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CC SR 20180501 02 - LAX Roundtable RANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 05/01/2018 AGENDA REPORT AGENDA HEADING: Regular Business AGENDA DESCRIPTION: Consideration and possible action to receive and file a status report on the City’s participation on the LAX Community Noise Roundtable. RECOMMENDED COUNCIL ACTION: (1) Receive and file a status report on the City’s participation on the LAX Community Noise Roundtable. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: Robert Nemeth, Associate Planner REVIEWED BY: Ara Mihranian, Director of Community Development APPROVED BY: Doug Willmore, City Manager ATTACHED SUPPORTING DOCUMENTS: A. Turboprop Community Overflight Activity Timeline (page A-1) B. PV Peninsula Turboprop Overflight Data (page B-1) C. Mokulele Airlines Turboprop Altitudes over PV Peninsula (page C-1) D. Pre/Post Metroplex Analysis of LAX Departures OSHNN (page D-1) E. OSHNN8 Departure Flight Path (page E-1) F. Draft PowerPoint Presentation by Mr. Calvagna (page F-1) G. Email from Mr. Calvagna to the FAA dated April 23, 2018 (page G-1) BACKGROUND & DISCUSSION Creation of the LAX Community Noise Roundtable The LAX Community Noise Roundtable (Roundtable) is a voluntary and independent body created in 2000 in order to function as a group to receive adverse jet and turbopropeller (turboprop) aircraft noise complaints from citizens, prioritize discussions and suggest feasible resolutions to reduce noise to the Federal Aviation Administration (FAA). The Roundtable, as an advisory body working cooperatively with the FAA, seeks to reduce jet and turboprop aircraft noise without shifting noise from one community to another. Roundtable membership consists of elected officials and designated staff, representatives of congressional offices, representatives of 1 Homeowner Associations and the City of Los Angeles World Airport (LAWA) staff, who function to gather data and offer analysis on aircraft arriving and departing from Los Angeles International Airport (LAX). Over the years, various City staff and/or Council-appointed volunteer RPV residents have served on the Roundtable. As a member of the Roundtable, RPV’s representative, currently Staff from the Community Development Department, participates in the regularly scheduled public meetings at LAX, which occur on the second Wednesday of every odd numbered month. In between Roundtable meetings, resident concerns regarding aircraft noise are submitted to Staff who tracks and reports this information at the Roundtable meetings. However, noise concerns regarding low flying aircraft that are below the altitudes of FAA published jet and turboprop departure procedures follow General Aviation Rules and outside the scope of Roundtable. Peninsula Overflight Outcomes Resulting from the Roundtable Turboprop Aircraft: Dating as far back as 2002, RPV Roundtable representatives made persistent attempts to work with the FAA to remove turboprop aircraft, which fly at lower altitudes than jet powered aircraft, from flying over the Peninsula (see Attachment A). Although some gains were made when the FAA routed, as a flight route test, turboprop aircraft to a more distant offshore route (JEDDD procedure), eastbound turboprop flights continued to cross Peninsula airspace. In October 2016, LAWA reported that the FAA cancelled the experimental JEDDD procedure route citing aircraft separation issues. The FAA reverted back to an established turboprop route procedure, which routed turboprop aircraft closer to the Peninsula and the FAA made a decision to not make changes to divert eastbound flights away from the Peninsula, thus curtailing the Roundtable’s earlier efforts to address turboprop aircraft over or near the Peninsula. During this period, due to the restructuring of one of the turboprop carries operating from LAX, turbopropo aircraft activity over the Peninsula decreased, but the decrease in flights was not attributed to Roundtable’s efforts. In 2015, SkyWest (an aircraft carrier) retired its turboprop aircraft fleet. The turboprop aircraft flights over the Peninsula decreased from 3,844 