Action: The Burbank Glendale Pasadena Airport Authority (BGPAA) has applied to the Federal Aviation Administration (FAA) to impose an airport noise and access restriction by establishing a mandatory nighttime curfew at
BGPAA position: BGPAA states that its goal is to “eliminate or to significantly reduce nighttime aviation-related noise at the airport, now and in the future, to provide meaningful nighttime noise relief to the communities it serves.
TIACA’s view: Because of the discriminatory nature of the proposed curfew, because it is not a reasonable action in light of all factors, and because of its potential adverse impact on the national airspace and aviation system, TIACA urges the FAA to reject BGPAA’s application for a nighttime curfew. We believe that a continuation of the current voluntary curfew is a better way to balance the interests of the many stakeholders affected by this application, meet the statutory requirements facing the FAA, and comply with the ICAO balanced approach guidelines endorsed by the
The proposed curfew fails to meet the statutory conditions which FAA must use to conduct its evaluation
As detailed in the Federal Register notice in which FAA announced its review of the BGPAA position, the FAA must base its review of BGPAA’s proposal on six statutory conditions (the conditions are specified in the Federal Register notice and are published in 14 CFR part 161, section 161.305). As discussed below, TIACA believes the proposed curfew fails to meet the nondiscriminatory and reasonableness standards set by Condition 1. It also would jeopardize efficient use of navigable airspace, as required by Condition 3, and could contribute to an undue burden on the national aviation system (Condition 6).
The only aircraft currently operating at
In addition to discriminating against all-cargo operators, TIACA also believes that the proposed curfew fails to meet the reasonableness standard also required of Condition 1. It should be noted that there are many legitimate and compelling reasons for operating aircraft during overnight hours. These include overall fleet and flight structure; infrastructure constraints; timing efficiencies; and customer needs with respect to dropoff and delivery.
BGPAA contends that the few operators affected by the curfew would simply shift their operations to nearby airports. TIACA believes that the current nighttime operations at
Furthermore, BGPAA notes that it has achieved a 95% compliance rate through its voluntary efforts to restrict flights during overnight hours. Additionally, all aircraft flying into
If FAA were to approve a curfew at
BGPAA’s proposed curfew would not adhere to ICAO’s “balanced approach”
TIACA strongly supports the “balanced approach” guidelines developed by the International Civil Aviation Organization (ICAO) to address airport noise management issues. The
BGPAA has proposed a 9-hour daily curfew to limit airport noise, but has not fully considered alternative options that might minimize noise impacts and have less severe consequences. TIACA believes that a continuation of the current voluntary curfew approach, local sound abatement program, and encouragement of airline measures to pursue noise abatement would better address