water corridor between Medina and Mercer Island. He believes that this could be easily implemented with FMS/RNAV technology. On South Flow arrivals, he concurs that the turn has shifted south from the original plan and in his opinion, the FAA needs a new Environmental Assessment for the track that they are currently using. Temple Johnson and I met with Stan Shepherd, Port of Seattle Noise Manager and Rob Adams, Landrum and Brown Consultant Part 150 Study Leader with the following results: (Meeting held Jan 26 th ) Temple Johnson discussed his background and role in the development of the Environmental Assessment (EA) for the Four Post Plan and its implementation in He also discussed the litigation that challenged the Four Post Plan EA as well as the Justice Department s opinion that although the FAA won the lawsuit, any deviations from the EA may not hold up in court. Temple Johnson clarified that the southward shift of the South Flow Arrival Stream over Medina is a clear violation of the Four Post Plan EA. Therefore, the planes that are cutting the corner over Medina are in violation of the FAA s EA approved operational procedures as well as being in violation of the Port s designated Noise Abatement Corridor. The Port made it clear that they do not have the authority over FAA procedures and are not responsible for the FAA following their own Environmental Assessments. As airport operator, they can monitor noise and noise abatement corridors and provide feedback to the FAA about non-compliance. They can set up training for air traffic control operators and provide information to airlines and pilots that encourage compliance..all of which do help but require ongoing monitoring. Resolution of the problem requires the FAA to hold their Air Traffic Controllers to a high standard of compliance with their operational procedures. Port agreed to the following next steps for South Flow compliance: o o o o The Port is committed to ongoing monitoring of the South Flow Arrivals. They tag all flights that are non-compliant and meet monthly with the FAA to discuss. In addition, they are now sending these reports to the Medina City Manager on a quarterly basis. This will continue. The Part 150 Consultant will review the visual landing procedures that are currently in use and make a recommendation on how to alter this so that flights that are given authorization to use a visual landing approach (and therefore cut the corner over Medina) will still have to follow the noise abatement corridor. As part of the Part 150 Review of the Port s Fly Quiet Program (an incentive based program for pilots and airlines to comply with procedures), the Port and Part 150 Consultant will review and make recommendations for incentives that will further encourage pilots and airlines to comply. The Port will review the materials they are using for their annual air traffic controller training to emphasize following the South Flow Arrival procedures. The North Flow East Turn over the open water and continued discussion of South Flow compliance by air traffic controllers is clearly an FAA action item and outside the scope of the Part 150. As a follow on to the November 2010 meeting between the Medina City Council, Port and FAA, Mayor Jordan sent a letter to Ron Fincher, FAA District Manager, requesting that Medina be allowed to insert a technical consultant into the process of reviewing both East Turn and South Flow arrival procedures. Ron Fincher finally responded (after several phone messages and s) that he is declining Medina s offer to insert a technical specialist into the process but would be happy to review the FAA s progress with us. Flight Track Update for City of Medina September 2011

24 Discussion and Action: Continuing to attend the Part 150 meetings will ensure that the South Flow compliance issue is documented and puts pressure on the Port and Part 150 team to come up with recommendations that are reviewed and implemented by the FAA. I will continue to attend the Part 150 Public Focus Meetings and Technical Sessions, as appropriate. The additional efforts are outside the scope of the Part 150 study but are critical if the City of Medina wants to remedy the noise problem. I will continue with the efforts below unless the Medina City Council provides different direction. Meeting with Ron Fincher, FAA District Manager is critical. For the past 15 years, the FAA has continued to promise Medina they will look into Medina s concerns but they have not followed through. Although Mr. Fincher has declined Medina s direct involvement at this time, he is willing to keep us apprised of his progress. I will continue to press for a meeting between him, Temple Johnson and myself so that we can review the work and progress that the FAA is making. In addition, the goal would be to persuade Mr. Fincher to allow us to work together. I believe that we may need Mayor Jordan to intervene and set up the meeting, as well as attend. Since Mr. Fincher has historically not been supportive of dealing with Medina s concerns, Temple Johnson is exploring other avenues within the FAA that we can utilize in order to get the FAA s attention. It is Temple s opinion that the local FAA is clearly not complying with their own procedures. We are trying to determine if there is an FAA oversight committee that we can get involved to review whether current operations are in line with the Environmental Assessment for the Four Post Plan. Flight Track Update for City of Medina September 2011

