these procedures actually have been whether to use reverse should be found to increase noise because of power left to the discretion of pilots. Therefore, applications needed to arrest high sink this measure does not merit further rates. consideration.

Conclusion: Because these procedures erode safety margins and are of little AIRPORT REGULATIONS practical noise abatement benefit, they do not deserve further consideration at Federal Aviation Regulation (F.A.R.) RNO. Part 150 requires that, in developing Noise Compatibility Programs, airports study the possible implementation of Reverse Thrust Restrictions airport use restrictions to abate noise. [See F.A.R. Part 150, Thrust reversal is routinely used to slow B150.7(b)(5).] The courts have immediately after recognized the right of airport touchdown. This is an important safety proprietors to reduce their liability for procedure which has the added benefit aircraft noise by imposing restrictions of reducing brake wear. Limits on the which are reasonable and do not violate use of thrust reversal can reduce noise contractual agreements with the FAA impacts off the sides of the runways, conditioning the receipt of federal aid. although they would not significantly (These are known as “grant reduce the size of the noise contours. assurances.”) In addition, constitutional Enforced restrictions on the use of prohibitions on unjust discrimination reverse thrust, however, are not and the imposition of undue burdens on considered fully safe. interstate commerce must be respected. The restrictions must also be crafted to Discussion: Given the location of noise- avoid infringing on regulatory areas sensitive uses in the RNO vicinity, a re- preempted by the federal government. striction on thrust reversal may produce Finally, the regulations must be some benefits. However, reverse thrust evaluated under the requirements of restrictions tend to erode safety F.A.R. Part 161. margins, increase occupancy time, and increase wear on aircraft. Airport noise and access restrictions Other mitigation measures, such as may be proposed by an airport operator noise barriers, would offer similar in its F.A.R. Part 150 Noise benefits without creating safety Compatibility Program. The FAA has concerns. made it clear that the approval of a restriction in an F.A.R. Part 150 Conclusion: Mandated limitations on document would depend on the noise the use of reverse thrust are inadvisable abatement benefit of the restriction at at RNO because of the reduced safety noise levels of 65 DNL or higher. Even margins and the potential for if the FAA should accept a noise alternative mitigation measures. As an restriction as part of an F.A.R. Part 150 operational procedure with a Noise Compatibility Program, the direct effect on safety, decisions about requirements of F.A.R. Part 161 would

5-18 still need to be met before the measure local Stage 3 noise or access restriction, could be implemented. the FAA must make the following findings:

F.A.R. Part 161 ! The restriction is reasonable, non- arbitrary, and non-discriminatory. In the Airport Noise and Capacity Act (ANCA) of 1990, Congress not only ! The restriction does not create an established a national phase-out policy undue burden on interstate or for Stage 2 aircraft above 75,000 foreign commerce. pounds, it also established analytical and procedural requirements for ! The restriction maintains safe and airports desiring to establish noise or efficient use of navigable airspace. access restrictions on Stage 2 or Stage 3 aircraft. Regulations implementing ! The restriction does not conflict these requirements are published in with any existing federal statute or F.A.R. Part 161. regulation.

F.A.R. Part 161 requires the following ! The applicant has provided actions to establish a local restriction on adequate opportunity for public Stage 2 aircraft: comment on the proposed restriction. ! An analysis of the costs and benefits of the proposed restriction ! The restriction does not create an and alternative measures. undue burden on the National Aviation System (NAS). ! Publication of a notice of the proposed restriction in the Federal Based on FAA's interpretations of Part Register and an opportunity for 161, the regulations do not apply to public comment on the analysis. restrictions proposed only for aircraft under 12,500 pounds. Because these While implementation of a Stage 2 light aircraft, which include small, aircraft operating restriction does not single engine aircraft, are not classified require FAA approval, the FAA does under Part 36 as Stage 2 or 3, the FAA determine whether adequate analysis has concluded that the 1990 Airport has been done and all notification Noise and Capacity Act was not procedures have been followed. intended to apply to them. (See Airport Noise Report, Vol. 6, No. 18, September For restrictions on Stage 3 aircraft, Part 26, 1994, p. 142.) 161 requires a much more rigorous analysis as well as final FAA approval of Very few Part 161 studies have been the restriction. Before approving a undertaken since the enactment of ANCA. Table 5B summarizes the studies that have been done to date.

5-19 TABLE 5B Summary of F.A.R. Part 161 Studies

Year

Airport Started Ended Cost Proposal, Status

Aspen-Pitkin County Airport, N.A. N.A. N.A. The study has not yet been submitted Aspen, Colorado to FAA.

Kahului Airport, Kahului, 1991 1994 $50,000 Proposed nighttime prohibition of Maui, Hawaii (est.) Stage 2 aircraft pursuant to court stipulation. Cost-benefit and statewide impact analysis found to be deficient by FAA. Airport never submitted a complete Part 161 Study. Suspended consideration of restriction.

Minneapolis-St. Paul 1992 1992 N.A. Proposed nighttime prohibition of International Airport, Stage 2 aircraft. Cost-benefit analysis Minneapolis, Minnesota was deficient. Never submitted a complete Part 161 study. Suspended consideration of restriction and entered into negotiations with carriers for voluntary cooperation.

Pease International 1995 N.A. N.A. Have not yet submitted a Part 161 Tradeport, Portsmouth, New study for FAA review. Hampshire

San Francisco International 1998 1999 $200,000 Proposing extension of nighttime Airport, San Francisco, curfew on Stage 2 aircraft over 75,000 California pounds. Started study in May 1998. Submitted to FAA in early 1999 and subsequently withdrawn.

San Jose International 1994 1997 Phase 1 - Study undertaken as part of a legal Airport, San Jose, California $400,000 settlement agreement. Studied a Stage Phase 2 - 2 restriction. Suspended study after $5 to $10 Phase 1 report showed costs to million at San Jose greater than benefits in (est.) San Jose. Never undertook Phase 2, systemwide analysis. Never submitted study for FAA review.

Burbank-Glendale-Pasadena 2000 Ongoing Phase 1 - Proposed curfew restricting all aircraft Airport $1 million operations from 10:00 p.m. to 7 a.m. (est.)

Naples Municipal Airport 2000 2000 Currently Enactment of a total ban on Stage 2 Naples, Florida $730,000 general aviation jet aircraft under 75,000 pounds (the airport is currently Expect an restricted to aircraft under 75,000 additional pounds). Stage 2 ban currently cost of deferred due to FAA request for $1.5 to additional analysis. Currently in $3.0 litigation due to suits from numerous million in organizations and individuals. Airport legal fees may have to repay all previous federal due to funding received for airport projects. litigation.

N.A. - Not available.

Sources: Telephone interviews with Federal Aviation Administration officials and staffs of various airports. Regulatory Options Regulatory options discussed in this section include the following: 5-20 departures by aircraft exceeding ! Nighttime curfews and operating specified noise levels. restrictions. Discussion: The time during which ! Landing fees based on noise or time nighttime restrictions could be applied of arrival. varies. The DNL metric applies a 10 decibel penalty to any noise event ! Airport capacity limitations based occurring between 10:00 p.m. and 7:00 on relative noisiness. a.m. That period could be defined as a curfew period. A shorter period, ! Noise budgets. corresponding to the very late night hours, say midnight to 6:00 a.m., could ! Restrictions based on aircraft noise also be specified. levels. Full Curfews: While full curfews can ! Restrictions on touch-and-go’s or totally resolve concerns about nighttime multiple approaches. aircraft noise, they can be indiscriminately harsh. Not only would ! Restrictions on engine maintenance the loudest operations be prohibited, but run-ups. quiet operations by light aircraft also would be banned by a full curfew. Full curfews also deprive the community of Nighttime Curfews And the services of some important Operating Restrictions nighttime airport users. In fact, according to the airport’s consolidated Curfews and operating restrictions can air carrier flight schedule, it is often be effective methods for reducing estimated that such a restriction would aircraft noise exposure around an affect 24 commercial scheduled to airport. Since noise is commonly arrive or depart between 10:00 p.m. and assumed to be most annoying in the late 7:00 a.m. Of course, full curfews would evening and early morning hours, restrict access to the airport by Stage 3 curfews are usually aimed at restricting aircraft. Thus, a full Part 161 analysis nighttime operations. However, curfews and FAA approval would be required have economic impacts on airport users, prior to implementation. those providing airport-related services, and the community as a whole. Other Important economic reasons drive communities also may be impacted nighttime airport activity. Early through curtailment of service. morning departures are often attractive for business travelers who wish to reach There are essentially three types of their destinations with a large part of curfews or nighttime operating the workday ahead of them. Not only is restrictions: (1) closure of the airport to this a personal convenience, but it can all arrivals and departures (a full result in a significant savings in the cost curfew); (2) closure to departures only; of travel by reducing the need for and (3) closure to arrivals and overnight stays. Accordingly, early morning departures are often very

5-21 popular, and the airlines have between the hours of 10:00 p.m. and attempted to meet this demand. 7:00 a.m. In addition, such a curfew Similarly, late night arrivals are would greatly affect air cargo carriers. important in allowing travelers to return home without incurring the costs As with a full curfew, a nighttime of another night away. Air carriers also prohibition on departures would restrict need to position their aircraft so they access to the airport by Stage 3 aircraft. are ready for the next day’s schedule. This would require a full Part 161 This tends to mandate nighttime analysis and FAA approval of the arrivals. Since RNO is the only restriction before it could be commercial service airport serving implemented. northern Nevada and a portion of California, economic impacts caused by Nighttime Restrictions Based on restrictions at the airport could affect Aircraft Noise Levels: Nighttime the entire region. operating restrictions can be designed to apply only to those aircraft which exceed Different, but equally compelling, specified noise levels. If it is to be reasons encourage cargo carriers and effective in reducing the size of the DNL courier companies to operate in the noise contours, the restricted noise level evening and at night. Cargo is collected would have to be set to restrict the during the business day. It is shipped to loudest, most commonly used aircraft at a hub facility in the evening or at night the airport. Representative aircraft that where it is sorted and, in the case of could be involved would be the B-727 package express service, delivered to its hushkit, B-737 hushkit, and the MD-80. destination the next business day. Bulk At RNO, this would affect 10 arriving cargo companies work essentially the and departing air carrier aircraft. This same way, although where speed is not number does not include aircraft of paramount importance, the collection currently used by air cargo operations at and delivery functions may involve more RNO. Because these aircraft all meet use of surface transportation. Modern Stage 3 noise levels, F.A.R. Part 161 air cargo service cannot operate without would require a detailed analysis and nighttime access to airports. approval by the FAA. In setting the restricted noise level, care would need to Prohibition of Nighttime Departures: be taken that the restriction did not fall The prohibition of nighttime departures too heavily upon one carrier. Otherwise, would allow aircraft to return home but charges of unjust discrimination could would prohibit departures, which are be levied. generally louder than arrivals. Although somewhat less restrictive, this Conclusion: Curfews and nighttime would have similar impacts at RNO as a operating restrictions can be an effective full curfew. It would interfere with air way to reduce the size of DNL noise carriers in their attempts to schedule contours around an airport. Because of early morning departures for the the extra 10 decibel weight assigned to business travel market. At RNO, this nighttime noise, removing a single would affect approximately 13 nighttime operation is equivalent to commercial departures scheduled eliminating 10 daytime operations. The

5-22 effect on the noise contours can be attacked as discriminatory if its affect significant. was to single out one, or a few, carriers for especially strict treatment. In A particularly troubling aspect of practice, however, landing fees are such curfews and nighttime operating a small part of the total operating costs restrictions is their potential adverse of an that increases in fees or effects on local air service and the noise-based surcharges may become region’s economy. This is especially merely an irritant to the carrier. compelling since RNO is the only commercial service airport operating in Before the adoption of the ANCA in the Reno area. Such a restriction could 1990, noise-based landing fees were potentially affect up to 24 air carrier often considered a way to encourage air aircraft in addition to those used by air carriers to convert to Stage 3 aircraft. cargo operations. Additionally, Under ANCA, full conversion of aircraft implementation of nighttime restrictions over 75,000 pounds to Stage 3 standards can be costly, problematic, and require was mandated by the year 2000. the completion and subsequent FAA Therefore, the traditional objective of approval of a Part 161 Study. noise-based landing fees is no longer Therefore, this measure does not relevant. Of course, different kinds of warrant further consideration. Stage 3 aircraft produce different levels of noise. B-727s and DC-9s equipped with Stage 3 hush kits, for example, are Noise-Based Landing Fees louder than B-737-300s and A-320s. In theory, a system of noise-based landing Commercial airports typically levy fees could be used to attempt to landing fees on aircraft to raise revenue encourage carriers to convert to the for airport operations and maintenance. quietest Stage 3 aircraft. It is Fees are typically based on aircraft questionable how effective this could be gross weight. Landing fees can also be in practice. An air carrier’s fleet based on aircraft noise levels and the composition is dictated by many time of day of . Thus, arrivals variables, including: aircraft purchase, at night by loud aircraft would be financing, and leasing costs; operating charged the highest fees, while arrivals and maintenance costs; air and during the day by quiet aircraft would maintenance crew training require- be charged the smallest. ments; manufacturer support; and marketing strategy. Whether one If noise-based landing fees are set high airport can exert enough leverage enough, they might encourage airlines through noise-based landing fees to to bring quieter aircraft into the airport. influence aircraft acquisition and route Noise-based landing fees that are set assignment decisions is questionable. high enough to affect air carrier operations would almost certainly be subject to legal challenge. The system could be vulnerable to attack as an undue burden on interstate commerce. The fee structure could also possibly be

5-23 If landing fees cannot be set high control cumulative noise exposure. This enough to have a demonstrable effect on kind of restriction would impose a cap airline behavior, noise-based fee on the number of scheduled operations. surcharges can still be a reasonable way This is only an imprecise way to control to raise money for financing noise aircraft noise. For one thing, abatement activities. This does not unscheduled operations would not be appear to be necessary at RNO, subject to the limit. In addition, the however, since adequate sources of local limit on scheduled operations actually funding are available. provides no incentive for conversion to quieter aircraft. Rather, if passenger Discussion: Landing fees are typically demand is increasing, it would set by the terms of an airline's lease encourage airlines to convert to larger with the airport. Thus, fees could only aircraft, which often (but not always) be adjusted at the time leases came up tend to be noisier than smaller aircraft for renewal, even if the AAWC did in the same Part 36 stage classification. establish a noise-based landing fee. The implementation of capacity Noise-based landing fees are considered limitations would entail the allocation of airport noise restrictions under F.A.R. operating slots among air carriers, an Part 161. A Part 161 analysis would be ongoing process which would likely required before such a fee system could require additional airport staff to deal be implemented. Any fee structure that solely with airline negotiations for would place a noise surcharge on Stage operating positions. The system would 3 aircraft would require FAA approval have to provide some allowance for entry prior to implementation. by new carriers to avoid being found to be an illegal restraint of trade. Conclusion: A noise-based landing fee system intended to provide strong Discussion: A cap on operations would incentives for carriers to convert their not necessarily provide significant noise fleets to quieter aircraft is not practical benefits. The forecast noise contours and is vulnerable to legal challenges. A presented in Chapter Three provide an noise-based landing fee surcharge example. A comparison of the noise intended to raise revenue for noise contours for forecast 2005 conditions mitigation activities is not considered and 2010 conditions (Table 3H on page necessary. The airport has other 3-18 of the Noise Exposure Maps potential sources of revenue such as document) shows only a slight increase PFC’s which can be used to provide in the size of the 65, 70, and 75 DNL funding for noise mitigation projects. noise contours from 2005 to 2010 to the Noise-based landing fees will not receive north. During that period, however, the additional consideration. number of annual aircraft operations is projected to increase from 179,862 to 201,762 (Table 3C on page 3-7 of the Capacity Limitations Noise Exposure Maps document).

Capacity limitations have been used by Conclusion: Airport capacity limitations some severely impacted airports to intended to control noise are too

5-24 imprecise to guarantee effectiveness and airport users are complying with the are unlikely to achieve significant noise allocations. Fifth is the establishment of reductions. They can also limit air sanctions for carriers that fail to operate service to the community, interfering within their allocations. Sixth, the with the needs of the local economy. system should be fine-tuned based on They can also be difficult and expensive actual experience. The only simple step to administer. Since they inevitably in this process is the first, setting a goal. would restrict access to the airport by From that point, it becomes increasingly Stage 3 aircraft, capacity limitations complex. would be subject to Part 161 analysis and approval by the FAA. Airport Discussion: Different approaches can be capacity restrictions, therefore, do not used to define noise in a way which merit additional analysis. permits allocation. It is possible to use the DNL metric, or a variant, for this purpose. This has some advantages in Noise Budgets that the FAA's Integrated Noise Model (INM) can be easily used to derive DNL In the late 1980s, noise budgets gained levels attributable to the average daily attention as a potential noise abatement operations of the various airport tool. After the enactment of the operators. The INM database can be Aviation Noise and Capacity Act used to establish a basis for noise (ANCA) of 1990, mandating the allocations based on aircraft type. An retirement of Stage 2 aircraft over alternative is to use the effective 75,000 pounds, interest in noise budgets perceived noise level (EPNL) metric. waned. Noise budgets are designed to This is the metric used to certify aircraft limit airport noise and allocate noise noise levels for compliance with F.A.R. among airport users. The intent is to Part 36. Noise levels of various aircraft encourage aircraft operators to convert expressed in EPNL are published in to quieter aircraft or to shift operations FAA Advisory Circulars 36-1E and 36- to less noise-sensitive hours. Before 2C. EPNL values for the aircraft used ANCA, the intent was to encourage by each operator on an average day conversion to Stage 3 aircraft and to could be summed to define the total discourage the use of Stage 2 aircraft. noise attributable to the operator.

While noise budgets can be designed in The third step, the design of the many different ways, six basic steps are allocation system, is the most difficult involved. First, the airport must set a and the least subject to fair and target level of cumulative noise objective definition. The allocations can exposure, usually expressed in DNL, be handled in different ways. They which it intends to achieve by a certain could be auctioned, but without careful date. Second, it must determine how to controls this could cause serious express that overall noise level in a way problems. It could give the financially that would permit allocation among stronger carriers the opportunity to buy airport users. Third, it must design the extra noise allocations for purposes of allocation system. Fourth is the design speculation or restraint of competition. of a monitoring system to ensure that Another way to allocate the noise would be through a lottery. A drawback with

5-25 both of these methods is that they would The use of quieter aircraft or operations not recognize past operating histories. during less noise-sensitive hours would It is also important that any allocation result in increased flights per allocation. system include provisions for the entry of new carriers in order to have any The fourth step involves monitoring chance of being legally permissible. compliance with the noise allocations. Any monitoring system will require An allocation system based on the recent extensive bookkeeping. The simplest operating histories of each airline would method would involve the monitoring of probably be the fairest approach, but it aircraft schedules. Total noise would not be problem-free. To be as fair contribution by carrier would be as theoretically possible, the allocation summed for the reporting period based should be based on each carrier's on the activity during the reporting contribution to existing noise levels at period. Noise levels for each flight the airport and its past performance in would be based on the certificated noise helping to reduce that noise. If the level, or the INM data base noise level, allocation system is based only on for each aircraft. While this system current noise contribution, the carriers would require large amounts of staff that have made significant investments time to administer, it would be in converting their fleets will be relatively simple to computerize and penalized in comparison with those would have the advantage of enabling which have not. The noisier airline, for carriers to plan their activities with a example, could conceivably be given a clear understanding of the noise competitive advantage because, if they implications of their decisions. were willing to convert to quieter aircraft, they would be able to increase A theoretically more precise method of their number of flights while still compliance monitoring, but a more reducing their overall noise output. expensive and complex method, would Carriers can also argue that their be to monitor actual aircraft noise corporate aircraft operating procedures levels. Actual noise from each aircraft result in less noise than the operating operation would be recorded for each procedures of their competitors and that operator. The advantage of this this should be recognized in the noise approach is that it would be based on allocation system. actual experience. A significant disadvantage, however, is that it could After establishing the initial allocation be quite difficult for carriers to make system, it would be necessary to develop predictions about the noise impact of a schedule of declining noise allocations their scheduling decisions. Many to each carrier in order to reach the variables influence the noise occurring overall noise reduction goals of the from any particular aircraft operation, program. Each carrier would have the including the weather, pilot technique, flexibility to develop scheduling at any and air traffic control instructions. In time of the day with any aircraft type, so addition, RNO would have to purchase a long as its allocation is not exceeded. monitoring and flight tracking system.

5-26 The fifth step is to establish a system of real and substantial improvements in fines or other sanctions to levy against the local airport noise environment is carriers which fail to operate within questionable and will not be discussed their assigned noise allocations. To be further. effective, the sanctions should be severe enough to provide a strong incentive to cooperate with the program. Restrictions Based On Aircraft Noise Levels In an era where all aircraft weighing more than 75,000 pounds are Stage 3, it Outright restrictions on the use of is difficult to imagine how a noise aircraft exceeding certain noise levels budget could promote significant noise can reduce cumulative noise exposure at reduction without reducing air service in an airport. Aircraft producing noise the community. While some Stage 3 above certain thresholds, as defined in aircraft are louder than others, some F.A.R. Part 36, could be prohibited from carriers operate with fleets almost operating at the airport at all or certain completely composed of among the times of the day. A variation is to quietest Stage 3 aircraft. Depending on impose a non-addition rule, prohibiting the noise allocation and the reduction the addition of new flights by aircraft target assigned to such a carrier, they exceeding the threshold level at all or might be able to meet the target only by certain times of the day. These eliminating flights. restrictions would be subject to the special analysis procedures of F.A.R. Conclusion: Noise budgets are complex Part 161. Any restrictions affecting methods of promoting airport noise Stage 3 aircraft would have to receive reduction. They are particularly FAA approval. vulnerable to attack on grounds of discrimination and interference with Noise limits based on F.A.R. Part 36 interstate commerce. Noise budgets are certification levels are based on fixed extremely difficult to design in a way national standards which are that will be seen as fair by all airport understood by all in the industry. They users and are likely to be quite are average values, however, and do not expensive to develop. Negotiations on consider variations in noise levels based noise budget design and noise on different methods of operating the allocations are likely to be long and aircraft. As an alternative, restrictions contentious and would require the could be based on measured noise levels assistance of noise consultants and at the airport. This has the advantage attorneys. The costs of administering of focusing on noise produced in a given the system also would be substantial. situation and, in theory, gives aircraft The bookkeeping requirements are operators increased flexibility to comply complex and additional administrative with the restrictions by designing staff would definitely be required. special approach and departure procedures to minimize noise. It has the At RNO, a noise budget does not appear disadvantage of requiring extra to be a practical option. The process administrative effort to design testing would be long, expensive, and procedures, monitor tests, interpret contentious. Its potential for delivering

5-27 monitoring data, and design the Touch-and-Go Restrictions restrictions. Restrictions on touch-and-go or multiple Discussion: Whether threshold noise approach operations can be effective in levels are based on F.A.R. Part 36 or reducing noise when those operations measured results, care must be taken to are extremely noisy, unusually frequent, ensure that the restriction does not fall or occur at very noise-sensitive times of with undue harshness on any one the day. At many airports, touch-and- carrier. The feasibility of complying go’s are associated with primary pilot with the restriction given existing training, although this type of operation technologies and equipment also must is also done by licensed pilots practicing be considered. If these things are approaches. ignored, the restriction could reduce the amount of air service in the community. Discussion: Current noise abatement It also would make the restriction procedures contain the following subject to legal challenge and rejection restrictions regarding touch-and-go by the FAA as unjust discrimination and activity: potentially burdensome to interstate commerce. < No training operations are permitted on any runway between Since January 1, 2000, RNO has had an 10 p.m. and 7 a.m. Monday thru air carrier fleet that is 100 percent Friday and until 8 a.m on weekends Stage 3 compliant. Stage 2 business jets and holidays. under 75,000 pounds are not subject to the Stage 2 phase-out law. This < Touch-and-go operations are includes nearly all typical business jets. restricted to piston-powered Restrictions of these aircraft would aircraft. (Aircraft over 12,000 require an analysis based on F.A.R. Part pounds require prior written 161. approval.)

Conclusion: Restrictions based on noise < Jet touch-and-go and low levels could be viewed as discriminatory approaches are prohibited. and therefore be subject to litigation and rejection by the FAA. In addition, the Pilots wishing to perform touch-and-go requirements of a costly F.A.R. Part 161 operations in contradiction to these Study would have to be met before any restrictions will need to request restriction on Stage 2 business jets permission from the on-duty operations under 75,000 pounds and Stage 3 air officer. All and large carrier aircraft could be implemented. aircraft traffic operating at RNO is Therefore, this measure does not merit considered to be itinerant. further discussion. Conclusion: Although training operations including practice instru-

5-28 ment approaches and touch-and-go interstate commerce, or conflict with operations are commonly performed by FAA grant assurances. As previously piston-powered aircraft, current discussed, noise due to aircraft restrictions curtail such activity by more maintenance run-up operations could be intrusive aircraft. In addition, these mitigated through the installation of a restrictions prohibit training activity run-up enclosure such as a hush-house. during times when the noise generated If constructed, it will be essential to would be an excessive burden to establish policies for the use of that surrounding land uses. Additional facility. restrictions on touch-and-go operations for noise abatement purposes would Discussion: RNO currently has several yield little benefit and do not merit restrictions concerning maintenance further discussion. run-ups:

< Engine run-up procedures are Engine Run-up Restrictions conducted at the north end of Taxiway “C” or at a location Engine run-ups are a necessary and designated by Airport Operations. critical part of aircraft operation and maintenance. Run-ups are required for < Air carriers wishing to perform various operations. maintenance run-up operations are Engine run-ups are often more annoying required to notify Airport than aircraft overflight noise because Operations at least one hour prior they are more unpredictable, have a to performing the operation. more sudden onset rate, and usually last longer. In addition, because run-ups < Jet engine run-ups above idle power occur on the ground, they tend to be are prohibited between 2 a.m. and 6 more sensitive than overflights to a.m. (The Operations Office may atmospheric effects. Temperature authorize run-ups at alternative inversions, for example, can cause noise times.) on the ground to travel further. For all these reasons, run-up noise can be more < Engine run-ups shall be limited to a annoying than a cursory analysis of A- duration of five minutes. weighted noise levels might indicate. < No aircraft may perform more than Engine maintenance run-ups may be four run-up operations per day. restricted by airport operators. These restrictions, when they apply to run-ups < All run-up operations will be as a separate function from the takeoff completed within a 30-minute and landing of the aircraft, do not period. appear to need special FAA review or approval under F.A.R. Part 161. (See < In the event that a run-up event Airport Noise Report, Vol.6, No. 18, generates complaints, air carrier September 26, 1994, p. 142.) They are, operators will be required to reduce nevertheless, subject to other legal and run-up power or cease run-up constitutional limitations on unjust operations. discrimination, undue interference with

5-29 Conclusion: Aircraft operational and Noise Effects. The purpose of this maintenance run-ups are an integral evaluation is to reduce aircraft noise on part of operations at RNO. A number of people. A reduction in noise impacts, if restrictions are currently in place any, over noise-sensitive areas are concerning maintenance run-up assessed. procedures and additional restrictions would greatly hinder airport operators, Operational Issues. The effects of the safety, and would likely facilitate alternative on the operation of aircraft, litigation. The additional mitigation of the airport, and local airspace are run-up noise would best be addressed considered. Potential airspace conflicts through the utilization of a run-up and air traffic control (ATC) constraints enclosure such as a “hush-house” and are discussed, and the means by which the establishment of policies governing they could be resolved are evaluated. run-up procedures. Potential impacts on operating safety are also addressed. FAA regulations and procedures will not permit aircraft SELECTION OF operation and pilot workload to be MEASURES FOR handled other than in a safe manner, but within this limitation differences in DETAILED EVALUATION safety margins occur. A significant reduction in safety margins will render Preliminary screening of the complete an abatement procedure unacceptable. list of noise abatement techniques indicated that some measures may be Air Service Factors. These factors potentially effective in the RNO area. relate to a decline in the quality of air These are evaluated in detail in this transportation service which would be section. expected from adoption of an abatement measure. Declines could possibly result from lowered capacity or rescheduling EVALUATION CRITERIA requirements.

Four operational alternatives have been Costs. Both the cost of operating selected for detailed analysis in addition aircraft to comply with the noise abate- to the possible effects of a run-up ment measure and the cost of con- enclosure. The noise analysis for each struction or operation of noise alternative was based on the 2005 abatement facilities are considered. baseline analysis presented in Chapter Estimated capital costs of implementing Four, "Aviation Noise Impacts." The the noise abatement alternative, where 2005 baseline was chosen to offer a com- relevant, are also presented. mon base of comparison for all alterna- tives. This timeframe allows time for Environmental Issues. Environ-mental FAA review and approval of the final factors related to noise are of primary Noise Compatibility Program and any concern in an F.A.R. Part 150 Update environmental assessments which may analysis. Procedures that involve a be required prior to implementation of change in air traffic control procedures the procedures. The alternatives are or increase noise over residential areas evaluated using the following criteria:

5-30