    Reagan National Airport: Limited Opportunities to Improve Airlines'
    Compliance with Noise Abatement Procedures (Letter Report, 06/29/2000,
    GAO/RCED-00-74).

    Pursuant to a congressional request, GAO: (1) described the specific
    noise abatement procedures at Ronald Reagan Washington National Airport;
    (2) determined whether the airlines comply with these procedures; and
    (3) assessed whether local citizen groups believe that existing noise
    abatement procedures and penalties are effective.

    GAO noted that: (1) local airport procedures and federal laws contain a
    number of provisions designed in part to limit aircraft noise at Reagan
    National; (2) a nighttime noise procedure imposed by the airport
    authority generally permits flight operations between 10 p.m. and 7.a.m
    only by certain aircraft that can meet relatively strict noise limits;
    (3) however, aircraft that were scheduled to arrive before 10 p.m. may
    land later if an air traffic controller cleared them prior to 10:30
    p.m.; (4) this exception recognizes that aircraft are sometimes delayed
    en route; (5) local airport rules require both departing and arriving
    flights to follow the Potomac River north and south of the airport for
    several miles before turning; (6) in particular, aircraft are prohibited
    from flying over federally protected areas in Washington, D.C., such as
    the Capitol and White House; (7) airport rules also require pilots of
    departing aircraft to reduce engine power, and thus engine noise, after
    reaching either a specified altitude or a certain distance from the
    airport, depending on the direction of the aircraft's departure; (8) the
    airport's noise abatement procedure incorporates the federal law that
    generally bars airlines from operating nonstop flights to or from an
    airport located more than 1,250 statute miles from Reagan National; (9)
    although information available from the Metropolitan Washington Airports
    Authority (MWAA) and the Federal Aviation Administration (FAA) on the
    number of violations of Reagan National's noise abatement measures
    suggests that the airlines have generally met local requirements,
    certain shortcomings in MWAA's and FAA's efforts to monitor airline
    operations raise doubts about the extent of the airlines' actual
    compliance; (10) data from MWAA show that violations of that rule have
    decreased since the early 1990s, in part because airlines have begun to
    replace older, noisier aircraft with newer, quieter versions; (11) MWAA
    says it has a high degree of confidence that these aircraft are being
    operated in compliance with the noise rule; (12) although FAA's data
    indicate that there were very few instances of pilots' failure to follow
    air traffic control instructions pertaining to the flight path, FAA
    officials acknowledged that they generally focus only on keeping
    aircraft away from the federally protected areas in Washington, D.C.,
    and do not track the number of incidents where pilots may have strayed
    from the flight path over local neighborhoods; and (13) local groups do
    not believe that existing procedures and penalties are as effective as
    they should be in encouraging airlines' compliance with noise abatement
    requirements.

    --------------------------- Indexing Terms -----------------------------

     REPORTNUM:  RCED-00-74
         TITLE:  Reagan National Airport: Limited Opportunities to Improve
    	     Airlines' Compliance with Noise Abatement Procedures
          DATE:  06/29/2000
       SUBJECT:  Airports
    	     Noise pollution control
    	     Airline regulation
    	     Environmental monitoring
    	     Noncompliance
    	     Aircraft
    	     Airline industry
    IDENTIFIER:  Ronald Reagan Washington National Airport (DC)

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    GAO/RCED-00-74

    Appendix I: Scope and Methodology

    26

    Appendix II: Comments From the Metropolitan Washington Airports Authority

    28

    33

    Figure 1: Aircraft Flight Path at Reagan National 8

    Figure 2: Enforcement Actions for Violations of the Nighttime Noise
    Restriction Have Generally Declined 12

    Figure 3: Actual Arrival and Departure Observations Along Reagan National's
    Flight Path, October 25, 1999 16

    Figure 4: Example Indicating the Position of One Airline's Departing
    Aircraft Relative to the Flight Path at a Point 6 Miles
    Northwest of Reagan National 18

    Figure 5: Denver International Airport's ANOMS Provides Detailed
    Data on Noise From Individual Aircraft 22

    ANOMS Airport Noise and Operations Monitoring System

    CONANDA Committee on Noise Abatement at National and Dulles Airports

    DOT Department of Transportation

    FAA Federal Aviation Administration

    GAO General Accounting Office

    MWAA Metropolitan Washington Airports Authority

    Resources, Community, and
    Economic Development Division

    B-284054

    June 29, 2000

    The Honorable James P. Moran
    House of Representatives

    Dear Mr. Moran:

