Comments & Questions
Consultants' Responses

Responses to Comments/Questions Received
NOISE COMPATIBILITY STUDY GROUP MEETING #4

Comments and questions summarized at Study Group Meeting #4 were received on the Project Website, Project Information Line, and submitted on pre-addressed Project Comment Forms between October 1, 1999, and December 31, 1999. The following is a breakdown of the means by which comments were received:

     
Medium Total received
Website
16
Project Information Line
15
Project Comment Forms
0

The following is a breakdown of the type of comment and question received:

Type Total received
General aircraft noise complaints (GEN) 0
Flight tracks (FT) 5
Nighttime noise (NN) 15
Volume of aircraft activity (VOL) 10
Runway use (RWY) 7
Aircraft altitudes (ALT) 4
Aircraft/engine noise (ENG) 6
Interior noise levels (INT) 5
Land acquisition (ACQ) 1
Nonnoise related complaint/comment (OTH) 3
Study comments/suggestions (STD) 3
General questions or requests for study
information (INFO)
5


Note: Depending on content, some comments are included in multiple categories.

A map depicting the location of comments and questions received is provided on the following page.

Map

GENERAL AIRCRAFT NOISE COMPLAINTS (GEN)

No community members provided general/generic complaints regarding aircraft noise. Each comment/complaint received identified a specific annoyance, such as nighttime noise, aircraft altitudes, or volume of aircraft activity. A number of commentors did state, however, that aircraft noise is affecting their quality of life, communications and indoor activities.

    Response

    All noise complaints have been noted and are included in the graphic and statistical summary of noise complaints. Individual responses have been made by RAA staff. Summaries will be posted on the Project Website (www.sdfnoisestudy.com) and included in the Project Workbooks (Project Workbooks are located at each of the six Project Informa-tion Centers, or can be inspected at the RAA’s offices). In addition, specific Noise Compatibility Study Group (Study Group) committees may use this information to analyze potential noise abatement and noise mitigation strategies.

FLIGHT TRACKS (FT)

General Flight Track Comments/Suggestions

A number of community members commented on the disturbances caused by air-craft overflights. A number of commentors suggested that aircraft should operate away from their homes, or over nonresidential areas. One commentor stated that aircraft should be operating more to the west of Audubon Park. Another commentor stated that aircraft are located everywhere in the sky.

    Response

    Actual flight tracks obtained from an analysis of Automated Radar Terminal System (ARTS) flight tracking data were presented at Study Group Meeting #2, on July 29, 1999. ARTS data depict the actual flight tracks of aircraft along the ground as well as the altitude of aircraft departing from and arriving at the Airport. The FAA is responsible for the control of aircraft in navigable airspace and the operation of aircraft in the air traffic control system. Consequently, the RAA has no direct control over airspace management and air traffic control, including use of recommended flight tracks or runway usage. Potential flight track changes may be implemented, however, if included in a FAA-approved Noise Compatibility Program (NCP).

    Potential changes in departure and arrival flight tracks and the identification of flight corridors over compatible land uses, such as I-65, were examined in the assessment of potential noise abatement measures. Information provided by the ARTS data, future land use trends, graphic depictions of noise complaints, and input from Study Group committees was included in the analysis of potential flight track changes.

    It should be noted that changes to aircraft flight tracks typically result in a shift of aircraft noise exposure to other areas. Potential flight track changes were carefully analyzed in regard to their potential to increase aircraft noise exposure in other residential areas in the Airport environs. Based on future land use data (presented at Study Group Meeting #2 on July 29, 1999) large amounts of residential land uses are located in all areas adjacent to the Airport. Thus, it was determined that few additional noise abatement flight tracks in addition to the informal noise abatement procedures already in place, could be successfully implemented.

Existing Noise Abatement Flight Tracks on Runways 17R and 17L

One commentor asked why aircraft turn immediately after departure when departures on Runways 17R and 17L must maintain the runway heading for four miles before turning on course.

One commentor suggested that the 20-degree divergent takeoff heading on 17R is the primary cause of aircraft noise in the 40214 and 40118 areas (south of the Airport), and that all aircraft conduct this departure turn when using Runway 17R. This commentor suggested that noise in areas southwest of the Airport is caused by aircraft turning (diverging) to the right, since they "hang" in the area longer and lose airspeed. In addition, this commentor suggested that aircraft require additional power to takeoff and diverge, thus increasing noise levels.

