Audit of the Department of Aviation's Noise Abatement Program, Exams of Aviation

Download Audit of the Department of Aviation's Noise Abatement Program and more Exams Aviation in PDF only on Docsity! OFFICE OF THE CITY AUDITOR – FINAL REPORT March 2, 2021 Mayor Council Members Eric Johnson Carolyn King Arnold Lee M. Kleinman Mayor Pro Tem Tennell Atkins Cara Mendelsohn Adam Medrano Adam Bazaldua Omar Narvaez Deputy Mayor Pro Tem Paula Blackmon Jaime Resendez B. Adam McGough David Blewett Casey Thomas, II Jennifer S. Gates Chad West Mark S. Swann, City Auditor Audit of the Department of Aviation's Noise Abatement Program Table of Contents Executive Summary .......................................................................................................................................... 1 Introduction ....................................................................................................................................................... 2 The City's Voluntary Noise Abatement Program ................................................................................................................... 2 Audit Results ...................................................................................................................................................... 5 Observation A: Noise Level Monitoring .................................................................................................................................... 5 Observation B: Program Management ..................................................................................................................................... 7 Appendix A: Methodology .......................................................................................................................... 11 Methodology ...........................................................................................................................................................................................11 Major Contributors to the Report .................................................................................................................................................11 Appendix B: Management’s Response ...................................................................................................... 12 Audit of the Department of Aviation's Noise Abatement Program 3 On June 15, 2006, the City of Dallas, the City of Fort Worth, Southwest Airlines, American Airlines, Inc, and DFW International Airport entered a joint agreement to resolve the Wright Amendment1 issues. In the agreement, the City of Dallas agrees that it will negotiate a voluntary noise curfew at Dallas Love Field, precluding scheduled airline flights between 11:00 pm and 6:00 am. Subsequently, in the Dallas Love Field Airport Use and Lease Agreement executed on February 13, 2009, Southwest Airlines agreed to adhere to a voluntary noise curfew at the Airport. According to the Department of Aviation's Noise Office, the City currently monitors the following noise reduction components: • Nighttime Preferential Runway: all turbojet aircraft and any aircraft weighting over 12,500 pounds should use runway 13R-31L rather than runway 13L-31R between the hours of 9:00 p.m. and 6:00 a.m. if it does not interfere with flight safety. Runway 13R-31L is located further from residential neighborhoods. Pilots can request any runway, and ultimately air traffic controllers make the decision about which runway to assign. • Trinity Departure: all turbojet aircraft and any aircraft weighting over 12,500 lbs. departing on runway 13R during night operations and when flying south should use a departure route over the Trinity River, which is adjacent to less densely populated areas. • Restrictions on Engine Run-Ups: prohibition of aircraft engine maintenance run-ups between the hours of midnight and 6:00 a.m., expanded with a voluntary moratorium between 10:00 p.m. and midnight. • Optimal Take-Off Profile: the use of a departure profile to quickly achieve a higher altitude and reduce noise. Other than the restriction on engine run-ups, the abovementioned Noise Abatement Program components are voluntary for the airlines and the Federal Aviation Administration. Since the program is voluntary, the City is unable to penalize air traffic controllers or pilots that do not follow the suggested preferences. Some additional components of the noise abatement program initiated by the Department of Aviation have had a positive impact (see Exhibit 1 on page 4): 1 The 1979 Wright Amendment restricted nonstop flights from Dallas Love Field to cities outside of Texas, Arkansas, Louisiana, New Mexico, and Oklahoma. In 2014, the Wright Amendment was repealed by the United States Congress. Audit of the Department of Aviation's Noise Abatement Program 4 Exhibit 1: Source: The Department of Aviation Noise Office's personnel Noise Abatement Additional measures to minimize the noise impact available to the City of Dallas may include a study in accordance with the Code of Federal Regulations, 14 CFR Part 150, Airport Noise Compatibility Planning, which allows airport operators to apply for federal grants for noise abatement projects. The 14 CFR Part 150 study is voluntary and airport operators are not required to participate. Established the Noise Office within the Department of Aviation This Unit consists of one Aviation Environmental Operations Manager and a Noise Monitoring Specialist. Implemented the Casper NoiseLab System The system uses noise and flight monitoring software that monitors, analyzes, reports aircraft noise and flight tracks, and manages noise-related citizen complaints. Hired a Consultant The consultant conducts an annual analysis of Dallas Love Field noise conditions. Established Noise Complaint Reporting Procedures These procedures provide guidance for tracking and responding to citizen noise complaints. Conducted the Love Field Environment Advisory Committee Meetings Love Field Environment Advisory Committee Meetings are held as a quarterly forum for the public and representatives from airlines, the Federal Aviation Adminitration, and the Department of Aviation to discuss issues related to aircraft noise, noise abatement, and airport events. Performed Zoning Change Request Reviews Zoning Change Request Reviews are performed to ensure no new residential developments within high noise areas around the Love Field. Recorded Audio of Flight Instructions The audio of flight instructions that air traffic controllers give to pilots during take-off is recorded to determine the reasons for non-participation for the Nighttime Preferential Runway measure. Audit