    A continuing concern of communities located near commercial airports is the
    amount of noise generated by aircraft during takeoffs and landings. At
    Ronald Reagan Washington National Airport (Reagan National), the takeoff and
    landing paths generally follow the Potomac River north and south of the
    airport. In the early 1980s, residents of Maryland, Virginia, and
    Washington, D.C., who live along the river urged the Federal Aviation
    Administration (FAA) to change Reagan National's arrival and departure
    routes. After testing various alternative departure routes and receiving
    negative public reaction, FAA restored the original flight paths. Since
    then, local groups have expressed concern primarily about how FAA and the
    Metropolitan Washington Airports Authority (MWAA), which operates Reagan
    National, interpret and apply the local procedures and federal laws that may
    affect aircraft noise for flights to and from the airport.

    As agreed with your office, this report responds to your request that we (1)
    describe the specific noise abatement procedures at Reagan National, (2)
    determine whether the airlines comply with these procedures, and (3) assess
    whether local citizen groups believe that existing noise abatement
    procedures and penalties are effective.

    Local airport procedures and federal laws contain a number of provisions
    designed in part to limit aircraft noise at Reagan National. First, a
    nighttime noise procedure imposed by the airport authority generally permits
    flight operations between 10 p.m. and 7 a.m. only by certain aircraft that
    can meet relatively strict noise limits. However, aircraft that were
    scheduled to arrive before 10 p.m. may land later if an air traffic
    controller cleared them prior to 10:30 p.m. This exception recognizes that
    aircraft are sometimes delayed en route. Second, local airport rules require
    both departing and arriving flights to follow the Potomac River north and
    south of the airport for several miles before turning. In particular,
    aircraft are prohibited from flying over federally protected areas in
    Washington, D.C., such as the Capitol and White House. Third, airport rules
    also require pilots of departing aircraft to reduce engine power, and thus
    engine noise, after reaching either a specified altitude or a certain
    distance from the airport, depending on the direction of the aircraft's
    departure. Fourth, the airport's noise abatement procedure incorporates the
    federal law that generally bars airlines from operating nonstop flights to
    or from any airport located more than 1,250 statute miles from Reagan
    National (the "perimeter rule"). In addition, a federal law and a federal
    regulation generally limit the number of flights to 60 per hour (the
    "high-density rule," also known as the slot rule ).

    Although information available from MWAA and FAA on the number of violations
    of Reagan National's noise abatement measures suggests that the airlines
    have generally met local requirements, certain shortcomings in MWAA's and
    FAA's efforts to monitor airline operations raise doubts about the extent of
    the airlines' actual compliance. With respect to the nighttime noise
    procedure, data from MWAA show that violations of that rule have decreased
    since the early 1990s, in part because airlines have begun to replace older,
    noisier aircraft with newer, quieter versions. MWAA says it has a high
    degree of confidence that these aircraft are being operated in compliance
    with the noise rule but acknowledges that it could do more to spot-check
    compliance. Although FAA's data indicate that there were very few instances
    of pilots' failure to follow air traffic control instructions pertaining to
    the flight path, FAA officials acknowledged that they generally focus only
    on keeping aircraft away from the federally protected areas in Washington,
    D.C., and do not track the number of incidents where pilots may have strayed
    from the flight path over local neighborhoods. With respect to compliance
    with the slot rule, FAA officials maintain that there have been no
    violations since at least 1994. However, these officials acknowledged that
    FAA does not regularly monitor compliance with the slot rule. Likewise, for
    reasons pertaining to time, cost, and privacy, it is impractical to monitor
    pilots' compliance with the requirement to reduce engine power shortly after
    takeoff. Finally, according to MWAA, airlines have operated in full
    compliance with the perimeter rule.

    Local groups do not believe that existing procedures and penalties are as
    effective as they should be in encouraging airlines' compliance with noise
    abatement requirements. One group representing local communities asserts
    that MWAA is not using available technologies to determine which airlines
    violate noise abatement procedures and laws. Although MWAA's 10-year-old
    system can provide a limited amount of information on aircraft noise, other
    airports are using a new, more sophisticated noise-monitoring system to
    analyze aircraft flight and noise data and communicate that information to
    local residents.

