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1.0 Quality of Life
2.0 Process
3.0 Economics
4.0 Limits
5.0 Safety
6.0 Right to Vote
Sandra Olliges
NASA Ames Research Center
Safety, Health, and Environmental Services Office
M/S 218-1
Moffet Field, CA 94035-1100
| Contents: 1.0 Quality of Life 2.0 Process 3.0 Economics 4.0 Limits 5.0 Safety 6.0 Right to Vote | ||||||
Sections: 1.1 Cargo Jets are Noisy 1.2 Proposed Flight Schedules are Incomplete and Misleading 1.3 Our Quality of Life Should Not be Sacrificed for Private Gain 1.4 Noise Contours Understate Deleterious Effect of Jet Noise 1.5 There are no Safeguards Against Worsening Noise 1.6 NEPA Regulations are not Being Followed
What will be the flight path for each flight scheduled into Moffett
Field? Over the Bay? Over the community? What alternative flight paths can
be used and when will use of them be triggered? [EA9606]
The regular flight path at Moffett Federal Airfield has the aircraft
approaching North over the City of Sunnyvale on Runway 32 and departing
over the Bay. In the early morning hours, however, there is little air traffic
over the Bay. There would also be little conflict with the traffic of other
regional airports during this time, particularly because San Jose International
Airport does not open until 6:30 am. NASA is therefore working with the
FAA to have most of the aircraft approaching Moffett between 10:00 pm and
6:30 am use Runway 14, or the Bay approach. Potential CRAF cargo operations
would fly in primarily between 4:00 am and 7:00 am. [EA9606]
You say that all cargo jets would be "class 3", the quietest
jets. How does this compare with SJC? What proportion of its' jets are in
class 1, 2, and 3? In response to another question, NASA said
that listening to jets at San Jose airport would be a poor indicator of
future noise at Moffett because San Jose doesn't have only class 3 jets.
What guarantees that only Stage 3 jets will be used? [EA9606]
While some of the carriers still have Stage 2 aircraft remaining
in their fleet at this time, MFA policy will prohibit such aircraft from
landing at or departing from MFA, except in extraordinary circumstances?
[EA9606]
If you really believe that your cargo jets are so quiet, put it to
a test. Land a 757 at Moffett every day at 6:30am, and then one day land
it at 4:00am. Don't tell anyone, supporters nor opponents, what day will
be the 4:00am day. See whether people notice. See whether the 6:30am flights
are as quiet as you say or as noisy as we fear.
Claims are misleading that "only 2% of night-time flights will
be over the city". They neglect to count landings between 6:30 am and
7:00 am, classified by the FAA as "night", 100% of which will
be over the city. There needs to be an accurate accounting of the proposed flight schedules,
not just vague statements of "so many flights between 4 and 7".
You must have made your best estimates of what types of planes would fly
at what times on what dates, in order to have calculated the CNEL noise
contours. Show us that data. If it's too voluminous to include in the EA,
summarize it there and put the complete information on your Internet web
site, and in city libraries. Seasonal variations in weather will make some months much worse.
In December they estimate 14 landings over the city between 4:00am and 6:30am.
That's one wakeup in the wee hours every other day. How steep would be the cargo jets' rates of ascent and descent? How
do those compare with ordinary passenger jets at SJC? What will be the altitude
of the cargo jets when they are over North Sunnyvale? South Sunnyvale? Cupertino?
Saratoga? Monte Sereno? Los Gatos? A few altitude and peak noise levels were put up on the overhead projector
in one of the public meetings on the draft EA, but were not distributed
to the public. NASA said the information would be made available to anyone
who wanted it.
It seems that 2% is a small number to some people, but a big number
to others. We are being asked to accept the fact that only 2% of the time
we can anticipate aircraft on approach over our homes. However, when asked
whether the air cargo carriers through a NASA policy, could choose to divert
to another location for the 2% of the time that the weather required them
to approach over the city, the answer was no, it would be too costly. NASA assumes that all residents have air conditioning and wish to
use it year-round, despite the Bay Area's mild climate. Their noise assessment
assumes that residents' windows are closed 24 hours a day, 365 days a year.
