Los Angeles International Airport Community Noise Roundtable LAX Departure Overflights of Palos Verdes and San Pedro

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Los Angeles International Airport Community Noise Roundtable LAX Departure Overflights of Palos Verdes and San Pedro Comments by Jeff Calvagna Rancho Palos Verdes 6 March 2018

Summary of Key Points LAX Departure overflights of South Palos Verdes and San Pedro have increased dramatically since NextGen Metroplex was implemented Rountable staff identified movement of the OSHNN departure waypoint from SLI (Seal Beach) to CAHIL (Fullerton) as the cause In truth, the actual root cause is that the FAA is ignoring their own documented standard instrument departure procedure (OSHNN8 SID) o OSHNN was designed for noise abatement, it keeps aircraft offshore longer and makes landfall over an unpopulated area o Yet over 70% of the time, SoCal TRACON vectors low flying departures off the SID and over Palos Verdes and San Pedro neighborhoods o How can a standard departure require so much shortcutting? Studying flight patterns and Air Traffic Control communications makes clear this is happening for ATC and pilot convenience (not required ) The FAA wants it both ways. OSHNN8 looks good on paper for noise abatement, but the de-facto SID is over Palos Verdes and San Pedro homes The FAA must follow its own documented procedures

OSHNN8 Standard Instrument Departure (SID) Source of Most Palos Verdes and San Pedro Overflights OSHNN landfall occurs at Seal Beach Naval Weapons Station, an unpopulated area. First residential neighborhoods are north of the 405 and at much higher altitudes than during PV shortcuts. OSHNN SID designed for noise abatement yet ATC routinely shortcuts noisy departures over PV and San Pedro Residential Neighborhoods

Over 70% of OSHNN Departures shortcut over/near the PV Peninsula Note: Chart is prior to Metroplex change from SLI to CAHIL waypoint. Overflights now are much worse and head further inland. SID Graphic from the Metroplex Technical Report shows OSHNN Departures and prevalence of SID Shortcutting

The OSHNN SID is a Standard Departure in name only Percentage of flights assigned OSSHNN that fly the SID versus those that shortcut over PV 60% 20% 20% OSHNN SID Adherence Typical patterns observed Jan-Feb 2018 GREEN Adhere to the SID (20%) YELLOW HOLTZ shortcut (20%) RED PEVEE shortcut (60%) FAA claims OSHNN is the standard departure to satisfy noise abatement requirements but doesn t follow its own documented procedures

OSHNN Shortcuts Jan 19 th, 9:20 PM to 10:02 PM 9:20 PM 9:22 PM 9:23 PM 9:25 PM 9:29 PM 9:33 PM 9:39 PM 9:42 PM 9:44 PM 9:45 PM 10:02 PM During this evening period, not a single flight correctly flew the SID, all shortcut over or near Palos Verdes During peak OSHNN usage aircraft can overfly PV every 2-3 minutes

Case Study Southwest 1283 (LAX LAS, 9:23 PM Departure) FEB 12 FEB 13 FEB 15 FEB 16 FEB 19 FEB 20 FEB 21 FEB 22 FEB 23 FEB 26 FEB 27 FEB 28 Out of 12 flights, 8 overflew Palos Verdes/San Pedro (67%) 2 flew the SID (green), 2 HOLTZ shortcut (yellow), 8 PEVEE shortcut (red)

Case Study Delta 1404 (LAX SLC, 6:00 AM Departure) FEB 13 FEB 14 FEB 15 FEB 16 FEB 19 FEB 20 FEB 21 FEB 22 FEB 23 FEB 25 FEB 26 FEB 27 Out of 12 flights, 8 overflew Palos Verdes/San Pedro (67%) 3 flew the SID (green), 1 HOLTZ shortcut (yellow), 8 PEVEE shortcut (red)

Why is This Happening? (ATC Vector Direct to CAHIL ) Regarding PV overflights, the July 2017 LAX Noise Roundtable report stated: FAA determines whether aircraft remain on RNAV procedure (OSHNN 7) or they vector them to another waypoint (e.g., CAHIL) when required for spacing Evaluation of flight patterns and monitoring SoCal TRACON communications with aircraft shows this is not required but being done for convenience If OSHNN truly requires deviation over 70% of the time then frankly it isn t safe Yet the Metroplex report didn t even mention these deviations and recommended no changes to the OSHNN SID The Metroplex technical report hints at what is really going on: Another major issued raised by both ATC and industry stakeholders is the inefficiency of using the OSHNN SID between 2100 and 0700, which adds between 14 NM to 23 NM to the route compared to the LOOP SID. ATC and pilots don t like OSHNN because it s inconvenient. Direct to CAHIL is a free pass at Palos Verdes and San Pedro resident s expense

Why is This Happening? (ATC Vector Direct to CAHIL ) Why would ATC and pilots want to shortcut the OSHNN SID? OSHNN is longer and takes more time particularly if the aircraft had originally filed for the ORCKA (loop) departure OSHNN is complex and slower three turns, at PEVEE, HOLTZ, and OSHNN OSHNN is busy PEVEE to OSNNH leg shared with the DOTSS departure o More ATC intervention needed to de-conflict with DOTSS traffic o Speed restrictions often needed to maintain separation o Altitude restrictions due to Long Beach (LGB) southern departures OSHNN delays ATC hand-off from SoCal TRACON to LA Center (ZLA) Since there is no PV air traffic, Direct to CAHIL is a free pass SoCal TRACON uses to make these concerns go away, rarely is it required for spacing Direct to CAHIL allows the FAA to have its cake and eat it too OSHNN SID looks good on paper and meets noise abatement requirements In reality, ATC routinely ignores it and the de-facto SID is over my house and thousands of others. The FAA isn t following its own procedures.

Metroplex Analysis Predicted a Noise Decrease for South PV and San Pedro Pre-Metroplex Noise Model Post-Metroplex Noise Predict South Palos Verdes and San Pedro predicted to see a small noise decrease. Instead, the opposite has happened. Difference between Pre- and Post-Metroplex Noise Model didn t consider that the OSHNN SID is ignored >70% of the time

We Need Action NOW, Not More Studies! The noise over Palos Verdes and San Pedro has increased dramatically and the FAA owes us some answers: Why isn t the FAA following its own documented OSHNN8 procedure? How can the OSHNN SID be a standard departure when it is ignored over 70% of the time? (definition of standard : used or accepted as normal) Why does SoCal TRACON think it s acceptable to routinely vector noisy low-altitude jet departures over thousands of residential homes? Why did the Metroplex analysis predict a decrease in Palos Verdes Peninsula noise levels when the opposite has happened? Why did the July 2017 report characterize these OSHNN deviations as required for spacing when the overwhelming majority clearly aren t? We don t need another year of studies! We need the FAA to follow its own documented procedures now. No more Direct to CAHIL vectoring, particularly before the HOLTZ waypoint! No deviations from the OSHNN SID unless there is a clear and compelling requirement to do so for safety.