Post on 09-Oct-2020
THE PROBLEM WITH THE FAA NEXTGEN
PROJECT IN SOUTH ORANGE COUNTY AND
A PROPOSED SOLUTIONPrepared 05/30/2017
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Laguna
HillsAliso
Viejo
South OC in 2011 South OC in 2017
South OC in 2018
THE PROBLEM
THERE IS A PROBLEM WITH
NEXTGEN FLIGHT PATHS OVER
SOUTH ORANGE COUNTY
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
San Juan
Capistrano
Dana
Point San Clemente
THE PROBLEMWITH NEXTGEN FOR SOUTH ORANGE COUNTY
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
After viewing a variety of flight path changes between 1998 and 2017 along the PIGGN departure
route at John Wayne Airport, the most striking problem starts to show up in 2013 when the FAA
implemented Performance Based Navigation (PBN) procedures at John Wayne Airport per FAA Order
8260.58 dated 9/21/2012 (See Appendix C). Additionally, incremental changes continued to occur
between 2014 through 2017 as the NextGEN project was unrolled…even though the FAA states that
the official implementation of NextGEN was November 2016.
The 2016 FAA Environmental Assessment (“EA”) for the NextGEN project failed to
recognize obvious incremental environmental impacts from 1998 to 2017, including
most particularly the PBN flight path changes of 2013, and it failed to recognize new
flight paths at lower altitudes from SNA, LAX, LGB, and ONT in new areas
throughout South OC from the NextGEN fight paths. It also failed to mitigate those
environmental impacts (noise and air pollution).
The definition of PBN can best be summarized in lay terms by saying that, prior to the PBN
procedures, pilots determined the course of the aircraft based on air traffic control instructions and the
location of certain navigation aids. After the introduction of PBN, the aircraft position was controlled by
on-board computers using GPS or inertial guidance systems.
In 2013, the environmental impacts of the Performance Based Navigation (PBN) procedures took
effect. No environmental assessment was performed by the FAA until 2016 after the FAA issued FAA
Order 8260.58a dated 3/14/2016 (See Appendix D) when the 2016 NextGEN Environmental
Assessment was prepared. A Finding of No Significant Impact (“FONSI”) was issued in 2016 by the
FAA, but the FAA FONSI failed to consider the impacts of the 2013 PBN procedures.
The result of NextGEN was a concentration of planes over Dana Point and San Juan Capistrano at
lower altitudes and jets from SNA are cutting the corner across Laguna Beach, Aliso Viejo and Laguna
Niguel. Many of these facts were n\observed in April 2014 by the DRAFT ENVIRONMENTAL
IMPACT REPORT NO. 617 JOHN WAYNE AIRPORT SETTLEMENT AGREEMENT AMENDMENT
prepared by Mestre Greve Associates, a Division of Landrum and Brown, but ignored by the FAA in
the Environmental Assessment and FONSI (See APPENDIX B)
SUMMARY OF INCREMENTAL FLIGHT PATH
CHANGES IN SOUTH ORANGE COUNTY BETWEEN
1998 AND 2017
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
The following summarizes the flight data in APPENDIX A showing flight paths in South OC
between 1998 and 2017.
• In 1998, very few jets flew over South Laguna Beach, South Laguna Niguel, Dana Point
and South San Juan Capistrano.
• In the year 2000, after the closure of the Marine Corps Air Station El Toro, there were
concentrations of jets starting to shift southerly over South Laguna Beach, Laguna Niguel,
and the north portion of San Juan Capistrano.
• In 2007, the central tendency was more jets starting to cut the corner over Laguna Beach
and South Laguna Niguel.
• In 2011, jets started to concentrate over north Laguna Beach, Aliso Viejo and Laguna Hills.
Very few jets flew over Laguna Niguel, San Juan Capistrano and Dana Point or South
Laguna Beach.
• In 2013, the environmental impacts really started to take effect as the FAA
implemented Performance Based Navigation (PBN) procedures.
