DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR PROPOSED RUNWAY 5L/23R:

A GROSSLY INADEQUATE DOCUMENT THAT SHOULD BE DENIED

ARLINE L. BRONZAFT, PH.D.

BACKSLIDING ON NOISE AS A DANGEROUS POLLUTANT

When the United States Congress passed the Noise Control Act of 1972, American citizens were given the right to enjoy an environment free from the noise that would endanger their health and welfare. The government charged the Office of Noise Abatement and Control in the Environmental Protection Agency to carry out this mandate. This charge included speaking to the dangers of aircraft noise. Illustrative of the government’s desire to protect citizens from the hazards of noise are the following quotes:

The statements of these two former federal administrators strongly demonstrated their awareness of noise as a health hazard. Dr. Stewart also understood that it was not necessary to identify every link between noise and health in order to call noise a health hazard. Furthermore, Administrator Russell E. Train, the former head of the Environmental Protection Agency, also acknowledged that those in the aircraft business know how to abate noise but simply lack the will to do it.

The Year 2000 - U.S. Government Regresses on Recognizing Dangers of Noise

It is sad to note that today, many years after Mr. Train’s statements, the aircraft industry as well as the United States government have continued to lack the will to remedy aircraft noise. Worse, those in charge of promoting air travel, for business or pleasure, have totally denied that noise is perilous to one’s health and well-being.

Guilty of this denial of the adverse effects of aircraft noise on human health and welfare is the Federal Aviation Administration which allows Environmental Impact Statements to be written without due consideration to these effects. By failing to include a careful examination of the potential threat of noise to health, the FAA is obviously in violation of the Noise Control Act of 1972 which was written to protect Americans from the dangers of noise. Furthermore, the FAA is mandated to treat environmental impact seriously in evaluating proposed projects. People live in the surrounding areas or the environment of the present proposal and the FAA should be reminded that the word "impact" in DEIS is referring to the impact on these people.

Noise and sound differ. Simply put, noise is unwanted sound. Whereas the human ear reacts to sound through processes that involve the ear and parts of the temporal lobe of the brain, it is the added interpretation by higher centers in the brain that deem the incoming sounds to be wanted or annoying, pleasant or unpleasant; thus transforming sounds into noises. Reactions to sounds that are very loud are less dependent on the individual’s feelings or personal taste regarding the sound. Although individuals can still differ in judging the pleasantness of loud sounds, with, for example, the young loving loud rock music and their parents typically detesting it, exposures to very high decibel levels can destroy the hair cells of the inner ear, leading to some loss in hearing, independent of personal reaction to the sound.

Irrespective of value judgments regarding the desirability of a particular loud sound, continuous exposure to very loud sounds has been responsible for hearing impairment in many millions of Americans. The National Institutes of Health (1990) estimated that of the 28 million Americans who suffer some hearing damage, at least 10 million could be attributed to loud sounds.

Aircraft Noise and Hearing Deficits

The rapid rise of aircraft traffic has brought heightened concern about whether these aircraft noises are loud enough to affect the auditory systems of the multitudes who live with overhead flights night and day. Until recently, the opinion, based upon available data, had been that exposure to aircraft noise should not lead to hearing impairments. However, the volume of overhead flights has never been what it is today. With air travel projected to increase even more in the future, there has been growing interest in looking more closely at this issue.

One study examined the auditory effects of aircraft noise on residents close to Kaohsiung airport in Taiwan (Chen, Chen, Hsieh, and Chiang, 1997). Two groups of individuals, one living near the airport (for at least one year) and one much further away, were compared and the authors concluded that "hearing ability was reduced significantly in individuals who lived near the airport and who were exposed frequently to aircraft noise." Specifically, the hearing thresholds of the majority (93.5%) of the group further from the airport were within normal limits but only 31.3% of the group near the airport exhibited normal limits. In the group near the airport the rate of hearing impairment was 68.7%; in the group not affected by aircraft noise the rate was 6.5%. In the second study, Kozo Hiramatsu and his colleagues (Hiramatsu, et al. 1997) found that a significantly greater number of women who lived near the airbase in Ryukyus, Okinawa airport answered "yes" to a question on whether they were hard of hearing than a group of women not exposed to airport noise.

Unquestionably further studies are called for in the area of aircraft noise and hearing but at the very least the findings of the above-cited studies should have been included in a draft DEIS.

How does noise - unwanted, uncontrollable, and unpredictable sound - affect individuals physiologically? Individuals exposed to noises, whether from an overhead jet or a neighbor’s loud stereo, react to them as they would any stressor. Intrusive sounds which cause stress can bring about a complex set of physiological reactions: a change in heart rate or rhythm, a rise in blood cholesterol, a rise in blood pressure, excessive hormonal secretions. Individuals may feel helpless in the face of pervasive, consistent noise over which they have no control, adding to the stress elicited by the noise stressor.