    Response

    The Airport currently employs five informal (i.e. voluntary) noise abatement departure flight tracks that are documented in the Louisville International Airport Informal Runway Use/Noise Abatement Procedures (effective date December 1, 1997). The following procedures are intended for turbojet aircraft whenever wind, weather, traffic density, and airfield conditions permit.

    • Departures on Runway 17L—maintain the runway heading until reaching the Louisville VORTAC 270 degree radial before turning on course

    • Departures on Runway 17R—westbound aircraft shall maintain a 15 degree divergent heading (180 degrees) and eastbound aircraft shall maintain the runway heading until reaching the Louisville VORTAC 270 degree radial before turning on course

    • Departures on Runway 35R—maintain the runway heading until reaching 3,000 feet MSL before turning on course

    • Departures on Runway 35L—maintain a 15 degree divergent heading (330 degrees) until reaching 3,000 feet MSL before turning on course

    • Departures on Runway 29—maintain the runway heading until reaching 3,000 feet MSL or four nautical miles before turning on course

    Once aircraft reach prescribed altitudes and/or air traffic control fix, they may turn on course or operate in the heading indicated by air traffic control.

    Based on the above informal procedures, turbojet departures on Runway 17L and eastbound turbojet departures on Runway 17R are recommended to not turn until reaching the Louisville VORTAC 270 degree radial, which is located approximately three miles south of the Airport. Westbound turbojet departures on Runway 17R are recommended to turn to a 15 degree divergent heading (180 degrees) immediately after departure until reaching the Louisville VORTAC 270 degree radial. Based on an analysis of four weeks of ARTS data, the overwhelming majority of turbojet aircraft adhere to these recommended procedures. The procedures, however, are not recommended for turboprop and piston aircraft used by general aviation and air carrier operators.

    In regard to the comment that the recommended 15 degree divergent heading (180 degrees) on Runway 17R is the cause of aircraft noise in the 40214 and 40118 areas may be valid. As noted in the response to the previous comments, changes to aircraft flight tracks typically result in a shift of aircraft noise exposure to other areas. The degree to which modified noise abatement flight tracks decrease the projected number of persons affected by significant levels of aircraft noise will be assessed in subsequent aspects of the Study.

    Turbojet aircraft that perform the recommended noise abatement measures do not use additional power when departing. In addition, departing aircraft do not lose airspeed when performing procedure turns.

Aircraft Procedure Turns

One commentor inquired whether aircraft were staging or in a holding pattern when heading south from Louisville and turning west of the Airport.

    Response

    Although the exact type of operation this commentor is referring to is unknown, it is likely that arriving aircraft heading south and turning west of the Airport are being given east bound headings (or vectors) from the ATCT toward the Airport, and then initiating a turn to a base leg. Based on the analysis of ARTS data, many aircraft enter the Louisville airspace from the north or west at altitudes ranging from 5,000 feet to 7,000 feet above mean sea level (MSL). When arriving on Runways 35R and 35L, aircraft turn to a base leg between five and ten miles from the Airport.

NIGHTTIME NOISE (NN)

Evening and Nighttime Aircraft Operations and Sleep Disturbance

Many community members commented on nighttime and early morning aircraft operations. Commentors stated that nighttime aircraft operations begin at approximately 11:30 p.m. and continue until approximately 2:30 a.m.; and then occur again between 4:30 a.m. until 9:00 a.m. The volume and frequency of aircraft operations during evening hours was also mentioned.

Many community members commented on sleep disturbance and wake-up problems caused by aircraft noise.

    Response

    All nighttime noise complaints have been noted and are included in the graphic and statistical summary of noise complaints. Such information may be used by Study Group committees to analyze potential noise abatement strategies. In addition, sound attenuation strategies will be assessed during the analysis of potential noise mitigation strategies. An overview of research conducted in the field of sleep disturbance is included in Working Paper #1.

