## 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 9 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. 01

– SPECIAL FEDERAL AVIATION REGULATION (SFAR) FOR

LOS ANGELES COUNTY

– HELICOPTER MINIMUM ALTITUDES

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 “LAAHNC” . 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 the 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 stakeho lders 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 issues 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 resolve th e 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 first of four being filed by LAAHNC.

LAAHNC r equests 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 discretion per 5 U.S.C. Sec. 70 6(1).

Please provide all replies and communications regard this matter to: Gerald A. Silver, (818) 990

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

- 9209, email: ggg@copper.net

Cordially yours,

Bob Anderson, President Los Angeles Area Helicopter Noise Coalition (LAAHNC)PETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 2 of 9 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 ver, (818) 990

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

- 9209, e mail: ggg@copper.net

October 20 , 2015

US Department of Transportation

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

Room W12

- 140 Washington, DC 20590

PETITION NO. 01

SPECIAL FEDERAL AVIATION REGULATION (SFAR) FOR LOS ANGELES COUNTY

HELICOPTER MINIMUM ALTITUDES

This Petition for rulemaking is filed pursuant to S ection 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. LAAHNC repr esents a Southern California a rea 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 helicopter noise and safety issues affecting Los A ngeles 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 helicopter 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 helicopter noise to Los Angeles County.

LAAHNC does not believe these helicopter noise and related 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 broad 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., 40 103(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) protecting 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, sh all prescribe * * * (ii) regulations to control and

abate aircraft noise * * *”PETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 3 of 9 Need for Special Federal Aviation Regulation (SFAR) to Address M inim um Helicopter Altitudes in Los Angeles County

Helicopter noise in Los Angeles County has been a concern to r esidents 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)

solici ted 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 abatem ent 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 economic 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. 2014), d irecting 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 gat hering;

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 participate 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 qua lity 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 a year with various 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 Petitioner 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 ther e are no meaningful changes in their helicopter flight practices to reduce noise. Other helicopter operators have develo ped a brochurePETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 4 of 9 detailing local “hot spots” for the pilot community. The brochure was developed by helicopter pilots unilaterally, rather than 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 complaints 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 number 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 noise 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) for 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 new Special Federal Aviation Regulation (SFAR)

This Petition is to amend Se ction 91.119 of Part 91 of 14 CFR pertaining to minimum safe altitudes over congested, urban areas in Los Angeles County. The following language in sub

- section (d) thereof

shall be struck out:

“(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft . If the operation is conducted without hazard to pers ons or property on the surface

– (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter com plies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.”

This amendment shall add the following language in place of that deleted above:

“ (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft . If the operation is conducted without hazard to persons or property on the sur face

– (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Minimum helicopter flight altitudes in Los Angeles County . Except when necessary for takeoff or landing, or in an em ergency or due to weather conditions or if otherwise necessary for safety of flight, or unless otherwise authorized by the Flight Standards District Office for a purpose listed in Section 3(b), no person may operate a helicopter in the Special Flight Rules Area at an altitude lower than the following:

Los Angeles County, 2 ,000 feet above su rface of the ground level (AGL).

The term ‘surface’ refers to the highest terrain within the area, which is within 2

, 000 feet laterally of the route of flight.PETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 5 of 9 Helicopt ers operated by any municipal, county, state or federal authority for active emergency services, rescue operations, police or fire protection, may be operated at less than the minimum prescribed in this section if the operation is conducted without hazard to perso ns or property on the

surface. ”

Arguments in Support of this Petition

The Petitioner believes that this Petition is reasonable and is in the public interest. It will do the following:

1. Increase the safety of helicopter operations by raising the minimum altitude that they fly. It will improve safety by reducing hazards from helicopters flying at low altitudes which does not allow time for recovery or forced landing preparation in the event of a power failure

2. Provide the Federal Aviation Adminis tration greater authority to enforce minimum safe altitude regulations similar to the provisions for all other aircraft.

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

4. Minimize the intrusion of helicopters in the community by reducing noise pollution in residential areas, near schools, parks and other noise sensitive areas.

5. Significantly reduce the noise impact from he licopter operations for more than ten million Los Angeles County residents.

The P rop osed SFAR Will Improve the Quality of the Natural and Social Environments

The Petitioner asserts that the proposed SFAR is consistent with the National Airspace System (NAS). The Petitioner asserts that this Petition is reasonable, in the interest of protecting and enhancing the natural and social environments. The Hollywood Bowl and numerous other outdoor venues in the County are sensitive to noise. Voluntary agreements between the Hollywood Bowl and local helicopter operators have not been honored nor effective in addressing the problem.