That noises from aircrafts are disturbing is an obvious point but the number of people that are actually affected by aircraft noise is striking. According to the statistics, compiled a number of years ago, that were cited by Annette Zaner in her article (1991), 14 million people were reported to be disturbed by aircraft noise. Despite the design of "so-called quieter" aircraft, the increase in air travel in the past fifteen years has undoubtedly raised the figure cited by Zaner. However, counting complaints is an inadequate method to assess actual aircraft disturbance because too few people actually complain (Borsky, 1980); thus complaint data are underestimating the annoyance of aircraft noises. With respect to aircraft noise complaints, too many citizens have found that their complaints "fall on deaf ears" and as a result have given up complaining to the authorities.

In a recent study, however, Bronzaft, et al. (2000) found that 62% of the respondents to an international noise survey claimed to be bothered by noises in the neighborhood. This was an unusually high response that might be explained by the fact that people who responded to the survey were more knowledgeable about the dangers of noise. In this survey, motor vehicles ranked first as the most bothersome noise source, motorcycles second, and airplanes and helicopters ranked third amongst the list of over 20 noise sources.

What happens when intrusive noises persist, as they most assuredly do with overhead aircraft? The body continues to react to these intrusions physiologically and over time there is the possibility of permanent bodily damage - damage to the circulatory, cardiovascular and gastrointestinal systems. Research on the non-auditory effects of continuous noise has been undertaken in communities where people have been exposed to noise from highways, railroads, and aircraft. Studies reporting these effects appear in the following: Bronzaft, 1998; Kryter, 1985 and 1994; Fay, 1991; Passchier-Vermeer, 1993.

The European studies cited in the above compilations indicate that individuals living near noisy airports have more cardiovascular and circulatory ailments. Although additional research is needed on the effects of noise on the immune system, studies have reported serum immunoglobulin concentrations falling in relation to noise exposure (Raymond, 1991). Immunoglubulins are linked to the body’s ability to withstand infectious diseases and Raymond calls for further study on the effects of noise on the immune function.

Of particular concern are two recent studies on the effects of noise on children conducted by Gary Evans and his colleagues (Evans, Bullinger and Hygge; 1998; Evans, Hygge and Bullinger, 1995). These authors demonstrated the relationship between aircraft noise exposure and elevated neuroendocrine measures, indicating these children were experiencing stress in their lives. The Evans et al. research also reported increased resting levels of systolic blood pressure in children exposed to aircraft noise. Quoting from the 1995 article: "These data are sobering when one considers that more than 10 million American schoolchildren are exposed to comparable noise levels." (p.337).

In another recent report (Bronzaft, Ahern, McGinn, O’Connor, & Savino, 1998) residents who complained that aircraft noises disturbed them also perceived themselves to be in poorer health. Similarly Hiramatsu, et al. (1997) reported that citizens living near an air base perceived their health to be poorer. It has been well documented that a patient’s perception of health in general, as well as personal evaluations of current health states, health outlooks, and susceptibility to illness, is a valid indicator that has proven useful in detecting health outcomes (Davies & Ware, 1991; Ware, 1986; 1990).

At the very least, the data linking noise and illness, suggest a connection between noise impacts and human health, calling for caution in exposing individuals to repeated noise sources such as overhead planes.

In addition to documented physiological health impacts, noise may dramatically impact an individual’s quality of life. Individuals living near airports may not yet have measurable physiological symptoms but their quality of life may be substantially diminished. In comparing two groups of residents, one living within a flight pattern and one residing in a nonflight area, Bronzaft et al. (1998) found that higher percentages of people exposed to the aircraft noise indicated that they could not open their windows, talk on the telephone, converse with others in their homes, or listen to their radios and televisions, or sleep well. The quality of life of these individuals was significantly diminished, a finding which is corroborated by the Evans, Hygge and Bullinger (1995) study regarding children living near an airport.

The subjects of this study may not yet manifest serious physical illnesses but they are definitely not living the "good life" as they cope with aircraft noise daily.

Repeated overhead night flights may adversely impact the sleep patterns of nearby residents. The Bronzaft et al. study (1998) noted that people living in the flight pattern community, identified as being bothered by the noise, reported themselves to have sleep difficulty. While night flights are of special concern in the area of sleep deprivation, the young, the old and the infirm often tend to sleep during the day, and thus day flights may prove intrusive to these individuals. Sleep difficulty as experienced by the subjects in the Bronzaft, et al. study may have long-term health consequences. Furthermore, sleep loss may impair task performance the next day, rendering individuals less productive in school and the workplace (Pollak, 1991). Dr. Pollak also cautions about a secondary effect for people living near airports. Their inability to sleep may cause them to turn to tranquilizers and other drugs and these drugs in turn may have harmful health implications.

The media is replete with stories of individuals saying that they cannot take the aircraft noise any longer. Their expressed anguish and unhappiness should not be overlooked, remembering that Hiramatsu, et al. (1997) suggest that the psychological disorders identified in their survey of residents living around Kadena Air Base are due to noise exposure.