    Base case noise exposure contours (presented at Study Group Meeting #3 on October 15, 1999) account for existing and forecast levels of nighttime aircraft operations at the Airport. For existing 1998 conditions, nighttime aircraft opera-tions account for 39% of total operations. Air carrier and air cargo aircraft represent 10% and 62% of total nighttime operations, respectively. Nighttime aircraft operations are projected to account for 38% of total operations in 2005. Air carrier and air cargo aircraft are projected to represent 11% and 64% of total nighttime operations, respectively.

    Sound events that occur during nighttime hours are weighted in the calculation of day-night average sound (DNL) levels since (1) people are normally more sensitive to intrusive sound events at night, and (2) the background sound levels are normally lower at night because of decreased activity. To account for these factors, a 10 dB penalty is added to sound levels occurring between 10 p.m. and 7 a.m. This 10 dB penalty means that one nighttime sound event is equivalent to 10 daytime events of the same level.

    In addition, changes to the Airport’s existing informal runway use program are being analyzed as a potential noise abatement measure. The primary purpose of this assessment is to minimize the number of nighttime aircraft operations over noise sensitive areas. Information provided by the ARTS data, future land use trends, graphic depictions of noise complaints, and input from Study Group committees has been included in the analysis.

UPS Nighttime Operations

A number of community members commented on noise generated by UPS aircraft during nighttime hours.

    Response

    UPS operates their primary sorting hub at Louisville International Airport. The nature of a cargo sorting hub requires a nighttime sort so that parcels can be delivered during the following business day. Consequently, the majority of UPS aircraft operations occur during nighttime hours.

    Imposition of access restrictions to prohibit nighttime operations would require successful completion of a benefit/cost analysis under the provisions of FAR Part 161. Further, such a restriction would likely be challenged on a number of legal grounds, including federal preemption, unjust discrimination, and undue burden on interstate commerce.

    Changes to the Airport’s existing informal runway use program are being analyzed as a potential noise abatement measure. The primary purpose of this assessment is to minimize the number of nighttime aircraft operations over noise sensitive areas. Information provided by the ARTS data, future land use trends, graphic depictions of noise complaints, and input from Study Group committees has been included in the analysis.

Kentucky Air National Guard Nighttime Operations

A number of community members commented on noise generated by Kentucky Air National Guard (KYANG) aircraft during early morning hours.

    Response

    The KYANG bases operations at Louisville International Airport. KYANG personnel have stated that the KYANG does not conduct morning operations.

VOLUME OF AIRCRAFT ACTIVITY (VOL)

Volume of Aircraft Activity During Evening Hours

A number of community members commented on the volume of aircraft operations. Many commentors stated that aircraft operations occur every one to two minutes. Most of these comments regarded nighttime aircraft operations.

    Response

    This Study addresses all aircraft activity. Although limitations on aviation activity may be investigated as noise reduction measures, the RAA is not able to restrict access to the Airport without following established Federal regula-tions that require an analysis balancing the economic and environmental impacts associated with a proposed access restriction. Imposition of access restrictions requires the successful completion of a benefit/cost analysis under the provisions of FAR Part 161. Such restrictions would likely be challenged on a number of legal grounds, including federal preemption, unjust discrimination, and undue burden on interstate commerce.

Volume of UPS Aircraft Operations

A number of community members commented on the volume of UPS aircraft operations during nighttime hours.

    Response

    UPS operates its primary sorting hub at Louisville International Airport. The nature of a cargo sorting hub requires a nighttime sort so that parcels can be delivered during the following business day. Consequently, the majority of UPS aircraft operations occur during nighttime hours. One of the primary goals of this Part 150 Study is to minimize the impact of aircraft noise exposure, especially during nighttime hours. Although limitations on aviation activity may be investigated as noise reduction measures, the RAA is not able to restrict access to the Airport without following established Federal regulations that require an analysis balancing the economic and environmental impacts associated with a proposed access restriction.

RUNWAY USE (RWY)

Departures to the North on Runway 35R or 35L

One commentor inquired as to why aircraft were operating over the residential areas north of the Airport and not to the south over the more industrial land uses during morning hours.

One commentor inquired as to why aircraft were departing on Runways 35R and 35L between mid morning and 9:00 p.m. on November 24, 1999 when on-field weather reporting and National Weather Service (NWS) readings indicated that wind conditions were consistently below threshold values for operations to these runways.

