## Los Angeles Area Helicopter Noise Coalition

Citizens seeking relief from helicopter noise

– A problem for more than 40 years

LAAHNC, Post Office Box 571448

, Tarzana, CA 91357

- 1448 page 1 of 10 LAHelicopterNoise.org

President

Bob Anderson
Sherman Oaks

Homeowners Association

Vice President

Richard Root

Citizens for Quiet Helicopters (Torrance)

Treasurer
Dave Garfinkle Tarzana Property Owners

Association

George Abrahams Beachwood Canyon Neighborhood Association

John Bailey

Southeast Torrance

Homeowners Association

Gerry Hans
Friends of Griffith Park

David Rankell Van Nuys Airport Citizens Advisory Council

Mike Savidan
Councilman

, City of Lomita

Donna Sievers Bluff Heights (Long Beach) Neighborhood Association

Gerald A. Silver
Homeowners of Encino

Rudy Whitcomb Rolling Hills Estates

Wayne Williams Van Nuys Airport Citizens Advisory Council October 20 , 2015

US Department of Transportation

– Document Operations 1200 New Jersey Avenue, SE West Building Ground Floor

Room W12

- 140 Washington, DC 20590

PETITION NO. 03

– SPECIAL FEDERAL AVIATION REGULATION (SFAR) FOR

LOS ANGELES COUNTY

– MANDATORY MEDIA HELICOPTER POOLING

This Petition for rulemaking is filed pursuant to Section 11.61 of 14 CFR, on behalf of the Los Angeles Area Helicopter Noise Coalition, herein referenced as “L AAHNC”. LAAHNC is an unincorporated non

- profit association seeking to address helicopter noise and safety issues in Los Angeles County.

Helicopter noise in Los Angeles County has been a concern to residents for many years. LAAHNC has worked closely with th e FAA, numerous elected officials, the public and the helicopter industry to address helicopter noise and safety issues affecting Los Angeles County residents. LAAHNC members have participated in 57 major and working group meetings with the FAA and pilot s takeholders since December 2012.

The cooperative efforts between the FAA, aviation associations, airport managers and aircraft operators have failed to produce significant, meaningful results. LAAHNC does not believe these helicopter noise and safety issue s can be resolved without the introduction of Special Federal Aviation Regulations ( SFARs) for Los Angeles County.

The attached Petition was prepared through a joint Board effort of the LAAHNC based our analysis and assessment of the failed efforts to reso lve the significant noise and safety problems plaguing Los Angeles County. The decision to proceed with this Petition was the result of a unanimous vote by our Board.

Please note that this Rule Change Petition is the third of four being filed by LAAHNC.

LA AHNC requests that the FAA treat each Petition submission as a discrete entity evaluating it fully on its merits and adhering to the Administrative Procedures Act and that the evaluation not be arbitrary, capricious or an abuse of discr etion per 5 U.S.C. S ec. 706(1).

Please provide all replies and communications regard this matter to:

Ge rald A. Silver, (818) 990

- 2757, e mail: gsilver4@earthlink.net George Abrahams (323) 463

- 9209, e mail: ggg@copper.net

Cordially yours,

Bob Anderson, President Los Angeles Area Heli copter Noise Coalition (LAAHNC)PETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 2 of 10 Los Angeles Area Helicopter Noise Coalition (LAAHNC)

Post Office Box 571448 Tarzana, CA 91357

- 1448

Please provide all replies and communications regard this matter to:

Gerald A. Sil v er, (818) 990

- 2757, e mail: gsilver4@earthlink.net George Abrahams (323) 463

- 9209, e mail: ggg@copper.net

October20 , 2015

US Department of Transportation

– Document Operations 1200 New Jersey Avenue, SE West Building Ground Floor

Room W12

- 140 Washington, DC 20590

PETITION NO. 03

SPECIAL FEDERAL AVIATION REGULATION (SFAR) FOR LOS ANGELES COUNTY

MANDATORY MEDIA HELICOPTER POOLING

This Petition for rulemaking is filed p ursuant to Section 11.61 of 14 CFR, on behalf of the Los Angeles Area Helicopter Noise Coalition, herein referenced as “LAAHNC”. LAAHNC is an unincorporated

non

- profit association seeking to address helicopter noise and safety issues in Los Angeles County, herein referenced as the “County.” LAAHNC represents a Southern California area with a population

of more than ten million residents. LAAHNC has worked closely with the FAA, numerous elected officials, the public and the helicopter industry to address hel icopter noise and safety issues affecting Los Angeles County residents.

