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HomeMy WebLinkAbout13 - FAA Letter re JWA Departure ProcedureCITY OF 4Q SEW PoR0 NEWPORT /F00. City Council Staff Report Agenda Item No. 13 April 9, 2013 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: City Manager's Office Dave Kiff, City Manager 949 - 644 -3001, dkiff @newportbeachca.gov PREPARED BY: Dave Kiff, City Manager APPROVED: TITLE: Required Navigation Performance (RNP) Departures for John Wayne Airport (JWA) ABSTRACT: The Federal Aviation Administration's (FAA's) "NextGen" program has brought the nation towards "airspace optimization," including at JWA. This means more focused arrival and departure tracks. The fanning that once occurred and "shared the pain" across the Newport Beach community is now more limited. JWA will see two major departure tracks for most commercial carriers — the already- approved "STREL" (for commercial flights going east of Las Vegas) and the pending " RAWLZ" (generally, the rest of the commercial flights — those going north, going directly to Las Vegas, or otherwise staying west of Las Vegas). The City hired GE Aviation /Naverus ( "Naverus ") to help us respond to the FAA's request to participate in the development of the RAWLZ. Naverus did so, and recommended that we send a letter to the FAA asking the FAA to develop an RNP departure for JWA that follows the curvature of the Upper Bay. RECOMMENDATION: Authorize the Mayor to send the attached letter to the FAA regarding the development of the RAWLZ departure procedure. FUNDING REQUIREMENTS: The City paid Naverus $75,000 to complete this analysis and report. There is no funding required to send the letter. If the FAA agrees with the recommended path, the April 09, 2013 Page 2 City may wish to engage Naverus again to further develop the departure pattern — funding from such an effort would come from the general fund or from Federal grant funds (if not sequestered) that can be awarded for similar purposes. We would work with our members of Congress to secure these funds. DISCUSSION: As much as we might want otherwise, neither the City of Newport Beach nor the County of Orange (the County is the operator of JWA) controls the airspace around JWA. Once the wheels are up, the control is with the FAA where safety is the top priority. Arguably, in years past, the community has preferred the "share the pain" approach of "fanning" departing commercial flights across various areas of town, where no single part of town (except Santa Ana Heights, Balboa Island, Balboa Village, and the Anniversary Tract) bears the brunt of most departures. But in recent years, the FAA has worked to "optimize airspace" across the nation, especially in congested areas like our own. As a result, the share the pain approach has changed to reflect more concentrated tracks that place the same number of planes over a narrower area. A good overall summary of NextGen is within the report by Naverus. The City hired Naverus in Fall 2012 for $75,000 to assist the City in evaluating if specific departure patterns could be designed that curve as the Upper Bay curves and thereby reduce the potential for overflights on both the east and west side of the bay. The report's executive summary is Attachment A, with the full report placed on the City's website. As readers see the full report, some key terms to know include: • NextGen. An umbrella term for the ongoing plan to modernize the National Airspace System (NAS). At its most basic level, NextGen represents an evolution from a ground -based system of air traffic control to a satellite -based system of air traffic management. • RNAV (Area Navigation). RNAV a method of instrument flight rules (IFR) navigation that allows an aircraft to choose any course within a network of navigation beacons, rather than navigating directly to and from the beacons. Area navigation used to be called "random navigation ", hence the acronym RNAV. • RNP (Required Navigation Performance). RNP is a type of performance -based navigation (PBN) that allows an aircraft to fly a specific path between two 3D- defined points in space. RNAV and RNP systems are fundamentally similar. The key difference between them is the requirement for on -board performance monitoring and alerting. z April 09, 2013 Page 3 As the FAA has pursued NextGen across the country, it has already developed one departure procedure for JWA called the STREL. The STREL — for planes equipped with the technology and going east of Las Vegas NV - comes after two previous attempts ( DUUKE ONE and DUUKE TWO) were discarded in part because of community concerns. STREL continues to have its detractors, including residents of Corona del Mar, Westcliff, Dover Shores, the Sea Island HOA, and the Crystal Cove area. Residents to the east say that the STREL takes planes too far east at mid -Bay (the crossing point is Noise Monitoring Station #7 or NMS7 near Newport Dunes) and allows them to turn eastward sooner once crossing the shoreline. People on the west side say the planes end up going farther west before initiating their turns to cross NMS7. About 50% of all commercial flights from JWA use the STREL. Other departures will be sent along the next departure