    We provided MWAA, FAA, and the Department of Transportation (DOT) with a
    draft of our report for review and comment. The agencies generally agreed
    with our findings but made several technical suggestions, which we
    incorporated to clarify the report. The report contains four recommendations
    to DOT and MWAA. However, neither agency commented on these recommendations.

    Shortly after the nation's major commercial airlines began jet service at
    Reagan National,1 airport noise was officially recognized as an
    environmental pollutant. The Federal Aviation Act, as amended in 1968,
    authorized FAA to prescribe standards for the measurement of aircraft noise
    and to prescribe regulations providing for the control and abatement of
    aircraft noise. In 1969, the National Environmental Policy Act began
    requiring that environmental impact assessments of proposed airport
    construction or improvement projects include aviation noise as a potential
    pollutant. Later, the Noise Control Act of 1972 clarified that FAA's
    authority to apply noise standards included issuing, amending, modifying, or
    revoking certificates for aircraft type design and equipment. The act
    further provided that future certificates for aircraft operations shall not
    be issued unless the new aircraft noise requirements are met. The Aviation
    Safety and Noise Abatement Act of 1979 set target dates for reducing the
    number of the noisiest aircraft then in use. Finally, the Airport Noise and
    Capacity Act of 1990 called for all airlines operating jet aircraft weighing
    over 75,000 pounds in the contiguous United States to meet relatively strict
    "Stage 3" engine noise emission limits by December 31, 1999.2 This law
    allowed aircraft operators to meet the Stage 3 requirements either by
    purchasing new aircraft with quieter engines or by retrofitting existing
    engines with so-called hush kits , designed to muffle engine noise.

    Beginning in 1982, at Reagan National, specifically, FAA, as airport owner
    and operator, placed limits on aircraft operations (takeoffs and landings)
    during the nighttime hours. This new procedure restricted all nighttime
    operations (10 p.m. to 7 a.m.) by imposing noise limits on departing and
    arriving aircraft. Because no airline operating at Reagan National could
    meet the nighttime noise limits then in effect, these restrictions
    represented a de facto curfew. Soon thereafter, airlines began operating
    McDonnell-Douglas MD-80 aircraft, which met the noise limits for landings,
    but not for takeoffs. Thus, these aircraft could land at Reagan National
    after 10 p.m., but could not depart until 7 a.m. MWAA adopted FAA's
    nighttime takeoff and landing restrictions in 1987, when it assumed
    authority for operating the airport. Some aircraft are now quiet enough to
    meet the nighttime noise limits, but these limits are stricter than FAA's
    Stage 3 requirements, thereby requiring aircraft operating at Reagan
    National during nighttime hours to be quieter than required by the U.S.
    national standards. In recent years, airlines have begun introducing quieter
    aircraft, such as Airbus A-319s and new Boeing 737s; generally, these
    aircraft can meet the nighttime limits governing both takeoffs and landings.

    National

    A combination of federal laws and local procedures required by the local
    airport authority seek to constrain aircraft noise at Reagan National.3 The
    official noise abatement procedure at the airport includes three local
    restrictions--restrictions on nighttime noise, flight paths, and engine
    power--and the federal perimeter rule. In addition, the slot rule, by
    limiting the number of aircraft operations during most hours of the day,
    also has the effect of restraining aircraft noise at the airport.

    The nighttime noise rule restricts aircraft operations between 10 p.m. and 7
    a.m. During those hours, only aircraft that generate less than 72 decibels
    of sound may take off, and only aircraft that produce less than 85 decibels
    may land.4 An aircraft scheduled to arrive before 10 p.m. may land after
    that time if air traffic controllers cleared it for landing prior to 10:30
    p.m. This exception exists because weather, air traffic factors, and
    mechanical difficulties can sometimes delay incoming flights.

    The flight paths to and from Reagan National are restricted in several ways.

    � Aircraft departing to the north generally are to fly directly over the
    Potomac River until they are approximately 4 miles north of the airport. At
    this point, the pilot has the option to continue following the river or to
    turn slightly and follow a northwesterly compass heading ("radial") until
    reaching a point 10 miles away from the airport.5 The compass heading
    generally follows the Potomac River. According to an FAA official at Reagan
    National, the radial gradually widens as the distance from the airport
    grows, providing a pilot with increasing latitude to maneuver the aircraft
    as it ascends and proceeds away from the metropolitan area. When an aircraft
    is 10 miles from the airport--near the Capital Beltway--the radial is
    approximately 4 miles wide. Thus, at this point, a pilot could be about 2
    miles off the precise center of the radial--over either Maryland or
    Virginia--and still be within the flight path. Similarly, aircraft arriving
    from the north are directed to follow the Potomac once they are within 10
    miles of the airport.

