we have demonstrated that a new "good neighbor" transport can be developed without destroying the inherent efficiency which has made our air transport system a mainstay of the national economy, and our aircraft the major element in sustaining our international balance of trade. I believe that the low certificated noise levels and our worldwide demonstrations of the L-1011 attest to the success of our efforts. We appreciate the opportunity which you have afforded us to contribute our thoughts toward rational legislation for improving the over-all acceptability of an airport within a community, and we recognize that more must be done. Addressing the points which you have outlined in your letter, we have the following comments: STATE OF TECHNOLOGY Knowing that we would have to work within the framework of legislation and regulations when we first addressed the problem of reduced aircraft noise, we, with the rest of the Industry, pointed out that it was impossible to create products with design lead-times of three to five years, followed by production durations of ten to fifteen years, against a "floating target" for required noise performance. Although our L-1011 has bettered current noise standards by several EPNdB, we see no reasonable way to achieve a 15 EPNdB improvement over Part 36 as your letter suggests. We have no promising clues to pursue and must await the results of research programs that have as yet not been formulated. The CARD Study done by the Department of Transportation suggested the possibility of 10 EPNdB below Part 36 might be possible in 1980. We believe that this is a reasonable target for certification of a new airplane, even though we still do not know how to achieve this goal with a practical design. In our efforts to set targets for incorporating improvements as the state of the art changes, the legislation should identify potential certification dates rather than new airplane delivery dates. It is not clear in your letter whether "new aircraft types manufactured after date of enactment . . ." refers to any new airplane or only to new airplane types certificated after enactment. If it means "all new aircraft manufactured" this will result in the shutting down of programs which fulfilled all regulations at their inception, and for which contracts have been entered into. SPECIFIC REQUIREMENTS FOR NEW AIRCRAFT Your suggestion that the regulations be lowered 15 EPNdB for any new aircraft type manufactured after date of the enactment of the legislation leads to major inconsistencies in the permissible noise levels of "old" and "new" aircraft. It would: a. Allow the manufacture and operation of older type airplanes indefinitely utilizing a refanned powerplant or modest suppression techniques only meeting Part 36 noise requirements. b. "New aircraft types", on the other hand, would have to meet a sound level 15 EPNdB below Part 36 by January of 1975. This would, in effect, force redesign of current wide-bodied aircraft now sold, all of which have utilized everything practically available in the state of the art to improve noise performance. In Lockheed's case, this [p. 40] would affect 100 to 200 airplanes which now are under firm contracts, or second buys, or additional follow-on airplanes from present customers. c. If your reference to "new aircraft types manufactured. . . ." actually means "certified" after enactment, there is still a major problem with new versions of present designs, such as twin conversions, longbodied modifications, extended range conversions, and similar models. These would all have to incorporate entirely new powerplants, and since we do not know how to meet a 15 EPNdB reduction, any such extension of our current models would be effectively stopped. RETROFIT Although Lockheed does not have current large transport aircraft which exceed the maximum noise level standards of Appendix C of Part 36 of the Federal Aviation Regulations, we recognize that most of the existing operational transports and some current production transports and business aircraft produce noise levels well above the regulations. We also recognize that the airlines are in no financial position to modify these airplanes, even if a powerplant existed which would bring them into full compliance. The extent of the problem is dramatized by the estimates of research and development for such a powerplant installation that vary between $100 million and $200 million. To this must be added retrofit costs that approach $2 million for each four-engine transport. It is our estimate that between 400 and 500 of these airplanes would still have a useful economic life by January of 1976, all of which suggests that development and retrofit costs might approach $1.25 billion to bring these aircraft into noise compliancea cost which the airlines and the aircraft manufacturers could not afford without major compensating increases in revenue. This estimate does not include retrofit of the smaller twin and trijet transports which would certainly average $300,000 to $500,000 per aircraft. We estimate that approximately 1300 of these would still have an economic future in January 1976, and retrofit of this number would therefore be nearly another $700 million. By introducing these costs, we do not wish to leave the impression that we oppose retrofit; we only want to emphasize the financial impact of the legislation which you propose, and to suggest that normal channels for financing such an endeavor do not exist to our knowledge. It is our opinion that the best approach to retrofit is by the use of a new fan on existing four-engine aircraft to increase the bypass ratio of the powerplants. We believe that the alternate concept of massive muffing of present powerplants which are inherently noisy leads to major cost burdens and inefficiency as well as excessive operational difficulties. This same comment holds true when the use of similar massive suppression is proposed to achieve the very last dB for more modern engines which are quiet to begin with. Modern high bypass engines could, indeed, be further suppressed, but the noise alleviation is so small that it probably would be unrecognizable by the community. Furthermore, it is obtained at a cost in operational economy which will make new aircraft unattractive to domestic investors and foreign purchasers alike. [p. 41] In summary, we recognize and applaud the natioanl emphasis on aircraft noise reduction. The Industry, without special financial assistance from the Government has made monumental efforts to respond, and is now delivering "quiet" aircraft which have retained the earning power to make them attractive to domestic and foreign airlines. The problem now is to bring the existing airline fleet into compliance with the new noise standards which have already been set. This will require Government financing in some form, and the dates for accomplishment must be compatible with this financial support to prevent a disastrous turmoil within our air transport system. We urge that the creators of new legislation recognize the strides we have made, and address the real problem of making our existing fleet suitable for the community. We also urge that the setting