overflights in 2014 to 1,662 overflights in 2015 (see Attachment B). However, despite this decrease, in June 2016, a new turboprop carrier, Mokulele Airlines, began operations out of LAX, which may have spurred new aircraft noise complaints. Mokulele Airlines uses Cessna Caravan turbopropellers, which are older and slower aircraft. LAWA had noted that FAA air traffic controllers appear to be setting a 5,000 feet altitude restriction for this airline when overflying the Peninsula (see Attachment C). The lower flying altitude for this noisier aircraft is a likely source for many recent resident noise complaints to LAWA’s aircraft noise complaint platform, www.lawa.org.laxanc. Southern California Metroplex Project: 2 In response to concerns raised by the Roundtable, in April 2017, the FAA began implementing its SoCal Metroplex Project, which is a regional redesign of the airspace over Southern California. The intent of Mextroplex was to redesign jet and turboprop flight paths with adequate spacing horizontally and vertically throughout the region. An outcome of this project was, among other things, to mitigate noise impacts. With respect to the jet aircraft departures from LAX towards the Peninsula, the SoCal Metroplex project did not change the flight routes where southbound and eastbound departing flights are routed over the ocean and away from the Peninsula. The FAA did, however, modify vector points or aircraft waypoints east of the Peninsula. According to the FAA, this is to provide a safe separation distance between aircraft. However, as reported by LAWA, after the implementation of the Metroplex project, Peninsula overflights more than doubled because, for many flights, FAA air traffic controllers were directing aircraft to leave their published flight route from a location approximately 10 miles offshore to destinations which took the aircraft over the Peninsula. LAWA staff compiles data of southbound jets, which depart LAX and are directed by the FAA to overfly the Peninsula. In February 2017, which was before the implementation of SoCal Metroplex, the number of vectored jets which overflew the Peninsula during the month was 198 (see Attachment D). In contrast, in February 2018, the number of vectored jets which overflew the Peninsula increased to 455 for that month. LAWA staff concluded that the reason for the Peninsula jet overflight increase is due to FAA air traffic controllers directing jets, for safety purposes, to a new waypoint location in Fullerton, which routes aircraft from a location west or south of the Peninsula. The previous waypoint, which has been eliminated by the FAA as part of the SoCal Metroplex, was a location near Seal Beach, which if followed, would route aircraft over the ocean instead of the Peninsula. A spike in noise complaints from concerned residents has resulted from the overflight increase this past year which prompted residents to question the legitimacy of the FAA’s concern for safe spacing of aircraft when jets are directed to fly over the Peninsula. According to Mr. Calvagna and others, it appears, that for the most part, there is no clear safety reason for routing flights over the Peninsula other than to shorten the duration of a flight (see Attachment G). At the March 14, 2018, Roundtable meeting, Mr. Calvagna presented information documenting the flights over the Peninsula and how drastically different these flight paths are from the Metroplex (an updated presentation will be provided by Mr. Calvagna at the May 1 City Council meeting). In response to the increase of Peninsula overflights, RPV Roundtable Staff sought and obtained the Roundtable’s support to send a letter to the FAA demanding the elimination of Peninsula jet overflights and to increase the overflight altitude of a specific turboprop carrier, Mokulele Airlines. Specifically, a motion was passed at the March 14, 2018, Roundtable meeting to draft a letter to the FAA demanding the following actions: • FAA air traffic controllers are to adhere to the published OSHNN8 offshore procedure (see Attachment E), which routes southbound jets from LAX around the Peninsula between 9 p.m. and 7 a.m.; 