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Mission: To enhance the region's economy and quality of life by providing efficient cargo and air pasSenger access to national and global markets. 

October 16, 2014 

Lynne S. Pickard 

Senior Advisor for Environmental Policy 

Office of Environment and Energy 

Federal Aviation Administration 

800 Independence Ave SW 

Washington, DC 20591 

RE: Port of Portland Comments on Federal Aviation Administration's Notice, 

Implementation of Legislative Categorical Exclusion for Environmental Review of 

Peiformance Based Navigation, Docket No. FAA-2014-0510 

Dear Ms. Pickard, 

The Port of Portland (Port) Aviation Noise Management Program appreciates the 

opportunity to comment on the Notice "hnplementation of Legislative Categorical 

Exclusion for Environmental Review of Performance Based Navigation," Docket 

Number FAA-2014-0510, which was published in the Federal Register on August 19, 

2014. 

Specifically, I am writing to ask that the FAA provide local airports with advance notice 

of pending PBN Categorical Exclusion actions that may affect their communities. I also 

ask that the FAA work together with the local airport to assess whether community 

outreach is needed and if so, determine what techniques will be most effective. 

The Port owns and operates three airports in the Portland, Oregon metropolitan area, 

providing access to markets, driving economic activity for our region, and connecting our 

communities globally. For the past three decades, the Port's Aviation Noise Management 

Program has been a leader in proactive noise management efforts that balance community 

needs with those of a vibrant and growing aviation industry. 

Through the combined efforts of engaged citizens, pilots, air traffic controllers, local 

municipalities and Port staff, we have forged partnerships to effectively address the 

challenges inherent in balancing airport operations with community expectations. My 

hope is that sharing some of our lessons learned will be relevant and useful inputs to 

policy development. 

Airport involvement in airport PBN projects is critical because of the local knowledge 

that airports offer. This expertise can help ensure successful implementation of PBN 

Port of Portland comments, page 1 noo NE Airport Way Portland OR 97218 

Box 3529 Portland OR 9nOB 

503.415.6000 

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procedures and minimize the risk of controversy or rework. At Portland International 

Airport (PDX), Noise Program staff participated in the PBN development process early 

enough to help bring potential community impacts and concerns into procedure design 

discussions. This resulted in an implementation that met industry goals for enhanced 

safety, capacity, efficiency, and reduced fuel-bum while complementing the noise 

program elements developed collaboratively over the past thirty years. 

Airports know their communities and can help tailor engagement strategies to local 

conditions- and we can help deliver an effective public outreach program. An 

understanding of community expectations; community relationships, and the likelihood 

of controversy are important considerations when identifying stakeholders and selecting 

public involvement techniques. Local expertise can help inform those assessments, 

provided that airport partners receive sufficient notice of and participation in the process. 

At PDX, the project team recognized that the collective efforts of the airport, FAA, 

airlines and the community had created longMstanding noise abatement procedures that 

balanced industry and community needs. From that foundation, proposed PBN 

enhancements in efficiency and fuel-bum reduction were weighed against potential 

community impacts, including changes in DNL exposure, increases in overflights, and 

increases in noise events over non-compatible areas. The project team achieved 

consensus through a process of dialog and negotiation and the Port's Citizen Noise 

Advisory Committee provided input to the airport regarding the tradeoff decisions for 

some of the proposed designs. I believe these elements of airport collaboration and 

community involvement contributed to our successful implementation. 

The level of community interest in and potential controversy over PBN implementation 

will vary by project and location, as will the level of community engagement required. 

There is no "one size fits all" approach to PBN implementation nor is there a universal 

approach to public outreach. PBN goals, although similar at a national level (that is, 

providing efficiency, safety, and environmental benefits), may vary from project-toproject in terms of specific prioritization, local impacts, and community concern or 

opposition. Some projects may result in significant changes (as perceived by the public) 

necessitating more outreach, while at PDX, the new PBN procedures were consistent 

with legacy procedures, requiring less outreach and generating less concern from the 

community. Local PBN project teams must include airports and must be provided the 

flexibility to manage projects in a way that considers both the needs of the National 

Airspace System and the local stakeholders and communities. Doing so will provide 

decisionmakers with access to rich information and promote durable decisions. It will 

also reduce the risk of surprises and resulting controversy. 

My remaining comments relate to the proposed Net Noise Reduction Methodology 

(NNR). Using the NNR as described, reductions in population exposed from DNL 45-64 

may be used to "offset" increases in DNL 65+. However, federal regulations identify 

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noise exposure below 65 DNL as "compatible" with noise sensitive uses such as homes 

and schools. Exposure levels above 65 DNL are considered non-compatible with noise 

sensitive uses. If this is the case, can a decrease in noise within "compatible" exposure 

levels offset noise exposure deemed incompatible? If residents are added to the DNL 

65+ exposure, are they entitled to mitigation? If so, who is responsible for the 

mitigation? 

The NNR methodology appears to undervalue the impact of annoyance resulting from 

concentration of flight operations. Under PBN a movement from wide flight paths to 

more narrow corridors is common and can significantly increase operations over specific 

communities. Although single-event exposure may be reduced in conventional vs. PBN 

patterns, the cumulative impact associated with a significantly higher number of 

operations can result in community concern, significant annoyance, and ultimately 

opposition. 

The Port of Portland Aviation Noise Management Program fully supports the national 

PBN initiative as we believe it will deliver substantial national and local benefits to 

communities and citizens. I appreciate the opportunity to comment on this proposed 

legislation and would be happy to provide further information. 

Sincerely, 

Philip Stenstrom 

Aviation Noise Program Manager, 

Port of Portland 

Box 3529 

Portland, Oregon 97208 

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