GAO

United States General Accounting Office

Report to the Honorable

James P. Moran, House of

Representatives

June 2000 REAGAN NATIONAL

AIRPORT

Limited Opportunities

to Improve Airlines’

Compliance With

Noise Abatement

Procedures

GAO/RCED-00-74

Page 1 GAO/RCED-00-74 Noise Abatement at Reagan National

Contents

Letter 3

Appendixes Appendix I: Scope and Methodology 26

Appendix II: Comments From the Metropolitan Washington Airports

Authority 28

Related GAO Products 33

Figures Figure 1: Aircraft Flight Path at Reagan National 8

Figure 2: Enforcement Actions for Violations of the Nighttime Noise

Restriction Have Generally Declined 12

Figure 3: Actual Arrival and Departure Observations Along Reagan

National’s Flight Path, October 25, 1999 16

Figure 4: Example Indicating the Position of One Airline’s Departing

Aircraft Relative to the Flight Path at a Point 6 Miles

Northwest of Reagan National 18

Figure 5: Denver International Airport’s ANOMS Provides Detailed

Data on Noise From Individual Aircraft 22

Abbreviations

ANOMS Airport Noise and Operations Monitoring System

CONANDA Committee on Noise Abatement at National and Dulles Airports

DOT Department of Transportation

FAA Federal Aviation Administration

GAO General Accounting Office

MWAA Metropolitan Washington Airports Authority
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Page 3 GAO/RCED-00-74 Noise Abatement at Reagan National

United States General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-284054 Letr

June 29, 2000

The Honorable James P. Moran

House of Representatives

Dear Mr. Moran:

A continuing concern of communities located near commercial airports is

the amount of noise generated by aircraft during takeoffs and landings. At

Ronald Reagan Washington National Airport (Reagan National), the takeoff

and landing paths generally follow the Potomac River north and south of

the airport. In the early 1980s, residents of Maryland, Virginia, and

Washington, D.C., who live along the river urged the Federal Aviation

Administration (FAA) to change Reagan National’s arrival and departure

routes. After testing various alternative departure routes and receiving

negative public reaction, FAA restored the original flight paths. Since then,

local groups have expressed concern primarily about how FAA and the

Metropolitan Washington Airports Authority (MWAA), which operates

Reagan National, interpret and apply the local procedures and federal laws

that may affect aircraft noise for flights to and from the airport.

As agreed with your office, this report responds to your request that we (1)

describe the specific noise abatement procedures at Reagan National, (2)

determine whether the airlines comply with these procedures, and (3)

assess whether local citizen groups believe that existing noise abatement

procedures and penalties are effective.

Results in Brief Local airport procedures and federal laws contain a number of provisions

designed in part to limit aircraft noise at Reagan National. First, a nighttime

noise procedure imposed by the airport authority generally permits flight

operations between 10 p.m. and 7 a.m. only by certain aircraft that can

meet relatively strict noise limits. However, aircraft that were scheduled to

arrive before 10 p.m. may land later if an air traffic controller cleared them

prior to 10:30 p.m. This exception recognizes that aircraft are sometimes

delayed en route. Second, local airport rules require both departing and

arriving flights to follow the Potomac River north and south of the airport

for several miles before turning. In particular, aircraft are prohibited from

flying over federally protected areas in Washington, D.C., such as the

Capitol and White House. Third, airport rules also require pilots of
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departing aircraft to reduce engine power, and thus engine noise, after

reaching either a specified altitude or a certain distance from the airport,

depending on the direction of the aircraft’s departure. Fourth, the airport’s

noise abatement procedure incorporates the federal law that generally bars

airlines from operating nonstop flights to or from any airport located more

than 1,250 statute miles from Reagan National (the “perimeter rule”). In

addition, a federal law and a federal regulation generally limit the number

of flights to 60 per hour (the “high-density rule,” also known as the slot

rule).

Although information available from MWAA and FAA on the number of

violations of Reagan National’s noise abatement measures suggests that the

airlines have generally met local requirements, certain shortcomings in

MWAA’s and FAA’s efforts to monitor airline operations raise doubts about

the extent of the airlines’ actual compliance. With respect to the nighttime

noise procedure, data from MWAA show that violations of that rule have

decreased since the early 1990s, in part because airlines have begun to

replace older, noisier aircraft with newer, quieter versions. MWAA says it

has a high degree of confidence that these aircraft are being operated in

compliance with the noise rule but acknowledges that it could do more to

spot-check compliance. Although FAA’s data indicate that there were very

few instances of pilots’ failure to follow air traffic control instructions

pertaining to the flight path, FAA officials acknowledged that they

generally focus only on keeping aircraft away from the federally protected

areas in Washington, D.C., and do not track the number of incidents where

pilots may have strayed from the flight path over local neighborhoods. With

respect to compliance with the slot rule, FAA officials maintain that there

have been no violations since at least 1994. However, these officials

acknowledged that FAA does not regularly monitor compliance with the

slot rule. Likewise, for reasons pertaining to time, cost, and privacy, it is

impractical to monitor pilots’ compliance with the requirement to reduce

engine power shortly after takeoff. Finally, according to MWAA, airlines

have operated in full compliance with the perimeter rule.

Local groups do not believe that existing procedures and penalties are as

effective as they should be in encouraging airlines’ compliance with noise

abatement requirements. One group representing local communities

asserts that MWAA is not using available technologies to determine which

airlines violate noise abatement procedures and laws. Although MWAA’s 10-

year-old system can provide a limited amount of information on aircraft

noise, other airports are using a new, more sophisticated noise-monitoring
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system to analyze aircraft flight and noise data and communicate that

information to local residents.

We provided MWAA, FAA, and the Department of Transportation (DOT)

with a draft of our report for review and comment. The agencies generally

agreed with our findings but made several technical suggestions, which we

incorporated to clarify the report. The report contains four

recommendations to DOT and MWAA. However, neither agency

commented on these recommendations.