Laboratory studies (Geen and O’Neal; 1969 and Donnerstein and Wilson, 1976) have demonstrated a relationship between noise and aggression. Individuals stressed by noise do engage in aggressive acts, often against those who have imposed the noise (see media stories cited on the Noise Clearinghouse website, www.nonoise.org). The growing opposition by community groups to increased air traffic and airport expansion may foretell a time when community groups express more hostile behavior in their encounters with airport representatives.

Above-noted studies by Gary Evans and his associates rightfully warned about the dangers of aircraft noise to the physical well-being of children. Kryter (1985) cites research that found children born to mothers living near airports had lower weight and a higher rate of birth defects such as cleft palates. The Committee on Environmental Health of the American Academy of Pediatrics (1997), after examining the studies associating noise with low birth, length of gestation periods, and other potential fetal and newborn problems, issued a document that stated that "fetuses and newborns exposed to excessive noise may suffer noise-induced hearing loss and other health effects."

The American Academy of Pediatrics’ conclusion was bolstered by the fact that the United States National Research Council (1982) had issued a warning that pregnant mothers avoid work in noisy workplaces.

Twenty-five years ago Bronzaft and McCarthy (1975) found that children attending a school near noisy elevated trains lagged behind in reading compared to children attending classes on the quiet side of the school building. By the sixth year, the difference in reading scores between the two groups of children was as much as one year. Evans and Maxwell (1997) recently found that children chronically exposed to aircraft noise in both their homes and schools suffered reading deficits and were slower in cognitive and language development. It is clear from these studies and others cited by Evans & Lepore (1993) that excessive noise levels may have a dramatic, adverse impact upon the development of children.

One should also be aware that parents who are disturbed by noise and who lose sleep because of noisy aircraft may have less patience and time for their children. Thus, children living with noisy aircraft suffer directly from being exposed to the noisy planes and indirectly by being reared by parents stressed out by having to cope with too much noise.

The FAA Draft Environmental Impact Statement for Proposed Runway 5l/23R of the Piedmont International Airport is grossly inadequate and should be denied for not including a critique of the growing body of literature that addresses the relationship between noise and physiological and psychological health. Special attention should have been paid to the research on noise and sleep.

OTHER SHORTCOMINGS OF DEIS

The Draft EIS doesn’t just fail with respect to examining noise impacts on health; the DEIS demonstrates a serious lack of understanding how people respond to noise in general and is written without presenting tables and figures that are clear and comprehensive. For example, in Appendix D, Aircraft Noise Review, there is a table identifying common sounds and their sound levels. Next to the sound levels are these terms "just audible, quiet, moderate, very loud, uncomfortable;" terms that appear to describe human reactions. "Uncomfortable" is listed as falling between 110 and 130 decibels. Even if one were to accept this muddled listing, it should be noted that most research clearly recognizes that humans are discomforted by sounds far less than 110 decibels.

Using tables and figures from resource materials published in the 1970s may not address the noise levels as they exist in the year 2000. For example, one could ask the following questions from Figure 7: Is that apartment in Harlem on the 2nd floor as noisy today as it was in 1974? Similarly, does the touch down at the Los Angeles airport generate as much, less or more noise in a home 3/4 of a mile away today as it did in 1974? Furthermore, when trying to explain noise levels to residents in the Piedmont area, might it not be better to cite comparative levels of noise from sources more familiar to these residents?

Appendix D also uses the Day Night Average Sound Level DNL as the descriptor of choice for airport noise assessment. There has been harsh criticism of the sole use of "day-night average sound level" which measures average sound levels in a 24 hour period because DNL ignores impacts on people of single noise events (Stenzel, 1996; Suter, 1994). From Dr. Suter: "It is very clear that the use of DNL...greatly underestimates the adverse reaction of the community."(p. 16) In the Piedmont matter, where nighttime flights are the issue, single noise events are of greater concern. It is apparent that this DEIS lacks an awareness of the most recent research and thoughts on the DNL and has relied primarily on studies conducted in the 1970s, ironically referred to as "recent studies." This DEIS also considers 65DNL as the level at which people are disturbed by noise; a level that is recognized by many professionals as too high (Stenzel, 1996).

The entire DEIS dismisses the impacts on people. The following statements are supportive of this conclusion. Under Degree of Controversy (p.34 of Executive Summary), it is noted that: "Many of these concerns have been voiced by the communities closest to PTIA. However, much of the larger Triad area appears supportive of the proposed development..." Yes, indeed, it is customary that people who believe they will be losing a decent "quality of life," and possibly their health, will fight to protect themselves. In fact, Berglund and Lindvall (1995) state that "noise is one of the most frequent reasons for public protest."(p.82).

Secondly, on p.21 of the Executive Summary under Noise, we find the following:...all of the alternatives would result in exceedances of the FAA’s ‘Threshold of Significance,’ and mitigation would be considered." How surprising that we finally read of an admission that noise will have an impact, but in using the word "would" with respect to mitigation, we find a total lack of concern for the effects of noise on people.

Since the DEIS has justified its conclusions on outdated information (See Appendix D), has carelessly defined terms in tables and figures, and has completely disrespected human rights and impacts, little weight, if any, should be given to this DEIS.

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