pattern, called the RAWLZ. When the City and area residents looked back on the development of STREL, several people asked whether a departing commercial plane could fly within the confines of the Upper Bay, turning two or more times. This departure is not typical in the continental US (it exists in Juneau AK), but it is more typical in other countries, as well as in the US for arrival procedures. Many of these were designed by Naverus staff members. We hired Naverus to see if JWA could be a place for the first continental US departure procedure using an RNP departure that follows the curvature of the Upper Bay. As a part of its work, Naverus reviewed the STREL, the two DUUKES, other departure procedures and sources, and met with interested community members, JWA staff and City staff in early February 2013. As the report shows, Naverus concluded that such a departure pattern can be developed, provided the FAA was willing to accept it and /or design it. The report included a detailed discussion of exactly how JWA could have an RNP for RAWLZ, and suggested text for a City letter sent to the FAA to encourage the FAA to actively consider it. The report offers some caveats which are important to include here. Naverus reported that the risks to the recommended approach are regulatory, not technical, and are as follows: • This would be the first public -use departure procedure in the continental US using the RNP specifications; • The geometry recommended for curved paths is not explicitly set, although it does include specifications for curved paths used in approach procedures; 3 April 09, 2013 Page 4 • The FAA would need to make an exception for this procedure, with the timeline for doing so unknown; • A charting standard for the proposed departure does not yet exist and would need to be developed; and • "The mechanism by which airlines are approved to fly an RNP departure is not fully evolved." Conclusion. The City and several in the community are excited about being able to suggest a path like this to the FAA. However, the FAA has a variety of ways it can respond: 1. It can reject our concept outright; 2. It can accept the concept in theory and ask us to develop it further, with no guarantee of final approval; or 3. It can accept the concept and develop it itself. With the latter being the best outcome, the City staff will forward the attached draft letter to the FAA if the Council consents to authorizing the mayor to sign it. We will work with the Council, the community, the Aviation Committee and other interested residents as this issue is further developed. As an additional caution, even if the FAA is willing to consider an RNP for RAWLZ, the FAA is unlikely to support or approve an RNP that does not have the unanimous support of the community. Staff would like to thank the community members who participated in this project to date, including Tom Anderson, LeAnne Bowman, David Browne, Tony Khoury, Martin Kraty, Bonnie O'Neil, Bob Taylor, and Karen Tringali. Additionally, we appreciate the recommendations of Tom Naughton and Robert Pastore, both of whom suggested the City hire Naverus to do this work. ENVIRONMENTAL REVIEW: Staff recommends the City Council find the approval of this letter is not subject to CEQA pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly. 4 April 09, 2013 Page 5 PUBLIC NOTICE: We presented the Naverus report to the Aviation Committee on March 25`h, 2013. The Committee was not asked to make a recommendation, but participants generally reacted favorably to the use of an RNP departure for RAWLZ. The agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the City Council considers the item). Submitted by: a" DYve Kiff City Manager Attachments: A — Naverus Report executive summary B — Draft letter from Mayor Curry to the FAA 5 John Wayne Airport Departure Feasibility GE Aviation Assessment Executive Summary 1. Executive Summary 1.1. Background GE Aviation's Air Traffic Optimization Services (Naverus, Inc.) has been contracted by the City of Newport Beach to evaluate the feasibility of developing an instrument departure procedure, based on recently published standards, in an effort to mitigate long- standing issues related to noise mitigation at John Wayne Airport (JWA)'. As part of a long -term plan to modernize airspace infrastructure in the United States, commonly known as NextGen, the FAA has published a new set of instrument flight procedure (IFP) design rules that take advantage of the latest generation of navigation technologies known as performance -based navigation (PBN), and in particular a specification of PBN known as required navigation performance (RNP). RNP allows for the creation of flight paths with complex geometry, including curved paths, and takes full advantage of latent capabilities onboard the majority of transport aircraft operating in the U.S. In general, the creation of RNP flight paths designed in accordance with the new and emerging rule sets are a fundamental part of the NextGen plan. As this report describes, an opportunity exists to create an RNP procedure, using this new rule set, for aircraft departing JWA to the south. RNP technology would allow the design of departure flight