Background Shortly after the nation’s major commercial airlines began jet service at

Reagan National,1 airport noise was officially recognized as an

environmental pollutant. The Federal Aviation Act, as amended in 1968,

authorized FAA to prescribe standards for the measurement of aircraft

noise and to prescribe regulations providing for the control and abatement

of aircraft noise. In 1969, the National Environmental Policy Act began

requiring that environmental impact assessments of proposed airport

construction or improvement projects include aviation noise as a potential

pollutant. Later, the Noise Control Act of 1972 clarified that FAA’s authority

to apply noise standards included issuing, amending, modifying, or

revoking certificates for aircraft type design and equipment. The act further

provided that future certificates for aircraft operations shall not be issued

unless the new aircraft noise requirements are met. The Aviation Safety and

Noise Abatement Act of 1979 set target dates for reducing the number of

the noisiest aircraft then in use. Finally, the Airport Noise and Capacity Act

of 1990 called for all airlines operating jet aircraft weighing over 75,000

pounds in the contiguous United States to meet relatively strict “Stage 3”

engine noise emission limits by December 31, 1999.2 This law allowed

aircraft operators to meet the Stage 3 requirements either by purchasing

new aircraft with quieter engines or by retrofitting existing engines with socalled hush kits, designed to muffle engine noise.

1

Until 1998, the airport was known as Washington National Airport.

2

FAA’s regulations define three classes of aircraft in terms of their noise levels. Aircraft

certified before 1969 that do not meet the noise standards issued in that year are classified

as Stage 1 aircraft (e.g., early-model Boeing 707s and McDonnell-Douglas DC-8s). Aircraft

meeting the 1969 standards (e.g., most Boeing 727s and DC-9s) are known as Stage 2

aircraft. Aircraft complying with more stringent standards issued in 1977 (e.g., Boeing 757s

and MD-80s) are classified as Stage 3 aircraft.
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Beginning in 1982, at Reagan National, specifically, FAA, as airport owner

and operator, placed limits on aircraft operations (takeoffs and landings)

during the nighttime hours. This new procedure restricted all nighttime

operations (10 p.m. to 7 a.m.) by imposing noise limits on departing and

arriving aircraft. Because no airline operating at Reagan National could

meet the nighttime noise limits then in effect, these restrictions

represented a de facto curfew. Soon thereafter, airlines began operating

McDonnell-Douglas MD-80 aircraft, which met the noise limits for landings,

but not for takeoffs. Thus, these aircraft could land at Reagan National

after 10 p.m., but could not depart until 7 a.m. MWAA adopted FAA’s

nighttime takeoff and landing restrictions in 1987, when it assumed

authority for operating the airport. Some aircraft are now quiet enough to

meet the nighttime noise limits, but these limits are stricter than FAA’s

Stage 3 requirements, thereby requiring aircraft operating at Reagan

National during nighttime hours to be quieter than required by the U.S.

national standards. In recent years, airlines have begun introducing quieter

aircraft, such as Airbus A-319s and new Boeing 737s; generally, these

aircraft can meet the nighttime limits governing both takeoffs and landings.

Federal Law and Local

Procedures Limit

Aircraft Noise at

Reagan National

A combination of federal laws and local procedures required by the local

airport authority seek to constrain aircraft noise at Reagan National.3 The

official noise abatement procedure at the airport includes three local

restrictions—restrictions on nighttime noise, flight paths, and engine

power—and the federal perimeter rule. In addition, the slot rule, by limiting

the number of aircraft operations during most hours of the day, also has the

effect of restraining aircraft noise at the airport.

The nighttime noise rule restricts aircraft operations between 10 p.m. and 7

a.m. During those hours, only aircraft that generate less than 72 decibels of

sound may take off, and only aircraft that produce less than 85 decibels

may land.4 An aircraft scheduled to arrive before 10 p.m. may land after that

time if air traffic controllers cleared it for landing prior to 10:30 p.m. This

3

Under federal case law, the abatement of aircraft noise is primarily the airport proprietor’s

responsibility.

4

The noise levels for arrivals and departures are measured in accordance with FAA’s

procedures for aircraft certification. Noise levels for arrival noise and departure noise are

not the same because measurements are taken at different locations relative to the airport.
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Page 7 GAO/RCED-00-74 Noise Abatement at Reagan National

exception exists because weather, air traffic factors, and mechanical

difficulties can sometimes delay incoming flights.

The flight paths to and from Reagan National are restricted in several ways.

• Aircraft departing to the north generally are to fly directly over the

Potomac River until they are approximately 4 miles north of the airport.

At this point, the pilot has the option to continue following the river or

to turn slightly and follow a northwesterly compass heading (“radial”)

until reaching a point 10 miles away from the airport.5 The compass

heading generally follows the Potomac River. According to an FAA

official at Reagan National, the radial gradually widens as the distance

from the airport grows, providing a pilot with increasing latitude to

maneuver the aircraft as it ascends and proceeds away from the

metropolitan area. When an aircraft is 10 miles from the airport—near

the Capital Beltway—the radial is approximately 4 miles wide. Thus, at

this point, a pilot could be about 2 miles off the precise center of the

radial—over either Maryland or Virginia—and still be within the flight

path. Similarly, aircraft arriving from the north are directed to follow the

Potomac once they are within 10 miles of the airport.

• Aircraft departing to the north are directed not to fly beyond the east

bank of the river into restricted airspace over Washington, D.C. This

airspace, which encompasses the Vice President’s official residence at

the U.S. Naval Observatory, the White House, and the U.S. Capitol, is

restricted up to an altitude of 18,000 feet. In addition, if encountering an

emergency situation—for example, conducting a fly-around to avoid

hitting an aircraft on the runway—aircraft arriving from the south are to

turn in time to remain clear of this airspace. This may require the

aircraft to fly due west over residential neighborhoods in northern

Virginia. Doing so may cause local residents to experience high-decibel

noise, but it is the required maneuver to ensure safe operations.

• Aircraft departing to the south are to track the river until they are 5

miles from the airport—beyond the Potomac River’s Wilson Bridge—

before turning toward their destination. Starting 5.6 miles from the

airport, aircraft arriving from the south are to approach the airport

directly over the river.