The residents have very little interest in helping the the cargo
carriers bottom lines at the expense of our peace and quiet.
The noise contours are averaged over 24 hours. A cargo jet going
overhead is as loud as a lawnmower three feet away. That's not very loud
when averaged over 24 hours, but when a lawnmower goes through your bedroom
at 4 am, you're going to be awakened. One resident says, "My house is not on even on the map released
by NASA, however any time aircraft are overhead we have to pause in our
conversations because we can't hear each other." One resident says, "All of NASA's noise contours assume that
noise below 65 or 60 decibels is acceptable. My neighborhood never shows
up at those levels, but a P-3 or C-130 overhead means we can't hear each
other." Simply stating that the activity is below that of the Navy does not
mean that it is acceptable to the community. The community tolerated the
Navy flights out of patriotism, but our sense of patriotic duty to the armed
forces doesn't extend to Federal Express Navy peak operations were more compatible with the community than
the proposed air cargo. Navy planes were loud, but very seldom flew over
the city at night: maybe 4 times a year, not every night as proposed by
NASA. With CRAF the total number of flights may be lower than the Navy peak,
but the number of nuisance flights looks to be much higher.
How can NASA restrict air cargo to specific morning and evening times
with the existence of a Federal law which negates such restrictions on airports
and air traffic? [MV9604] What authority does the City have with regard to damages or violations
of any such agreement on the air cargo companies' behalf?[MV9604]
The draft EA uses 2010 as the comparison year, and assumes that nothing
will change in regional air traffic other than Moffett operations until
that time. Yet it is very likely that by 2010 San Jose will complete its
master plan, at which time it will lose its' grandfathered exemption and
its' ability to enforce a night curfew, and will move toward 24-hour operations.
If flights from San Jose are taking off to the north, the FAA may determine
that it's unsafe for planes to land at Moffett from the north. How many
flights would it take for that to become a serious consideration? Furthermore,
what if San Francisco and/or Oakland also increases their night and early
morning landings? A cargo jet can also land over the city at night if the pilot requests
it of air traffic control, e.g. to save some time.
The proposal uses the wrong baseline [Appendix
2]. Baseline means NOW. NASA's draft environmental assessment uses a
baseline assuming that without air cargo, government flights would increase
back to historical levels, though NASA admits there is "no way we
could approach that". This violates the requirements of the National
Environmental Protection Act, and invalidates NASA's central claim that
anything no worse than peak Navy activity causes "less than significant"
impact. The report of the 1991 Base Realignment and Closure (BRAC) Commission,
which recommended the closure of Moffett Naval Air Station, "found
that ground and airspace encroachment at Naval Air Station Moffett Field
and quality of life problems for Navy personnel in the San Francisco Bay
Area are significant." That is, the first part of the sentence says
that the level of Navy air activity in 1991 was too much for the area.
From the time it was first reported, officials kept saying don't
worry, there is no firm proposal, nothing will happen for years, the press
is just hysterically stirring things up without cause. Then, suddenly it's
a done deal. No alternatives can be considered, there's a very short time
line for reviewing the proposal, and criticisms are out of line - we should
have spoken up much sooner. When did NASA first discover that there was
a "firm proposal" - indeed that it was NASA's own proposal, and
that it had a very short time line for review and comment? When was this
information first communicated to Mountain View and Sunnyvale officials?
From the time it was first reported, city officials kept saying that
they had no say on the subject and were just being consulted by NASA out
of courtesy. However on June 17, 1996, for the first time, NASA admitted
that it had no statuatory authority to operate CRAF air cargo. Such authority
would require special enabling legislation from Congress, which would be
extremely unlikely without the support of the cities in the area. When did
NASA first discover that special legislation would be required, and when
was that information first communicated to Mountain View and Sunnyvale officials?
Why were no alternatives considered by NASA? Why is no discussion
of alternatives allowed by the City of Sunnyvale? Initially you claimed
the reason for your failure to consider alternatives was that they would
require special legislation. But now you admit that the air cargo proposal
itself will also require special legislation. [SV9606]
So I ask again, why are no alternatives considered? The Presidio precedent should be followed. A base redevelopment can
support the needs of the community, federal agencies, and the environment,
while making money. Other uses of Moffett Field, such as corporate jets and an air museum,
should be explored.[MV9604] Is the City aware of any groups interested in Hanger 1?[MV9604]
The combined use of Moffett Field for a museum/airfield should be considered.