paths that could potentially balance the differing, and sometimes competing environmental and noise interests of citizens from different neighborhoods in Newport Beach. RNP design offers a number of significant benefits including: o The designed location of the flight path could incorporate input from citizens of Newport Beach to a greater extent than has been previously possible with legacy navigation methods. A curved flight path could be designed that would greatly reduce the potential for direct overflights of residential communities on both the east and west sides of the Back Bay. o The new departure procedure would represent an important milestone for the FAA's NextGen plan: the first use of the RNP specification for a public -use departure. o The RNP departure procedure could be flown by the majority of airline operators serving JWA. Designing on RNP departure procedure for JWA that balances the needs of all stakeholders is a complex task that requires detailed knowledge and understanding of a broad range of technical, operational, and regulatory subjects. In addition, in order to achieve a successful outcome, special attention must be given to the integration of community interests within the technical design process. This report provides a comprehensive overview of these subjects as they relate to JWA in order to better inform the design of future departures from JWA and to provide guidance on design options available. 1 JWA, a commonly used abbreviation for John Wayne Airport, will be used throughout this report. The ICAO identifier for John Wayne Airport is SNA. 004329 -4CS52 Page 6 of 61 Rev New, 28 February 2013 John Wayne Airport Departure Feasibility GE Aviation Assessment Executive Summary 1.2. Overview of Current Operations 1.2.1. Current Procedures Currently, aircraft departing to the south from JWA fly a number of IFPs that use a variety of navigation technologies. These include legacy procedures that rely on ground -based navigation transmitters, as well as a form of PBN known as RNAV. As a result, communities on both sides of the Back Bay are exposed to overflights depending on a number of factors, including wind conditions, the departure that is being flown, and the type of aircraft flying it. 1.2.2. Current Concerns The FAA has designed and implemented a number of different departures at JWA that have had varying degrees of success in avoiding overflights of communities surrounding the Newport Back Bay. The variety of technologies employed and the unique elements related to these technologies have resulted in a number of expressed community concerns: Departures based on older technologies (such as the MUSEL SIX) have a relatively wide dispersion pattern of paths across the ground. This has resulted in a commonly held perception by residents on both sides of the Back Bay that aircraft flying the MUSEL SIX departure create flight paths that are less concentrated over a single area but that scatter community overflights over a wide area. Departures based on PBN technologies (such as the DUUKE TWO RNAV Departure) have reduced the dispersion of paths across the ground. However, this has created a widespread community perception that aircraft flying the DUUKE TWO RNAV produce flight paths that are more concentrated and that directly and routinely overfly communities on the east side of the Back Bay. The most recently published RNAV departure (STREL ONE RNAV departure) was designed, in part, to address community concerns about concentrated overflights resulting from aircraft flying the DUUKE TWO RNAV departure. The design of the STREL procedure was intended to shift flight paths to the west over the center of the bay. However, this new path has created the perception that departures are now more highly concentrated over communities on the west side of the Back Bay. 1.2.3. Current Proposals The FAA has proposed a new departure, the RAWLZ ONE RNAV, whose primary purpose is to address airspace issues related to integrating departures from JWA into the airspace infrastructure beyond the immediate vicinity of the airport. The initial proposed design for RAWLZ ONE utilizes the some initial path as the current STREL ONE RNAV departure and does not remedy the community perception of concentrated overflights on the west side of the Back Bay. 1.3. Recommended Solution Based on the design objectives and implementation risks described in this report, GE Aviation recommends modifying the design of the proposed RAWLZ departure using new RNP criteria. This change would eliminate some straight -line flight segments currently in the RNAV design and replace them with a precisely engineered path that consists of a series of curves approximating the center of 004329 -4CS52 Page 7 of 61 Rev New, 28 February 2013 John Wayne Airport Departure Feasibility GE Aviation Assessment Executive Summary the Back Bay —from the departure end of the runway to open water. With community input, the path could be designed to avoid, to the maximum extent possible, populated areas on both the east and west sides of the bay. Furthermore, aircraft flying the RNP departure path would be able to more precisely track the centerline of the new curved path regardless of wind conditions. 