    � Aircraft departing to the north are directed not to fly beyond the east
    bank of the river into restricted airspace over Washington, D.C. This
    airspace, which encompasses the Vice President's official residence at the
    U.S. Naval Observatory, the White House, and the U.S. Capitol, is restricted
    up to an altitude of 18,000 feet. In addition, if encountering an emergency
    situation--for example, conducting a fly-around to avoid hitting an aircraft
    on the runway--aircraft arriving from the south are to turn in time to
    remain clear of this airspace. This may require the aircraft to fly due west
    over residential neighborhoods in northern Virginia. Doing so may cause
    local residents to experience high-decibel noise, but it is the required
    maneuver to ensure safe operations.

    � Aircraft departing to the south are to track the river until they are 5
    miles from the airport--beyond the Potomac River's Wilson Bridge--before
    turning toward their destination. Starting 5.6 miles from the airport,
    aircraft arriving from the south are to approach the airport directly over
    the river.

    Figure 1 depicts the flight path that pilots are generally supposed to
    follow at Reagan National.

    aThe airspace above the National Observatory is prohibited to commercial air
    traffic because the Vice President's official residence occupies the
    grounds.

    Source: GAO's depiction of information from MWAA.

    Another method of limiting aircraft noise is the requirement that pilots of
    aircraft departing to the north reduce engine power to a given target
    setting once they have reached an altitude of 1,500 feet or a point 2 miles
    away from the airport. Likewise, this "thrust management" procedure requires
    pilots of southbound departing aircraft to reduce power at a point 3 miles
    away from the airport. Pilots of all departing aircraft are to maintain
    reduced engine power until their aircraft reach a point 10 miles from the
    airport. At this point, pilots are to increase power to normal climb
    settings.6 According to FAA and MWAA officials, reducing engine power in
    this manner effectively reduces the amount of noise generated during
    takeoff. Only an air traffic controller's instruction to "expedite climb"
    releases the pilot from the requirement to maintain reduced engine power.

    Although not primarily a noise mitigation rule, the federal perimeter rule
    generally bars airlines from operating nonstop flights to or from any
    airport located more than 1,250 statute miles from Reagan National. Coupled
    with Reagan National's relatively short main runway, the perimeter rule
    effectively prevents airlines from using certain jets that may emit more
    noise than some smaller aircraft now operating at Reagan National. However,
    many newer aircraft capable of flying beyond the existing perimeter, such as
    the Airbus A-320, create less sound than older aircraft equipped with hush
    kits, which are now in use at the airport.

    Although also not originally intended as such, the federal slot rule for
    Reagan National serves as a noise abatement measure.7 A "slot" is an
    authorization from the federal government for an aircraft to take off or
    land under instrument flight rules during any given hour. The slot rule
    specifies that no more than 60 operations--37 air carrier, 11 commuter, and
    12 general aviation operations--may be scheduled per hour.8 In 1984, FAA
    used its exemption authority to permit Braniff Airlines to resume operations
    at Reagan National with four slots, even though all air carrier slots were
    already allocated.9 In 1990, FAA allocated those four slots to America West
    Airlines.10

    In April 2000, the President signed legislation directing the Secretary of
    Transportation to grant 24 additional exemptions to the slot and perimeter
    rules, provided that certain conditions generally relating to increased
    competition are met, including a condition that the additional flights do
    not result in increased travel delays.11 The legislation specifies that 12
    of these exemptions be reserved for flight operations to and from locations
    beyond the existing perimeter and that the remaining 12 be reserved for
    operations to small and medium-sized communities inside the perimeter. The
    legislation also includes provisions designed to ensure that the quality of
    the human environment is not significantly affected and that noise standards
    are not compromised.