5

Under the flight path procedure for Reagan National, a relatively small number of flights

that arrive from or depart for certain destinations to the northeast are to follow the

Anacostia River.
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Figure 1 depicts the flight path that pilots are generally supposed to follow

at Reagan National.

Figure 1: Aircraft Flight Path at Reagan National

a

The airspace above the National Observatory is prohibited to commercial air traffic because the Vice

President’s official residence occupies the grounds.

Source: GAO’s depiction of information from MWAA.

Prohibited 

area Potomac River

395

95

Maryland

Anacostia

River

Reagan

National

Airport

Virginia

Wilson

Bridge

Washington, D.C.

National 

Observatorya

328 ̊

radial

95

N
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Page 9 GAO/RCED-00-74 Noise Abatement at Reagan National

Another method of limiting aircraft noise is the requirement that pilots of

aircraft departing to the north reduce engine power to a given target setting

once they have reached an altitude of 1,500 feet or a point 2 miles away

from the airport. Likewise, this “thrust management” procedure requires

pilots of southbound departing aircraft to reduce power at a point 3 miles

away from the airport. Pilots of all departing aircraft are to maintain

reduced engine power until their aircraft reach a point 10 miles from the

airport. At this point, pilots are to increase power to normal climb settings.6

According to FAA and MWAA officials, reducing engine power in this

manner effectively reduces the amount of noise generated during takeoff.

Only an air traffic controller’s instruction to “expedite climb” releases the

pilot from the requirement to maintain reduced engine power.

Although not primarily a noise mitigation rule, the federal perimeter rule

generally bars airlines from operating nonstop flights to or from any airport

located more than 1,250 statute miles from Reagan National. Coupled with

Reagan National’s relatively short main runway, the perimeter rule

effectively prevents airlines from using certain jets that may emit more

noise than some smaller aircraft now operating at Reagan National.

However, many newer aircraft capable of flying beyond the existing

perimeter, such as the Airbus A-320, create less sound than older aircraft

equipped with hush kits, which are now in use at the airport.

Although also not originally intended as such, the federal slot rule for

Reagan National serves as a noise abatement measure.7 A “slot” is an

authorization from the federal government for an aircraft to take off or land

under instrument flight rules during any given hour. The slot rule specifies

that no more than 60 operations—37 air carrier, 11 commuter, and 12

6

According to FAA officials, this procedure is consistent with safe operations and is

considered to be a standard rate of climb for jet aircraft operating at Reagan National.

7

The slot rule was established to reduce delay and congestion at Reagan National and other

major airports. In 1969, facing increasing delays and congestion, FAA applied special air

traffic rules to certain airports that it designated as high-density airports: Chicago’s O’Hare;

New York’s LaGuardia and Kennedy; Newark, New Jersey; and Reagan National. (The

Department of Transportation suspended Newark International Airport’s designation as a

high-density airport in October 1970.) Because of the restricted number of allowable

operations, these airports are generally known as slot-controlled, and the special rules

governing the allowable number of operations are referred to as slot rules. The total

number of slots allowed at Reagan National has remained unchanged, although FAA

reduced the number of air carrier slots from 40 to 37 per hour in 1981. For more information

on the federal slot rule, see Reagan National Airport: Capacity to Handle Additional Flights

and Impact on Other Area Airports (GAO/RCED-99-234, Sept. 17, 1999).
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Page 10 GAO/RCED-00-74 Noise Abatement at Reagan National

general aviation operations—may be scheduled per hour.8 In 1984, FAA

used its exemption authority to permit Braniff Airlines to resume

operations at Reagan National with four slots, even though all air carrier

slots were already allocated.9 In 1990, FAA allocated those four slots to

America West Airlines.10

In April 2000, the President signed legislation directing the Secretary of

Transportation to grant 24 additional exemptions to the slot and perimeter

rules, provided that certain conditions generally relating to increased

competition are met, including a condition that the additional flights do not

result in increased travel delays.11 The legislation specifies that 12 of these

exemptions be reserved for flight operations to and from locations beyond

the existing perimeter and that the remaining 12 be reserved for operations

to small and medium-sized communities inside the perimeter. The

legislation also includes provisions designed to ensure that the quality of

the human environment is not significantly affected and that noise

standards are not compromised.

Airlines’ Compliance

With Noise Abatement

Procedures Appears

High, but Certain

Shortcomings in FlightMonitoring Efforts

Raise Doubts

Although information available from MWAA and FAA on the number of

violations of Reagan National’s noise abatement measures suggest that the

airlines have generally met local requirements, shortcomings in MWAA’s

and FAA’s efforts and abilities to monitor airlines’ operations raise doubts

about the extent of the airlines’ actual compliance. MWAA’s and FAA’s data

indicate that the major airlines generally comply with the procedure

governing nighttime operations and the law concerning slot use. Yet, the

two agencies do not verify whether the airlines comply in practice. At the

same time, it is not possible for MWAA and FAA to determine with certainty

whether pilots comply with procedures governing the airport’s flight path

and the reduction of engine power on takeoff. Although FAA’s radar data

8

The term air carrier generally refers to large commercial jets. The term commuter refers to

smaller jet- or propeller-powered aircraft that typically offer regional service. The term

general aviation refers to nonscheduled operations by small aircraft; at Reagan National, it

generally refers to corporate jets.

9

See FAA Exemption No. 2927 (Feb. 24, 1984). FAA used its statutory authority, since

amended, under 49 U.S.C. section 40109 to grant this exemption from its slot rules on the

basis of a public interest finding.

10See FAA Exemption No. 5133 (Jan. 12, 1990).

11See P.L. 106-181.
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may suggest that an aircraft has violated flight path restrictions, unless

those data can be combined with air traffic controllers’ instructions, they

cannot indicate with certainty whether a violation took place. Furthermore,

it is impractical to fully monitor pilots’ compliance with the procedure

requiring reduced engine power. Under these circumstances, not all

violations are likely to be detected, reported, or investigated, and the exact

extent of airlines’ compliance with the Reagan National noise abatement

procedures cannot be determined. On the other hand, MWAA and FAA

officials agree that airlines have fully complied with the perimeter rule.