• In 2017, jets are constantly cutting the corner of the PIGGN flight path crossing over
Laguna Beach, Aliso Viejo and Laguna Niguel, and there is a noticeable change in the
number of general aviation planes (smaller aircraft) crisscrossing South OC with jets
“concentrated” in Dana Point and San Juan Capistrano at noticeably lower altitudes than
previously observed.
NextGEN’s Environmental Assessment needs to properly study the incremental and
cumulative environmental impacts to South OC between 1998 (before El Toro Airport
closure) through 2013 (prior to PBN) and through 2017 (NextGEN).
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
WHAT IS THE PIGGN DEPARTURE PROCEDURE?PIGGN is the name given by NextGEN to a waypoint to help navigate jet departures
from SNA over South Orange County. This “waypoint” system seems to have
started in 2009 at John Wayne. Altitude restrictions were added to the procedure to
deconflict with Airway V23 (which is a flight corridor between LAX and Mexico).
Now the jets are allowed by the air traffic controllers to cut the corner through
Laguna Beach, Aliso Viejo and Laguna Niguel at altitudes as low as 4,000-Feet.
PIGGN’s lateral tracks allowed by NEXTGEN are designed to fly under the LAX flight
path “DOTTS” and LGB Flight Path “FRITR”, which pushed PIGGN lower.
WHAT IS THE PIGGN DEPARTURE PROCEDURE?The PIGGN departure procedure for SNA jets directs the jets over the ocean and
towards the SHIRR waypoint at or above 7,000-feet and thence towards the PIGGN
waypoint at or above 9,000-feet.
Notice the Airway named V-23 from Mexico to LAX crosses through this area at
about 4,000-feet. As a result, the SNA jets must navigate over those lower flying jets.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
Dana
Point
Ladera
Ranch
Laguna
Beach
Dana
Point
FINZZ DEPARTUREThe FINZZ is a departure procedure from SNA over the ocean and over Huntington
Beach. This procedure has the jets going over the coastline at over 10,000-feet and
continuing to rise to 15,000-feet
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
Dana
Point
Ladera
RanchLaguna
Beach
COMPARISON OF PIGGN AND FINZZFINNZ jets fly out 8-miles over the ocean and gain a higher altitude before they cross
over Huntington Beach at or above 10,000-feet, while the PIGGN jets fly out only 3-
miles over the ocean and the jets are at or above the 7,000-feet elevation at the
Dana Point shore line (which is too low and is causing noise and air pollution
impacts, and possibly harming bats and swallows in San Juan Capistrano). Also, the
jets that are cutting the corner at low altitudes over Laguna Beach, Aliso Viejo and
Laguna Niguel and are causing noise impacts and possibly harming sensitive wildlife
habitats in Aliso Woods Canyon and Laguna Coast Wilderness Park.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
Dana
Point
Laguna
NiguelLaguna
Beach
Huntington
Beach
THE PROBLEM IS NOT JUST JOHN WAYNE!!Note that NextGEN involves plane flights from many regional airports, not just John
Wayne. Any change to the flight paths has to consider the impacts to the flights from
the other airports. Did the FAA consider the cumulative impact when they made
changes with NextGEN…it does not seem so, for example many helicopters and
many “loud” general aviation planes are noted to be flying lower in 2016 to avoid the
lower flying NextGEN jets.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
THE SOLUTION
HERE IS A SOLUTION FOR
NEXTGEN FLIGHT PATHS OVER
SOUTH ORANGE COUNTY
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
THE SOLUTIONFOR NEXTGEN FLIGHTS IN SOUTH ORANGE COUNTY
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
SOLUTION: Citizens for No Plane Noise recommends pushing the SNA departing flights using
PIGGN to over 10-miles out over the ocean and much higher. For example, SHIRR waypoint
should move 10-miles off-shore and the jets need to fly to 15,000-feet (currently 7,000-feet at
SHIRR) and then to 30,000-feet at the PIGGN waypoint (currently 9,000-feet). NO MORE jets
cutting the corner! Also the LAX to Mexico jets along the V23 Airway need to be pushed from
4,000-feet to over 20,000-feet since they are flying 24-hours a day.