3 • When necessary for safe spacing, FAA air traffic controllers are to direct jets from the route OSHNN8 procedure beginning east of the HOLTZ waypoint (see Attachment E). This will allow jets to more closely follow the published jet route over the ocean and not overfly RPV and other communities; and, • FAA air traffic controllers are to raise the 5,000-feet altitude restriction on Mokulele Airlines’ Cessna Caravan turboprop overflying the Peninsula. LAX Roundtable Ad Hoc Committee: In November 2017, a Roundtable Ad Hoc Committee was created to further convey Roundtable recommendations to the FAA through letters and meetings. The FAA is anticipated to resume participating at the Roundtable meetings (the FAA stopped attending the Roundtable in November 2017), which Staff believes will help with communication between Roundtable recommendations and implementation with air traffic controllers. The RPV Roundtable staff motion at the March 14, 2018, Roundtable meeting was approved for the Ad Hoc Committee to draft a letter to the FAA, which will likely occur within the next few weeks. Reporting Aircraft Noise Information on aircraft noise related matters can be found on the City’s website under the Community Development Department homepage for Airspace Noise and Safety Concerns (http://www.rpvca.gov/274/Airspace-Noise-Safety-Concerns). Additionally, Roundtable updates are reported in the City’s Weekly Administrative Report, the City’s quarterly newsletter, and to list-serve subscribers. Jet and turboprop aircraft noise complaints originating and departing from LAX can be filed on the following platform administered by LAWA: • LAX Noise Complaints at https://www.lawa.org/laxanc/ Other aircraft noise complaints which are caused by low flying aircraft including small planes towing advertising banners, small planes carrying tourists, WW2 vintage planes, ultralight “flying lawnmotor” aircraft, are not administered by LAWA’s complaint platform as these aircraft are considered to be operating under the FAA’s General Aviation Rules. However, noise complaints or any other complaints attributed to low flying aircraft can be made to the airports where the aircraft has originated from or directly to operators of the aircraft. Both Torrance Municipal and Long Beach (LGB) airports provide noise complaint hotlines, respectively (310) 784-7950 and (562) 570-2665. With respect to commercially-operated helicopter noise complaints, noise reduction efforts have been led by the Los Angeles Area Helicopter Noise Coalition. The Coalition had recent setbacks when the FAA denied 4 petitions to regulate helicopter flight routes, minimum altitudes, and hovering time. Still, the Coalition monitors coastal area helicopter noise and safety issues and provides a website where noise complaints can be submitted, http://lahelicopternoise.org/complaints/. 4 Residents are also encouraged to attend and voice their concerns at the Roundtable meetings. The March 14th Roundtable meeting was attended by almost a dozen RPV residents. ADDITIONAL INFORMATION At the May 1, 2018, City Council meeting, Mr. Calvagna will be presenting a PowerPoint on the results of his independent monitoring of aircraft flights over the Peninsula and on his independent communication with the FAA (see Attachment G). The draft presentation is attached (see Attachment F). 5 artures at LAX with the understanding that the FAA controller may the quest or that the inboard runway may be closed during that ti • In Ma 014, Roundtable Facilitator provided a briefing on the L Preferential Runway e Report which examined the effectiveness of th referential Runway Use Policy LAX. The report indicated that adherence to e Policy continued to be high with o 90% of the operations complying wit e Policy and included recommendation o further improve adherence. Th report was prepared and submitted to Caltran as part of the Title 21 Nois • Status: Active Assigned Priority: mpac escription: High 9 10 Turboprop aircraft departing to the south with destinations to the east overfly the PV Peninsula and Torrance heading to the Seal Beach VOR. Areas Primarily Affected: Southern Sector (PV