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; ,, '-. Mission: To enhance the region's economy and quality of life by providing efficient cargo and air pasSenger accessto national and global markets.
October 16, 2014 Lynne S. Pickard Senior Advisor for Environmental Policy Office ofEnvironment and Energy Federal Aviation Administration 800 Independence Ave SW Washington, DC 20591

RE: Port ofPortland Comments on Federal Aviation Administration's Notice, Implementation of Legislative Categorical Exclusionfor EnvironmentalReview of Peiformance BasedNavigation, Docket No. FAA-2014-0510
DearMs. Pickard,
The Port ofPortland (Port) Aviation Noise ManagementProgram appreciates the opportunity to comment on the Notice "hnplementation ofLegislative Categorical Exclusion for Environmental Review ofPerformance Based Navigation," Docket NumberFAA-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 ofpending PBN Categorical Exclusion actions thatmay affect their communities. I also ask that the FAA work together with the local airport to assess whether community outreach is needed and ifso, 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 ourregion, and connecting our communities globally. For the past three decades, the Port's Aviation Noise Management Program has been aleaderin proactive noise management efforts that balance community needs with those ofa vibrant and growing aviation industry. Through the combined efforts ofengaged 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 ofour lessons learned will be relevant and useful inputs to policy development. Airport involvement in airport PBN projects is critical because ofthe local knowledge that airports offer. This expertise can help ensure successful implementation ofPBN

Port ofPortlandcomments, page 1 nooNEAirport Way Portland OR 97218 Box3529 Portland OR 9nOB 503.415.6000

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procedures and minimize the risk ofcontroversy orrework. At Portland International Airport (PDX), Noise Program staffparticipated in the PBN developmentprocess early enough to help bring potential community impacts and concerns into procedure design discussions. This resulted in an implementation that metindustry goals for enhanced safety, capacity, efficiency, and reduced fuel-bum while complementing the noise program elements developed collaboratively over the pastthirty years. Airports know theircommunities and can help tailor engagement strategies to local conditions- and we can help deliver an effective public outreach program. An understanding ofcommunity expectations; community relationships, and the likelihood ofcontroversy are importantconsiderations when identifying stakeholders and selecting public involvementtechniques. Local expertise can help inform those assessments, provided that airportpartners receive sufficientnotice ofand participation in the process. AtPDX, the project team recognized that the collective efforts ofthe airport, FAA, airlines and the community had created longMstanding noise abatementprocedures that balanced industry and community needs. From thatfoundation, 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 aprocess ofdialog and negotiation and the Port's Citizen Noise Advisory Committee provided inputto the airportregarding the tradeoffdecisions for some ofthe proposed designs. Ibelieve these elements ofairport collaboration and community involvement contributed to our successful implementation. The level ofcommunity interest in and potential controversy overPBNimplementation will vary byproject and location, as will the level ofcommunity engagementrequired. 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 anational level (thatis, providing efficiency, safety, and environmental benefits), may vary from project-toprojectin terms ofspecific prioritization, local impacts, and community concern or opposition. Some projects may result in significant changes (as perceivedby the public) necessitating more outreach, while atPDX, 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 mustbe provided the flexibility to manage projects in away that considers both the needs ofthe National Airspace System and the local stakeholders and communities. Doing so will provide decisionmakers with access to rich information and promote durable decisions. Itwill also reduce the risk ofsurprises 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 PortofPortland comments, page 2 3/4503-415-6829 09:59: 14a.m. 10-16-2014

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. Ifthis is the case, can adecrease in noise within "compatible" exposure levels offsetnoise exposure deemed incompatible? Ifresidents are added to the DNL 65+ exposure, are they entitled to mitigation? Ifso, who is responsible for the mitigation?


### The NNR methodology appears to undervalue the impact ofannoyance resulting from concentration offlight operations. UnderPBN 

### amovementfrom wide flight paths to more narrow corridors is common and can significantly increase operations over specific communities. Although single-eventexposure may bereduced in conventional vs. PBN patterns, the cumulative impact associated with asignificantly higher number of operations can result in community concern, significant annoyance, and ultimately opposition.
The Port ofPortland Aviation Noise ManagementProgram 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 NoiseProgram Manager, Port ofPortland Box 3529 Portland, Oregon 97208

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