The estimated noise for a Boeing 737 at Coast of Dana Point is as follows:
Jet at 7,000 feet = 85.00 dBJet at 15,000 feet = 76.48 dBJet at 20,000 feet = 74.00 dBJet at 25,000 feet = 72.00 dBJet at 30,000 feet = 70.46 dB
Existing SHIRR Waypoint at 7,000-feet to be moved further off shore
PIGGN Jets to be PROHIBITED from cutting the corner
Existing PIGGN Waypoint at 9,000-Feet to be raised to
30,000-feet
New SHIRR Waypoint at 15,000-feet at 10-
miles off-shore
APPENDIX A
FLIGHT PATHS BETWEEN 1998
and 2017 OVER SOUTH
ORANGE COUNTY
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
FLIGHT PATHS IN 1998
BEFORE EL TORO AIRPORT CLOSEDVery few jets flew over South Laguna Beach, South Laguna Niguel, Dana Point and
South San Juan Capistrano
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Beach
Laguna
Niguel San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Mission
Viejo
Laguna
HillsAliso Viejo
FLIGHT PATHS IN 2000
AFTER EL TORO AIRPORT CLOSEDConcentration of jets started to shift southerly over South Laguna Beach, Laguna
Niguel, and north portion of San Juan Capistrano
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
Laguna
Beach
FLIGHT PATHS IN 2007More jets started to cut the corner over Laguna Beach and South Laguna Niguel
WHO ARE THE CITIZENS FOR NO PLANE NOISE?
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
Laguna
Beach
Flight Paths in March 2011Jets sated to concentrate over north Laguna Beach, Aliso Viejo and
Laguna Hills. Very few jets flew over Laguna Niguel, San Juan
Capistrano, Dana Point and South Laguna Beach.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Laguna
HillsAliso
Viejo
Laguna
Beach
Mission
Viejo
“THE SMOKING GUN” - Flight Paths of Sept 2013In 2012, the FAA issued FAA Order 8260.58 (See APPENDIX C) which set forth Performance
Based Navigation (PBN) procedures ant it was implemented in 2013, but no environmental
assessment was performed. In 2016, the FAA issued FAA Order 8260.58a (See APPENDIX D)
as part of NextGEN and an Environmental Assessment was prepared in 2016 along with a finding
of “No Significant Impact”. Even so, these PBN procedures were already implemented in 2013 at
John Wayne Airport, and resulted in a concentration of planes over Dana Point and San Juan
Capistrano and jets started to cut the corner across Laguna Beach, Aliso Viejo and Laguna
Niguel. These Environmental Impacts to South OC were not studied.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
PointSan
Clemente
Aliso
Viejo
Mission
Viejo
Noise Impacts Over South Orange County Between
1998 and 2017 Need to be Studied
Many incremental changes in flight paths over South OC took place between 1998 and 2017 and were not
properly studied by the FAA. For example, look at ENVIRONMENTAL IMPACT REPORT NO. 617 for the
JOHN WAYNE AIRPORT SETTLEMENT AGREEMENT AMENDMENT OF 2014 which states: Federal
Aviation Orders 5050.4 and 1050.1E for Environmental Analysis of Aircraft Noise Around Airports.
The FAA has developed guidelines (Order 5050.4B) for the environmental analysis of airports. Specific
policies and procedures for evaluating environmental impacts are described in Order 1050.1E CHG 1, with
an effective date of March 20, 2006. The noise analysis related policies and procedures are presented in
Section 14 of the Appendix A of the Order. The Significant Impact thresholds are presented in Section 14.3
as follows: “A significant noise impact would occur if analysis shows that the proposed action will cause
noise sensitive areas to experience an increase in noise of DNL 1.5 dB or more at or above DNL 65 dB
noise exposure when compared to the no action alternative for the same timeframe. For example, an
increase from 63.5 dB to 65 dB is considered a significant impact. ”
Section 14.4c specifies that impacts to receptors with noise exposures between 60
and 65 DNL should be examined in accordance with the 1992 FICON (Federal Interagency Committee on
Noise) Recommendations.