LAAHNC members have participated in 57 major and working group meetings with the FAA and pilot stakeholders since December 2012. LAAHNC proposed numerous methods for reducing helicopt er noise and has worked with pilots and the FAA to address helicopter flights in the County’s complicated airspace. In spite of these extensive efforts LAAHNC has been unable to reach voluntary agreements that would bring substantial reductions in helicopt er noise to Los Angeles County. LAAHNC does not believe these helicopter noise and safety issues can be resolved without the introduction of Special Federal Aviation Regulations (SFARs) for Los Angeles County.

Authority for this Rulemaking

The FAA has broa d authority and responsibility to regulate the operation of aircraft, the use of the navigable airspace and to establish safety standards for and regulate the certification of airmen, aircraft, and air carriers. (49 U.S.C. 40104 et seq., 40103(b)). The FAA ’s authority for this rule is contained in 49 U.S.C. 40103 and 44715. Under § 40103, the Administrator of the FAA has authority to “prescribe air traffic regulations on the flight of aircraft (including regulations on safe altitudes) for * * * (B) protecti ng individuals and property on the ground. (49 U.S.C. 40103(b)(2)). ” In addition, § 44715(a), provides that to “relieve and protect the public health and welfare from aircraft noise,” the Administrator of the FAA, “as he deems necessary, shall prescribe * * * (ii) regulations to control and

abate aircraft noise * * *”PETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 3 of 10 Need for Special Federal Aviation Regulation (SFAR) to Require Media Pooling for Helicopter

O perations in Los Angeles County

Helicopter noise in Los Angeles County has been a concern to residents for many years. Voluntary measures by helicopter pilots to avoid of noise

- sensitive areas in Los Angeles County have been ineffective. Cooperative efforts between the FAA, aviation associations, airport managers and aircraft operators have failed to satisfactory address helicopter noise problems. This has created the need for Special Federal Aviation Regulations (SFARs) for Los Angeles County.

In response to ongoing complaints about helicopter noise, the Federal Aviation Administration (FAA)

solic ited input from local communities and other stakeholders on helicopter noise and safety issues. On May 3 1, 2013, the FAA published the Report on the Los Angel es Helicopter Noise Initiative

. In the report, the FAA expressed support for voluntary noise abatement measures developed by engaged stakeholders and the FAA at the local level and supported by local consensus. The FAA recommended engaging in a local process aimed at reducing helicopter noise that was responsive to community quality

- of

- life and ec onomic interests that was consistent with National Airspace System (NAS) safety and efficiency.

In January 2014, based on the FAA’s May 31, 2013 Report, Congress included language in the Consolidated Appropriations Act, 2014, Pub. L. No. 113

- 76 (Jan. 3. 20 14), directing the FAA to undertake the following six actions:

1. Evaluate and adjust existing helicopter routes above Los Angeles to lessen noise impacts and make adjustments to such routes if the adjustments would lessen impacts on residential area s and

noise

- sensitive landmarks;

2. Analyze whether helicopters could fly safely at higher altitudes in certain areas above Los Angeles County;

3. Develop and promote best practices for helicopter operators for helicopter hovering and electronic news gatherin g;

4. Conduct outreach to helicopter operators to inform them of voluntary policies and to increase awareness of noise sensitive areas and events;

5. Work with stakeholders to develop a more comprehensive noise complaint system; and

6. Continue to parti cipate in collaborative engagement between community representatives and helicopter operators.

The legislation stated that within one year of enactment, the Secretary “shall begin a regulatory process related to the impact of helicopter use on the quality of life and safety of the people of Los Angeles County unless the Secretary can demonstrate significant progress in undertaking the actions.”

This proposed SFAR is consistent with the legislative mandate. The FAA has worked for more than two years with var ious stakeholders to implement these six actions. Unfortunately little or no demonstrable progress has been achieved on these issues. Voluntary practices of helicopter pilots to

avoid noise

- sensitive areas have repeatedly failed to produce results. The Pet itioner believes that positive results cannot be made through the collaborative process alone.