    but Certain Shortcomings in Flight-Monitoring Efforts Raise Doubts

    Although information available from MWAA and FAA on the number of violations
    of Reagan National's noise abatement measures suggest that the airlines have
    generally met local requirements, shortcomings in MWAA's and FAA's efforts
    and abilities to monitor airlines' operations raise doubts about the extent
    of the airlines' actual compliance. MWAA's and FAA's data indicate that the
    major airlines generally comply with the procedure governing nighttime
    operations and the law concerning slot use. Yet, the two agencies do not
    verify whether the airlines comply in practice. At the same time, it is not
    possible for MWAA and FAA to determine with certainty whether pilots comply
    with procedures governing the airport's flight path and the reduction of
    engine power on takeoff. Although FAA's radar data may suggest that an
    aircraft has violated flight path restrictions, unless those data can be
    combined with air traffic controllers' instructions, they cannot indicate
    with certainty whether a violation took place. Furthermore, it is
    impractical to fully monitor pilots' compliance with the procedure requiring
    reduced engine power. Under these circumstances, not all violations are
    likely to be detected, reported, or investigated, and the exact extent of
    airlines' compliance with the Reagan National noise abatement procedures
    cannot be determined. On the other hand, MWAA and FAA officials agree that
    airlines have fully complied with the perimeter rule.

    High, but MWAA Could Take More Measures to Verify Compliance

    Available data suggest that airlines' compliance with the nighttime noise
    procedure, as measured by the number of enforcement actions initiated, has
    increased since the late 1980s. From July 1982 through December 1987,
    roughly the period immediately before MWAA assumed operational control at
    the airport, FAA initiated 224 formal enforcement actions against airlines
    for operating aircraft that produced excess noise between 10 p.m. and 7 a.m.
    In those 224 cases, FAA sent 141 letters of correction or warning and levied
    62 civil penalties totaling $41,600. The number of enforcement actions
    peaked in 1989, when MWAA initiated 70 enforcement actions. Since 1989,
    compliance appears to have improved because the number of enforcement
    actions that MWAA has taken has declined. From 1990 through 1999, MWAA
    initiated a total of 120 enforcement actions. MWAA officials believe that
    two major factors contributed to the decrease in the number of enforcement
    actions taken for nighttime noise violations. First, airlines began to
    replace older, noisier aircraft with newer, quieter versions. Second, MWAA
    succeeded in raising the maximum civil penalty it could assess from
    $1,000--which, according to MWAA officials, some airlines regarded as
    nothing more than a cost of doing business at the airport--to $5,000. Total
    civil penalties assessed in 1999 equaled $12,750. MWAA considers the
    airlines' compliance to be very good and believes that its vigorous and
    consistent enforcement has led to an improved compliance attitude among the
    airlines. Figure 2 shows the number of enforcement actions that MWAA has
    initiated against the airlines over time.

    Restriction Have Generally Declined

    Source: MWAA.

    MWAA relies on FAA's reports to determine the types of aircraft that flew
    into and out of the airport during the nighttime restricted hours but does
    not independently verify whether the newer, quieter aircraft are actually
    operated in a manner that complies with established decibel limits.
    According to an MWAA official, the agency's operations staff receive a
    report each morning from FAA personnel at Reagan National's air traffic
    control tower showing the types of aircraft that flew into and out of the
    airport during the previous evening. Any enforcement action that MWAA may
    take depends on the type of aircraft being operated, the lawful maximum
    weight at which that aircraft may operate, and the amount of noise produced
    at the aircraft's maximum weight.

    � If FAA's report indicates that certain aircraft, such as an older Boeing
    727, operated between 10 p.m. and 7 a.m., MWAA initiates an enforcement
    action. All Boeing 727 models clearly produce more than 72 decibels of sound
    on takeoff and more than 85 decibels on approach--the sound thresholds for
    takeoffs and landings.

    � MWAA does not verify on a flight-by-flight basis whether flights by
    certain newer, relatively quiet aircraft comply with the nighttime noise
    standards. For instance, if FAA's report shows that US Airways--Reagan
    National's largest airline--made a nighttime operation with one of its newer
    aircraft, such as an Airbus A-319 or Airbus A-320, MWAA presumes the flight
    to be in compliance. MWAA bases this presumption on US Airways' obligation
    to operate its aircraft in accordance with the "type certificate" provided
    by the aircraft's manufacturer--Airbus Industrie. An aircraft's type
    certificate, which is approved by FAA, specifies its operating requirements,
    including the maximum weights at which it may take off or land at particular
    airports. The certificate that US Airways holds for its Airbus A-320
    operations at Reagan National, for instance, specifies an allowable takeoff
    weight of 73.5 tons--about 13 tons less than the maximum takeoff weight that
    the aircraft could accommodate, according to Airbus Industrie's
    calculations. According to FAA's calculations, this combination of aircraft
    and weight for an Airbus A-320 generates approximately 69 decibels of sound
    on takeoff, which is less than the 72-decibel limit that MWAA allows for
    nighttime operations at Reagan National. US Airways managers have agreed
    with MWAA to operate all of the airline's Airbus A-319s and A-320s during
    daytime and nighttime hours in a manner consistent with these weight
    requirements.

