THE PROBLEM WITH THE FAA NEXTGEN PROJECT IN SOUTH … · San Juan Capistrano Dana Point Ladera Ranch San Clemente Mission Viejo Laguna Hills Aliso Viejo The following summarizes the

THE PROBLEM WITH THE FAA NEXTGEN

PROJECT IN SOUTH ORANGE COUNTY AND

A PROPOSED SOLUTIONPrepared 05/30/2017

CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US

Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente

Laguna

HillsAliso

Viejo

South OC in 2011 South OC in 2017

South OC in 2018

http://www.noplanenoise.us/

THE PROBLEM

THERE IS A PROBLEM WITH

NEXTGEN FLIGHT PATHS OVER

SOUTH ORANGE COUNTY


San Juan

Capistrano

Dana

Point San Clemente


THE PROBLEMWITH NEXTGEN FOR SOUTH ORANGE COUNTY


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

After viewing a variety of flight path changes between 1998 and 2017 along the PIGGN departure

route at John Wayne Airport, the most striking problem starts to show up in 2013 when the FAA

implemented Performance Based Navigation (PBN) procedures at John Wayne Airport per FAA Order

8260.58 dated 9/21/2012 (See Appendix C). Additionally, incremental changes continued to occur

between 2014 through 2017 as the NextGEN project was unrolled…even though the FAA states that

the official implementation of NextGEN was November 2016.

The 2016 FAA Environmental Assessment (“EA”) for the NextGEN project failed to

recognize obvious incremental environmental impacts from 1998 to 2017, including

most particularly the PBN flight path changes of 2013, and it failed to recognize new

flight paths at lower altitudes from SNA, LAX, LGB, and ONT in new areas

throughout South OC from the NextGEN fight paths. It also failed to mitigate those

environmental impacts (noise and air pollution).

The definition of PBN can best be summarized in lay terms by saying that, prior to the PBN

procedures, pilots determined the course of the aircraft based on air traffic control instructions and the

location of certain navigation aids. After the introduction of PBN, the aircraft position was controlled by

on-board computers using GPS or inertial guidance systems.

In 2013, the environmental impacts of the Performance Based Navigation (PBN) procedures took

effect. No environmental assessment was performed by the FAA until 2016 after the FAA issued FAA

Order 8260.58a dated 3/14/2016 (See Appendix D) when the 2016 NextGEN Environmental

Assessment was prepared. A Finding of No Significant Impact (“FONSI”) was issued in 2016 by the

FAA, but the FAA FONSI failed to consider the impacts of the 2013 PBN procedures.

The result of NextGEN was a concentration of planes over Dana Point and San Juan Capistrano at

lower altitudes and jets from SNA are cutting the corner across Laguna Beach, Aliso Viejo and Laguna

Niguel. Many of these facts were n\observed in April 2014 by the DRAFT ENVIRONMENTAL

IMPACT REPORT NO. 617 JOHN WAYNE AIRPORT SETTLEMENT AGREEMENT AMENDMENT

prepared by Mestre Greve Associates, a Division of Landrum and Brown, but ignored by the FAA in

the Environmental Assessment and FONSI (See APPENDIX B)


SUMMARY OF INCREMENTAL FLIGHT PATH

CHANGES IN SOUTH ORANGE COUNTY BETWEEN

1998 AND 2017


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

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Point

Ladera

Ranch

San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

The following summarizes the flight data in APPENDIX A showing flight paths in South OC

between 1998 and 2017.

• In 1998, very few jets flew over South Laguna Beach, South Laguna Niguel, Dana Point

and South San Juan Capistrano.

• In the year 2000, after the closure of the Marine Corps Air Station El Toro, there were

concentrations of jets starting to shift southerly over South Laguna Beach, Laguna Niguel,

and the north portion of San Juan Capistrano.

• In 2007, the central tendency was more jets starting to cut the corner over Laguna Beach

and South Laguna Niguel.

• In 2011, jets started to concentrate over north Laguna Beach, Aliso Viejo and Laguna Hills.

Very few jets flew over Laguna Niguel, San Juan Capistrano and Dana Point or South

Laguna Beach.

• In 2013, the environmental impacts really started to take effect as the FAA

implemented Performance Based Navigation (PBN) procedures.