Combined uses do not exclude other potential uses of Moffett Field.[MV9604]
Community input regarding the future of Moffett Field should be encouraged.
The City should consult with the community.[MV9604]
You say that CRAF operations at Moffett are important to maintaining
the nation's airlift capabilities. How many additional aircraft will each
of the carriers commit to CRAF as a result of access to Moffett? [NA960701-2]DHL: Could not say there would be any specific commitment.FedEx: Did not answerUPS: Did not answerLt. Col. Heisel, USAF: We estimate that one to three additional aircraft
will be committed.
You say the CRAF program needs additional airlift capacity. You say
in the only activation of the CRAF program - the Persian Gulf War - about
100 CRAF airplanes were used. [NA960701-2].
However, the CRAF Internet web site [CRAF]
says "As of fiscal year 1996, 32 carriers and 547 aircraft were
enrolled in the CRAF. This includes 368 aircraft in the Long-Range International,
111 aircraft in the Short-Range International, and 49 and 19 aircraft, respectively,
in the Domestic and Aeromedical sections." Why do you need more
than five times the capacity of the largest airlift operation in history?In taking positions on the future of Moffett Field, there should be
broader input from the community.[MV9604]
At the meetings NASA acknowledged that there was high public interest
in the CRAF proposal. This is contradictory to their position that this
is not a controversial issue and that an EA will suffice rather than an
EIR/EIS. It is also inconsistent with a FONSI (finding of no significant
impact). Who initiated this proposal? The Air Force? NASA? Or the cargo carriers?
[NA960701] NASA Who is paying for the environmental assessment? [SV960710]NASA Do you expect to be reimbursed for that cost if the air cargo proposal
is approved? By whom? Who will bear the cost if the air cargo proposal is
not approved? How much has been spent by NASA on the air cargo proposal
to date, and how much is budgeted for these activities?Mountain View city channel 3 has been posting the position that the
city cannot control the process, but this seems inconsistent with NASA's
assertion that the process will not go forward without the blessing of the
Mountain View and Sunnyvale City Councils.
NASA doesn't even know what the Moffett Airfield deficit is from year
to year due to unpredictable Federal budgets. The stated deficit of $3.5M
is only 0.5% of Ames' budget. When NASA took over from the Navy, a NASA/Ames
planner said "it would cost NASA about $10 million a
year to run the airfield, a small fraction of the Ames Research
Center's budget." [MN910411,
emphasis added]. Why is $10 million a small fraction and $3.5 million an
insupportably large fraction? NASA doesn't know how much money (if any) will be raised by air cargo.
You keep claiming that you cannot even make a rough estimate of how much
money air cargo will bring. I can make an upper bound estimate based on
your figures: Air cargo could bring at most $500-900 thousand per year initially,
increasing to no more than $1.8 million by the year 2010. [Appendix
3] If these figures are not correct, provide corrected estimates in
the final EA.Since air cargo will not come close to meeting Ames' needs, why will
you not work with the community to find other alternatives which could bring
much more?When local leaders supported NASA taking over Moffett from the Navy
that support was based on NASA's misleading information. [Appendix
1] . Important details of airfield operating costs are missing. No assessment has been made of the income potential of other redevelopment
alternatives, e.g. the Presidio concept. NASA and Sunnyvale almost came up with plans for privatization and redevelopment
of Moffett, but shelved the plans when NASA said it could operate the airfield
for less money, and keep out commercial aviation. [MN910906]
What happened to that plan? In the final EA, provide a copy of the November
1990 working memo from NASA/Ames to Sunnyvale City Manager Thomas Lewcock,
discussing the plan to raise $5 million per year from an air and space museum
at Hangar One. No consideration has been made of economic impacts to the community,
e.g. depressed real estate values, lost wages and taxes. You claim that industry needs overnight package delivery for economic
vitality. Silicon Valley ships an increasing portion of its' products over
the Internet. Cargo carriers claim they need Moffett to serve Silicon Valley, butwithout
air cargo at Moffett "the valley is growing faster than at any time
in 12 years... Measured by jobs, Santa Clara County grew at a faster clip
in the last 12 months than any other major metropolitan area but Atlanta,
which is preparing for next month's Olympics." [MN960630]. Oakland,
San Francisco, and San Jose have plenty of capacity. Pre-dawn landings are
useful only for "next business morning" packages, not for "next
business day" packages. Cargo carriers want to land at Moffett in the
middle of the night only because San Jose protects the quality of life of
its' citizens with an airport noise curfew Why is it that NASA can keep CRAF/CAMI monies but cannot keep rent or
other monies from a museum? Either you can keep non-appropriated monies
or you can't. If CAMI is not permitted to compete with local airfields, how can CRAF/CAMI
be used to divert existing business from Oakland, SJC, or SFO to Moffett?
