Washington, DC, August 21, 2000 – The National Business Aviation Association (NBAA) today filed extensive comments with the City of Naples, Florida Airport Authority opposing a proposed ban on the operation of Stage 2 business jets at the Naples Municipal Airport.
Federal law requires that any airport proposing access restrictions on jet aircraft first must comply with Part 161 of the FAA regulations. For restrictions proposed on Stage 2 aircraft, Part 161 requires the preparation of a detailed benefit/cost study and a 180-day notice and comment period before the restriction can be enacted. Naples is the first airport to initiate the Part 161 procedure to support a Stage 2 access restriction.
NBAA faulted the airport’s Part 161 study in several respects. Although as a matter of law the 65-decibel contour (day/night average) “remains the FAA’s limit for defining significant noise impact on people,” the Naples study used a 60-decibel contour. “Under the ‘design your own’ standard used in the study,” NBAA stated in its comments, “an airport operator could justify any access restriction on Stage 2 or Stage 3 aircraft simply by pushing the contour out as far as necessary.” The irony, NBAA noted, is that the airport, working with the FAA and the user community, had successfully resolved any noise concerns within the 65-decibel contour. Moreover, three years ago, the FAA approved the airport’s plan to establish a land use buffer zone within the 60-decibel contour. Instead of restricting land use within that contour, the community actively has developed residential uses in that area.
NBAA also faulted the benefit/cost analysis as incomplete and flawed. The study made no effort to quantify the benefits of the proposed ban, and no benefits are apparent. The cost estimates are inconsistent and filled with methodological errors. Finally, the study failed to consider non-restrictive alternatives such as operating procedures that would mitigate noise and sound insulation for properties in the allegedly affected area.
NBAA’s position is firm: a ban on Stage 2 aircraft operations at Naples will violate the law. However, NBAA made it clear that it is remains ready to work with the entire community to assure that continued progress is made in reducing noise at the airport.
NBAA represents the aviation interests of over 6,100 companies which own or operate general aviation aircraft as an aid to the conduct of their business, or are involved with business aviation. NBAA Member Companies earn annual revenues approaching $5 trillion — a number that is about half the gross domestic product — and employ more than 19 million people worldwide. The NBAA Annual Meeting & Convention is the world’s largest display of civil aviation products and services.