Peninsula, Torrance) Mitigation Activities: • In 2002, FAA has routed most turboprops off the PV Peninsula, with only ONT, PSP and SNA operations overflying communities. • Roundtable sent a letter to FAA, in May 2003, to request remaining aircraft to be routed offshore from Palos Verdes Peninsula. • Roundtable sent a letter to FAA, in February 2004, requesting the floor altitude of the Class B airspace to be increased near PV Peninsula. FAA did not make the requested change. • FAA established and implemented the HOLTZ, KARVR and OSHNN RNAV departure procedures, in late 2004, to move jet departures that would be flying the LAXX DP further offshore with the intent of possibly moving more turboprops over the ocean. • FAA developed a new RNAV procedure for turboprop aircraft called JEDDO in April 2008 to reroute turboprops further offshore from the PV Peninsula. Testing is required before the procedure can be utilized. FAA anticipated that the procedure will be active by April 2010. The JEDDO procedure will not reroute turboprops with destinations to ONT, PSP, and SNA. FAA will explore alternative options for these aircraft. 10 A-1 • In December 2010, Roundtable sent a letter to FAA to inquire the status on the JEDDO procedure. In January 2011, FAA responded to indicate that it decided not to implement the procedure because, through testing, it was not able to maintain aircraft separation between jets and turboprops without vectoring aircraft off the JEDDO route. However, FAA noted that it will explore other options such as redesigning the JEDDO procedure or creating an entirely new RNAV procedure for turboprop aircraft. • Roundtable's letter to FAA regarding OAPM (Metroplex) recommendations dated September 2012 included suggestions to 1) explore options of redesigning the JEDDO procedure that will meet all necessary requirements to allow full implementation of the procedure, 2) reroute the remaining turboprop aircraft that are currently overflying the Peninsula to offshores routes, and 3) if option 2 proves infeasible, then increase the minimum altitude of turboprop aircraft that overfly the Peninsula. • In October 2016, FAA confirmed the cancellation of the JEDDO procedure due to aircraft separation issues as noted previously in the FAA's January 2011 response letter. The FAA indicated that developing a new departure procedure for turboprop aircraft would require Class B airspace modification, which is outside the scope of the Metroplex project. Furthermore, the FAA indicated that the turboprop traffic at LAX has decreased significantly since SkyWest retired its turboprop aircraft in mid- 2015. • In July 2017, LAWA provided a preliminary analysis indicating an increase in lower altitude turboprop operations over PV Peninsula. This may have occurred due to Mokulele Airline's Cessna Caravan performance characteristics and an FAA altitude restriction in place for this aircraft type. LAWA is working with FAA to obtain a better understanding of this issue and plans to report back to the Roundtable at a later date with more information. Ongoing Actions: • LAWA to continue monitoring turboprop operations and provide statistical updates to the Roundtable. This update is currently scheduled for May and November of each year. Status: Active Assigned Priority: Low Js,,,['f;:''H45i·--r I I I J High 1 2 3 4 5 6 7 8 9 10 LAWA Workload: Medium of Aircraft n newly 11 A-2 Palos Verdes Peninsula -Turboprop Overflights llllS~ Los Angeles ~~ World Airports Monitoring southbound turboprops departing from LAX that overfly Peninsula .7 \... "'\ I ·' ~ ( "-,~ {, I lOml TI Note: Prior to SkyWest's fleet mix change (turboprop to jet) in early 2015, monthly southbound turboprops were ~800 and PV overflights were ~300. Arr iv als •Departures 0 Overflig hts ' Annual Comparison __..,_Southbound Turlx>props ---PV Overflights 14000 ~----------------------------~ en Q) 12000 ~ _w_z3_ -~·Ge99 :s 10000 t co g-8000 0 10072 -0 Q; 6000 ~--5862 ~ .j .0 § 4000 z 2000 ~- (14) -, a r =:t 17olf (11) (5) 0 +-----...,.-------,---------..-----~--...:........:..