    � MWAA presumes that US Airways will abide by those weight restrictions
    because it is an obligation under federal law and airport rules, and because
    of the severe penalty that FAA could impose on the airline. If US Airways
    were to operate one of these aircraft contrary to this agreement, not only
    would it be violating MWAA's nighttime noise procedure, but it would also be
    violating a federal aviation regulation by operating the aircraft in a
    manner inconsistent with its certificate.12 In such an event, FAA could
    apply a range of enforcement actions, including suspending the airline's
    operating certificate--effectively grounding the airline. However, FAA has
    notified MWAA that it will not police how US Airways operates its aircraft,
    leaving that responsibility to local airport officials.

    � MWAA officials recognize that other newer aircraft, such as Boeing
    737-800s, may or may not meet the nighttime decibel limits, depending on
    their weight and how they are operated. MWAA has recently concluded
    agreements with two other airlines--Delta and American--about the weight
    with which, and the manner in which, their aircraft will be operated.

    According to an MWAA official, MWAA is able to verify whether US Airways
    aircraft are complying with the terms of a May 1999 agreement with the
    agency. This agreement allows MWAA full and regular access to company
    records regarding aircraft takeoff and landing weights. However, MWAA has
    not conducted spot checks on US Airways aircraft to determine whether these
    aircraft are being operated either in accordance with the airline's
    certificate or in compliance with Reagan National's nighttime noise limits.
    If MWAA conducted such inspections, it would be able to determine whether US
    Airways was adhering to the conditions specified in its operating
    certificate. According to an MWAA official, the agency has checked the
    records, which indicate compliance, but has not yet begun checks on the
    actual aircraft, which have been operating at Reagan National since October
    1999.

    MWAA and airline officials believe that violations of the nighttime noise
    rule are few and will continue to decrease as airlines phase in a new
    generation of quieter aircraft. During early 2000, US Airways began
    introducing new Airbus A-320 aircraft for its shuttle service to New York's
    LaGuardia Airport, and Delta Air Lines will soon deploy new Boeing 737s for
    its competing shuttle service. Operations using these aircraft will be fully
    compliant not only with FAA's nationwide Stage 3 engine-noise requirements,
    but also with MWAA's stricter nighttime noise limits--provided that they are
    operated in accordance with the type certificates provided by the
    manufacturer or FAA operations specifications with weight restrictions.

    Traffic Control Instructions to Follow Reagan National's Flight Paths

    FAA's radar data suggest that pilots flying to, from, or near Reagan
    National almost always comply with controllers' instructions to follow the
    airport's approved flight paths. Except in emergency situations, federal
    aviation regulations require pilots to follow all instructions from air
    traffic controllers. At Reagan National, these instructions incorporate the
    airport's noise procedures, which include a directive to follow the Potomac
    River flight path. A pilot's failure to follow air traffic control
    instructions as required by federal aviation regulations is an enforceable
    infraction known as a pilot deviation . For example, a pilot's failure to
    maintain the altitude directed by air traffic controllers could be
    considered a pilot deviation.

    In fiscal year 1999, out of about 330,000 aircraft operations at Reagan
    National, FAA initiated 18 enforcement actions for alleged pilot deviations.
    This equates to approximately 5 enforcement actions for every 100,000
    aircraft operations (takeoffs and landings). From fiscal year 1996 through
    fiscal 1998, FAA took enforcement actions against 75 pilot deviations. This
    equates to roughly 8 enforcement actions for every 100,000 aircraft
    operations. Of all the enforcement actions taken for pilot deviations during
    these 3 fiscal years, 63 were against pilots of general aviation or
    corporate aircraft and 30 involved pilots of commercial aircraft. In each of
    these 93 cases, FAA pursued the enforcement action because a pilot failed to
    avoid secured federal airspace over Washington, D.C.--not because the pilot
    flew over a local residential neighborhood west of the Potomac River.