“In accordance with the 1992 FICON (Federal Interagency Committee on Noise) recommendations,
examination of noise levels between DNL 65 and 60 dB should be done if determined to be appropriate
after application of the FICON screening procedure (FICON p.3-5). If screening shows that noise sensitive
areas at or above DNL 65 dB will have an increase of DNL 1.5 dB or more, further analysis should be
conducted to identify noise-sensitive areas between DNL 60-65 dB having an increase of DNL 3 dB or more
due to the proposed action. The potential for mitigating noise in those areas should be considered, including
consideration of the same range of mitigation options available at DNL 65 dB and higher and eligibility for
federal funding.
This is not to be interpreted as a commitment to fund or otherwise implement mitigation measures in any
particular area. (FICON p. 3-7).”
Section 14.5e specifies the supplemental analysis that should be performed for projects with study areas
that are larger than the immediate vicinity of the airport.
“For air traffic airspace actions where the study area is larger than the immediate vicinity of an airport,
incorporates more than one airport, or includes actions above 3,000 feet AGL, noise modeling will be
conducted using Noise Integrated Routing System (NIRS). For those
types of studies, NIRS will be used to determine noise impacts from the ground to 10,000 feet AGL. This
noise analysis will focus on the change in noise levels as compared to populations and demographic
information at population points throughout the study area. Noise contours will not be prepared for the NIRS
analysis. However, NIRS will be used to produce change-of-exposure tables and maps at population
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Mission
ViejoLaguna
Hills
Aliso
Viejo
Laguna
Beach
Flight Paths in March 2014Performance Based Navigation (PBN) procedures at John Wayne
Airport, implemented in 2013, show concentration of planes over
Dana Point and San Juan Capistrano. Also shows jets cutting the
corner across Laguna Beach, Aliso Viejo and Laguna Niguel.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Mission
Viejo
Laguna
Hills
Aliso
Viejo
Laguna
Beach
Flight Paths in March 2016, “prior to NextGEN”Performance Based Navigation (PBN) procedures at John Wayne
Airport implemented in 2013, show concentration of planes over Dana
Point and San Juan Capistrano. Also shows jets cutting the corner
across Laguna Beach, Aliso Viejo and Laguna Niguel.
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
Laguna
Niguel
San Juan
Capistrano
Dana
Point
Ladera
Ranch
San
Clemente
Mission
Viejo
Laguna
HillsAliso
Viejo
Laguna
Beach
Flight Paths in March 2017, “after to NextGEN”Performance Based Navigation (PBN) procedures at John Wayne
Airport, implemented in 2013 show concentration of planes over Dana
Point and San Juan Capistrano. Still shows jets cutting the corner
across Laguna Beach, Aliso Viejo and Laguna Niguel and now many
more general aviation planes crisscrossing South OC. Clearly, the
NextGEN is resulting in more flights over South Orange County and is
concentrating jets in the area shown in blue. NextGEN’s
Environmental Assessment needs to compare the impacts to South
OC in 2011 (prior to PBN) to 2017 (NextGEN).
APPENDIX B
EXERPTS PERTAINING TO LAGUNA
BEACH FROM:
2014 DRAFT ENVIRONMENTAL IMPACT
REPORT NO. 617 JOHN WAYNE AIRPORT
SETTLEMENT AGREEMENT AMENDMENT
Prepared by Mestre Greve Associates, a
Division of Landrum and Brown
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
APPENDIX C
FAA ORDER 8260.58
9/21/2012
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
APPENDIX D
FAA ORDER 8260.58a
3/14/2016
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US
APPENDIX D
FAA ORDER 8260.58a
CITIZENS FOR NO PLANE NOISEWWW.NOPLANENOISE.US