Another commentor cited the time and type of aircraft departures over Parkway Village between 4:50 a.m. and 5:30 a.m.

    Response

    The reasons why FAA air traffic controllers direct aircraft to utilize Runways 35R and 35L on certain days or times is unknown without comprehensive and detailed information. The RAA and ATCT have agreed upon an informal runway use program designed to moderate aircraft noise over noise-sensitive areas. The following informal runway uses are documented in the Louisville International Airport Informal Runway Use/Noise Abatement Procedures, and are to be used to the extent possible by turbojet aircraft whenever wind, weather, traffic density, and airfield conditions permit:

      Daytime runway use

      Daytime 1 - Land on Runway 17L and depart on Runways 17R and 17L

      Daytime 2 - Land and depart on Runways 17R and 17L

      Daytime 3 - Land on Runways 35R and 35L, depart on Runway
      35R

      Daytime 4 - Land and depart on Runways 35R and 35L

      Daytime 5 - Land and depart on Runway 29

      Nighttime runway use

      Nighttime 1 - Land on Runways 35R and 35L; and depart on Runways 17R and 17L (Contraflow)

      Nighttime 2 - Land on Runway 17L and depart on Runways 17R and 17L

      Nighttime 3 - Land and depart on Runways 17R and 17L

      Nighttime 4 - Land on Runways 35R and 35L and depart on Runway 35R

      Nighttime 5 - Land and depart on Runways 35R and 35L

      Nighttime 6 - Land and depart on Runway 29

    The most preferred runway use configurations, Daytime 1 and Nighttime 1, are used whenever wind, weather, traffic density, and airfield conditions permit. However, it should be noted that during Daytime 1 and Nighttime 1 conditions, some arrivals or departures may occur from/to the north if they are against the general flow of operations. In addition, the ATCT directs aircraft to depart or land on specific runways based on actual on-field wind and weather conditions at the time the aircraft requests to depart or land. Runway use decisions are made by FAA air traffic controllers based on real-time weather, wind speed, and wind direction equipment in the ATCT. The NWS reported wind speed and direction information are derived based on a single sample of data taken during the hour.

    Changes to the Airport’s existing informal runway use program are being analyzed as a potential noise abatement measure. The purpose of this assessment is to minimize the number of aircraft operations over noise sensitive areas. Information provided by the ARTS data, future land use trends, graphic depictions of noise complaints, and input from Study Group committees has been included in the analysis.

Use of Runway 17R-35L

Two commentors stated that aircraft noise is louder since Runway 17R-35L was opened in December 1997. One commentor suggested that there has been an increase in operations on Runway 17R in the previous four months.

    Response

    It is likely that the opening of Runway 17R-35L caused an increase in aircraft activity in certain parts of the Airport environs—especially in those neighborhoods located beneath departure and arrival flight tracks to Runway 17R-35L.

    Preliminary review of actual aircraft operations data for the period from May 23, to June 19, 1999, indicates that approximately 37% of all aircraft operations (approximately 9,200 departures and arrivals) occurred on Runway 17R-35L, and approximately 62% of all aircraft operations occurred on Runway 17L-35R. The average annual use of these runways may be different since wind and weather conditions that occur throughout the year affect annual runway use. In addition, runways at the Airport are closed periodically by the RAA for required maintenance, such as painting, rubber removal, light pavement maintenance, FAA navigational aid maintenance, etc.—which may cause temporary increases in the use of certain runways.
    Changes to the Airport’s existing informal runway use program are being analyzed as a potential noise abatement measure. The purpose of this assessment is to minimize the number of aircraft operations over noise sensitive areas. Information provided by the ARTS data, future land use trends, graphic depictions of noise complaints, and input from Study Group committees has been included in the analysis.

AIRCRAFT ALTITUDES (ALT)

General Comments Regarding Aircraft Operations at Low Altitudes
A number of community members commented on aircraft operating at low altitudes.

    Response

    The altitudes of aircraft departing from and arriving at an airport are determined by a number of factors, including aircraft weight, payload, engine type, engine thrust, weather conditions, safety factors, and instructions provided by the ATCT. There is no "correct" height for aircraft operating from an airport on takeoff. For landings, aircraft follow a prescribed glide slope once established on the approach.
    A total sample of twenty-eight (28) days of ARTS data was analyzed for this Study to assess existing runway and flight track use at the Airport. ARTS data depict the actual flight tracks of aircraft along the ground as well as the altitude of aircraft departing and arriving from the Airport. Based on the analysis of ARTS data and experience analyzing such data at airports throughout the United States, the altitudes of aircraft operating in the Louisville airspace are typical of aircraft altitudes in terminal airspace.