• In 2017, jets are constantly cutting the corner of the PIGGN flight path crossing over

Laguna Beach, Aliso Viejo and Laguna Niguel, and there is a noticeable change in the

number of general aviation planes (smaller aircraft) crisscrossing South OC with jets

“concentrated” in Dana Point and San Juan Capistrano at noticeably lower altitudes than

previously observed.

NextGEN’s Environmental Assessment needs to properly study the incremental and

cumulative environmental impacts to South OC between 1998 (before El Toro Airport

closure) through 2013 (prior to PBN) and through 2017 (NextGEN).



Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

WHAT IS THE PIGGN DEPARTURE PROCEDURE?PIGGN is the name given by NextGEN to a waypoint to help navigate jet departures

from SNA over South Orange County. This “waypoint” system seems to have

started in 2009 at John Wayne. Altitude restrictions were added to the procedure to

deconflict with Airway V23 (which is a flight corridor between LAX and Mexico).

Now the jets are allowed by the air traffic controllers to cut the corner through

Laguna Beach, Aliso Viejo and Laguna Niguel at altitudes as low as 4,000-Feet.

PIGGN’s lateral tracks allowed by NEXTGEN are designed to fly under the LAX flight

path “DOTTS” and LGB Flight Path “FRITR”, which pushed PIGGN lower.


WHAT IS THE PIGGN DEPARTURE PROCEDURE?The PIGGN departure procedure for SNA jets directs the jets over the ocean and

towards the SHIRR waypoint at or above 7,000-feet and thence towards the PIGGN

waypoint at or above 9,000-feet.

Notice the Airway named V-23 from Mexico to LAX crosses through this area at

about 4,000-feet. As a result, the SNA jets must navigate over those lower flying jets.


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

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Ladera

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San Clemente

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Viejo

Laguna

HillsAliso

Viejo

Dana

Point

Ladera

Ranch

Laguna

Beach

Dana

Point


FINZZ DEPARTUREThe FINZZ is a departure procedure from SNA over the ocean and over Huntington

Beach. This procedure has the jets going over the coastline at over 10,000-feet and

continuing to rise to 15,000-feet


Laguna

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San Juan

Capistrano

Dana

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Laguna

HillsAliso

Viejo

Dana

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Ladera

RanchLaguna

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COMPARISON OF PIGGN AND FINZZFINNZ jets fly out 8-miles over the ocean and gain a higher altitude before they cross

over Huntington Beach at or above 10,000-feet, while the PIGGN jets fly out only 3-

miles over the ocean and the jets are at or above the 7,000-feet elevation at the

Dana Point shore line (which is too low and is causing noise and air pollution

impacts, and possibly harming bats and swallows in San Juan Capistrano). Also, the

jets that are cutting the corner at low altitudes over Laguna Beach, Aliso Viejo and

Laguna Niguel and are causing noise impacts and possibly harming sensitive wildlife

habitats in Aliso Woods Canyon and Laguna Coast Wilderness Park.


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

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San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

Dana

Point

Laguna

NiguelLaguna

Beach

Huntington

Beach


THE PROBLEM IS NOT JUST JOHN WAYNE!!Note that NextGEN involves plane flights from many regional airports, not just John

Wayne. Any change to the flight paths has to consider the impacts to the flights from

the other airports. Did the FAA consider the cumulative impact when they made

changes with NextGEN…it does not seem so, for example many helicopters and

many “loud” general aviation planes are noted to be flying lower in 2016 to avoid the

lower flying NextGEN jets.


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo


THE SOLUTION

HERE IS A SOLUTION FOR

NEXTGEN FLIGHT PATHS OVER

SOUTH ORANGE COUNTY


Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente


THE SOLUTIONFOR NEXTGEN FLIGHTS IN SOUTH ORANGE COUNTY


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

SOLUTION: Citizens for No Plane Noise recommends pushing the SNA departing flights using

PIGGN to over 10-miles out over the ocean and much higher. For example, SHIRR waypoint

should move 10-miles off-shore and the jets need to fly to 15,000-feet (currently 7,000-feet at

SHIRR) and then to 30,000-feet at the PIGGN waypoint (currently 9,000-feet). NO MORE jets

cutting the corner! Also the LAX to Mexico jets along the V23 Airway need to be pushed from

4,000-feet to over 20,000-feet since they are flying 24-hours a day.