Local law enforcement has identified opportunities to fly neighborly when operations permit. However, they have not agreed to any voluntary measures and there a re no meaningful changes in their helicopter flight practices to reduce noise. Other helicopter operators have develo ped a brochurePETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 4 of 10 detailing local “hot spots” for the pilot community. The brochure was developed by helicopter pilots unilaterally, rather th an through the collaborative process, and it simply reiterates long standing practices that have been ineffective in reducing noise impacts.

The FAA began operating a new Automated Complaint System on April 1, 2015 and is beginning to collect helicopter co mplaints across Los Angeles County. This does not in itself reduce helicopter noise. It simply underscores the growing noise problems. Since its inception in April 2015, between

6

, 500 and 8

, 000 complaints have been file d each month using the system. The nu mber has been increasing, with 7

, 958 complaints filed in August 2015

. LAAHNC is also concerned this system will not be continued or consistently promoted to the public in order to acquire sufficient resident complaint data for an accurate reading of the no ise problem.

The Petitioner believes that all reasonable and collaborative efforts to address helicopter noise and safety problems have failed. The only remaining means to resolve these issues are by imposing Special Federal Aviation Regulations (SFARs) fo r Los Angeles County. The purpose of this Petition is to resolve the problems that have not been adequately addressed by the aforementioned efforts.

The Proposed Language for a N ew Special Fede ral Aviation Regulation (SFAR)

This Petition is to amend Sectio n 91.119 of Part 91 of 14 CFR pertaining to minimum safe altitudes over congested, urban areas in Los Angeles County. The following language shall be appended to

Section 91.119 of Part 91 of 14 CFR:

A. Emergency, unplanned incidents involving helicopter me dia coverage.

(a) When an unanticipated emergency occurs in Los Angeles County that that involves a major freeway incident, significant crime scene investigation, fire, earthquake, flood, disaster or other broad scale infrastructure failure that draws a la rge number of helicopters to the scene, an immediate and mandatory media pool share system must be put in place to manage media helicopter operations in Los Angeles County. Helicopter coverage of other events, such as a Presidential visit, tracking of medi a personalities, coverage of criminal activities and outdoor venues must also be required to adhere to the mandatory pooling system. This system must be a cooperative arrangement run and coordinated by the media industry that use helicopters over Los Angel es County.

(b) The terms, conditions and length of time that a mandatory media pool helicopter is in place over an event shall be at the discretion of the affected public service agency with a maximum time of five (5) minutes for immediate coverage and a minimum return time of ten (10) minutes

. (c) Before implementing a mandatory helicopter media pool, the affected public service agency shall make findings that there is a need for a mandatory media pool to protect public health, safety and general welfare of residents and other persons within their jurisdictions and to allow for the orderly operation of the public service agency and prevent interference from media helicopter traffic.

(d) The requirement to pool helicopter operations shall not apply to any m unicipal, county, state or federal authority helicopter engaged in emergency services, rescue operations, police or fire protection within Los Angeles County.

(e) The mandatory pool coverage shall be given to everyone at the same time; no one can use the stories, pictures or videos until everyone has them. Particip ation in a press pool rotates

– by

m edia, not government selection

– to different outlets each time a “pool” is required.PETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 5 of 10 A. Non

- emergency, planned incidents or events involving helicopter media coverage.
(a) When a foreseeable non

- emergency incident, event or major activity occurs that creates significant traffic problems, freeway closures or major events that draws significant number of media helicopters to the scene in Los Angeles County, a vol untary media pool share must be implemented among media helicopter operators. This system must be a cooperative arrangement run and coordinated by the media industry that oper ate helicopters over Los Angeles County.

(b) The terms, conditions and length of time that the voluntary media pool shall be reviewed by the impacted public service agency. Media seeking to cover the event shall cooperate with authorities in establishing a pool that minimizes noise and safety issues.

(c) The pool coverage shall be prov ided to all participants at the same time; no participant can use the stories, pictures or videos until every participant has them. Particip ation in a press pool rotates

– by me dia, not government selection

– to different outlets each time a “pool” is requ ired.

(d) Al l pool members are expected to “share the load” equally. In the case of ongoing events, a different station might provide a pool reporter and/or camera every day. For one

- time events, each organization may have its own responsibility (such as p roviding all cameras or mobile trucks). If there are different venues, each location can be covered by a different member of the pool. If there is not a practical way to divide the responsibilities, organizations in the pool will split the cost.

(e) Pool m embers shall not use their specia l access in order to garner an “exclusive” for themselves. A pool helicopter photographer is expected to turn over all of the material that was taped rather than keeping certain select shots for his or her own employer. Pri nt pool reporters are prohibited from including any detail in their own stories that was not included in the pool report, even if it is only a matter of local color.