    Changes in altitudes prescribed by FAA air traffic controllers to arriving aircraft are being analyzed as a potential noise abatement measure. The purpose of this assessment is to reduce the noise levels in the study area caused by arriving aircraft entering or operating in the Louisville airspace. Information provided by the ARTS data, future land use trends, graphic depictions of noise complaints, and input from Study Group committees has been included in the analysis.

AIRCRAFT/ENGINE NOISE (ENG)

Two comments were provided in regard to aircraft that were "screaming". Both commentors suggested that these aircraft were producing noise not typical of jet aircraft. One commentor stated that Grand Aire operates an aircraft at Louisville that causes significant departure noise.

    Response

    Standard air carrier, air cargo, commuter, and general aviation aircraft operate from the Airport. The cause of the "screaming" sound referred to by this commentor is unknown.

    The Airport Noise and Capacity Act (ANCA) mandates that all aircraft exceeding 75,000 pounds meet FAR Part 36 Stage 3 noise standards by December 31, 1999. Aircraft exceeding 75,000 pounds currently operating at the Airport are certified under FAR Part 36 as Stage 3. However, some B-727 aircraft may have been re-certified as a Stage 3 aircraft using hushkits, re-engined, or technological upgrades. These types of aircraft may generate the "screaming" sound referred to by this commentor.

A number of community members provided comments regarding ground noise, especially during late night (10:00 p.m.) and early morning hours (4:00 a.m.). These commentors suggested that ground noise was generated by aircraft engine run-ups.

    Response

    Ground noise is typically attributed to aircraft engine run-ups conducted for maintenance, aircraft ground movements, and the use of reverse thrust to slow aircraft immediately after touchdown.

    The Airport currently has engine run-up restrictions in place. Under this program, all run-ups are conducted during daytime hours and currently take place on Taxiway F, located in the center of the airfield north of the UPS facilities. The RAA has plans to construct a permanent run-up location on the southwest corner of the Airport, adjacent to Runway 17R-35L. Nighttime run-ups require the advanced approval from the RAA.

INTERIOR NOISE LEVELS (INT)

Many members of the community commented on interior noise levels. Most com-mentors stated that aircraft overflights disrupted conversation and other indoor activities such as watching television. Other commentors mentioned that they were compelled to leave windows closed.

    Response

    All noise complaints have been noted and are included in the graphic and statistical summary of noise complaints. Sound attenuation measures will be assessed during the analysis of potential noise mitigation strategies. An overview of the effects of noise exposure on people is provided in Working Paper #1, FAR Part 150 Noise Compatibility Study Overview.

LAND ACQUISITION (ACQ)

One community member stated that since the RAA purchased and relocated Minor Lane Heights, why not purchase and relocate the homes located beneath the departure flight tracks north of the Airport.

    Response

    The ongoing land acquisition program was included in the previous Part 150 Study. The intent of the current program is to acquire the residential homes generally located within the DNL 65 noise exposure contours identified in that study. At this time, additional acquisition cannot be justified by the RAA until this Part 150 Study is complete.

NON-NOISE RELATED COMPLAINT/COMMENT (OTH)

Garbage Dumping

One commentor expressed concern regarding illegal dumping that is occurring on the land between Crittenden Drive and what was Louisville Avenue.

    Response

    These comments are noted. Illegal dumping activities are not included in the scope of this Study. However, the RAA has taken steps to abate this activity.

Property Damage

One community member expressed concern regarding perceived damage to rooftops of residences in the Airport environs caused by aircraft fuel dumping.

    Response

    At present, there is no evidence to support the notion of localized effects of pollution or residue from aircraft engines. Independent studies conducted for other airports in the United States found that residues collected by local residents were not from jet fuel. Studies conducted in the Louisville area indicate that dark spots or stains on residential rooftops originate from a type of mildew characteristic of the region. It should be noted that, except in rare emergency situations, aircraft do not dump fuel from their fuel tanks. Fuel dumping for emergency purposes normally takes place at high altitudes away from residential areas.