of goals for future development remain with the FAA (DOT), ably supported by the technical talent within NASA. Very sincerely yours, Hon. JOHN V. TUNNEY, D. J. HAUGHTON, Chairman of the Board. THE BOEING CO., Seattle, Wash., September 18, 1972. U.S. Senate, Committee on Public Works, DEAR SENATOR TUNNEY: Your letter of September 8, 1972, poses many complex questions that are of vital interest to all parties concerned with aircraft noise. The timing of your request and the complexity of the questions make complete answers difficult if not impossible. My first impression is that passage of a law with the language as suggested in your letter would inevitably bring air transportation, as we know it today, to a standstill. My second impression is that legislating technology and schedule of accomplishment is unsound. There exists today industry and government sponsored research work aimed at producing a valid decisionmaking base. It is not clear how new legislative acts can establish both levels and schedules for noise reduction before government and industry can develop the technology required to do the job. It seems there is risk of establishing a law that is not enforceable. Your proposal to require all aircraft landing at U.S. airports to meet Appendix C noise levels by January 1, 1976, could have a far reaching impact. It would stop a major portion of domestic and international air service. There is no apparent way the current JT8D and JT3D fleet of commercial aircraft could be retrofit or replaced by January 1, 1976, as you suggest, regardless of research and development funding or monetary support to the airlines. The suggested 15 EPNDB reduction by January 1, 1975, cannot be commented on unless the specific meaning of "new aircraft types manufactured after" is interpreted. If this includes 747, DC-10 and L-1011 aircraft types, it would stop production of these new quieter airplanes. If the requirement applies only to future new type designs, it would stop development of new designs until that required noise reduction technology could be developed. Although certainly later than 1975, the timing for this accomplishment is unknown and is completely dependent upon an adequately funded research program. In either case, [p. 42] the noise reduction capability to accomplish this objective does not exist today. Boeing is taking part in both the nacelle retrofit feasibility program and the new front fan program. Our original estimate for the required new front fan R&D was for about 130 million dollars. We most emphatically endorse pursuing the new front fan concept because of its great promise for meaningful noise reduction as well as airplane performance improvement. However, we are extremely concerned that a partially funded program will not produce timely results. As you may know, the Aerospace Industries Association (AIA) has been opposed to giving prime responsibility to the EPA for prescribing and amending aircraft noise standards. We consider it inadvisable and potentially dangerous to the traveling public, as well as those living under flight paths to give authority to a new agency to rule on matters that can affect flight safety. Today air transportation has an enviable flight safety record and no action should be taken that puts this in jeopardy. I share the frustrations that exist relative to the noise problem. Currently we have over 400 scientists, engineers and technicians at Boeing directly involved in noise reduction research and development. The attachment to this letter contains a summary of expenditures at Boeing since 1958 on noise reduction research. Över 43 million dollars of Boeing funds have been spent on this problem. Even though we have made significant progress through the use of these resources, the greatest lesson we have learned is that the problem is complex; and that simple, fast, inexpensive solutions do not exist. Although not answering your questions to the extent I'm sure you desired, I hope these comments might be of help to the Public Works Committee in their deliberations on this very significant legislation. My recommendation for alternate rule language would be to suggest funding programs at a level to accomplish noise reduction to the extent technically feasible and at the rate the Congress and the Nation desires. Note: Above expenditures do not include production development costs for airplane noise reduction activities totaling over $23,000,000. [p. 43] Hon. JOHN V. TUNNEY, MCDONNELL DOUGLAS CORP., DEAR SENATOR TUNNEY: I am writing in response to your letter of September 8 addressed to J. S. McDonnell, concerning provisions of the noise pollution control act (S. 3342) introduced by you and Senator Muskie. Clearly there is too much noise around airports and we are determined to do our part to help. The attached letter from Jack McGowen, President of our Douglas Aircraft Company, to Jack Shaffer, Administrator of FAA, in response to his request for informal comments on tentative FAA regulations in this area, is a good statement of our position. I would like particularly to emphasize that the current state of the art in technology makes it impossible to promise today that commercially viable airplanes and engines can be produced which generate far less noise than the requirements of F.A.R., Part 36, without cost and other penalties in excess of what the taxpaying public will accept. Research and development can undoubtedly improve our ability to produce airplanes which generate less noise, but there is no way to reliably evaluate the cost of reaching specific quantitative goals until after adequate research, development, testing and evaluation has been accomplished. I therefore urge that the government place great emphasis on expediting the necessary RDT & E so as to establish what is feasible, and only then stipulate dates when mandatory accomplishment will be required. The FAA has experience in regulations of this kind, whereas the EPA has little. We would urge that advantage be taken of such experience in establishing the requirements and their administration. McDonnell Douglas is devoting a great deal of attention to the problem of noise. If you or your staff would be interested in having one of our technical specialists provide a briefing covering the many complex aspects of this problem, I would be most happy to arrange it. Sincerely, KENDALL PERKINS. DOUGLAS AIRCRAFT CO., Hon. JOHN H. SHAFFER, Administrator, Federal Aviation Administration, DEAR JACK: Your letter of August 11, 1972, in which you discussed a notice of proposed rule making that would require noise levels 10 EPNdB below FAR Part 36 for future production aircraft, has convinced me that you take the airport noise problem as seriously as I do. I really believe we must think in such terms if we are to achieve an air transportation system that meets the requirements for compatibility with communities around our airports. I'm not suggesting that we know how to accomplish reductions which are in all cases as large as 10 EPNdB, nor am I suggesting that we could accomplish significant reductions by July 1, 1976. However, I believe that the industry and the FAA should get together to deter [p. 44] |