Arguments in Support of this Petition

The Petitioner believes that this Petition is cons istent with the National Airspace System (NAS), is reasonable and in the public interest. It will do the following:

1. Increase the safety of helicopter operations by reducing hazards from media helicopters flying over or near major freeway incidents, sig nificant crime scene investigations, fires, earthquakes or

other critical events.

2. Provide the Federal Aviation Administration greater authority to control media helicopter traffic over major freeway incidents, significant crime scene investigations, fir es, earthquake or other

critical events.

3. Not unduly burden helicopter operators with increased costs or loss of efficiency.

4. Minimize the intrusion of helicopters that interfere with the orderly operation of public service agencies, prevent interfere nce with other helicopter traffic, and protect the public health, safety and general welfare of residents and other persons within Los Angeles County.

5. Significantly reduce the noise impact from h elicopter operations for more than ten million Los Angeles County residents.PETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 6 of 10 The Proposed SFAR Will Improve Safety, Police Efficiency by Managing Helicopter Media Coverage of Critical E vents in Los Angeles County

Low flying helicopters are a danger and nuisance to residents living in Los Angeles County. They depr ive residents of the peaceful enjoyment of their property. Helicopters that fly through Los Angeles County air space at low altitudes result in serious discomfort, inconvenience and interference with the use and enjoyment of private property. Residents rep eatedly complain of helicopter noise drowning out normal conversation, vibrating walls of homes, disturbing sleep, inability to hear or understand speech or television, radio, and telephone conversations.

Televised coverage of car chases in Los Angeles Cou nty has exploded over the last dozen years. This has resulted in many media outlets dispatching helicopters and interrupting scheduled programming to

offer live blow

- by

- blow footage of runaway drivers engaged in car chases. A battery of Internet
entreprene urs have developed an ancillary industry built around notifying police pursuit fans when a chase begins and which channels to watch it on.

Los Angeles has become the world capital of police car chases, with more than 1,000 pursuits annually in the city, m ost of them offering hours of live television coverage. High

- speed car chases are recognized as a road safety problem, as vehicles not involved in the pursuit may be hit by the elusive driver, who will often violate a number of traffic laws, often repeated ly, in their attempt to escape, or by the pursuing police cars. Car chases occur when a suspect uses a vehicle to escape from law enforcement while attempting to avoid arrest. The assumed offence committed may range from minor

traffic infractions to feloni es as serious as murder. When the suspect realizes that they have been spotted by law enforcement, they attempt to lose their pursuers by driving away, sometimes at high speed

– all caught on video.

Los Angeles television station KCAL reported a quadrupli ng of ratings when police pursuits are aired. Police officials have asked news media to reduce coverage of chases, claiming that they encourage suspects to flee and inciting gawkers to possibly get in the way of the pursuit. The media claims that

coverage of chases provides a public service and is a deterrent to police brutality. This Petition does not seek to stop media helicopter coverage of an event, but assures that coverage is provided in a safe and responsible manner.

Unregulated Helicopter Media Coverage is D angerous
Unregulated helicopter coverage is dangerous to helicopter operators, as well as people on the ground. On July 27, 2007 two helicopters crashed in mid air over Phoenix, Arizona while covering a police pursuit. Four people were killed: KTVK pilot Scott Bowerbank and photographer Jim Cox; and pilot Craig Smith and photographer Rick Krolak of KNXV. No one on the ground was injured. This tragic event could have been prevented had media pooling been in place.

Los Angeles officials urged te levision stations to curb their coverage of police car chases which have become a major source of entertainment in Los Angeles County. The growing popularity of high

- speed pursuits in Los Angeles County with its sprawling urban landscape crisscrossed by a tangle of highways and long boulevards, is endangering lives. Former Los Angeles Mayor Jim Hahn said that the televising of chases encouraged lawbreakers. “ They are life

- and

- death situations that put drivers, police officers, pedestrians, other innocent members of the community at risk.” Hahn and former Los Angeles Police Department Chief William Bratton sent a letter to directors of local news stations asking them to reduce their live coverage of what has become near a daily phenomenon in the city.PETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 7 of 10 On S eptember 28, 2012, Fox News aired a live police chase in Arizona that ended in the suspect shooting himself in the head. Fox News was airing it in a five

- second delay instead of a normal ten

second delay, which resulted in the shooting being aired on a liv e broadcast of the Fox Report. Shepard Smith soon apologized for the broadcast and vowed to never let it happen again. The compelling nature of car chases is summed up by the following comment from a Los Angeles County resident: “ I have to be honest, whene ver I see a chase I just have to sit and watch.”