Also, under this prohibition on competition, how can CRAF/CAMI offer longer
operating hours than the nearest competing airport? You can see the effects of jet overflights
by looking at the flight path of San Jose airport: boarded up houses and
bulldozed lots. With cargo jets overhead every day at 6:30 am, every night
at 11:00 pm, and occasionally at 4:00 am, there will be economic impacts.
Who will bear the costs of these impacts? Who will pay for soundproofing,
for vacant houses, for bulldozed condominiums? SJC "expects to retrofit
the impacted homes at an average cost of $25,000 each." [SJCweb]
"About $75 million has been spent to acquire 620 parcels to date."
Who will bear the risk of lost real estate value around Moffett? If as you
say the cost will be zero, then NASA, the air cargo companies, and the city,
should be glad to guarantee that zero cost. You should guarantee to buy
out any resident at current market value, who is forced to move by your
cargo jets. But if the cost is too high for you to bear, then why are you
asking private citizens to bear it instead? [SV9606]
Mayor Parker: I can certainly tell you the city of Sunnyvale is not
going to bear those costs. Maybe the cargo carriers would like to speak
for themselves. Mountain View: No answer DHL, Federal Express, UPS: No answer NASA: No answer. However Suzanne Petroni of NASA claimed that where
San Jose has boarded up houses, Moffett has open water of the bay.
If NASA gets statuatory authority for civil aviation at Moffett Field,
there's little to stop it from growing far beyond the bounds of this proposal.
There is no regulatory oversight. The proposed 11,200 flights would be bad enough for our quality of life.
But if that doesn't make enough money to satisfy them, they could without
any additional approvals, increase to 60,000 cargo flights by replacing
government flights with commercial cargo flights, as agencies relocate to
other areas. The projected 2% of nighttime flights over the city would be bad enough.
But if weather, safety considerations, or increased traffic warrant, they
could without any additional approvals, divert any or all of nighttime flights
over the city. The projected schedule of nighttime and early morning flights are bad
enough. But if the cargo carriers demand it, they could without any additional
approvals, fly jets overhead any time of the day or night. This air cargo proposal could be just the foot in the door for all types
of commercial aviation at Moffett, with general aviation next. No, it would be much harder to get the special legislation to authorize
general aviation at Moffett than to authorize air cargo. San Jose keeps
asking [NASA] and we keep telling them no. There are also many passenger airlines in the CRAF program. If CRAF
is allowed at Moffett, what would prevent future expansion into commercial
passenger operations in addition to air cargo? [NA960701-2]Moffett Airfield doesn't have the passenger facilities required to operate
commercial passenger liners, and we don't intend to build such facilities.
The airport can only be used by airplanes with 20 (or 30?) passengers or
fewer.
Will 12 safety waivers be transferred to air cargo?[MV9604]
The draft EA details the safety waivers under U.S. Navy airport design
criteria which were transferred to NASA.
In two advisory votes by both Mountain View and Sunnyvale, citizens
voted overwhelmingly against civil aviation at Moffett. Other cities which will be impacted by air cargo noise have not been
invited into the hearing process. Monte Sereno has adopted a proposal against air cargo. The public should be provided the opportunity to vote on air cargo at
Moffett Field.[MV9604] There should
be two advisory measures on the November ballot in each city.