SUGGESTED COMMENTS: BUR REPLACEMENT TERMINAL
It is very important to submit comments from as many people during the comment period that is still open, due before 5pm PST on March 1st. A lot of you have submitted comments already, either at the meeting or by sending them in. We encourage you to keep sending comments, and enlist your friends and neighbors! We have some suggested comments written out in detail below, summarized in image form and written out below. Please use these as you see fit, and also put your own stories on how the expansion affects you into your submissions.
ADDRESSES TO SEND LETTERS TO
DETAILED SUGGESTED TALKING POINTS TO PULL FROM ARE BELOW, AND A LETTER TEMPLATE TO REFERENCE IS LINKED HERE (NOTE, YOU'LL NEED TO ADD YOUR OWN EXPERIENCES AND PICK FROM THE POINTS BELOW AS WELL WHEN YOU WRITE YOUR LETTER:
1. Impact Analysis
a. NEPA requires federal agencies to account for all reasonably foreseeable direct, indirect, and cumulative impacts of a proposed project. Here, the impact analysis must account for the reasonably foreseeable possibility that the replacement terminal — with its expanded amenities and increased efficiency —will result in increased departures and arrivals at BUR even if the number of terminal gates remains constant.
b. The impact analysis must use an appropriate baseline. In developing the baseline, the FAA should account for the fact that (i) the Metroplex NEPA analysis did not address the actual departure routes currently flown at BUR; and (ii) the number and routing of BUR departures remains in flux. Pre-Metroplex conditions therefore provide the most appropriate and equitable baseline against which to measure project impacts.
c. To accurately address the significant noise issues at BUR — which will be intensified by the new terminal and supporting infrastructure — the EIS must incorporate and address the following:
Impacts on all noise-sensitive land uses, including schools, parks, open space, preserves, historic resources, and others.
Unique topography, including, in particular, the hills and canyons south of the airport.
Single-event noise measurements.
California and federal noise metrics.
The likelihood that aircraft will not adhere to published departure and arrival routes
d. NEPA requires federal agencies to address the cumulative impacts of their proposed projects together with other past, present, and reasonably foreseeable future actions. Here, the impacts of the terminal replacement project must be considered cumulatively with at least the following:
The Metroplex project
Changes to, and eventual closure of, SMO, including relocation of some SMO operations to other area facilities.
Changes in operations and routes at VNY
Proposed open SIDs for OROSZ 3 and SLAPP 2 at BUR
2. Alternatives and Mitigation
. NEPA’s implementing regulations require the FAA to “rigorously explore and objectively evaluate all reasonable alternatives,” and state that this analysis must be “the heart” of the EIS. The regulations further provide that the alternatives evaluated should be based on the affected environment and the environmental consequences of the proposed action. Because noise is one of the most significant impacts at BUR, the FAA must make a good-faith effort to identify alternatives that would decrease noise impacts in surrounding communities. Those alternatives should include, but may not be limited to, the following:
Alternatives involving time-of-day restrictions
Alternatives involving changes to departure and/or arrival routes, including changes that would keep departures over the Highway 101 corridor
Additional procedures allowing different take-off and landing configurations under certain meteorological circumstances
Alternatives restoring pre-Metroplex routes
b. We understand that some alternatives may be outside the sole jurisdiction of the FAA. But that fact does not preclude their consideration in the EIS. On the contrary, NEPA requires the FAA to fully consider alternatives that may require planning and approval by other agencies.
c. An EIS must fully evaluate measures to help mitigate the potential impacts of a proposed project. Noise mitigation is especially important here.