25 Flight Track Update for Medina City Council March - September, 2011 March 4 th Meeting Review: Mark Nelson, Temple Johnson and Allyson Jackson met with Ron Fincher, FAA Columbia District Manager to discuss the East Turn Departures and South Flow Arrivals. Council was given a detailed report. A brief review follows: Fincher conveyed that new South Flow Arrival and East Turn departure procedures would be developed under the Greener Skies Initiative which is part of the FAA s move to a GPS based system. He conveyed that the FAA is motivated to get the East Turn departures over the open water between Medina and Mercer Island because it is a shorter distance to get them out of Puget Sound airspace. He suggested that Medina attend the Greener Skies meetings. There was discussion about arrival visual approaches that tend to be the flights that most often overfly Medina. There was discussion of whether the Port s flight monitoring system is tracking non-compliant south flow arrival flights in a manner consistent with the EA for the Four Post Plan. Fincher said he would follow up with the Port on this issue. Fincher shared that flight volumes appear to be low enough on Sat night and Sunday morning to justify extending curfew. Current curfew requires that all north flow departures go out the Duwamish Corridor after 10 pm and before 6 am, 7 nights a week. The potential new curfew would begin at 8 pm on Saturday night and end at 7 am Sunday morning. Testing and final review are still required. Flight Track Update for City of Medina September 2011

26 Updates since March 4 th : Fincher has communicated that the Greener Skies Initiative will not be developing new procedures for the south flow arrivals from the east after all. He has not yet provided any additional information with regard to North Flow departures. He also looked into Medina attending the Greener Skies meetings, however he informed us that they are not currently open to the public. The Part 150 Consultant has developed some alternative improvements for visual south flow arrival approaches that he presented to the FAA for their review. In the meantime, Temple Johnson has been monitoring the tower radio frequencies and his random sampling has revealed that almost all of the flight that are given clearance by the tower to visually approach and land at the airport are not using the proper Husky Visual Approach. The approach directs the pilots to stay north of 520 before making their turn to head south to the runway. Conversations between us, the FAA and Port continue on this topic. We are currently waiting for the FAA s evaluation of the alternatives provided by the Part 150 Consultant. Conversations also continue with regard to our assertions that the Port s flight monitoring system is not tracking non-compliant south flow arrival flights in a manner consistent with the EA for the Four Post Plan. The Port created an alternative report for us which showed all the flights in Feb 2011 that did not comply with a strict interpretation of the Four Post Plan. That report showed about 33% of all south flow arrivals as non-compliant with the Four Post Plan. However, the official Port s compliance report shows that only 5% were non-compliant. The difference is due to the parameters the Port is using to track flights. We have pushed the Port to change their parameters to reflect the procedures outlined in the EA. However, they have told us that the FAA provides the tracking parameters based on the FAA s interpretation of the noise abatement corridors. We are questioning why the so called noise abatement corridors differ from the EA approved flight tracks and if they do, who created them, how and when and where is the documentation for these noise abatement corridors. The Port is looking into the background on this. The Port believes their role is to gather data, create reports and interface to the public. Therefore they have told us that how the flights are monitored is an issue that Medina needs to resolve directly with the FAA. Temple s preliminary FAA and industry inquiries suggest that the local FAA s interpretation is not consistent with industry standards. We are continuing to gather data and will meet with Fincher to continue to pursue this issue. As long as the Port measures compliance using the current parameters, the FAA and Port will continue to look like they are reasonably compliant and therefore, it will be difficult for us to justify our case if we decide to escalate this issue within the FAA. The testing for the extended curfew for departures on Sat night and Sun morning will be completed in November. Recommendations: Allyson and Temple should continue to hold the Port, FAA and Part 150 Consultant accountable to enforce a HUSKY visual approach every time a Visual Approach is allowed. Allyson and Temple continue their efforts to work directly with the FAA to address the issue of arrival compliance being consistent with the Four Post Plan EA. Flight Track Update for City of Medina September 2011