Case histories of media coverage illustrate need for a SFAR

Below are several short case histories that illustrate situations where media helicopters were involved in covering an event that caused huge disru ptions to the public, impeded public safety or interfered with police, fire or other public service activities. The list below spans many decades and illustrates the ongoing need for media helicopter pooling over Los Angeles County.

1. Westwood Water Main Break. On January 21, 2015 a large 6

- inch water main broke in Westwood sending a huge volume of water coursing through city streets. The Los Angeles Department of Transportation was quickly on scene to help with road closures, including Sunset Boulevard Th e deluge of water flooded neighboring streets. The water main break was just north of the UCLA campus, causing extensive damage and requiring shutting down Sunset Boulevard for days. During this closure period dozens of media helicopters orbited and hovere d over Sunset Boulevard and nearby residences causing endless hours of noisy, unnecessary disturbance. This flooding event was unpredictable. The disruptions and nuisance could have easily been prevented or minimized by implementing a voluntary media helic opter pool.

2. Carmageddon 405 Freew ay Closure, July 16

- 17, 2011. “Carmageddon” was the name Los Angeles residents gave the inevitable epic traffic tie

- up that resulted when a 10

- mile stretch of the 405 Freeway

was closed in both directions between the 10 1 and 10 freeways for construction. The 405 Freeway carries about 281,000 cars per day. The clo sure impacted two of the nation’ s busiest interchanges. The unprecedented 53

- hour shutdown delayed motorists for hours on alternate routes with ripple effects on dozens other major highways and alternative routes, as crews demo lished a bridge as part of a
$1 billion freeway

- widening project. During this closure period dozens of media helicopters orbited and hovered over the freeway causing hundreds of hours of noi sy, unnecessary disturbances to residents. This event was predictable many months in advance. The disruptions and nuisance could have easily been prevented or minimized by implementing a media helicopter pool. A year later, when

the second half of the brid ge was removed, the media industry did implement a media pooling of helicopter coverage that significantly limited the impact on residents, but this practice was not formalized for future events as example number 1 above shows. Thus a mandatory media pooli ng system must be put in place.

3. The Lakers’ Victo ry Riot June 19, 2000. The 1999

- 2000 NBA season ended up being fortuitous for the Los Angeles Lakers, who were in their inaugural year playing out of the Staples Center. On the night of June 19, 2000, the Lakers beat the visiting Indiana Pacers, winning their first Championship in twelve years. While the game took place inside the arena, it was broadcast for free outside on a large video screen. Thousands gathered to watch the game on the screen in the pro ximity of the arena. As soon as the game ended, the crowd quickly turned violent as opportunists began attacking property, making bonfires, beating up a Lincoln limo and two LAPD cars, flipping a news van, and setting fire to a Ford Explorer, as well as lo oting local businesses. All local media channels covered the riot live on television and in the air via helicopters. Again excessive noise was generated by the unregulatedPETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 8 of 10 efforts of numerous media helicopters in the air. Clearly the disruptions and nuisan ce could have been prevented or minimized by implementing a media helicopter pool.

4. Democratic National Convention, August 14

- 17, 2000. Another example of unregulated helicopter media coverage occurred at the Democratic National Convention, August 14 to August 17, 2000. In order to provide security from the large number of protestors around the Staples Center, Los Angeles Convention Center (which housed print and radio media), and the large media contingent housed outside in a “Media Village” , the LAPD, L os Angeles Fire Department and United States Secret Service designed a large secure zone surrounded by a perimeter fence consisting of K

- rail barriers with

a 10

- foot fence rising up from it. The parking lots adjacent to the Staples Center were designated f or the large Media Village (consisting of many trailers and media vehicles for the television press), transportation department vehicles, se curity checkpoints, as well as “VIP Vehicles” to be parked immediately in front of the Staples Center. A large numbe r of protestors attended the event. As a result of this layout, the perimeter fence remained a city block away from the Staples Center, and placed the proposed space for the exp ected protestors (known as the “Protest Zone” ) a substantial distance from

the event they were protesting. All of the activities were covered by media helicopters, shooting videotape of protestors and other events downtown during the Convention, causing noise and disturbance to the surrounding community.