-~ 2012 2013 2014 2015 2016 ( ) = dai ly average l\/bnthly Comparison 400 ~Southbound Turboprops 350 -1 _ _ __ -· --1 ~PVOverflights en ~ 300 -11-----') :::I t ~250 Q) 0 200 -1--,,,,;!!!:. 0 ~ 150 11 63 ~ 100 -----------· z 153 50 -I ~--- ----------------------- 162 143 0 -I---~-~-~-~-~-~-~-~--,--~-~-~-__, Sep-Oct-Nov-Dec-Jan-Feb -Mar-Apr-May-Jun-Jul-Aug-Sep- 16 16 16 16 17 17 17 17 17 17 17 17 17 5 B-1 Turboprop Altitudes over PV Peninsula March 2017 to May 2017 300 .-------------------------------__ ] •Other Carriers 250 "' -:§> 200 -r 189 ;+:: "- Q) > 0 a.. 0 150 "-a.. 0 ..c "- :l I-..... 0 100 "-Q) ..c E :l z 50 0 d Los Angeles ~ World Airports 10 C-1 Pre/Post Metroplex Analysis of LAX Departures OSHNN/SEBBY Overflying Palos Verdes Peninsula (PV) Vectored Jet Jet Departures Vectored Jet II Departures Month-Year . ~· (OSHNN/SEBBY) Departures % Overflying PV I % Oct-16 2,450 1,865 76 .1% 200 8.2% Nov-16 1,984 1,607 81 .0% 166 8.4% Dec-16 1,979 1,542 77 .9% 220 11.1% 1,951 1.551 79.5% 19 1 1,876 1,213 64.7% 347 18.5% May-17 1,813 1,077 59.4% 442 24.4% Jun -17 2,366 1,338 56.6% 426 18.0% Jul-17 2,745 1,722 62.7% 562 20.5% Aug-17 2,528 1,540 60.9% 536 21 .2% Sep-17 2,166 1,320 60.9% 481 22.2% Oct -17 2,245 1,266 56.4% 381 17.0% Nov-17 2,313 1,297 56.1% 503 21 .7% Dec-17 2,000 1,198 59.9% 491 24.6% Jan -18 1,985 1,200 60.5% 23.3% Post-Metroplex Monthly Average 2,198 1,317 ,. 59.9% Ii 20.8% Note: Pre -Metroplex SEBBY and OSHNN departures were vectored SLI VOR; Post-Metroplex departures vecto e D-1 (50 (/) (/) II Zz ~z Om (/) - I G') ZI z--1 D-ATIS DEP 135 .65 CLNC DEL 120.35 327.0 CPD LC GNDCON (N) 121.65 327 .0 (S) 121.75 327.0 (W) 121.4 327.0 8 ~OG CIVVIJ ~o oi 8 ~OG 83.::1 ~o '£-MS TAKEOFF M INIMUMS Rwys 6L/R, 7L/R: NA-ATC. TOP ALTITUDE: 17000 LAS VEGAS LAS HAILO Q /~ ~\J\Jr;:,~/ IJ "-~u <-\JCS 0 ~(J ~'\ BEALE FABRA "' (',':) ~ 6 N ENNEY ''2\ 3000 640 AR*MY t;:J-!:::'" IJ / BLAZN '\<:Pr;:,~/ ::::o AANC 5000 ' 530 A~\ 251 ° ,~\ <f><:l <) ci"> ~ ~ i-2 53"~~i56"~--2517 = ':._.,&"<)/ 'C\~0 MI SE N ~ ~ $ (71 12) -<ID(;"EY"6:0-== GUNNR ,./"' NNrVY .:;g.'<§'/6 ~~/ WYZEE DOC KR 3000 640 /y ,<!? fj Cl#" ~ 3000 ~-L,.25)..'.'. 0 .§'0 / Cl \ ()<,\ N o;o-WEILR ~('J/T; == &fv ,'l (','\-s<f'P / ~o '-J m E: ""'O ~ )> '-J ;;:o -I c ;;:o m LOS ANGELES TOWER (N) 133.9 239.3 (S)l20.95 379 .l SOCAL DEP CON 124.3 363.2 (045°-224°) 125.2 263 .025 (225°-044°) Rwys 24L/R , 25L/R : Standard with minimum climb of 500' per NM to 640. ri,ri 64 <P -!:?'co~/ ~ 3000 _Q PlAYY ,,_cf"' A ~ C)J ~ RCUS /. q 0 ADORE ,.,<§:Po/ ,s<fl Oo (/) (/) II zZ z~ mo -(/) G') I IZ --IZ o~ m 2:J ""'O .,.. )> - ~ c ;;:o m ::::0 z ~ )> r- t-0 w '-J ~ HAY 1~'),~\ 5000 SEBB~C>'>\ \'I-";\ 5 ~ NK y \'l-0 NOff DME/ "' SHAEF ,ff' J NOTE: RNA DME/IRU or GPS . )> 0-..,_'l n'5 NOTE . V 1. required Z ~ :? -::~ <Y& 'RAD . C> > .-/ u>_ g ~ <§' ).{ '° NOTE· Th"A dR required. m z o '" o Cl <)/f; · " ep 5j " " '\. l ,~(\; Z(X)MM th e LO m!uce to be osed o I · z _§ ......_ l. Cl .f2' 16000 NOTE' Rwy; 2~~~:CKA DEPART;.r;,;Sunoble to u;e .:: £ PEVE~Jtao r§/ CAHIL NOTE~EVEE pdoct:=~~xpectRADARve 1 ~ Q (9?"......_ 7BOO ..,_Cl$<'> 15000 . A ~2 ot HllPR and ocx:KR '°' ta 5 Q,; <\JOL~078"-.){ {]' NOff MISE~p<>e<fon. me cequ;ced lac -~ > ' IBJ Yo TRANSITION R z - ---------SHNN NOTE· lAS complex . ce;tdcied ta a;cccaft I . ~ l\1 · HAILO/LAS/NN anding 0 ..- ( N AVY TRAN P' l)i ARRA TIVE ON SITIONS A TC o I _rn z FOLLOWING PA n y. n -i GE ) lo;:::: ,., t'"-1 ~> ~~ )> ..___, SW-3, 01 FEB 2018 to 01 MAR 20 18 D - 1 (50 (/) (/) II Zz ~z Om (/) - I G') ZI z--1 D-ATIS DEP 135 .65 CLNC DEL 120.35 327.0 CPD LC GNDCON (N) 121.65 327 .0 (S) 121.75 327.0 (W) 121.4 327.0 8 ~OG CIVVIJ ~o oi 8 ~OG 83.::1 ~o '£-MS TAKEOFF M INIMUMS Rwys 6L/R, 7L/R: NA-ATC. TOP ALTITUDE: 17000 LAS VEGAS LAS HAILO Q /~ ~\J\Jr;:,~/ IJ "-~u <-\JCS 0 ~(J ~'\ BEALE FABRA "' (',':) ~ 6 N ENNEY ''2\ 3000 640 AR*MY t;:J-!:::'" IJ / BLAZN '\<:Pr;:,~/ ::::o AANC 5000 ' 530 A~\ 251 ° ,~\ <f><:l <) ci"> ~ ~ i-2 53"~~i56"~--2517 = ':._.,&"<)/ 'C\~0 MI SE N ~ ~ $ (71 12) -<ID(;"EY"6:0-== GUNNR ,./"' NNrVY .:;g.'<§'/6 ~~/ WYZEE DOC KR 3000 640 /y ,<!? fj Cl#" ~ 3000 ~-L,.25)..'.'. 0 .§'0 / Cl \ ()<,\ N o;o-WEILR ~('J/T; == &fv ,'l (','\-s<f'P / ~o '-J m E: ""'O ~ )> '-J ;;:o -I c ;;:o m LOS ANGELES TOWER (N) 133.9 239.3 (S)l20.95 379 .l SOCAL DEP CON 124.3 363.2 (045°-224°) 125.2 263 .025 (225°-044°) Rwys 24L/R , 25L/R : Standard with minimum climb of 500' per NM to 640. ri,ri 64 <P -!:?'co~/ ~ 3000 _Q PlAYY ,,_cf"' A ~ C)J ~ RCUS /. q 0 ADORE ,.,<§:Po/ ,s<fl Oo (/) (/) II zZ z~ mo -(/) G') I IZ --IZ o~ m 2:J ""'O .,.. )> - ~ c ;;:o m ::::0 z ~ )> r- t-0 w '-J ~ HAY 1~'),~\ 5000 SEBB~C>'>\ \'I-";\ 5 ~ NK y \'l-0 NOff DME/ "' SHAEF ,ff' J NOTE: RNA DME/IRU or GPS . )> 0-..,_'l n'5 NOTE . V 1. required Z ~ :? -::~ <Y& 'RAD . C> > .-/ u>_ g ~ <§' ).{ '° NOTE· Th"A dR required. m z o '" o Cl <)/f; · " ep 5j " " '\. l ,~(\; Z(X)MM th e LO m!uce to be osed o I · z _§ ......_ l. Cl .f2' 16000 NOTE' Rwy; 2~~~:CKA DEPART;.r;,;Sunoble to u;e .:: £ PEVE~Jtao r§/ CAHIL NOTE~EVEE pdoct:=~~xpectRADARve 1 ~ Q (9?"......_ 7BOO ..,_Cl$<'> 15000 . A ~2 ot HllPR and ocx:KR '°' ta 5 Q,; <\JOL~078"-.){ {]' NOff MISE~p<>e<fon. me cequ;ced lac -~ > ' IBJ Yo TRANSITION R z - ---------SHNN NOTE· lAS complex . ce;tdcied ta a;cccaft I . ~ l\1 · HAILO/LAS/NN anding 0 ..- ( N AVY TRAN P' l)i ARRA TIVE ON SITIONS A TC o I _rn z FOLLOWING PA n y. n -i GE ) lo;:::: ,., t'"-1 ~> ~~ )> ..___, SW-3, 01 FEB 2018 to 01 MAR 20 18 E - 1 Rancho Palos Verdes City Council Meeting LAX Departure Overflights of Palos Verdes and San Pedro Comments by Jeff Calvagna Rancho Palos Verdes 1 May 2018 jcalvagna@netzero.com F-1 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 around 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 F-2  The FAA must follow its own documented procedures OSHNN8 Standard Instrument Departure (SID) Source of Most Palos Verdes and San Pedro Overflights OSHNN SID designed for noise abatement yet ATC routinely shortcuts noisy departures over PV and San Pedro Residential Neighborhoods 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. F-3 70% of OSHNN Departures shortcut over/near the PV Peninsula Graphic from the Metroplex Technical Report shows OSHNN Departures and prevalence of SID Shortcutting Note: Chart is prior to Metroplex change from SLI to CAHIL waypoint. Overflights now are much worse and head further inland. SID F-4 The OSHNN SID is a “Standard Departure” in name only FAA claims OSHNN is the “standard” departure to satisfy noise abatement requirements but doesn’t follow its own documented procedures OSHNN SID Adherence Typical patterns observed Jan-Feb 2018 GREEN – Adhere to the SID (20%) YELLOW – HOLTZ shortcut (20%) RED – PEVEE shortcut (60%) 60% 20% 20% Percentage of flights assigned OSSHNN that fly the SID versus those that shortcut over PV F-5 OSHNN Shortcuts – Jan 19th, 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 peak OSHNN usage aircraft can overfly PV every 2-3 minutes During this evening period, not a single flight correctly flew the SID, all shortcut over or near Palos Verdes F-6 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 28 FEB 27 FEB 26 Out of 12 flights, 8 overflew Palos Verdes/San Pedro (67%) 2 flew the SID (green), 2 HOLTZ shortcut (yellow), 8 PEVEE shortcut (red) F-7 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 27 FEB 26 FEB 25 Out of 12 flights, 8 overflew Palos Verdes/San Pedro (67%) 3 flew the SID (green), 1 HOLTZ shortcut (yellow), 8 PEVEE shortcut (red) F-8 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  Peninsula overflights are a minimum of 7.5 miles off the SID  If OSHNN truly “requires” this deviation 70% of the time then frankly it isn’t safe  This just isn’t credible. The NextGen Metroplex report didn’t even mention these deviations and recommended no changes to the OSHNN SID. The NextGen 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.” Why is This Happening? (ATC Vector “Direct CAHIL”) 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 F-9 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. Why is This Happening? (ATC Vector “Direct CAHIL”) F-10 Metroplex Analysis Predicted a Noise Decrease for South PV and San Pedro Pre-Metroplex Noise Model Post-Metroplex Noise Predict Difference between Pre- and Post-Metroplex Noise Model didn’t consider that the OSHNN SID is ignored >70% of the time South Palos Verdes and San Pedro predicted to see a small noise decrease. Instead, the opposite has happened. F-11 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 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 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. We Need Action NOW, Not More Studies! F-12 From:Ara Mihranian To:Robert Nemeth; John Alvarez Subject:FW: Palos Verdes SID shortcutting 4/22/2018 Date:Monday, April 23, 2018 9:47:46 PM FYI… We should add this as public comments. From: Doug Willmore Sent: Monday, April 23, 2018 6:12 PM To: Ara Mihranian <AraM@rpvca.gov>; Gabriella Yap <gyap@rpvca.gov> Subject: FW: Palos Verdes SID shortcutting 4/22/2018 From: Jeff Calvagna [mailto:jcalvagna@netzero.com] Sent: Monday, April 23, 2018 9:13 AM To: ian.gregor@faa.gov; richard.sullivan@faa.gov Cc: joey.apodaca@mail.house.gov; jacqueline.hamilton@mail.house.gov; Susan Brooks <SusanB@rpvca.gov>; CC <CC@rpvca.gov>; Robert Nemeth <rnemeth@rpvca.gov>; atm@laartcc.org; nickolas.christopher@faa.gov; allen.kenitzer@faa.gov; dennis.roberts@faa.gov; tamara.a.swann@faa.gov; brian.harmelink@faa.gov; michael.valencia@faa.gov; tracey.johnson@faa.gov; tom.hayes@faa.gov; david.keeling@faa.gov; Sherry.avery@faa.gov; Anthony.porras@faa.gov; jason.dedrick@faa.gov; gregory.haywood@faa.gov Subject: Palos Verdes SID shortcutting 4/22/2018 To: Ian Gregor - FAA Public Affairs Office Richard Sullivan - Air Traffic Manager, SoCal TRACON CC: Joey Apodaca - Staff, Congressman Lieu Jacqueline Hamilton - Staff, Congresswoman Bass Susan Brooks - Mayor, Rancho Palos Verdes Members - Rancho Palos Verdes City Council Robert Nemeth - RPV LAX Noise Roundtable representative Additional FAA personnel copied as noted at the bottom of this email Mr. Gregor and Mr. Sullivan, After several days of good adherence to the OSHNN8 SID, Air Traffic Control discipline completely broke down last night as LAX departures were continuously shortcut over the G-1 Palos Verdes Peninsula. Late Sunday night, (4/22), Air Traffic Control directed 22 LAX Departures to shortcut off the SID and overfly our community. Review of adjacent air traffic shows that none of these were required for aircraft separation. This illegal shortcutting must stop. Our noise monitor network recorded 18 separate noise events 20 dB or more above the ambient noise level. The OSHNN8 SID was designed for noise abatement and cannot be ignored simply because the Controllers find it inconvenient. This behavior is illegal as the FAA should realize, since it was recently sued by Laguna Beach, California for this exact same behavior. The January 2018 FAA settlement with Laguna Beach demonstrates that the FAA understands this. We also expect the FAA to follow its own published procedures, or we will take whatever steps are necessary to protect our community. Aircraft direct by ATC to shortcut the SID over the Palos Verdes Peninsula (PVP) late night on 4/22: 9:17 PM – SWA2543 (LAX – DEN), shortcut OSHNN8 11 miles west of SID over PVP 9:24 PM – SWA3012 (LAX-LAS) shortcut OSHNN8 11 miles west of SID over PVP 9:45 PM – DAL1506 (LAX-LAS) shortcut OSHNN8 10 miles west of SID over PVP 10:05 PM – AAL2685 (LA-LAS), shortcut OSHNN8 9.5 miles west of SID over PVP 10:50 PM - DAL877 (LAX-IND), shortcut OSHNN8 11 miles west of SID over PVP 11:01 PM – SWA2728 (LAX-LAS), shortcut OSHNN8 9 miles west of SID over PVP 11:21PM – WJA1103 (LAX-YYZ), shortcut OSHNN8 11 miles west of SID over PVP 11:23 PM – JBU988 (LAX-BOS), shortcut OSHNN8 10 miles west of SID over PVP 11:39 PM – DAL1106 (LAX-DTW), shortcut OSHNN8 11 miles west of SID over PVP 11:48 PM – UAL660 (LAX-ORD), shortcut OSHNN8 10 miles west of SID over PVP 11:53 PM – ASA1114 (LAX –IAD), shortcut DOTSS2 1 mile off PVP coast 12:05 AM – SWA2967 (LAX-DEN), shortcut OSHNN8 12 miles west of SID over PVP 12:08 AM – NKS128 (LAX-BWI), shortcut OSHNN8 10 miles west of SID over PVP 12:14 AM – AAL219 (LAX-ORD), shortcut DOTSS2 0.5 mile off PVP coast 12:20 AM, AAL2406 (LAX-DFW), shortcut DOTSS2 1 mile off PVP coast 12:27 AM – NKS658 (LAX-PIT), shortcut OSHNN8 10 miles west of SID over PVP 12:34 AM – DAL308 (LAX-CUN), shortcut DOTSS2 0.5 mile off PVP coast 12:43 AM – AAL1875 (LAX-CLT), shortcut DOTSS2 1 mile off PVP coast 12:50 AM – DAL1352 (LAX-DTW), shortcut OSHNN8 11 miles west of SID over PVP 1:03 AM – UAL910 (LAX-ORD), shortcut DOTSS2 1 mile off PVP coast 1:07AM – FFT408 (LAX-DEN), shortcut OSHNN8 11 miles west of SID over PVP 1:11 AM – ETH505 (LAX-DUB), shortcut OSHNN8 9 miles west of SID over PVP It should be noted that on the following Monday morning (4/23), SID adherence was again excellent. This disparate behavior indicates that this illegal shortcutting can be attributed to specific Controllers on duty at the time. The FAA must implement corrective action to ensure all Controllers understand that shortcutting aircraft over the Palos Verdes Peninsula is unacceptable, unless clearly required for safety. None of last night’s shortcuts fell in that category. Although I have corresponded with you for the last month, I have widened the distribution of this email to include additional FAA personnel. For their benefit, I will restate what we expect from the FAA: G-2 ATC will cease shortcutting OSHNN8 SID departures over the Palos Verdes Peninsula (PVP). ATC will not shortcut aircraft off the OSHNN8 SID (Direct CAHIL, Direct SEBBY) prior to reaching the HOLTZ waypoint. ATC will cease shortcutting DOTSS2 SID departures over/along the coast of the PVP. ATC will not shortcut aircraft off the DOTSS2 SID (Direct DOTSS, Direct EYEDL) prior to reaching the PEVEE waypoint. The FAA will implement effective corrective action and police the behavior of its controllers. While SID adherence has improved over the last month, these continued breakdowns demonstrate that specific Controllers require oversight from TRACON leadership. The PVP’s western location and protrusion from the coastline make our community particularly susceptible to LAX Departure noise events if the SIDs are ignored. This was why the SIDs were designed to keep aircraft a minimum of four miles of the PVP coast. They are not optional; they cannot be ignored simply because a Controller finds them inconvenient. Also, we have taken steps to ensure we have independent means to assess the FAA behavior in this regard: We have implemented an ADS-B/multilateration network on the PVP to compile our own flight track data and altitude data. We are compiling data on adjacent aircraft during shortcut events. We are rolling out a Peninsula-wide noise monitor network to continuously record and archive noise event levels. The first monitor is already online with the second going online next week. We are installing equipment to continuously record and archive ATC/aircraft communications by TRACON (both Del Rey and Coast areas) and the LA ARTCC. We are reviewing our legal options particularly in light of the Laguna Beach settlement. We are very serious about protecting our quality of life and we expect effective corrective action on the FAA’s part. These continued breakdowns demonstrate any corrective action to date has not been sufficient. Again, we invite both of you to attend the May 1st Rancho Palos Verdes City Council meeting (as this topic is on the agenda) to discuss the FAA’s behavior in this regard. Jeff Calvagna Rancho Palos Verdes, CA Additional personnel copied on this email: • Dennis Roberts, FAA Regional Administrator • Tamara Swann, FAA Regional Deputy Administrator Air Traffic Operation Western Service Area South • Brian Harmelink, Deputy Director of Operations WS (Renton, WA) Southern California District, Lawndale o Michael Valencia, Manager, Southern California District o Tracey H. Johnson, Assistant Manager, Southern California District G-3 Southern California TRACON, San Diego • Tom J Hayes, Manager, SoCal TRACON • Richard Sullivan, Air Traffic Manager, SoCal TRACON • David V Keeling, ATC Specialists Supervisor, SoCal TRACON LAX Air Traffic Control Tower, LAX • Sherry Avery, Manager, LAX Air Traffic Control Tower • Anthony Porras, LAX Air Traffic Control Tower • Jason P Dedrick, ATC Specialists Supervisor, LAX Air Traffic Control Tower Los Angeles Center (ZLA), Palmdale • Lisa Jones, Operations Manager, Los Angeles ARTCC (Honolulu) • Gregory Haywood, Air Traffic Manager, Los Angeles ARTCC (Palmdale) G-4