Helicopter noise has a detrimental impact on schools and residences throughout Los Angeles County. School operations are interrupted by the noise of overflying helicopters. Helicopter noise impacts residents’ sleep, interrupts conv ersations and the ability to listen to information from various sources, impacts the ability to enjoy the outdoors, and reduces property values in those areas that experience low altitude helicopter flights. Due to similar situations in other parts of the country, regulations have been imposed in the New York and other areas.

Helicopter noise has a detrimental impact on wildlife and on animal habitats throughout Los Angeles County. Noise associated with helicopter over

- flights cause a significant adverse ef fect on the natural quiet habitat of the Griffith Park and other open spaces in the County. Raising the minimum helicopter

altitude to 2

, 000 f ee t AGL (the long standing FAA advisory altitude for overflying parks) reduces egregious impacts and will reduce n oise complaints.

Because of well

- documented adverse affects on wildlife, SFARs have been enacted by statute for

Yosemite and Haleakala National Parks. See SFAR 50

- 2 and SFAR 71. SFAR 50.2 states: “ The Air Access Coalition sponsored data demonstrate that S FAR 50.2 has reduced aircraft sound levels

si gnificantly at some locations.”PETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 6 of 9 The Proposed SFAR Will Improve Safety for Pilots and P assengers , and Improve Quality

- of

- L ife

f

or Los Angeles County Residents

Low flying helicopters are a danger and nuisance to the residents living in Los Angeles County, and especially the Santa Monica Mountains and the Hollywood Hills. They deprive residents of the peaceful enjoyment of their property. The terrain of canyons and valleys in Los Angeles County focus

and concentrat e aircraft noise to high decibel levels. Helicopters that fly through air space at low altitudes result in serious discomfort, inconvenience and interference with the use and enjoyment of private property. Residents repeatedly complain of helicopter noise drowning out normal conversation, vibrating walls of homes, disturbing sleep, inability the ability to hear or understand speech, television, radio, and telephone and causing general annoyance,

Current FAA regulations permit helicopters to operate at an al titude conducted “without hazard to persons or property on the surface allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.” This regulation leaves the minimum altitude required entirely at the d iscretion of the pilot. This long

- standing minimum altitude exemption of helicopters is an anachronism that society can no longer uphold. When this exemption was originally promulgated many years ago, the population density of Los Angeles County was a frac tion of its present level. In

1950

, the Los Angeles County population was a little more than 1 .9 million. Today it exceeds

10 million people. Millions more are now impacted magnifying the scope of the problem. Moreover, the volume of helicopters comprising air traffic has progressed geometrically.

Much of Los Angeles County south of the Tehachapi Mountains is densely populated with few open spaces. Flying at low altitudes gives a pilot very little time to find a suitable location to land in an emergency. Hi gher altitude provides more time to reach a suitable emergency landing area. NTSB records indicated that of the 146 helicopter accidents in the United States in 2013, about one

- third of these involved loss of power or mechanical malfunction as opposed to p ilot error.

The proposed SFAR would mandate a minimum altitude of 2

, 000 feet AGL for helicopters operating over Los Angeles County, resolving many of these issues. No Safety Risk Management (SRM) evaluations have been done for helicopters operating in Los Angeles County nor has the FAA identified any feasible route modifications to date that could or would lessen noise impacts. In the abundance of caution it is reasonable and logical to assume that a 2 ,000 foo t AGL minimum altitude is preferable to a lack o f any quantitative minimum operating standard.

Relevant Technical and Scientific Information Supporting the N eed for a SFAR

According to the acoustics industry, noise begins to interfere with outdoor speech at 60 dB. Noise testing done by LAAHNC (100 rando m noise meter readings) shows that at an altitude of 2

, 000 feet AGL about half of Robinson Helicopter Company’s helicopter flights still produced more than 62.5 dB (maximum) on the ground

– enough to interfere with speech. Therefore, even at 2

, 000 feet AGL , small helicopters still produce too much noise on the ground. Moreover, 2

, 000 feet AGL does not resolve the problems caused by larger helicopters, including emergency responders and news media, multiple helicopters hovering at the same location, or areas experiencing frequent flights.

The FAA has no relevant noise metric or noise standard for helicopter cruise flyovers. The pilots rely on the helicopter industry’s recommendation as contained in the Helicopter Association International (HAI) Fly Neighborl y Guide. The Guide states that 65 dB (max) is the “generally accepted criterion”. But, it does not indicate by whom it is generally accepted. A committee comprising helicopter industry representatives developed this guideline. The general public was not re presented and had no input. Note that 65 dB interferes with speech on the ground, and that is not acceptable to the community.PETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 7 of 9 In addition, the Guide recommends that helicopters fly at or above 1

, 000 feet AGL to maintain noise levels on the ground under 65 dB. This is not accurate. LAAHNC’s noise testing produced different

results. LAAHNC tests show that at an altitude of 1

, 000 feet AGL, half of Robinson helicopters produce noise on the ground above 69 dB. LAAHNC tests indicate the helicopters tested would have to fly at least 2

, 500 feet AGL in order to keep half of the flights from interfering with speech on the ground.