5. The North Hollywood shooto ut February 28, 1997. This incident involved a confrontation between two heavily armed and armored bank robbers and officers of the Los Angeles Police Department in the North Hollywood. At 9:17 AM, Larry Phillips, Jr. and Emil M ă t ă s ă reanu entered and robbe d the North Hollywood Bank of America branch. Phillips and M ă t ă s ă reanu were confronted by LAPD officers when they exited the bank and a shootout between the officers and robbers ensued. The two robbers attempted to flee the scene were killed, eleven police officers and seven civilians were injured, and numerous vehicles and other property were damaged or destroyed. Approximately 1,750 rounds of ammunition were fired by the robbers and police. Most of the incident, including the death of Phillips

and the dea th of M ă t ă s ă reanu, was broadcast live by news helicopters, which hovered over the scene

and televised the action as events unfolded. More than 300 law enforcement officers from various forces had responded to the city

- wide TAC alert. During this event doze ns of media helicopter orbited and hovered over the scene generating hundreds of hours of noisy, unnecessary disturbances to residents and interfering with police work.

6. Brown/Goldman Murders. At 12:10 a.m. on June 13, 1994, Nicole Brown Simpson and Rona ld

Goldman we re found murdered outside Brown’ s Bundy Drive condo in the Brentwood area of Los Angeles. Evidence found and collected at the scene led police to suspect that O. J. Simpson was the murderer. Lawyers convinced the LAPD to allow Simpson to turn himself in at 11 a.m. on June 17, 1994, even though the double murder charge meant no bail and a possible death penalty verdic t if

convicted. More than 1,000 reporters waited for Simpson at the police station, but he failed to appear. At 2 p.m., the Los An geles Police Department issued an all

- points bulletin for Simpson. This event caused dozens of media helicopters to orbit and hover over the Bundy Drive condo in Brentwood, causing hundreds of hours of noisy, unnecessary disturbances to residents.

7. O.J. Simpson 405 Freeway Incident. Another example occu rred on June 17, 1994 when

O.J. Simpson, hiding in a white Ford Bronco was driven by a friend down the 405 Freeway, moving at a slow speed. The police pursued the Bronco moving at a low

- speed pace, attracte d dozens of media helicopters. While dozens of car chases and crime scene stories followed by helicopters unfolded on Los Angeles freeways, this event remains one of the strangest, most unforgettable collisions of news,PETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 9 of 10 crime, and celebrity in TV history. The media coverage was incredible as a battery of media helicopter followed the slow speed chase for hours until its conclusion and the arrest of Mr. Simpson.

Media Helicopter Pools are Feasible and E ffective , and Benefit the Public and Helicopter Media

O u tlets

Media helicopter pools are feasible, effective and have been employed by media outlets for decades. On January 14, 2009, WTTG entered into talks with local NBC WRC

- TV to share helicopters and pool news video. On January 14, 2009, WRC

- TV and WTTG ente red into a Local News Service (called LNS) agreement in which the two stations pool video and share news helicopter footage. The agreement is similar to ones already made between Fox and NBC owned

- and

- operated stations in Chicago (WMAQ

- TV and WFLD) and Phi ladelphia (WCAU and WTXF). WUSA later joined that agreement. In 2012, News Director Camille Edwards announced the station would no longer participate in LNS, but the stations would continue to share the helicopter.

The name Local News Service refers to a v ariety of news resource share services all started in 2008 and 2009. Typically, these services include pooling video crews to cover routine events and sharing helicopters used for newsgathering. For 2009, the biggest development for local TV was content

po oling. Since 2000, Fox News, ABC and CBS have been partners in a national news pool partnership. In January 2009, NBC Local Media and Fox Television Stations set up the first Local News Service with their Philadelphia stations after testing since the summe r 2008. Fox and NBC then added other markets were they both own stations. In March, the first local news pool not formed by the NBC

- Fox alliance was formed in Columbus, OH by Media General ’ s WCMH

- TV and Sinclair Broadcast Group’ s WSYX and WTTE.