    Figure 3 shows the actual flight paths taken by aircraft arriving at Reagan
    National from the south and departing from Reagan National to the north
    along the Potomac and Anacostia rivers on a randomly selected day. The
    figure highlights the extent to which northbound departing aircraft
    generally follow the Potomac River, avoiding the restricted airspace over
    central Washington, D.C. It also shows the spread-out pattern of various
    points at which aircraft landing from the south turn to fly over the river
    from either the Maryland or the Virginia side of the Potomac.

    Source: MWAA, based on radar data provided by FAA.

    This figure suggests, but does not prove, that some aircraft may have been
    west of the flight path at various points during departure, thereby possibly
    violating the flight path restriction. FAA officials acknowledged that both
    they and airline personnel are generally more concerned about ensuring that
    aircraft avoid the prohibited area over Washington, D.C., than about
    overflying northern Virginia suburbs. Yet without knowing what the air
    traffic controllers' instructions to the pilots were, it is not possible to
    determine with certainty whether the flights shown in figure 3 were not
    complying with the flight path procedure. Both FAA and MWAA officials
    reported that controllers are usually unable to recall specific instructions
    given to specific flights from a previous day. Thus, these radar data alone
    are not sufficient to indicate whether a pilot may have erred.

    Despite federal control over the use of airspace, MWAA independently
    supplements FAA's enforcement actions. MWAA periodically tracks aircraft
    movements along the airport's flight paths using FAA's radar data.13 MWAA
    plots the horizontal and vertical position of each aircraft as it passes
    through four electronic checkpoints (or "gates") that bisect the flight path
    north of the airport. This information helps noise abatement officials
    determine how effectively aircraft maintain their positions over the river.
    MWAA later relays this information to the airlines to remind them of the
    importance of following the river to minimize the noise generated over
    residential neighborhoods. MWAA takes this approach--encouraging airlines to
    follow the established flight path--because it does not have the authority
    to compel compliance. According to MWAA officials, this has encouraged
    airlines to pay closer attention to the local flight path requirements.

    Figure 4 illustrates where an airline's MD-80 aircraft passed through one of
    MWAA's gates during a randomly selected day. It shows that, at a point
    approximately 6 miles northwest of the airport, these aircraft were either
    directly above or west of the river (over Virginia) by roughly one-half mile
    at altitudes of between 4,000 and 6,000 feet, which is well within the range
    of normal altitudes at that point, according to MWAA officials. Again, as
    with figure 3, because these data cannot be matched with instructions from
    the air traffic controller, these flights could not be considered either to
    be off the flight path or operated not in accordance with air traffic
    control instructions, according to FAA and MWAA officials.

    Note: GAO's depiction based on data supplied by MWAA.

    Impractical

    Because there is no practical way for MWAA or FAA to do so, assessing
    whether airlines and their pilots comply with Reagan National's procedure
    requiring reduced engine power on takeoff is virtually impossible. MWAA and
    FAA officials told us that determining whether a pilot has complied with
    Reagan National's power management procedure could theoretically be done in
    two ways. Yet according to these officials, neither of these two options is
    currently feasible.

    � First, FAA could propose new rules that would require airlines to install
    video cameras in the flight deck of all aircraft to monitor pilots'
    decisions. The Air Line Pilots Association--a union representing 55,000
    pilots at 51 North American airlines--has generally opposed installing video
    recorders in cockpits, citing concerns about pilots' privacy and the misuse
    of information obtained from the recorders. The union supports the use of
    cockpit video recorders for accident investigation purposes only. Because
    current flight data recorders (i.e., the "black box") capture data on engine
    throttle settings, the union maintains that any cockpit video recorder must
    be installed to ensure that it focuses on and records only the instrument
    panel of the cockpit and not the flight crew's activity, including how they
    set engine throttles. Thus, such union concerns effectively prevent cockpit
    video recorders from being used as a means to determine compliance with
    engine power requirements.