27 Flight Track Update for Medina City Council October February, 2012 Repeated follow up attempts with Ron Fincher, FAA Manager Columbia District Mr. Fincher took a temporary assignment in WA DC and therefore was unavailable and unresponsive for several months. He eventually put me in touch with Bill Washington who is the current Acting Manager Columbia District manager. Meeting with Bill Washington, FAA Acting Manager Columbia District Manager. Discussion focused on bringing Bill Washington up to speed on Medina s efforts to date with the Port and FAA. Specifically, Temple Johnson and I focused on the following: o South Flow Arrivals from the East. Based on current flight track data, it appears that there are many arrivals not in compliance with the Four Post Plan Environmental Assessment which states that: Turbojet arrivals from the Northeast and Southeast arrival fixes will be positioned so as to be established on the Runway 16 final approach course no closer to the airport than SR 520 (11 nautical miles) north and no lower than 5000 feet MSL. Although the Port of Seattle monitors flight track non-compliance, the parameters used to measure compliance are based on the Port s Noise Abatement Corridors, not the FAA s Four Post Plan. Therefore at least 25% of south flow arrivals from the east show in compliance when in fact they do not comply with the above wording in the Four Post EA. The flights that the Port does capture as non-compliant appear to be on Visual Approach and the tower is giving them a clear to airport rather than a clear to Husky Visual directive. To continue our discussion, we agreed to meet in the New Year after Bill Washington could review the information we presented. o Curfew Extension for North flow Departures: Bill Washington shared that the curfew test had been completed and preliminary results indicated that curfew could begin on Saturday nights at 9 instead of 10 pm and end at 7 am Sun morning, instead of 6 am. However, before a change can be implemented, feedback needs to be gathered from the Seattle Tower. o East Turn North Flow Departures: We touched briefly on Medina s concern that the majority of north flow East Turn Departures tend to fly several miles beyond the 8 NM turning point specified in the Four Post Plan Environmental Assessment, placing the majority of north flow East Turn flights directly over Medina, rather than in the open water between Medina and Mercer Island. Flight Track Update for City of Medina September 2011

28 FAA Reauthorization Bill review and letter to Senator Cantwell. On Feb 6 th, Congress passed the FAA Reauthorization Bill which primarily deals with funding the FAA. However, buried within the bill is a section that deals with the roll out of NextGen technology which is the FAA s new GPS based navigation system. By utilizing GPS technology combined with cockpit navigation tools now available in the majority of national carrier aircraft, the FAA can build a more reliable air traffic system that concentrates arrivals and departures in a very tight corridor, allows them to safely fly closer together and utilize a gradual descent pattern into airports. The results should be less fuel consumption, higher airport capacity and less noise for some residential populations. For those populations that end up under the highly concentrated flight track, the result will likely be more noise, more often. In order to expedite the implementation of NextGen, the Reauthorization bill includes a categorical exemption from NEPA environmental review for all new NextGen procedures thereby relieving the FAA of their responsibility to assess environmental consequences of the new procedures. (More information available at: 1/faa-reauthorization-act-exempts-next-generation-airspace-redesign-projects-from-environmental-review/ Fortunately, the categorical exemption built into this bill will not have an immediate impact on Medina. The SeaTac NextGen flight track procedures currently under development are not the flight tracks that impact Medina. In addition, there are no current plans to utilized NextGen procedures on the departure and arrival tracks that impact Medina. However, longer term, if NextGen procedures are developed for the North Flow Departure East Turn and Southflow arrivals from the east, under this new bill, there will be no Environmental Review or recourse if the new flight tracks concentrate flights directly over our city. Therefore, I provided a letter to the City of Medina that can be sent to Senator Cantwell (whose subcommittee introduced the amendment described above) which requests the language be changed in order to provide adequate environmental review and protection for residential neighborhoods when new NextGen flight tracks are developed. Greener Skies Public Meeting: Information available at : I attended the first Public Meeting for the Greener Skies Environmental Assessment (EA). Greener Skies is SeaTac s roll out of NextGen. This meeting occurred prior to the passage of the Reauthorization Bill described above. Therefore, it remains to be seen whether the FAA will continue with this EA. The procedures that are under review are arrivals from the west and therefore do not directly impact Medina. I confirmed with the project manager that there are no plans in place to make NextGen procedural changes to departures to the east and arrivals from the east. I did provide public input to the process. Recommendations: Continued follow up with Bill Washington to press for FAA action, utilizing Temple Johnson as appropriate. Flight Track Update for City of Medina September 2011