On April 1 , Fox Stations entered into its first pooling agreements without NBC in Phoenix (KSAZ

- TV)

wit h Scripps’ KNXV

- TV and Meredith’ s KPHO

- TV and in Detroit (WJBK) with Scripps’ s WXYZ

TV. The Fox (WFLD)

- NBC (WMAQ

- TV) partnership on May 11 started its Chicago pool its firs t with

outside members: Tribune’s WGN

- TV and CBS’ s WBBM

- TV. On June 29, 2009, six weeks after the start of the Atlanta group, WGCL

- TV exited the pool as they considered it restraining their ability to

differentiation. The Orlando local news servic e launched July 16, 2009 is the first to include a local news cable channel, Central Florida News 13.

Media outlets have expressed concern that these agreements will cause local news coverage to be overly similar while others believe it will enhance it. Stations claim that pools will help the stations by allowing more specialized reporting by not tying up resourcing for routine events. Media pools are a natural solution along with outsourcing and other partnerships and content sharing to offset revenue

de cline. Successful media pooling arrangements prove that both voluntary and mandatory media pools are doable. Voluntary sharing does not replace the need for mandatory helicopter media pools implemented by public service agencies to control excessive noise over critical incidents.

Los Angeles County Is Unique and Requires a SFAR

At 4,083 square miles

, Los Angeles County with more than ten million residents is larger than the combined areas of the states of Rhode Island and Delaware. The county seat is Los An geles, the

second

- largest city in the United States. Los Angeles County is home to hundreds of based helicopters operated by police, fire, Sheriff, government, media, tour operators, paparazzi and others. An SFAR is necessary to control the impact of this over

- concentration of helicopters.

Los Angeles County is unique to all other parts of the country. The Los Angeles Police Department has a fleet of 19 helicopters, the largest of any police force in the nation. They routinely have at least twoPETITION NO. 03

– Special Fede ral Aviation Regula tion (SFAR) f or Los A ngeles County Mandatory Media Helicopter Pooling

LAAHNC page 10 of 10 helicopters on patrol over the City sixteen hours a day. The Lo s Angeles Fire Department has

6 helicopters that routinely service the Los Angeles area. The Lo s Angeles County Sheriff has

14 helicopters, Burbank/Glendale 3, El Monte 3, Hawthorne 1, Long Beach 2 and Pa sadena 4. In addition helicopters are flown over Los Angeles County by the California Highway Patrol, Federal Agencies, news gathering and traffic reporting organizations, other neighboring cities, EMS medical/hospitals, other City and County Fire Departme nts, civilian flight schools, bank check couriers, air charter, air taxi and utility services and the military. Los Angeles County has without question the most concentrated and ubiquitous helicopter operations in the nation.

Los Angeles County is founded upon the automobile and the car culture with its inherent massive traffic problems. Dozens of media outlets provide video and audio traffic reports each day predominately from helicopters. Raw video coverage of wild police pursuits can be a daily occurren ce. Much of this is from low

- flying helicopters that compete with and interfere with active police investigations and patrols.

The Costs and Benefits Weigh in Favor of the P roposed SFAR

The proposed SFAR will not impose any significant recordkeeping or reporting burden on the helicopter industry, nor on the FAA. It will not negatively affect small businesses, small organizations, small governmental jurisdictions or any Indian tribes. It w ill in fact have a positive impact on the quality of the natural and social environments in Los Angeles County. The Proposed SFAR conforms to International Civil Aviation Organization (ICAO) Standards and Recommended Practices to the maximum extent practic able. Implementation of this SFAR will not involve any of the extraordinary circumstances listed in Section 304 of FAA Order 1050.1E. The SFAR qualifies for the categorical exclusion identified in paragraph 312f of FAA Order 1050.1E. It will have no known negative environmental impacts and will in fact benefit noise

- sensitive locations.

The proposed SFAR does not contain any Federal intergovernmental or private sector mandates. Therefore, the requirements of Title II of the Unfunded Mandates Reform Act of 1995 do not apply. There are no Federalism Implications of this SFAR under the principles and criteria of Executive Order 13132, Federalism. The SFAR will not have a substantial direct effect on the States, on the relationship between the national Governme nt and the States, or on the distribution of power and responsibilities among the various levels of government. This SFAR does not warrant the preparation

of a Federalism Assessment.

The foregoing constitutes the summary that may be published in the FEDERA L REGIST ER as provided under Subpart B.

Executed at Los A ngeles, California on October 20 , 2015

Bob Anderson, President Los Angeles Area Helicopter Noise Coalition (LAAHNC) Info@LAHelicopterNoise.org