Noise Berm

One community member inquired as to the implementation of a noise berm to decrease aircraft ground noise.

    Response

    The use of sound barriers, including noise berms, to mitigate noise nearby the Airport will be considered as part of this Study. Sound barriers will be examined during the analysis of potential noise abatement measures. Data obtained from the noise monitoring program, input from Study Group committees, and information provided by the summary of noise complaints will be included in the identification and screening of such measures.

STUDY COMMENT/SUGGESTIONS (STD)

One community member suggested a location for noise monitoring.

    Response

    The noise monitoring program for this Study was conducted during May and June 1999. In accordance with the Study Group Charter, focused committees such as the Noise Monitoring Committee have a key role in evaluating techni-cal elements of the Study and making decisions. In regard to the selection of noise monitoring sites, the Noise Monitoring Committee met on April 29, May 6, and May 26, 1999 to discuss technical materials provided by the consultant team and select a total of ten noise monitoring sites. The ten sites selected by the Committee were endorsed by the Study Group on May 26, 1999, and provided to the consultant team that evening.

    No additional noise monitoring is planned for this Study. A permanent noise monitoring system may be recommended in the final NCP. In this event, the location for permanent noise monitors would be identified.

    The results, location of noise monitors, and dates/times that noise monitoring took place will be posted on the Project Website (www.sdfnoisestudy.com) and included in the Project Workbooks (Project Workbooks are included at each of the Project Information Centers).

One community member suggested better advertisement of the Project Website

    Response

    The address for the Project Website (www.sdfnoisestudy.com) has been advertised at each Study Group meeting, is provided on the RAA’s meeting announcements, and is included on all meeting advertisements included in the Louisville Courier Journal. In addition, the address has been provided on numerous occasions as part of televised news stories about the Study.

One community member suggested announcing the times when certain runways will be used.

    Response

    This comment is noted. Expansion of the existing Project Website to communicate information such as actual runway use and scheduled runway maintenance will be considered in later aspects of this Study.

GENERAL QUESTIONS OR REQUEST FOR STUDY INFORMATION (INFO)

Requests for Information

Some community members asked how to participate on Study Group committees.

    Response

    Participation on Study Group committees is open to any member of the community. Committee sign up sheets are provided at Study Group meetings. Dates and times for Study Group meetings are announced on the Project Website (www.sdfnoisestudy.com). In addition, the RAA mails future meeting announcements to all study participants. To receive meeting announcements in the mail, please provide your name and address on the sign in sheet provided at all Study Group meetings, or call the RAA at (502) 368-6524, Ext. 119.

Technical Questions

One commentor asked what areas would be included in this Study.

    Response

    The specific study area for this Part 150 study is generally bound by the Ohio River (including some parts of southern Indiana) to the north, Bowman Field to the east, Brooks Hill Road to the south, and the intersection of I-264 and Dixie Highway to the west. However, potential noise abatement measures will be assessed for their potential to reduce noise exposure levels in areas outside of the specific study area boundary. A description of land uses and noise sensitive facilities located within the study area was presented at Study Group Meeting #2, and is currently provided on the Project Website (www.sdfnoisestudy.com).

One community member inquired about divergence waivers provided by the FAA.

    Response

    Diverging heading departure flight tracks are required by the FAA for simultaneous departures on parallel runways, and are currently in use on Runways 17R and 35L. The Environmental Impact Statement prepared for the Louisville International Airport Improvement Program (LAIP/EIS) suggested that the FAA be requested to waive the departure divergence requirement on the parallel runways. However, this waiver was not approved. The Consultant Team is unaware of any airports in the United States that have departure divergence waivers.

Miscellaneous Requests

A number of community members requested that RAA or Consultant Team members contact them individually to discuss problems associated with aircraft noise.

    Response

    RAA staff and members of the Consultant Team are available to speak with any member of the community regarding aircraft noise at Study Group meetings. In addition, the designated chair of each Study Group committee may call designated members of the consultant team with technical or other questions at any time. Community members wanting an individual response to a noise event are encouraged to call the RAA at 368-6524, extension 119 during business hours.

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