Airlines’ Compliance With

the Nighttime Noise

Procedure Appears High,

but MWAA Could Take More

Measures to Verify

Compliance

Available data suggest that airlines’ compliance with the nighttime noise

procedure, as measured by the number of enforcement actions initiated,

has increased since the late 1980s. From July 1982 through December 1987,

roughly the period immediately before MWAA assumed operational control

at the airport, FAA initiated 224 formal enforcement actions against airlines

for operating aircraft that produced excess noise between 10 p.m. and 7

a.m. In those 224 cases, FAA sent 141 letters of correction or warning and

levied 62 civil penalties totaling $41,600. The number of enforcement

actions peaked in 1989, when MWAA initiated 70 enforcement actions.

Since 1989, compliance appears to have improved because the number of

enforcement actions that MWAA has taken has declined. From 1990

through 1999, MWAA initiated a total of 120 enforcement actions. MWAA

officials believe that two major factors contributed to the decrease in the

number of enforcement actions taken for nighttime noise violations. First,

airlines began to replace older, noisier aircraft with newer, quieter versions.

Second, MWAA succeeded in raising the maximum civil penalty it could

assess from $1,000—which, according to MWAA officials, some airlines

regarded as nothing more than a cost of doing business at the airport—to

$5,000. Total civil penalties assessed in 1999 equaled $12,750. MWAA

considers the airlines’ compliance to be very good and believes that its

vigorous and consistent enforcement has led to an improved compliance

attitude among the airlines. Figure 2 shows the number of enforcement

actions that MWAA has initiated against the airlines over time.
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Figure 2: Enforcement Actions for Violations of the Nighttime Noise Restriction Have Generally Declined

Source: MWAA.

MWAA relies on FAA’s reports to determine the types of aircraft that flew

into and out of the airport during the nighttime restricted hours but does

not independently verify whether the newer, quieter aircraft are actually

operated in a manner that complies with established decibel limits.

According to an MWAA official, the agency’s operations staff receive a

report each morning from FAA personnel at Reagan National’s air traffic

control tower showing the types of aircraft that flew into and out of the

airport during the previous evening. Any enforcement action that MWAA

may take depends on the type of aircraft being operated, the lawful

maximum weight at which that aircraft may operate, and the amount of

noise produced at the aircraft’s maximum weight.

• If FAA’s report indicates that certain aircraft, such as an older Boeing

727, operated between 10 p.m. and 7 a.m., MWAA initiates an

enforcement action. All Boeing 727 models clearly produce more than

72 decibels of sound on takeoff and more than 85 decibels on

approach—the sound thresholds for takeoffs and landings.

0

10

20

30

40

50

60

70 Number of violations

Year

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999
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Page 13 GAO/RCED-00-74 Noise Abatement at Reagan National

• MWAA does not verify on a flight-by-flight basis whether flights by

certain newer, relatively quiet aircraft comply with the nighttime noise

standards. For instance, if FAA’s report shows that US Airways—Reagan

National’s largest airline—made a nighttime operation with one of its

newer aircraft, such as an Airbus A-319 or Airbus A-320, MWAA

presumes the flight to be in compliance. MWAA bases this presumption

on US Airways’ obligation to operate its aircraft in accordance with the

“type certificate” provided by the aircraft’s manufacturer—Airbus

Industrie. An aircraft’s type certificate, which is approved by FAA,

specifies its operating requirements, including the maximum weights at

which it may take off or land at particular airports. The certificate that

US Airways holds for its Airbus A-320 operations at Reagan National, for

instance, specifies an allowable takeoff weight of 73.5 tons—about 13

tons less than the maximum takeoff weight that the aircraft could

accommodate, according to Airbus Industrie’s calculations. According

to FAA’s calculations, this combination of aircraft and weight for an

Airbus A-320 generates approximately 69 decibels of sound on takeoff,

which is less than the 72-decibel limit that MWAA allows for nighttime

operations at Reagan National. US Airways managers have agreed with

MWAA to operate all of the airline’s Airbus A-319s and A-320s during

daytime and nighttime hours in a manner consistent with these weight

requirements.

• MWAA presumes that US Airways will abide by those weight restrictions

because it is an obligation under federal law and airport rules, and

because of the severe penalty that FAA could impose on the airline. If

US Airways were to operate one of these aircraft contrary to this

agreement, not only would it be violating MWAA’s nighttime noise

procedure, but it would also be violating a federal aviation regulation by

operating the aircraft in a manner inconsistent with its certificate.12 In

such an event, FAA could apply a range of enforcement actions,

including suspending the airline’s operating certificate—effectively

grounding the airline. However, FAA has notified MWAA that it will not

police how US Airways operates its aircraft, leaving that responsibility

to local airport officials.

• MWAA officials recognize that other newer aircraft, such as Boeing 737-

800s, may or may not meet the nighttime decibel limits, depending on

their weight and how they are operated. MWAA has recently concluded

agreements with two other airlines—Delta and American—about the

12See 14 C.F.R. 121.189.
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weight with which, and the manner in which, their aircraft will be

operated.

According to an MWAA official, MWAA is able to verify whether US

Airways aircraft are complying with the terms of a May 1999 agreement

with the agency. This agreement allows MWAA full and regular access to

company records regarding aircraft takeoff and landing weights. However,

MWAA has not conducted spot checks on US Airways aircraft to determine

whether these aircraft are being operated either in accordance with the

airline’s certificate or in compliance with Reagan National’s nighttime noise

limits. If MWAA conducted such inspections, it would be able to determine

whether US Airways was adhering to the conditions specified in its

operating certificate. According to an MWAA official, the agency has

checked the records, which indicate compliance, but has not yet begun

checks on the actual aircraft, which have been operating at Reagan

National since October 1999.

MWAA and airline officials believe that violations of the nighttime noise

rule are few and will continue to decrease as airlines phase in a new

generation of quieter aircraft. During early 2000, US Airways began

introducing new Airbus A-320 aircraft for its shuttle service to New York’s

LaGuardia Airport, and Delta Air Lines will soon deploy new Boeing 737s

for its competing shuttle service. Operations using these aircraft will be

fully compliant not only with FAA’s nationwide Stage 3 engine-noise

requirements, but also with MWAA’s stricter nighttime noise limits—

provided that they are operated in accordance with the type certificates

provided by the manufacturer or FAA operations specifications with weight

restrictions.

