Dear Ms. D'Alessandro,
We write regarding the August 14, 2020 consolidated Federal Aviation Administration (FAA)/Industry stakeholder assessment of eight preliminary Boston MIT Block 2 proposals related to Runways 33 Left and 22 Right/Left.
In October 2016, the FAA, Massport, and our respective offices signed a Memorandum of Understanding (MOU) to study the noise impacts of Area Navigation, or RNAV, at Boston Logan International Airport. The first stated objective of that MOU was to "identify specific proposed ideas to reduce overflight noise from RNAV concentration." After nearly four years of significant study and effort, the Massport Community Advisory Committee (CAC) requested that the FAA provide an early feasibility assessment to a series of Block 2 RNAV design concepts for RWY 33L/22L/R at Boston Logan International Airport. There were eight different proposals presented, and the assessment for all eight was that they were each "not a candidate for further evaluation."
Although we appreciate your willingness to provide this early assessment, it is deeply disappointing that after four years of work to address the issue of overflight airplane noise caused by RNAV, the assembled stakeholders would reject all eight proposals as not needing "further evaluation." We understand that this assessment does not take the place of the more formal and requisite .41 process, and we recognize and appreciate that safety and efficiency must be ensured in the implementation of any new procedure. However, the dismissal of all eight proposals without offering potential modifications or alternatives for evaluation is inconsistent with the spirit of cooperation laid out in the MOU.
We respectfully ask that the FAA recommit to the MOU's first stated objective to "identify specific proposed ideas to reduce overflight noise from RNAV concentration," and work in partnership with the Massport CAC to identify and present proposals for evaluation. To that end, we request further evaluation of the MIT Block 2 proposals and explanation of the FAA/Industry stakeholder assessment.
We appreciate your time and attention to this difficult undertaking, and we thank you for your consideration of our request.
Sincerely,