The Aircraft Owners and Pilots Association has told the San Mateo County (California) Board of Supervisors that a proposed noise ordinance for San Carlos Airport (SQL) violates federal law.
The ordinance is directly aimed at limiting flight training at the San Francisco Bay-area airport. It would prohibit "touch and goes, low approaches, or full stop-taxi back" operations during the evening, nighttime, and early morning hours. Stop-and-go operations would be prohibited at all times, and simulated emergency maneuvers couldn't be initiated below traffic pattern altitude.
In a March 3 letter to the supervisors, AOPA Counsel Kathleen Yodice said that federal law requires that airport regulations be fair, reasonable, and non-discriminatory.
"The pervasive nature of the proposed ordinance goes far beyond what may be necessary to address and remedy what has yet to be demonstrated to be a valid noise concern," Yodice wrote. "The county's attempt to effectively prohibit a class of airport operations at the airport, specifically flight training, may go beyond the authority of the airport proprietor to reasonably regulate noise."
AOPA reminded the county that it had contractually agreed to keep San Carlos Airport "available for public use on fair and reasonable terms and without unjust discrimination" when it accepted federal airport funding.
The Federal Aviation Administration has already determined the proposed ordinance would unjustly discriminate against flight training operations.
The association said that a fair and legal way to develop noise regulations would be to conduct a "Part 150" study and submit the results and proposed regulations to the FAA.
(Part 150 refers to the section of the federal aviation regulations governing "airport noise compatibility planning.")
"Without research, investigation, and analysis, it is almost impossible to put operational restrictions in place that adequately respond to the concern without being unnecessarily overbroad," Yodice said.
AOPA said it is willing to work with the pilots at San Carlos Airport and the people in surrounding communities to develop voluntary programs to help limit noise.
"Over the years, AOPA has demonstrated its concern for the environment by promoting pilot education and encouraging civilian pilots to voluntarily observe recommended noise abatement procedures," said Yodice. "In our experience, most pilots exercise good-faith efforts to comply with recommended operational procedures."
For example, AOPA recently produced an extensive noise abatement video, Flying Friendly, and distributed it free of charge to airport managers and pilot groups.
"The peaceful coexistence of airports and surrounding communities is of great interest to AOPA's members," Yodice concluded. "Most communities understand the value that an airport has to their community by providing transportation access for residents and visitors, by generating income for the municipality and the local economy, and by providing business, career, and educational opportunities."
And therein lies a small irony, noted AOPA. San Carlos underlies an approach path to busy San Francisco International Airport. "If we shut down flight training operations," mused one AOPA official, "where will we get the pilots to fly the ever-increasing number of airline passengers?"
A copy of AOPA's letter to the San Mateo County Board of Supervisors is available on AOPA Online.
The 355,000-member Aircraft Owners and Pilots Association is the world's largest civil aviation organization. More than one half of the nation's pilots are members, as are some 45,000 California pilots.
March 10, 2000