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As part of the hundreds of pages of documents that the FAA released in its initial environmental report last spring, the agency published an extensive "Aircraft Noise Technical Report" with projected sound level changes for more than 12,000 individual grid points within the NorCal Metroplex. The data included hundreds of stats corresponding to specific geographic locations within Point Reyes and Golden Gate National Recreation Area, the two parks most impacted by regional flights.
Although multiple NPS officials had urged the administration to closely consider potential impacts on federally protected wilderness areas, the FAA's raw data provided no comprehensible explanation of the projected effect on national parks. Instead, the FAA relied on the same sound formula it used to model noise increases throughout the region — average airplane noise over the course of 24 hours.
Even after the NPS made formal requests, the FAA refused to disclose how many commercial jets currently fly over the national parks within the metroplex and how that number would change through its NorCal project. This is despite the fact that federal law requires the FAA to provide a "clear, accurate description of the potential environmental impacts" and respond to public comments, whether from a private citizen or another federal agency.
Gregor, the FAA spokesperson, also declined my repeated requests over several weeks for historical and current data on the frequency of flights over Point Reyes National Seashore.
In the absence of basic flight frequency data, Rocchio was forced to do her own analysis with the limited numbers available. She and NPS mapping experts plotted each projected change in noise levels in the affected national parks. The resulting map was troubling: Some of the quietest parts of Point Reyes would experience huge increases in jet noise for a wilderness area — five to seven decibels above current levels. While the eastern portion of the park, along with the very western tip of the Point Reyes peninsula, would experience some decreases in airplane noise, the central part of the park — including a significant portion of sensitive habitat known as the Phillip Burton Wilderness Area — would see a big jump in disruptions.
The NPS "is concerned that rather than reduce or eliminate potential overflight impacts, the project may simply shift the impacts to new areas of the park and Phillip Burton Wilderness," wrote Christine Lehnertz, the then-NPS Pacific West regional director, in an April 2014 letter to the FAA.
"You would not build a freeway offramp in Point Reyes National Seashore," said Michael McEneany, a resident of Inverness, a small town adjacent to Point Reyes. "So why on God's green earth would you propose building an aerial freeway right through the middle of the wilderness area? It's absurd." McEneany spent a decade serving as the Marin County representative on the Oakland Airport Community Noise Management Forum, an advisory group within the airport, and has long argued for reductions in jet noise around Point Reyes.
The FAA, however, concluded that the decibel increases at Point Reyes were insignificant. That's in large part because the FAA's metrics don't consider how noise increases are particularly harmful in quiet, natural habitats. On the contrary, the FAA, as an official practice, does not even consider jet noise impacts in areas with an existing background soundscape of less than 45 decibels — a baseline level that is very quiet. Many wilderness parks have natural sound levels in the 30–40 decibel range. The FAA essentially argues that it's pointless to analyze plane noise impacts when an area is already so quiet and thus easily disturbed by minor noise increases.
But in practice, that means the FAA effectively allows unlimited noise increases in the quietest wilderness habitats. And that allows the FAA to claim an increase of six decibels is not environmentally significant — even though research shows that this intrusion in nature slashes the size of the area in which wildlife can hear by 75 percent, and thus substantially impacts some animals' abilities to communicate.
"We feel like the wilderness here deserves more protection — that really was our goal," said Rocchio. "But rather than reduce or eliminate [the noise], it actually increased." Rocchio argued that it was misleading for the FAA to not openly disclose this huge noise increase in a national park — and even more frustrating when the agency responded to the NPS by dismissing its concerns and simply restating that its plan would have no significant impact.
"They didn't want anyone to see this," Rocchio said, referring to the NPS-generated map showing the concentrated region of five-to-six decibel noise increases in Point Reyes. "A picture is worth a thousand words, and it still didn't help."
The FAA also refused to answer the NPS's questions about whether the NorCal project would result in fewer aircrafts flying in "holding patterns" over Point Reyes — meaning when jets fly in circles waiting to land. Historically, flights en route to SFO have frequently engaged in holding patterns over the park, which can exacerbate noise pollution. But the FAA stated in its environmental assessment that holding patterns are based on traffic, weather, and other factors and that it could not provide any specifics on the current or future use of this strategy in the Point Reyes area. Gregor also declined to provide this data to me, but confirmed that the FAA's new procedures still allow jets to go into holding patterns over Point Reyes.