29 Flight Track Update for Medina City Council March June 2012 Summary of March 16th meeting with Bill Washington, FAA: Curfew Extension for North flow Departures: Although testing has shown that volumes are low enough to safely begin the curfew on Saturday nights at 9 and end the curfew at 7 am Sunday morning, the FAA has decided not to implement changes due to airline pressure that the alternative Duwamish routing is inefficient. South Flow Arrivals from the East: In our previous meeting we had discussed Medina s concern that there are many arrivals not in compliance with the Four Post Plan Environmental Assessment which states that: Turbojet arrivals from the NE and SE arrival fixes will be positioned so as to be established on the Runway 16 final approach course no closer to the airport than SR 520 (11 NM) north and no lower than 5000 feet MSL. Although the Port of Seattle monitors flight track non-compliance, their compliance parameters reflect the Port s Noise Abatement Corridors, not the FAA s Four Post Plan. Specifically, Medina has requested a response to the question: Why are so many south flow arrivals from the east not established on final approach north of SR 520 as required by the Four Post EA and the published Husky Visual? Your response is that the FAA considers turbojets on a 30 degree intercept to final as established on final even though they are joining the centerline of the runway south of SR 520 and below 5000 feet. Therefore in your opinion, the FAA considers these planes to be compliant with the Four Post Plan EA. We requested that you provide this interpretation officially in writing to the City of Medina and you indicated you would first need the City of Medina to send a formal written request. With regard to compliance with the Husky Visual, we requested that training for the Husky Visual Approach be included in upcoming controller training sessions to ensure that controllers don t clear pilots directly to the airport but direct them to the Husky visual, as is clearly stated in both the Jeppesen charts and SeaTac s CVFP. We did not receive commitment that this information would be included in those training sessions. East Turn North Flow Departures: We reiterated that a large percentage of north flow East Turn Departures tend to fly several miles beyond the Four Post specified 8 DME turning point before initiating their turn east. We concurred that this flight path complies with the Four Post EA which states that turbojets turn after reaching the 8 DME arc. However, as we discussed with Ron Fincher in March 2011, both the FAA and Medina have a shared interest in the jets turning as close as possible to the 8 DME. It benefits the airlines by shortening the distance to leave Puget Sound airspace, it is an existing flight track currently in use and in compliance with the EA, and it puts the flights over non-residential open water. As Mr. Fincher suggested at that time, with such a high percentage of the fleet now equipped with appropriate cockpit technology, there should be the potential to safely and efficiently accomplish the East Turn open water goal with minimal controller intervention. Medina s continued request is that the FAA review these operational procedures and put as many flights as possible over the open water corridor between Medina and Mercer Island. Flight Track Update for City of Medina September 2011

30 Flight Track Update for City of Medina September 2011

31 Flight Track Update for City of Medina September 2011

32 Bill Washington s written response: City of Medina 501 Evergreen Point Road Po Box 144 CITY EDINA Medina, WA April 27, 2012 Dear Mayor Luis: Thank you for your letter of April 4, 2012, regarding air traffic operations in the Seattle area. As you know, my office has met with your consultants on two occasions regarding this subject. In your letter you mention how aircraft are vectored onto the final approach during south flow operations at Seattle Tacoma International Airport. You allege that the intercept point on the final approach is not in compliance with the 1990 Record of Decision( ROD). Our internal electronic flight track data, examples of which were reviewed with your consultants in March, indicate compliance, as well as data from the Port of Seattle which our facility management meets with regularly. Interestingly, in your note referencing interviews with commercial airline captains you allude to a measure final approach deflection in the aircraft being comparable to the azimuth of a radar vector. The two figures you cite refer to different measures: the criteria to be within 2 '/ 2 degrees to be established on final refers to deflection from an electronic final approach signal( such as an Instrument Landing System) that is displayed on an indicator in the aircraft, while the 30 degree heading refers to a compass course that is tracked on a radar screen in the approach control. Hence these values are not comparable. In regard to the Husky Visual Approach, all controllers at the approach control are trained on all of the approach procedures for all of the airports within the airspace. Additionally, recurring refresher training sessions include briefings and radar simulation scenarios that reinforce approach procedure knowledge as well as noise abatement procedures. As far as usage of the procedure, I stated to your consultants in March that assignment of the Husky Visual Approach in every case is impractical, as traffic flows and operational requirements vary throughout each day. You can be assured that the approach is assigned whenever practical and the proper conditions exist. Should you have questions or need further information, please let me know. Sincerely, William Washington Manager, Columbia Terminal District Flight Track Update for City of Medina September 2011