    � Second, FAA officials could retrieve the flight data recorder from an
    aircraft to determine whether a pilot properly reduced engine thrust.
    However, because the recorder is designed to produce data for only the last
    30 minutes of a flight, information pertaining to an aircraft's takeoff
    would be missing for all flights into or out of Reagan National. In
    addition, according to information from Delta Air Lines, obtaining engine
    thrust information from the flight data recorder is also not feasible
    because removing that equipment from aircraft is both time-consuming and
    costly.

    Ongoing Monitoring Makes It Difficult to Fully Assess Airlines' Compliance

    As we have reported in the past, FAA does not have a systematic way to
    monitor compliance with or enforce violations of Reagan National's slot
    rule.14 To determine that an airline has violated the slot rule, FAA
    officials told us they must find that the airline displayed a pattern of
    operations that diverges significantly from scheduled times and did so
    intentionally. FAA staff do not consider single events in which aircraft
    arrive early or late to be violations because various factors outside the
    airline's control (e.g., poor weather and air traffic delays) can affect
    aircraft operations.15

    FAA officials acknowledged that, although they routinely attempt to discern
    patterns indicating airlines' intent to violate the slot rule, they do not
    regularly compare airlines' scheduled operations with their actual
    operations. Even were they to do so, officials stated that they do not have
    a firm definition for exactly when a consistent pattern of delays or early
    operations constitutes a slot violation and that they do not use an
    established period of time--for example, 30, 60, or 90 days--against which
    to measure airlines' compliance. FAA officials said that they had recorded
    no violations of the slot rule at Reagan National since at least 1994.

    Our analysis of flight operations data, however, revealed numerous
    situations that would seem to merit additional investigation by FAA. We
    independently analyzed information on flight arrivals and departures
    covering the period from September 30, 1999, through December 31, 1999. Of
    the approximately 580 scheduled daily operations by large air carriers
    (large jets) at Reagan National, 8 flights appeared to arrive consistently
    at times other than their scheduled hours. One of those flights arrived at
    Reagan National not during the 9 p.m. hour but after 10 p.m. nearly 90
    percent of the time. Similarly, several other flights departed Reagan
    National consistently in hours other than their scheduled hours. For
    example, of the five flights that airlines scheduled to depart precisely at
    8 a.m., four departed ahead of schedule at least 70 percent of the time.

    MWAA officials report that the airlines are in full compliance with the
    perimeter rule, which bars airlines from operating nonstop flights to and
    from destinations located more than 1,250 miles from the airport. Industry
    officials agree that an airline could not schedule, market, or operate a
    flight to or from a point beyond the perimeter without FAA's, the general
    public's, and especially competing airlines' taking notice and reporting the
    flight to MWAA.

    Enforce Noise Abatement Procedures Could Be More Effective

    Although officials with MWAA, FAA, and key airlines operating at Reagan
    National generally regard these noise monitoring and enforcement efforts as
    effective, outside groups have a somewhat different opinion. For example,
    the Committee on Noise Abatement at National and Dulles Airports
    (CONANDA)--an advisory committee of the Metropolitan Washington Council of
    Governments, which is a regional planning authority composed of locally
    elected officials--believes that MWAA's noise abatement efforts at Reagan
    National are not effective enough. This committee believes that, while
    aircraft are generally operating within Reagan National's prescribed
    departure radial, many aircraft create excessive amounts of noise over local
    neighborhoods by not tracking the Potomac River as closely as possible.

    CONANDA officials asserted that MWAA cannot adequately respond to local
    residents' concerns about the noise generated by particular aircraft. They
    stated that a more sophisticated system in use at Denver International
    Airport can identify the source, location, and decibel level of individual
    noise events with great accuracy and could possibly have applications at
    Reagan National. For instance, Denver's $2 million Aircraft Noise and
    Operations Monitoring System (ANOMS) combines data recorded at
    noise-monitoring stations located in noise-sensitive areas around the
    airport with flight progress data from FAA. ANOMS can then identify the
    amount of noise generated by particular aircraft at specific points along
    their arrival and departure flight paths. Figure 5 displays a sample of data
    available from ANOMS. The figure shows an arriving aircraft's flight path
    and altitude, along with the noise that the aircraft generated at a
    particular point.

    Source: Denver International Airport.

    Denver airport officials noted that ANOMS has provided at least two
    significant benefits. First, because ANOMS can combine flight path and noise
    data to identify a particular, high-decibel event with greater precision
    than some other systems currently in use, airport officials are better able
    to respond to area residents' complaints about aircraft noise. