Comment from Marcia Bullard

I am providing comments in support of those submitted by the Chair of the Palisades Community Association’s Aircraft Noise Committee and the District of Columbia’s Ward 3 member on the Metropolitan Washington Airport Authority’s Community Workgroup on noise at DCA. Overall, I agree with the comments submitted to the FAA to improve its Noise Portal. Many of these comments align with the objectives of ours and other community groups working with local airport management to establish “Fly Quiet (FQ)” programs. I am concerned that the FAA’s design of its Noise Portal is based on its outdated reliance on using the vintage 1970s “Schultz Curve” dose-response methodology to measure “community annoyance” based on average aircraft noise exposure. FQ programs recognize that noise concentration resulting from NextGen is not a “community annoyance,” but a potential public health hazard. The FAA’s own 2021 Neighborhood Environmental Survey (NES) recognized that it needed to update its noise analysis methodology to include more meaningful metrics. Accepting many of the noise metrics and analytics recommended by commenters aligns with the NES conclusions and could provide substantial support for building nationwide FQ programs. In addition, this assistance could reduce the need for roundtable groups to obtain funding from local government budgets; resulting in aggregate savings to taxpayers. Based on the FAA’s response to the submitted comments, it is obvious that the agency is trying to avoid additional work. I understand that its staff resources are stretched and that agency leadership is lacking. The FAA could, however, encourage airport authorities to fund SME resources to assist local community efforts to build FQ programs. The FAA could also utilize the FQ Roundtable-of-roundtables group as a clearinghouse for best practices regarding appropriate metrics and analytic methodologies. Moreover, coordinated collaboration and information sharing, such as FQ best practices, across community groups would help avoid airport authorities funding duplicative initiatives. Thank you.