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36 Aug 9, with a few added notes. Dear Medina City Council Members, Attached is the most recent letter from Bill Washington. This is the letter that we have been anticipating in order to proceed with the City s request to FAA Airspace Management for a compliance review of south flow arrivals at SeaTac. Note throughout his letter Mr. Washington states that he already provided this information to Medina s consultants. Some of the information was provided verbally but we needed it in writing. Now that we have his position in writing, we can move forward. I will develop a draft letter to be sent to Donna Warren, FAA Airspace Management and submit it for your review later next week. To date, we have been relying on Temple Johnson s extensive background and experience with the FAA to interpret the FAA Four Post Plan language. His expertise has been invaluable. However as we move forward with the FAA Air Space Management Division, as neither Temple nor I are attorneys, I recommend that the City consider retaining an aviation attorney to review the information that we have gathered to date, provide a legal interpretation to the City and be responsible for future correspondence with the FAA, as needed. This letter to the Airspace Management Group should be all that is required to effect change. But the FAA is unpredictable and it may require a letter written by an attorney to create the urgency needed for them to take action. Mr. Washington s August 6th letter continues to avoid addressing Medina s concern. Because the language is subtle, I have added a detailed interpretation. Below you will find a list of the concerns from Medina s last letter to Mr. Washington, a copy of his response to each and then my commentary for your review. Issue 1: Medina s letter: Flight tracks from the Port of Seattle show a significant percentage of south flow arrivals clearly intercepting the final approach course south of SR 520. The Final Environmental Assessment (EA) dated March 1990 states that turbo jets must be established on the Runway 16 final approach course north of State Route 520. Since your letter states that these aircraft intercepting south of 520 are in compliance with the above named EA, are you saying that the FAA considers an arrival aircraft on a 30 degree intercept heading to final the same as an aircraft established on the Runway 16 final approach course? FAA response: Commentary: The PDARS flight track data that Mr. Washington references was very similar to the Port s data. He is correct. Both flight tracks show most of the flights starting to turn towards final north of 520. But that is not our issue and not the clarification we asked for. The Four Post EA does not regulate when the turn is initiated. The Four Post EA states that aircraft have to be positioned on the final approach course north of 520. Neither the Port data nor the PDARS data show all the flights following that mandate. Temple Johnson has advised that this very specific FAA language was purposefully used in the EA in order to avoid aircraft cutting the corner as they are today. In

37 his opinion and based on his experience with the FAA, he believes that escalating the issue to Airspace Management for review is the appropriate next step. As an aside, Mr. Washington would not allow us to take the copies of his PDARS flight tracks to share with the City. Additionally, he in incorrect when he says he has not seen the data we are referring to. He and his staff were provided copies at our meeting and he receives copies regularly from the Port. Issue 2: Medina s letter: Recent Port of Seattle flight tracks also show that the base leg of the south flow arrivals has shifted significantly south since the above name EA was implemented. Please clarify how this flight track can be shifted without new Environmental Assessment. FAA response: None Commentary: Mr. Washington s lack of response is significant. The reason that the base leg of the arrival stream has shifted south over Medina is because aircraft are allowed to establish themselves on the final approach course south of the 520 bridge and lower than 5000 feet, in violation of the Four Post EA. To illustrate, please review the following attachments: The March 1992 flight track (one year after implementation of the Four Post Plan) shows the arrival flights joining the final approach north of the 520 bridge. In contract, please review the sample Port of Seattle June 2002 flight tracks. In the June 2002 flight track map you can see how the base leg (the track over the water) has shifted from being close to Kirkland in 1992 to now being much closer to Medina and in some cases right over Medina. Issue 3: Medina s letter: In your letter you mention that the Port of Seattle data shows FAA compliance to the above named EA. In conversations with the Port of Seattle, they have indicated that their tracking system measures compliance to their own Noise Abatement Corridors, not the EA procedures. Can you provide clarification then on how the FAA uses the Port of Seattle flight tracking data to measure FAA compliance to the above named EA? FAA response: Commentary: Significant response! This is the first time the FAA has ever admitted that the Port s compliance tracking utilizes separate noise abatement parameters. Notice that he does not mention that the FAA utilizes parameters from the Four Post Plan, only their own noise abatement objectives. Historically, the FAA has directed us to talk with the Port and review the Port s compliance data when we have questioned their compliance. Historically they have used the Port s data to prove that they are in compliance. Issue 4:

38 Medina s letter: Your letter states that certain conditions make it impractical for controllers to assign the published Husky Visual. Please provide clarification for what these certain conditions might be and why a Visual Approach would be assigned in lieu of the Husky Visual. FAA response: Commentary: We accomplished our goal here which was to get in writing when and why they don t use the Husky Visual Approach. Temple Johnson has been able to tune into the pilot/air traffic frequency and actually listen to their conversations. His observation is that on days with perfect visual weather conditions, air traffic is providing instruction to the pilots that they can arrive on the route of their choosing instead of using the Husky Visual which keeps these visual approaches in compliance with the Four Post EA. Temple has also noted that operational sequencing has historically not been a valid reason for ignoring an EA. Please let me know if you have additional questions. Sincerely, Allyson Jackson