The estimated noise for a Boeing 737 at Coast of Dana Point is as follows:

Jet at 7,000 feet = 85.00 dBJet at 15,000 feet = 76.48 dBJet at 20,000 feet = 74.00 dBJet at 25,000 feet = 72.00 dBJet at 30,000 feet = 70.46 dB

Existing SHIRR Waypoint at 7,000-feet to be moved further off shore

PIGGN Jets to be PROHIBITED from cutting the corner

Existing PIGGN Waypoint at 9,000-Feet to be raised to

30,000-feet

New SHIRR Waypoint at 15,000-feet at 10-

miles off-shore


APPENDIX A

FLIGHT PATHS BETWEEN 1998

and 2017 OVER SOUTH

ORANGE COUNTY


Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente


FLIGHT PATHS IN 1998

BEFORE EL TORO AIRPORT CLOSEDVery few jets flew over South Laguna Beach, South Laguna Niguel, Dana Point and

South San Juan Capistrano


Laguna

Beach

Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo



Laguna

Beach

Laguna

Niguel San Juan

Capistrano

Dana

Point

Ladera

Ranch

San

Clemente

Mission

Viejo

Laguna

HillsAliso Viejo

FLIGHT PATHS IN 2000

AFTER EL TORO AIRPORT CLOSEDConcentration of jets started to shift southerly over South Laguna Beach, Laguna

Niguel, and north portion of San Juan Capistrano



Laguna

Niguel San Juan

Capistrano

Dana

Point

Ladera

Ranch

San

Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

Laguna

Beach

FLIGHT PATHS IN 2007More jets started to cut the corner over Laguna Beach and South Laguna Niguel


WHO ARE THE CITIZENS FOR NO PLANE NOISE?


Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

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San

Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

Laguna

Beach

Flight Paths in March 2011Jets sated to concentrate over north Laguna Beach, Aliso Viejo and

Laguna Hills. Very few jets flew over Laguna Niguel, San Juan

Capistrano, Dana Point and South Laguna Beach.



Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San

Clemente

Laguna

HillsAliso

Viejo

Laguna

Beach

Mission

Viejo

“THE SMOKING GUN” - Flight Paths of Sept 2013In 2012, the FAA issued FAA Order 8260.58 (See APPENDIX C) which set forth Performance

Based Navigation (PBN) procedures ant it was implemented in 2013, but no environmental

assessment was performed. In 2016, the FAA issued FAA Order 8260.58a (See APPENDIX D)

as part of NextGEN and an Environmental Assessment was prepared in 2016 along with a finding

of “No Significant Impact”. Even so, these PBN procedures were already implemented in 2013 at

John Wayne Airport, and resulted in a concentration of planes over Dana Point and San Juan

Capistrano and jets started to cut the corner across Laguna Beach, Aliso Viejo and Laguna

Niguel. These Environmental Impacts to South OC were not studied.



Laguna

Niguel

San Juan

Capistrano

Dana

PointSan

Clemente

Aliso

Viejo

Mission

Viejo

Noise Impacts Over South Orange County Between

1998 and 2017 Need to be Studied

Many incremental changes in flight paths over South OC took place between 1998 and 2017 and were not

properly studied by the FAA. For example, look at ENVIRONMENTAL IMPACT REPORT NO. 617 for the

JOHN WAYNE AIRPORT SETTLEMENT AGREEMENT AMENDMENT OF 2014 which states: Federal

Aviation Orders 5050.4 and 1050.1E for Environmental Analysis of Aircraft Noise Around Airports.

The FAA has developed guidelines (Order 5050.4B) for the environmental analysis of airports. Specific

policies and procedures for evaluating environmental impacts are described in Order 1050.1E CHG 1, with

an effective date of March 20, 2006. The noise analysis related policies and procedures are presented in

Section 14 of the Appendix A of the Order. The Significant Impact thresholds are presented in Section 14.3

as follows: “A significant noise impact would occur if analysis shows that the proposed action will cause

noise sensitive areas to experience an increase in noise of DNL 1.5 dB or more at or above DNL 65 dB

noise exposure when compared to the no action alternative for the same timeframe. For example, an

increase from 63.5 dB to 65 dB is considered a significant impact. ”

Section 14.4c specifies that impacts to receptors with noise exposures between 60

and 65 DNL should be examined in accordance with the 1992 FICON (Federal Interagency Committee on

Noise) Recommendations.