FAA’s Data Suggest but Do

Not Confirm That Pilots

Abide by Air Traffic Control

Instructions to Follow

Reagan National’s Flight

Paths

FAA’s radar data suggest that pilots flying to, from, or near Reagan National

almost always comply with controllers’ instructions to follow the airport’s

approved flight paths. Except in emergency situations, federal aviation

regulations require pilots to follow all instructions from air traffic

controllers. At Reagan National, these instructions incorporate the airport’s

noise procedures, which include a directive to follow the Potomac River

flight path. A pilot’s failure to follow air traffic control instructions as

required by federal aviation regulations is an enforceable infraction known

as a pilot deviation. For example, a pilot’s failure to maintain the altitude

directed by air traffic controllers could be considered a pilot deviation.
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In fiscal year 1999, out of about 330,000 aircraft operations at Reagan

National, FAA initiated 18 enforcement actions for alleged pilot deviations.

This equates to approximately 5 enforcement actions for every 100,000

aircraft operations (takeoffs and landings). From fiscal year 1996 through

fiscal 1998, FAA took enforcement actions against 75 pilot deviations. This

equates to roughly 8 enforcement actions for every 100,000 aircraft

operations. Of all the enforcement actions taken for pilot deviations during

these 3 fiscal years, 63 were against pilots of general aviation or corporate

aircraft and 30 involved pilots of commercial aircraft. In each of these 93

cases, FAA pursued the enforcement action because a pilot failed to avoid

secured federal airspace over Washington, D.C.—not because the pilot flew

over a local residential neighborhood west of the Potomac River.

Figure 3 shows the actual flight paths taken by aircraft arriving at Reagan

National from the south and departing from Reagan National to the north

along the Potomac and Anacostia rivers on a randomly selected day. The

figure highlights the extent to which northbound departing aircraft

generally follow the Potomac River, avoiding the restricted airspace over

central Washington, D.C. It also shows the spread-out pattern of various

points at which aircraft landing from the south turn to fly over the river

from either the Maryland or the Virginia side of the Potomac.
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Figure 3: Actual Arrival and Departure Observations Along Reagan National’s Flight

Path, October 25, 1999

Source: MWAA, based on radar data provided by FAA.

This figure suggests, but does not prove, that some aircraft may have been

west of the flight path at various points during departure, thereby possibly

violating the flight path restriction. FAA officials acknowledged that both

they and airline personnel are generally more concerned about ensuring

that aircraft avoid the prohibited area over Washington, D.C., than about

overflying northern Virginia suburbs. Yet without knowing what the air

traffic controllers’ instructions to the pilots were, it is not possible to

determine with certainty whether the flights shown in figure 3 were

notcomplying with the flight path procedure. Both FAA and MWAA officials

Va.

D.C.

Arrivals Departures Flight path
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reported that controllers are usually unable to recall specific instructions

given to specific flights from a previous day. Thus, these radar data alone

are not sufficient to indicate whether a pilot may have erred.

Despite federal control over the use of airspace, MWAA independently

supplements FAA’s enforcement actions. MWAA periodically tracks aircraft

movements along the airport’s flight paths using FAA’s radar data.13 MWAA

plots the horizontal and vertical position of each aircraft as it passes

through four electronic checkpoints (or “gates”) that bisect the flight path

north of the airport. This information helps noise abatement officials

determine how effectively aircraft maintain their positions over the river.

MWAA later relays this information to the airlines to remind them of the

importance of following the river to minimize the noise generated over

residential neighborhoods. MWAA takes this approach—encouraging

airlines to follow the established flight path—because it does not have the

authority to compel compliance. According to MWAA officials, this has

encouraged airlines to pay closer attention to the local flight path

requirements.

Figure 4 illustrates where an airline’s MD-80 aircraft passed through one of

MWAA’s gates during a randomly selected day. It shows that, at a point

approximately 6 miles northwest of the airport, these aircraft were either

directly above or west of the river (over Virginia) by roughly one-half mile

at altitudes of between 4,000 and 6,000 feet, which is well within the range

of normal altitudes at that point, according to MWAA officials. Again, as

with figure 3, because these data cannot be matched with instructions from

the air traffic controller, these flights could not be considered either to be

off the flight path or operated not in accordance with air traffic control

instructions, according to FAA and MWAA officials.

13At Reagan National, MWAA obtains these data only after a 1-week delay; national security

considerations require the delay to allow time to strip out pertinent information, such as

movements of the President’s helicopter.
B-284054

Page 18 GAO/RCED-00-74 Noise Abatement at Reagan National

Figure 4: Example Indicating the Position of One Airline’s Departing Aircraft Relative to the Flight Path at a Point 6 Miles

Northwest of Reagan National

Note: GAO’s depiction based on data supplied by MWAA.

Determining Pilots’

Compliance With Engine

Power Procedure Is

Impractical

Because there is no practical way for MWAA or FAA to do so, assessing

whether airlines and their pilots comply with Reagan National’s procedure

requiring reduced engine power on takeoff is virtually impossible. MWAA

and FAA officials told us that determining whether a pilot has complied

with Reagan National’s power management procedure could theoretically

be done in two ways. Yet according to these officials, neither of these two

options is currently feasible.

• First, FAA could propose new rules that would require airlines to install

video cameras in the flight deck of all aircraft to monitor pilots’

decisions. The Air Line Pilots Association—a union representing 55,000

pilots at 51 North American airlines—has generally opposed installing

video recorders in cockpits, citing concerns about pilots’ privacy and

the misuse of information obtained from the recorders. The union

-10,000 -5,000 0

Va. Gate in-plane coordinates in feet D.C.

