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14. Mohamad Ghazwan Majaj, Apt. 117, 2000 F Street, N.W., Washington, D.C. 20006, 783-1834; 727-2081 x117.
15. Athanasios D. Paroutsas, 2141 Eye St. N.W., Washington, D.C. 20006, 223-3859.
BERNARD COHEN'S ENVIRONMENTAL LITIGATION CLASS-RESEARCH ASSISTANTS (GWU)
1. Professor Allison Dunham, School of Law, University of Chicago, 1111 East 60th Street, Chicago, Illinois 60637, (312) 753-2453 (Law School), 753-4752 (The "Center"), No 7-1379 (home).
2. Alvin Greenwald, Esq., Greenwald & Bain, 6505 Wilshire Boulevard, Los Angeles, California 90048.
3. Professor Jan Z. Krasnowiecki, College of Law, University of Pennsylvania, 3400 Chestnut Street, Philadelphia, Pennsylvania 19104, (215) 594-7483.
4. Stephen I. Lingenfelter, Esq., Missouri River Division Office of Counsel (MRDOC), U.S. Corps of Engineers, New Federal Office Building, 215 North 17th Street, Omaha, Nebraska 68101, (412) 221-3047 (office), 572-1157 (home).
5. James B. Minor, Esq., 3104 Kent Street, Kensington, Maryland 20795, (301) 942-9397.
6. Professor Sheldon Plager, College of Law, University of Illinois, Champaign-Urbana, Illinois 61820, (217) 333-3098 (office), 367-2128 (home). 7. Raymond A. Shepanek, Esq., 6603 Beverly Avenue, McLean, Virginia 22101, 821-3400 (home).
8. David Standley, Esq., Executive Director, Boston Air Pollution Control Commission, Quincy Building, Room 84, Boston, Massachusetts 02109, (617) 227-4890.
9. Dr. Joseph Vittek, Jr., Esq., Deputy Director, Flight Transportation Laboratory, Dept. of Aeronautics & Astronautics, Massachusetts Institute of Technology, Cambridge, Massachusetts 02139, (617) 253-2261.
10. Nicholas C. Yost, Esq., Deputy Attorney General, State of California, 600 State Building, Los Angeles, California 90012, (213) 620-3473, 620-3030. 11. Robert D. Rudich, (formerly with National Transportation Safety Board), Air Transportation Consultants, P.O. Box 7351, Alexandria Va. 22307, (703) 765-7097.
12. Raymond A. Shepanek, Esq., (formerly with FAA), P.O. Box 277, 6603 Beverly Avenue, McLean, Va. 22101, (Office) 821-3400, (Home) 356-8110.
Senator CANNON. Dr. Clifton Von Kann, executive vice president of the Air Transport Association.
STATEMENT OF CLIFTON F. VON KANN, SENIOR VICE PRESIDENT, OPERATIONS AND AIRPORTS, AIR TRANSPORTATION ASSOCIATION OF AMERICA
Mr. VON KANN. Thank you very much, Mr. Chairman.
I will try to go through my statement briefly and skip as much as I can in the interest of saving time.
Senator CANNON. Your statement will be made a part of the record in full and you may summarize as you see fit.
Mr. VON KANN. Thank you very much, sir.
I will omit talking about the relations between the air transport industry, the airport and the local economy since Mr. Moore has already done that very well. I might mention a few words about the approach of the airlines in environmental matters and why we, ourselves, are rather frustrated members of this community.
Actually, we have very little control over airport locations and configurations, clear zones, or other land use factors. We have pleaded for better land use measures for some years now and I was very happy to see the interest of the committee earlier today in land
As a practical matter, though, there are only what I would call effective land use laws in two States, Minnesota and Iowa, and we would like to see stronger measures brought into play.
As far as the technology, we have no control over that, since the manufacturers develop it. We indicate what we want, and I will go into that in much more detail later on. I will exprsss concern in the course of my statement about the fact that more Government R. & D. is not being programmed for noise R. & D. because in the long run this is what is going to be needed to bring aircraft noise down to levels that are acceptable to the public.
We do have some control over the flightpaths that our aircraft use, subject to FAA regulations. I will have some more on that later.
In any event, the industry has been deeply concerned about the environment for more than 20 years. We have what we feel to be a good record of action in this respect and we feel that our policies are constructive.
We have statements of airline policies and airline reactions to my statements, if they can also be made a part of the record.
Now, I would like to talk about the problem in fairly precise terms. We have had some discussion about the fleet noise level rule. We have given a great deal of attention to this rule and while we have some differences on the technical aspect of the rule, it is nevertheless a useful tool to allow us to look at the overall fleet noise as it is today and to determine what it takes to get it down to the part 36 level.
I think that I can best do that by pointing to the eight charts at the end of my statement.
Do you have copies of that?
Senator CANNON. Yes.
Mr. VON KANN. I will sort my way through those, if I may.
Again, I now point out that we are talking about overall noise levels and I am not trying to claim that this is an exhaustive picture of all ramifications of aircraft noise. When you talk about fleet noise, you sometimes gloss over individual aspects. But, subject to that, I think this gives some indication of what the measures are to bring the fleet to the part 36 noise level.
The first figure-figure 1-indicates where we 1-indicates where we are today and largely it tells what part 36 says-where part 36 says we should be in terms of takeoff and approach noise and the actual fleet levels as we compute them today.
That is where we are.
Figure 2 indicates where we are going. At the left-hand side of figure 2 is figure 1, again, and next we show where FAR 36 will be in 1977 and where the actual noise will be and then we do the same thing for 1982.
Now an interesting thing comes up in this connection.
Since part 36 is computed on the level of gross weight, the level allowed under part 36 will go slightly over the years, and meanwhile, with the normal attrition that we estimate now, and with the replacement of four-engine aircraft with the wide-bodied and assuming that the new DC-8 powered aircraft, which we purchased, meet part 36, this chart indicates what is going to happen to the actual fleet noise over the next decade and, as you can see, the actual noise goes down although not nearly as much as any of us would like to
The gaps I have summarized on figure 3. This shows how far apart we will be in the takeoff and approach regimes from part 36 with the expected attrition and anticipated levels which FAR 36 will permit.
Now, as you can see, an interesting point here is that by 1982 the takeoff gap gets down to a rather small number of effective perceived noise decibels, but there is still a somewhat larger approach gap.
If you look at it in these broad terms, it leads you to believe that the big problem is in the approach regime, whereas this may not really be true, because this problem of jet roar on takeoff, even though it does not show in the numbers, may actually be a serious problem for the public.
Anyway, since we are doing this on a mathematical exercise, here, I will continue and talk now in terms of what might be done to bridge the gaps.
Now, figure 4, really, is the retirement strategy. This one assumes that we would replace our 707, our 720's and our DC-8's with wide-bodied aircraft on a 2 for 3 basis.
As you can see, this one solves the takeoff problem pretty well even by 1977. You would get your takeoff levels down and I think that the DC-10 and L-1011 is one of the reasons for this.
Now, on the other hand, you still have a gap in the approach regimes of about 32 EPNdB by 1978 and to 0.8 EUNdB by 1982. However, I call attention to the cost of this program. $5.3 billion for 1977 and $3.8 billion by 1982, so the costs are very high for the replacement strategy even though some time ago many of us thought that this was probably the way to go, but there is some considerable cost there in terms of the dollars involved.
Figure 5, now, gets into retrofit, or refanning, programs and as we know the R. & D. is still underway. The engineering estimate has not yet been verified, nor has the cost, but using the best estimate that we can get, I think that we can get a bona fide figure on that.
Again, I use the approach regime, because the way the numbers come out in the overall fleet noise formula, the takeoff gaps are very small.
We are looking now at the JT-3(d) aircraft, and if we were to retrofit those aircraft with the FAA quiet nacelles, the gap would be down to 3.6 EPNdB by 1977 and 2.9 by 1982. This still leaves a gap.
The other problem with this strategy is that the DOC's will be higher and the fuel specifics will not be as good. We then look at the possibility on figure 8-6, pardon me, of putting new front fans on the JT-3(d) aircraft.
This one is a little bit disappointing because that new front fan does more in the takeoff regime than in the approach regime and you can see that it does not do very much as far as cutting down the gap in the approach part. It costs twice as much to put on the FAA quiet nacelles. On the other hand, if some formula could be used where the improvement in the takeoff could be used in some tradeoff, where if you do better here, you can miss a little there. You can do a little better here, but you would not entirely close the gap.
So, the conclusions that you have to draw from what I have presented so far is that you cannot close the gap with a JT-3(d) powered aircraft only. There has to be something more than that that has to be done.
Now, we go to figure 7 and we look at the JT-8 (d) and in this figure we have both the retrofit and the refanning approaches shown.
The main points that come out of this chart is that either one of these also leaves a gap and in the case of the as a matter of fact, in 1977 the gap is larger and it is no smaller in 1982.
As you can see, from the cost here, the costs are relatively not too high for a retrofit, but they are extremely high for refanning.
But, the point is that with a JT-8 (d) fleet, you cannot do it alone either. So, that means that you have got to do something on the JT-3(d) powered part of the fleet as well as the JT-8 (d) and that is summarized on Figure 8 and if you retrofit both the JT-3(d)'s and the JT-8 (d)'s with the FAA quiet nacelles, you could not bring your numbers down to the Part 36 levels. The cost for the hardware only is somewhere in the half-billion dollar area and while you meet Part 36, you suffer penalties in the form of degraded performance, higher DOC's and higher fuel consumption and this is an interesting one with what is happening with the fuel these days.
This looks to us as if it would require that we use about 100 to 150 million gallons more a year. This is just a one to a one and a half percent increase in fuel consumption for these engines, but it looks like it would come in something like this, and that in turn means more engine emissions.
So, there are tradeoffs here anyway you go.
Now, to return to my statement for a few minutes here, if I may, and I will be resuming at around page 9.
Considerable doubt has been expressed that reduction of a fleet noise level to meet Part 36 would really provide meaningful relief to the public. In the absence of solid knowledge of what is meant by "meaningful relief" we have strongly recommended additional government R&D to learn more about the subjective reaction of people to noise, and how much reduction will achieve truly meaningful relief.
However, a recent Swedish study on takeoff noise published in 1972 indicates that in areas exposed to a high number of takeoffs, in
the neighborhood of 63 or more per 24 hours, noise will remain a significant problem as long as the noise levels from single takeoff overflights exceeds 73 db(A), which is roughly 86 EPNdB. Boeing studies on aerodynamic noise in the approach configuration show that this approximates 93-95 EPNdB on the 727 and 98-102 EPNdB on the 747.
Now, none of the suggestions, which I have gone through in these charts, will provide the relief that we believe may be necessary. It should be noted that, as we add more and more so-called "quiet" wide body jets, the fleet noise level allowed by Part 36 rises, as was indicated in Figure 2.
This is because that Part 36 allowables are based on gross weight. On the other hand, the fleet noise level rule does not take into account the benefit of noise reduction through the use of operational procedures. Our main purpose, and that of the government, should be to reduce the noise for the greatest number of people.
Meeting Part 36 noise levels at the specified measuring points does not necessarily accomplish this. Although, Mr. Skully's testimony indicated that the FAA has under consideration further out measuring points and I think this would be useful. At the same time, as we have depicted in Figure 9, a Boeing 727-200 aircraft executing a two-segment approach procedure can reduce the 90 EPNdB impacted area from 5.5 to 1.8 square miles, a 67 percent reduction.
It so happens that that will have a considerable beneficial effect right here in Inglewood. The same procedure would also reduce the 95 EPNdB impacted area from 2.1 to 1.0 square miles, a 48 percent reduction.
This is depicted in Figure 10, which is just schematic, but I think it makes a point.
So, it seems to me that these facts are trying to tell us something. Achievement of Part 36 FNL's will provide little discernable noise relief to the public. Because of the expense of modifying existing aircraft, there must be some question as to the cost/effectiveness of this approach, regardless of who pays the bill. If the achievement of the Part 36 FNL does not give the public meaningful relief, the result would be a loss of credibility by both industry and government. Improved operational procedures offer the greatest relief for the most people in the shortest time span. Our long-term efforts should concentrate on significant noise reduction on newly type certificated aircraft.
The manufacturers, in response to an FAA request, have indicated a reduction of 10 EPNdB below Part 36 Noise Standard constitutes a "desirable goal".
We think a better target might be 15 EPNdB. To reach this goal, however, improvements in basic aircraft design must be considered because we would now be approaching that level of noise which current aircraft would make in a power-off glide, in other words, aerodynamic noise.
This brings us back to the subject of research and development which we have emphasized over the years as the surest path to meaningful noise reduction. At the present time the Government is spending approximately $50 to $60 million on R&D. Although it is