“In accordance with the 1992 FICON (Federal Interagency Committee on Noise) recommendations,

examination of noise levels between DNL 65 and 60 dB should be done if determined to be appropriate

after application of the FICON screening procedure (FICON p.3-5). If screening shows that noise sensitive

areas at or above DNL 65 dB will have an increase of DNL 1.5 dB or more, further analysis should be

conducted to identify noise-sensitive areas between DNL 60-65 dB having an increase of DNL 3 dB or more

due to the proposed action. The potential for mitigating noise in those areas should be considered, including

consideration of the same range of mitigation options available at DNL 65 dB and higher and eligibility for

federal funding.

This is not to be interpreted as a commitment to fund or otherwise implement mitigation measures in any

particular area. (FICON p. 3-7).”

Section 14.5e specifies the supplemental analysis that should be performed for projects with study areas

that are larger than the immediate vicinity of the airport.

“For air traffic airspace actions where the study area is larger than the immediate vicinity of an airport,

incorporates more than one airport, or includes actions above 3,000 feet AGL, noise modeling will be

conducted using Noise Integrated Routing System (NIRS). For those

types of studies, NIRS will be used to determine noise impacts from the ground to 10,000 feet AGL. This

noise analysis will focus on the change in noise levels as compared to populations and demographic

information at population points throughout the study area. Noise contours will not be prepared for the NIRS

analysis. However, NIRS will be used to produce change-of-exposure tables and maps at population



Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

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San

Clemente

Mission

ViejoLaguna

Hills

Aliso

Viejo

Laguna

Beach

Flight Paths in March 2014Performance Based Navigation (PBN) procedures at John Wayne

Airport, implemented in 2013, show concentration of planes over

Dana Point and San Juan Capistrano. Also shows jets cutting the

corner across Laguna Beach, Aliso Viejo and Laguna Niguel.



Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San

Clemente

Mission

Viejo

Laguna

Hills

Aliso

Viejo

Laguna

Beach

Flight Paths in March 2016, “prior to NextGEN”Performance Based Navigation (PBN) procedures at John Wayne

Airport implemented in 2013, show concentration of planes over Dana

Point and San Juan Capistrano. Also shows jets cutting the corner

across Laguna Beach, Aliso Viejo and Laguna Niguel.



Laguna

Niguel

San Juan

Capistrano

Dana

Point

Ladera

Ranch

San

Clemente

Mission

Viejo

Laguna

HillsAliso

Viejo

Laguna

Beach

Flight Paths in March 2017, “after to NextGEN”Performance Based Navigation (PBN) procedures at John Wayne

Airport, implemented in 2013 show concentration of planes over Dana

Point and San Juan Capistrano. Still shows jets cutting the corner

across Laguna Beach, Aliso Viejo and Laguna Niguel and now many

more general aviation planes crisscrossing South OC. Clearly, the

NextGEN is resulting in more flights over South Orange County and is

concentrating jets in the area shown in blue. NextGEN’s

Environmental Assessment needs to compare the impacts to South

OC in 2011 (prior to PBN) to 2017 (NextGEN).


APPENDIX B

EXERPTS PERTAINING TO LAGUNA

BEACH FROM:

2014 DRAFT ENVIRONMENTAL IMPACT

REPORT NO. 617 JOHN WAYNE AIRPORT

SETTLEMENT AGREEMENT AMENDMENT

Prepared by Mestre Greve Associates, a

Division of Landrum and Brown















APPENDIX C

FAA ORDER 8260.58

9/21/2012



FAA ORDER 8260.58



APPENDIX D

FAA ORDER 8260.58a

3/14/2016



APPENDIX D

FAA ORDER 8260.58a



Documents

THE PROBLEM WITH THE FAA NEXTGEN PROJECT IN SOUTH … · San Juan Capistrano Dana Point Ladera Ranch San Clemente Mission Viejo Laguna Hills Aliso Viejo The following summarizes the