-15,000 15,000

0

2,000

4,000

6,000

Potomac

River

8,000

5,000 10,000
B-284054

Page 19 GAO/RCED-00-74 Noise Abatement at Reagan National

supports the use of cockpit video recorders for accident investigation

purposes only. Because current flight data recorders (i.e., the “black

box”) capture data on engine throttle settings, the union maintains that

any cockpit video recorder must be installed to ensure that it focuses on

and records only the instrument panel of the cockpit and not the flight

crew’s activity, including how they set engine throttles. Thus, such union

concerns effectively prevent cockpit video recorders from being used as

a means to determine compliance with engine power requirements.

• Second, FAA officials could retrieve the flight data recorder from an

aircraft to determine whether a pilot properly reduced engine thrust.

However, because the recorder is designed to produce data for only the

last 30 minutes of a flight, information pertaining to an aircraft’s takeoff

would be missing for all flights into or out of Reagan National. In

addition, according to information from Delta Air Lines, obtaining

engine thrust information from the flight data recorder is also not

feasible because removing that equipment from aircraft is both timeconsuming and costly.

FAA’s Data Indicate No

Violations of the Slot Rule,

but Lack of Ongoing

Monitoring Makes It

Difficult to Fully Assess

Airlines’ Compliance

As we have reported in the past, FAA does not have a systematic way to

monitor compliance with or enforce violations of Reagan National’s slot

rule.14 To determine that an airline has violated the slot rule, FAA officials

told us they must find that the airline displayed a pattern of operations that

diverges significantly from scheduled times and did so intentionally. FAA

staff do not consider single events in which aircraft arrive early or late to be

violations because various factors outside the airline’s control (e.g., poor

weather and air traffic delays) can affect aircraft operations.15

FAA officials acknowledged that, although they routinely attempt to

discern patterns indicating airlines’ intent to violate the slot rule, they do

not regularly compare airlines’ scheduled operations with their actual

operations. Even were they to do so, officials stated that they do not have a

firm definition for exactly when a consistent pattern of delays or early

14See Airport Noise: FAA’s Enforcement of Noise Rules at National Airport (GAO/RCED-88-

117, Apr. 15, 1988).

15The slot rule specifically exempts certain types of unscheduled operations—that is,

operations that are not regularly scheduled—from the hourly limits. These exceptions

include (1) charter flights, (2) extra sections of scheduled commuter or air carrier flights

(e.g., the “shuttle”) that may have been overbooked, and (3) the movements of empty

aircraft to position them for future operations.
B-284054

Page 20 GAO/RCED-00-74 Noise Abatement at Reagan National

operations constitutes a slot violation and that they do not use an

established period of time—for example, 30, 60, or 90 days—against which

to measure airlines’ compliance. FAA officials said that they had recorded

no violations of the slot rule at Reagan National since at least 1994.

Our analysis of flight operations data, however, revealed numerous

situations that would seem to merit additional investigation by FAA. We

independently analyzed information on flight arrivals and departures

covering the period from September 30, 1999, through December 31, 1999.

Of the approximately 580 scheduled daily operations by large air carriers

(large jets) at Reagan National, 8 flights appeared to arrive consistently at

times other than their scheduled hours. One of those flights arrived at

Reagan National not during the 9 p.m. hour but after 10 p.m. nearly 90

percent of the time. Similarly, several other flights departed Reagan

National consistently in hours other than their scheduled hours. For

example, of the five flights that airlines scheduled to depart precisely at 8

a.m., four departed ahead of schedule at least 70 percent of the time.

Airlines Have Fully

Complied With Reagan

National’s Perimeter Rule

MWAA officials report that the airlines are in full compliance with the

perimeter rule, which bars airlines from operating nonstop flights to and

from destinations located more than 1,250 miles from the airport. Industry

officials agree that an airline could not schedule, market, or operate a flight

to or from a point beyond the perimeter without FAA’s, the general public’s,

and especially competing airlines’ taking notice and reporting the flight to

MWAA.

Local Groups Believe

That MWAA’s and FAA’s

Efforts to Monitor and

Enforce Noise

Abatement Procedures

Could Be More

Effective

Although officials with MWAA, FAA, and key airlines operating at Reagan

National generally regard these noise monitoring and enforcement efforts

as effective, outside groups have a somewhat different opinion. For

example, the Committee on Noise Abatement at National and Dulles

Airports (CONANDA)—an advisory committee of the Metropolitan

Washington Council of Governments, which is a regional planning

authority composed of locally elected officials—believes that MWAA’s

noise abatement efforts at Reagan National are not effective enough. This

committee believes that, while aircraft are generally operating within

Reagan National’s prescribed departure radial, many aircraft create

excessive amounts of noise over local neighborhoods by not tracking the

Potomac River as closely as possible.
B-284054

Page 21 GAO/RCED-00-74 Noise Abatement at Reagan National

CONANDA officials asserted that MWAA cannot adequately respond to

local residents’ concerns about the noise generated by particular aircraft.

They stated that a more sophisticated system in use at Denver International

Airport can identify the source, location, and decibel level of individual

noise events with great accuracy and could possibly have applications at

Reagan National. For instance, Denver’s $2 million Aircraft Noise and

Operations Monitoring System (ANOMS) combines data recorded at noisemonitoring stations located in noise-sensitive areas around the airport with

flight progress data from FAA. ANOMS can then identify the amount of

noise generated by particular aircraft at specific points along their arrival

and departure flight paths. Figure 5 displays a sample of data available

from ANOMS. The figure shows an arriving aircraft’s flight path and

altitude, along with the noise that the aircraft generated at a particular

point.
B-284054

Page 22 GAO/RCED-00-74 Noise Abatement at Reagan National

Figure 5: Denver International Airport’s ANOMS Provides Detailed Data on Noise

From Individual Aircraft

Source: Denver International Airport.

Denver airport officials noted that ANOMS has provided at least two

significant benefits. First, because ANOMS can combine flight path and

noise data to identify a particular, high-decibel event with greater precision

than some other systems currently in use, airport officials are better able to

respond to area residents’ complaints about aircraft noise. Using ANOMS

data, the airport can readily provide local residents with detailed

information about the particular noise event, including whether the flight

took off from or was landing at Denver’s airport or nearby military

facilities. Second, under the intergovernmental agreement that governs

Arrival

January 14, 2000

United Airlines 1157

Boeing 737-300

Monitoring 

device measured

68 decibels of 

sound at this point. 