1.4. Risks The primary risks to this proposal are regulatory in nature and not technical. These regulatory risks are described in detail in this report and related to the fact that this procedure would represent the first public -use departure procedures using the RNP specification in the United States. These risks include: The specific geometry recommended for the modifications (curved paths) is not explicitly described in the 8260.58 rule set for use in departure procedure design. However, 8260.58 does include specifications for curved paths used in approach procedures. In order to use curved paths for the departure the FAA would need to make an exception for this procedure based on a "waiver" to the regulatory criteria. The timeline to develop and approve this waiver is unknown. Standards related to the charting of the proposed departure do not yet exist and would need to be developed. The mechanism by which airlines are approved to fly an RNP departure is not fully evolved. 1.5. Recommended Next Steps The City of Newport Beach should respond to the FAA requesting modifications to the initial legs of the proposed RAWLZ departure using RNP technology, in accordance with the recommendations of this report. Suggested language for that response is included in Appendix A: Proposed Language. 004329 -4CS52 Page 8 of 61 Rev New, 28 February 2013 April 09, 2013 Page 6 ATTACHMENT B April 10, 2013 Mr. David Soumi Acting Regional Administrator FAA Western - Pacific Region P.O. Box 92007 Los Angeles, CA 90009 RE: Development of an RNP Departure for John Wayne Airport (Orange County, CA) Dear Mr. Soumi: In response to the FAA's offer to the City of Newport Beach to review the proposed RAWLZ RNAV departure, the City and GE Aviation /Naverus have conducted an analysis of recently published criteria related to performance -based navigation (PBN) instrument procedure design, the technical issues related to design and implementation of PBN departure procedures, and the legal challenges surrounding operations at John Wayne Airport. The City believes that as a part of the FAA's NextGen plan, an opportunity exists to improve upon the long- standing issues related to noise mitigation at John Wayne Airport by modifying the proposed RAWLZ RNAV departure to take advantage of the recently published FAA Order 8260.58 PBN Instrument Procedure Design criteria. The City respectfully requests that the FAA consider the following: e Develop the proposed RAWLZ RNAV departure using the RF leg type to design an RNP departure that follows the center of the Back Bay from the departure end of the runway to open water. The path should be designed to avoid the populated areas on both the east and west side of the bay. The city of Newport Beach, through community engagement, could provide appropriate detail to the procedure designers as to the desired location of the path. 9 All elements of the modified departure should conform to the criteria used to design the current proposed RAWLZ departure with the following exceptions: • Waive the required departure leg types to allow for a series of RF legs beginning not later than 1.0 NM past the departure end of the runway and extending out towards the proximate location of the current STREL waypoint. • Construct the RF legs and obstacle evaluation area (OEA) in accordance with FAA Order 8260.58, Volume 6, Chapter 1.3.3 with waivers as necessary to allow for a combination of connected, opposite direction RF legs. o Ensure that the design path remains within the lateral bounds of the current departures being flown at 1WA. 9 April 09, 2013 Page 7 0 Publish the procedure as an RNP -1 with the additional procedure note: "RF required." a Operators could be authorized to fly the procedure via OPSPEC C063. Air carriers currently flying RNAV departures at JWA should already have this authorization. 6 The procedure should qualify as a Categorical Exclusion under FAA Order 1050.1 SEC 311. This could be substantiated during the design and review process through the use of historical radar data. The proposed modifications should not require a substantially higher level of coordination and review with airspace managers and stakeholders than the current proposed RAWLZ RNAV departure. The majority of air carriers flying RNAV departures at JWA are currently equipped with the enabling avionics to fly a departure procedure with RF legs. We look forward to your consideration of this input. We suggest having a discussion on how we could develop a project framework and establish the mechanism that the City should use to define and communicate the location of the desired flight path. Please do not hesitate to contact us at 949 - 644 -3001 (please ask for City Manager Dave Kiff). As always, thank you for your continued concern for communities affected by flight paths. Sincerely, KEITH CURRY Mayor of Newport Beach cc: Members of the Newport Beach City Council Members of the Newport Beach Aviation Committee US Congressman John Campbell US Congressman Dana Rohrabacher Mr. John M.W. Moorlach, Orange County Supervisor Mr. Alan Murphy, John Wayne Airport Thomas Hatch, City Manager of Costa Mesa John Pietig, City Manager of Laguna Beach 19