No studies have ever been done on environmental or economic impacts of helicopters in the Los Angeles area, including impacts associated wi th existing voluntary routes. Data shows that a helicopter flying at 1

, 000 feet AGL produces a noise footprint (averaging from 60 to 69 dB) that is a mile wide, sufficient to interfere with speech on the ground, with potential negative impacts on hundreds of people and businesses for every mile along its flight path.

Los Angeles County Is Unique and Requires a SFAR

At 4,083 square miles Los Angeles County with more than 10 million residents is larger than the

combined areas of the states of Rhode Island and Delaware. The county seat is Los Angeles, 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

nece ssary 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 rou tinely have at least two 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 Pasadena 4. In addition helicopters are flown over Los Angeles County by the California Highway Patrol, Coast Guard, Federal Agencies, news gathering and traffic reporting organizat ions, other neighboring cities, EMS medical/hospitals, other City and County Fire Departments, civilian flight schools, bank check couriers, air charter, air taxis, oil rig transports and utility services and the military. Los Angeles County has without qu estion the most concentrated and ubiquitous helicopter operations in the nation.

Los Angeles County borders 70 miles of coast on the Pacific Ocean, encompasses mountain ranges, deep valleys, forests, islands, lakes, rivers, and desert. Los Angeles County has sub

- tropical Mediterranean climate, characterized by dry summers and a limited winter rainy season with modest

year

- round temperatures. Millions of Los Angeles County residents and visitors spend time out of doors, vastly different life

- styles than the rest of the country.

The Los Angeles basin frequently experiences a unique temperature inversion layer that redirects helicopter noise downward and intensifies helicopter noise on the ground. Homes are built in and near canyons where noise reverberates of f canyon walls intensifying the impact.

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 helicopte rs. Raw video coverage of wild police pursuits is a daily occurrence.

Much of this is from low

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

Los Angeles County is home to the rich and famous. Their backya rds, swimming pools, weddings, events and activities are covered endlessly from the air by paparazzi, radio, television and other media. The County is home to more than 30 helicopter tour operators that fly approximately 85 helicoptersPETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 8 of 9 from twelve airports at low altitudes throughout the day and night. They hover and orbit to view Hollywood

– the entert ainment capital of the world

– the Hollywood Sign, Beverly Hills, Southern California Coastline, Rodeo Drive, movie stars homes, Playboy Mansion, Pacific bea ches, Hollywood Walk of Fame, Hollywood Boulevard, Sunset Boulevard, Kodak/Dolby Theatre home to the Oscars, Grauman’s Chinese, Universal City Walk, Venice Beach, Zuma Beach, Rose Bowl, Hollywood Bowl and of course the affluent Malibu colony. No other part of the country has that much helicopter air coverage in one county.

Los Angeles County has six major film studios

— Paramount Pictures, 21 st Century Fox, Sony, Warner Bros., Universal Pictures, and Walt Disney Studios.

Los Angeles is a common venue for sho oting scenes for motion pictures, commercials, TV shows and music videos. Filming location shoots are conducted night and day throughout the year. The work of film crews out on the streets is frequently stopped because of noise from low flying helicopters.

Numerous other outdoor venues are disturbed by low flying helicopters. Six Flags Magic Mountain, Universal Studios, Hollywood Bowl, Pacific Park, Staples Center, Los Angeles Zoo, Griffith Observatory, Huntington Botanical Gardens, La Brea Tar Pits, Olver a Street, Exposition Park, Farmers Market, Griffith Park, the Los Angeles County Fair in Pomona, the Los Angeles Arboretum, Sepulveda Basin Recreation Area and the RMS Queen Mary in Long Beach are targets for low

- flying helicopters.

Los Angeles County is h ome to Robinson Helicopter Company, the largest manufacturer of civil helicopters in the world. Robinson produced as many as 893 helicopters in a single year. Each is test flown multiple times before delivery, accounting for approximately 5,000 operations per year. Robinson conducts dozens of pilot training classes, numerous marketing and demonstration flights each year impacting a heavily populated portion of Los Angeles County.

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

The proposed SFAR w ill 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 will 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 practicable. Implementatio n 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

environmen tal 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 Government 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 FEDERAL REGISTER as provi ded under Subpart B.PETITION NO. 01

– Special Federal Aviation Regulation ( SFAR) f or Lo s Angeles County Helicopter Minimum Altitudes

LAAHNC page 9 of 9 Executed at Los A ngeles, California on October 20 , 2015

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