of the Department of Aviation's Noise Abatement Program 5 Audit Results As required by City Council Resolution 88-3428, departments will establish internal controls in accordance with the standards established by the Comptroller General of the United States pursuant to the Federal Managers’ Financial Integrity Act of 1982. Administrative Directive 4-09, Internal Control prescribes the policy for the City to establish and maintain an internal control system. The audit observations listed are offered to assist management in fulfilling their internal control responsibilities. Observation A: Noise Level Monitoring The land area and population exposed to excessive noise have been increasing and can soon exceed the projections (see Exhibit 2 on page 6). As a result, more residences and other noise sensitive facilities, including churches and schools, may experience adverse effects of excessive noise exposure. Between 2013 and 2019, the annual noise level analysis reports by Harris Miller Miller & Hanson Inc. have identified the actual population and land areas exposed to noise levels above 65 decibels2 and compared these to the 2006 projection of what the population and land areas would be in 2020.3 The Department of Aviation has used the comparison to inform the community of the noise levels. 2 Code of Federal Regulations, 14 CFR Part 150, Airport Noise Compatibility Planning and Code of Federal Regulations, 24 CFR Part 51, Environmental Criteria and Standards, establish 65 decibels as a noise threshold, above which the noise is unacceptable for residential areas, except under limited circumstances. 3 According to the Department of Aviation, the 2006 projection was developed to model potential noise impact without the Wright Amendment. Audit of the Department of Aviation's Noise Abatement Program 8 The nighttime preferential runway has been a focus for the Department of Aviation's Noise Office. This program component encourages turbojet aircraft and any aircraft weighting over 12,500 pounds to use runway 13R-31L between the hours of 9:00 p.m. and 6:00 a.m. rather than runway 13L-31R (if it does not interfere with flight safety), as Runway 13R-31L is located further from residential neighborhoods. Exhibit 4 shows the runway locations in relationship to residential neighborhoods. Exhibit 4: Dallas Love Field and Land Use of the Surrounding Area Source: Dallas Love Field 2018 Day-Night Average Sound Level Contours by Harris Miller Miller & Hanson Inc., Figure 26. Without performance measures in place, there is no guarantee that the current positive trend in usage (see Exhibit 5) will be sustainable or that it will continue to be prioritized. Audit of the Department of Aviation's Noise Abatement Program 9 Exhibit 5: Nighttime Preferential Runway Utilization Source: Dallas Love Field 2013-2019 Day-Night Average Sound Level Contours by Harris Miller Miller & Hanson Inc. *Note: 2013 data was prior to the repeal of the Wright Amendment. Refer to page 3 for more information about the Wright Amendment. Criteria ❖ Standards for Internal Control in the Federal Government: • Principle 3.09 – Documentation of the Internal Control System • Principle 6 – Define Objectives and Risk Tolerances • Principle10 – Design Control Activities s • Principle 16 – Perform Monitoring Activities ❖ The Texas Performance Measure Management Guide We recommend the Director of the Department of Aviation: B.1: Develop and implement documented work procedures for investigating excessive noise complaints. Assessed Risk Rating: Low 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 2013* 2014 2015 2016 2017 2018 2019 Preferential Runway Use Percentage Audit of the Department of Aviation's Noise Abatement Program 10 B.2: Develop and implement documented work procedures for monitoring airline participation in the following program components — Trinity departure, prohibition of engine maintenance run- ups, and optimal take-off profile. B.3: Create performance measures specifying the participation percentage for the nighttime preferential runway usage that would initiate an escalation to next level of actions. Audit of the Department of Aviation's Noise Abatement Program 13 Audit of the Department of Aviation's Noise Abatement Program 14 Assessed Risk Rating Recommendation Concurrence and Action Plan Implementation Date Follow-Up/ Maturity Date Low We recommend the City Manager: A.1: Develop a plan of action aimed at reversing, slowing down, or holding steady the growing land area and population exposed to excessive noise. Accept Risk: The City Manager accepts the risk as revised building codes now include requirements for sound insulation for all new buildings and some modified buildings, which require soundproofing to achieve a DNL of 45 or less inside the building. N/A N/A We recommend the Director of the Department of Aviation: B.1: Develop and implement documented work procedures for investigating excessive noise complaints. Agree: The Department of Aviation will update the existing procedure and develop a checklist for staff to follow and detailed instructions for the training of future staff. 6/30/2021 12/31/2021 B.2: Develop and implement documented work procedures for monitoring airline participation in the following program components — Trinity departure, prohibition of engine maintenance run-ups, and optimal take-off profile. Agree: Trinity Departure: Aviation will initiate reporting on level of use using the Casper Flight Tracking System. However, until the RNAV procedures are implemented by the FAA, the use of the Trinity Departure will remain low. Maintenance run-ups: Aviation will log maintenance run-ups to track compliance with the current measure. Optimal Takeoff Profile: Aviation will receive a written acknowledgment from airlines stating that they are flying the optimal takeoff profile. 6/30/21 6/30/2022 Audit of the Department of Aviation's Noise Abatement Program 15 Assessed Risk Rating Recommendation Concurrence and Action Plan Implementation Date Follow-Up/ Maturity Date B.3: Create performance measures specifying the participation percentage for the nighttime preferential runway usage that would initiate an escalation to next level of actions. Accept Risk: The City Council has not formally reviewed and re-adopted the noise program, including the preferential runway component, in 30 years. The program has some policies which are no longer applicable. In order to update the program to align with the current legal environment, the Department of Aviation will review the Noise Program and make recommendations to Council to revise the program as needed and sunset outdated practices. N/A N/A