Flight path

Altitude
B-284054

Page 23 GAO/RCED-00-74 Noise Abatement at Reagan National

noise abatement at Denver, violations are generally defined in terms of the

total amount of noise averaged over a period of time. Consistent with

federal measurements of noise levels, single high-decibel events are not

themselves subject to legal action. Denver’s ANOMS is designed in part to

capture the data needed to make these determinations.

Conclusions Airlines’ compliance with two important noise abatement procedures—

limiting nighttime aircraft operations and capping the number of hourly

slots in which airlines may operate—appears to have been high during

recent years. Nevertheless, we believe that MWAA’s and FAA’s statistics on

violations of these measures may understate the actual number because

not all violations are likely to have been detected, reported, or investigated.

For example, MWAA has not checked to determine whether certain aircraft

types comply with its nighttime noise procedure and FAA has not

systematically monitored compliance with the slot rule. If MWAA and FAA

were to police these requirements more aggressively, they may find more

situations that should be investigated, reported, and enforced. At the same

time, while airlines’ compliance with two other procedures—flight path

and engine power management—also appears high, several matters create

uncertainty for MWAA and FAA in their efforts to determine whether

airlines and their pilots comply in practice. To achieve certainty on flight

path compliance, FAA’s radar data would need to be combined with a

controller’s recall of a single flight event, which is difficult or impossible, as

shown by experience. Moreover, because there are no flights into or out of

Reagan National of less than 30 minutes’ duration, it is impossible to

retrieve engine thrust information from flight data recorders. As a result, it

is impractical to determine the extent to which pilots reduce power shortly

after takeoff.

More advanced noise detection technology would be able to provide

residents who complain about particular noise events with greater amounts

of information. However, MWAA would still be hampered in its efforts to

disseminate this information by FAA’s obligation to clean raw radar data

pertaining to national security flights. This exercise delays MWAA’s ability

to analyze these data by at least 1 week. MWAA may also be hampered by

its inability to position monitoring stations as Denver did because the

Potomac River covers much of the noise-sensitive area around Reagan

National.
B-284054

Page 24 GAO/RCED-00-74 Noise Abatement at Reagan National

Recommendations to

the Metropolitan

Washington Airports

Authority

To ensure that airlines operating at Reagan National during nighttime hours

do so in compliance with the local nighttime noise rule, we recommend

that the President/Chief Executive Officer, Metropolitan Washington

Airports Authority, commit to a schedule of randomly verifying that

arriving and departing aircraft are being operated in a manner consistent

with the terms of legally binding agreements that some airlines have

reached with MWAA and FAA. We also recommend that the President/Chief

Executive Officer, Metropolitan Washington Airports Authority, study the

relative benefits and costs of procuring a more technologically advanced

noise-monitoring system.

Recommendations to

the Secretary of

Transportation

To improve oversight of the federal slot rule, particularly in light of the

addition of 24 flights at Reagan National, we recommend that the Secretary

of Transportation direct the Administrator, Federal Aviation

Administration, to (1) develop a reliable method (including definitions and

procedures) for consistently determining whether airlines are complying

with the federal slot rule and (2) maintain a system of records of the

violations identified and FAA’s disposition of them in a form that will enable

FAA to evaluate its overall monitoring and enforcement effort.

Agency Comments We provided MWAA, FAA, and DOT with a draft of our report for review

and comment. We met with officials from FAA, including a senior attorney

from the Office of the General Counsel, officials responsible for monitoring

airlines’ compliance with the slot rule, and a manager from the Flight

Standards District Office that oversees Reagan National’s flight operations.

FAA generally agreed with our findings but asked us to clarify technical

issues concerning slot use and engine power management. We

incorporated these remarks as appropriate. FAA did not comment on our

recommendations. DOT did not comment on the facts, findings, or

recommendations contained in our draft report.

MWAA generally agreed with our findings but said we should clarify our

presentation on several matters, including the purpose of the airport’s

perimeter rule and nighttime noise procedure, which we incorporated as

appropriate. MWAA did not comment on our recommendations. MWAA’s

comments and our responses are included as appendix II.
B-284054

Page 25 GAO/RCED-00-74 Noise Abatement at Reagan National

We conducted our review from October 1999 through June 2000 in

accordance with generally accepted government auditing standards. (For a

detailed description of our scope and methodology, see app. I.)

As arranged with your office, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 30 days after the

date of this letter. At that time, we will send copies of this report to the

Honorable Rodney E. Slater, Secretary of Transportation; Ms. Jane Garvey,

Administrator, Federal Aviation Administration; Mr. James Wilding,

President/Chief Executive Officer, Metropolitan Washington Airports

Authority; and the Honorable Jacob J. Lew, Director, Office of Management

and Budget. We will make copies available to others on request.

If you have any questions, please call me at (202) 512-2834. Key

contributors to this report were Steven C. Martin, Aaron Casey, and David

Hooper.

Sincerely yours,

John H. Anderson, Jr.

Director, Transportation Issues
Page 26 GAO/RCED-00-74 Noise Abatement at Reagan National

Appendix I

Scope and Methodology ApApenednxidexiIs

To describe the noise abatement procedure at Ronald Reagan Washington

National Airport (Reagan National), we reviewed documentation from the

Metropolitan Washington Airports Authority (MWAA) regarding the four

methods—nighttime operating restrictions, flight path restrictions, engine

power management, and the perimeter rule—on which it formally relies for

abating noise at the airport. We reviewed applicable local procedures and

federal laws and met with officials representing MWAA and the Federal

Aviation Administration (FAA) to obtain an interpretation of these

procedures and laws, including their purpose. We interviewed officials with

both agencies to understand how each of these procedures and laws may

limit aircraft noise. In addition, we interviewed officials with FAA’s slot

administration and general counsel’s offices to obtain a description of how

the slot rule may also serve as a noise abatement procedure.

To determine whether airlines comply with Reagan National’s noise

abatement procedures, we interviewed MWAA and FAA officials, analyzed

available enforcement data, reviewed case files, and independently

assessed data on aircraft operations at the airport. Specifically, to assess

the extent to which airlines comply with Reagan National’s nighttime noise

limits, we interviewed officials with MWAA’s noise abatement and general

counsel’s offices and reviewed documentation from FAA and MWAA

regarding how determinations are made about the noise emitted by new

aircraft. To determine whether airlines are complying with federal

regulations requiring pilots to follow air traffic controllers’ instructions, we

interviewed officials with FAA’s offices of Air Traffic Services and Flight

Standards Services. Additionally, we reviewed data from FAA on the

number of reported and investigated pilot deviation cases during the past 4

fiscal years. To examine whether pilots comply with the procedure

requiring reduced engine power during takeoff, we interviewed officials

with MWAA and FAA’s Office of Environment and Energy. To assess

airlines’ compliance with the federal perimeter rule, we interviewed staff

with MWAA’s Office of the General Counsel. Finally, to understand whether

airlines are complying with the slot rule at Reagan National—and how FAA

searches for slot use patterns—we interviewed officials with FAA’s Office

of the General Counsel and Office of Slot Administration. We

independently reviewed and analyzed FAA’s data comparing airlines’

published schedules for the period between September 30, 1999, and

December 31, 1999, at Reagan National, against data on actual operations

during the same period. We selected this period because it provided the

most recent data available. In our analysis, we used FAA’s data on the time

that aircraft arrived at the gate, instead of the time that the aircraft’s wheel

touched down on the runway, as the arrival time. Similarly, for the analysis
Appendix I

Scope and Methodology

Page 27 GAO/RCED-00-74 Noise Abatement at Reagan National

of departure times, we used FAA’s data on the time that aircraft pushed

back from the gate and not the time that aircraft wheels lifted off the

runway.

To assess the extent to which parties concerned with aircraft noise at

Reagan National believe that existing procedures and penalties are

effective in encouraging airlines’ compliance, we interviewed staff

representing the Metropolitan Washington Council of Governments’

Committee on Noise Abatement at National and Dulles Airports. In

addition, on several occasions, we attempted to contact another interested

party—Citizens Against Aircraft Noise—that has campaigned for a

reduction in aircraft noise at Reagan National. However, this party did not

respond to our inquiries. Finally, for the purpose of comparison with noise

abatement efforts at Reagan National, we met with officials representing

Denver International Airport to assess that airport’s own such efforts.

We conducted our review from October 1999 through June 2000 in

accordance with generally accepted government auditing standards.
Page 28 GAO/RCED-00-74 Noise Abatement at Reagan National

Appendix II

Comments From the Metropolitan Washington

Airports Authority ApendxiI

Note: GAO’s comments

supplementing those in the

report text appear at the end

of this appendix.

See comment 1.
Appendix II

Comments From the Metropolitan

Washington Airports Authority

Page 29 GAO/RCED-00-74 Noise Abatement at Reagan National

See comment 5.

See comment 2.

See comment 3.

See comment 4.

See comment 1.

See comment 1.

See comment 4.

See comment 1.
Appendix II

Comments From the Metropolitan

Washington Airports Authority

Page 30 GAO/RCED-00-74 Noise Abatement at Reagan National

Now on p. 11.

See comment 1.

See comment 1.

Now on p. 13.

See comment 1.

See comment 1.

See comment 1.
Appendix II

Comments From the Metropolitan

Washington Airports Authority

Page 31 GAO/RCED-00-74 Noise Abatement at Reagan National

See comment 1.

See comment 1.

See comment 1.
Appendix II

Comments From the Metropolitan

Washington Airports Authority

Page 32 GAO/RCED-00-74 Noise Abatement at Reagan National

The following are GAO’s comments on the Metropolitan Washington

Airport Authority’s letter of May 25, 2000.

GAO’s Comments 1. We have incorporated this change.

2. We disagree with the change suggested by MWAA. Airport rules—and not

FAA’s noise abatement procedures—oblige pilots to reduce engine power

after reaching an altitude of 1,500 feet. FAA does not establish noise

abatement operating procedures for individual airports, although it does

offer advisory guidance. Accordingly, we did not make this suggested

change to our report.

3. We agree that, technically, the perimeter rule was not originally

established at Reagan National as a noise abatement provision, and

because we discuss this in the body of the report, we made no change to

the Results in Brief language.

4. We do not agree that the noise created by an aircraft is unconditionally

related to whether or not it is capable of flying beyond the 1,250-mile

perimeter at Reagan National. Many large newer aircraft (e.g., the Airbus A320), which typically operate at weights exceeding those of some older

smaller aircraft (e.g., the Boeing 727), can easily fly to and from

destinations located beyond the perimeter. These newer aircraft are

equipped with engines designed to emit less noise than some older aircraft,

even though they are heavier. Accordingly, we did not modify the report in

response to this comment.

5. Although we agree with MWAA that the major airlines have

demonstrated a high degree of compliance with the airport’s nighttime

noise procedure, we do not agree that the major airlines have definitively

complied in all cases. We believe that MWAA’s proposed deletion of the

word “generally” implies that the airlines have definitively complied.
Page 33 GAO/RCED-00-74 Noise Abatement at Reagan National

Related GAO Products

Reagan National Airport: Capacity to Handle Additional Flights and Impact

on Other Area Airports (GAO/RCED-99-234, Sept. 17, 1999).

Aircraft Noise at Memphis International Airport (GAO/RCED-97-37R, Dec.

17, 1996).

Transportation Noise: Federal Control and Abatement Responsibilities May

Need to Be Revised (GAO/RCED-90-11, Oct. 12, 1989).

Aircraft Noise: Eight Airports’ Efforts to Mitigate Noise (GAO/RCED-89-

189, Sept. 14, 1989).

Aircraft Noise: Status and Management of FAA’s West Coast Plan

(GAO/RCED-89-84, May 8, 1989).

Aircraft Noise: Implementation of FAA’s Expanded East Coast Plan

(GAO/RCED-88-143, Aug. 5, 1988).

Airport Noise: FAA’s Enforcement of Noise Rules at National Airport

(GAO/RCED-88-117, Apr. 15, 1988).

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