Regulatory Alert: AAAE Submits Comments on FAA's Research Efforts to Inform Aircraft Noise Policy
April 14, 2021
Today AAAE submitted comments to the Federal Aviation Administration (FAA) in response to a request for input on the research activities that the agency is conducting to inform future aircraft noise policy. As airports are aware, FAA recently released results from the agency's aircraft noise annoyance study, called the 'Neighborhood Environmental Survey' (NES), which showed a substantially higher percentage of people highly annoyed over a range of aircraft noise levels in comparison to the last study completed nearly 30 years ago. In light of the results, FAA has requested input from stakeholders primarily on what additional noise-related research should be conducted before FAA considers potential policy changes. 
Based on member feedback, AAAE shared additional areas of research that FAA should consider pursuing, including, among other things, further technical research into reducing noise at the source; new methods or tools to better communicate with community members; research on the impacts of non-aviation noise sources; and additional methods for using operational procedures to reduce noise impacts at specific airports. AAAE also emphasized that if FAA begins to pursue policy changes, there will be major implications for airports, especially financially, that need to be carefully considered and addressed. In addition, any potential policy changes must be part of a collaborative effort amongst FAA and all stakeholders and based on sound science and any additional research conducted.
Background. For several years airports have been anxiously awaiting the results of the agency's study on aircraft noise annoyance, which was initiated by FAA in 2015 to update existing evidence and understanding of the relationship between aircraft noise exposure and its effects on communities around airports. In January, FAA finally released results of the NES survey, which demonstrated a 'substantially higher percentage of people highly annoyed over the entire range of aircraft noise levels' in comparison to the last study completed in 1992. 
FAA emphasized to AAAE that publication of the NES is not a policy change. The agency indicated that they want to hear feedback from industry and conduct additional research before considering any updates to policy. Thus, in conjunction with the release of the NES results, FAA provided an overview of its ongoing research initiatives to better manage, mitigate and understand aircraft noise and requested feedback from stakeholders on its noise-related research portfolio. 
AAAE's January 12 Regulatory Alert provides more background information on the NES results and FAA's noise research portfolio and request for comments. 
Highlights from AAAE's Comments. FAA's request for input focused on two primary questions: (a) what factors may be leading to an increase in levels of noise annoyance, as demonstrated by the NES results; and (b) what, if any, additional research, analysis, and investigations should FAA conduct to inform potential changes to noise policy. In its comments, AAAE highlighted the following for FAA. 
Considerations for Future Noise Policy. AAAE provided feedback to FAA on the implications and major questions associated with changing aircraft noise policy, including the appropriate metric to measure noise exposure and the future of DNL 65 dB as the threshold; the roles and responsibilities of FAA and all stakeholders on how to address concerns most effectively; and the major financial implications for airports if additional mitigation measures would be needed.  
What's Next? As of today, FAA has received nearly 2,800 comments in response to its request for input. FAA indicated that they will be reviewing each of the comments, but not adjudicating them because this is not a formal rulemaking. However, if FAA decides to pursue policy changes based on the NES results and additional research, the agency will have to proceed through the rulemaking process, specifically to modify any of the standards associated with Part 150 airport noise compatibility programs. This process would take years to complete, include opportunity for stakeholder comments, and require any proposed changes to be subject to a cost-benefit analysis. 
Resources on the NES Results
Today AAAE submitted comments to the Federal Aviation Administration (FAA) in response to a request for input on the research activities that the agency is conducting to inform future aircraft noise policy. As airports are aware, FAA recently released results from the agency's aircraft noise annoyance study, called the 'Neighborhood Environmental Survey' (NES), which showed a substantially higher percentage of people highly annoyed over a range of aircraft noise levels in comparison to the last study completed nearly 30 years ago. In light of the results, FAA has requested input from stakeholders primarily on what additional noise-related research should be conducted before FAA considers potential policy changes. 
Based on member feedback, AAAE shared additional areas of research that FAA should consider pursuing, including, among other things, further technical research into reducing noise at the source; new methods or tools to better communicate with community members; research on the impacts of non-aviation noise sources; and additional methods for using operational procedures to reduce noise impacts at specific airports. AAAE also emphasized that if FAA begins to pursue policy changes, there will be major implications for airports, especially financially, that need to be carefully considered and addressed. In addition, any potential policy changes must be part of a collaborative effort amongst FAA and all stakeholders and based on sound science and any additional research conducted.
Background. For several years airports have been anxiously awaiting the results of the agency's study on aircraft noise annoyance, which was initiated by FAA in 2015 to update existing evidence and understanding of the relationship between aircraft noise exposure and its effects on communities around airports. In January, FAA finally released results of the NES survey, which demonstrated a 'substantially higher percentage of people highly annoyed over the entire range of aircraft noise levels' in comparison to the last study completed in 1992. 
FAA emphasized to AAAE that publication of the NES is not a policy change. The agency indicated that they want to hear feedback from industry and conduct additional research before considering any updates to policy. Thus, in conjunction with the release of the NES results, FAA provided an overview of its ongoing research initiatives to better manage, mitigate and understand aircraft noise and requested feedback from stakeholders on its noise-related research portfolio. 
AAAE's January 12 Regulatory Alert provides more background information on the NES results and FAA's noise research portfolio and request for comments. 
Highlights from AAAE's Comments. FAA's request for input focused on two primary questions: (a) what factors may be leading to an increase in levels of noise annoyance, as demonstrated by the NES results; and (b) what, if any, additional research, analysis, and investigations should FAA conduct to inform potential changes to noise policy. In its comments, AAAE highlighted the following for FAA. 
- Potential Factors for Increased Annoyance. AAAE discussed potential factors that are contributing to the change in how communities may be responding to aircraft noise, including population distribution and growth in areas near airports; work and lifestyle changes; increased traffic levels; and the heightened awareness of local and national noise issues due to social media and FAA's implementation of NextGen and Metroplex initiatives. 
- Additional Areas for Potential Research. AAAE shared feedback on additional areas of research that FAA should consider pursuing, including, among other things, further technical research into reducing noise at the source; new methods or tools to better communicate with community members; improvements to the Aviation Environmental Design Tool (AEDT) to make analyses more widely accessible and valuable; research on the impacts of non-aviation noise sources on annoyance; better understanding the relationship between noise impacts and annoyance levels; and additional methods for using operational procedures to reduce noise impacts at specific airports. 
What's Next? As of today, FAA has received nearly 2,800 comments in response to its request for input. FAA indicated that they will be reviewing each of the comments, but not adjudicating them because this is not a formal rulemaking. However, if FAA decides to pursue policy changes based on the NES results and additional research, the agency will have to proceed through the rulemaking process, specifically to modify any of the standards associated with Part 150 airport noise compatibility programs. This process would take years to complete, include opportunity for stakeholder comments, and require any proposed changes to be subject to a cost-benefit analysis. 
Resources on the NES Results
- AAAE's April 14 Comments to FAA on Aircraft Noise Research Activities 
- FAA's February 22 Webinar on the NES and Noise Research Portfolio 
- FAA Final Report, 'Analysis of the Neighborhood Environmental Survey' 
- FAA Summary of the Neighborhood Environmental Survey 
- FAA Federal Register Notice of Research Programs and Request for Comments 
- AAAE's January 12 Regulatory Alert on the Summary of Aircraft Noise Annoyance Study Results  
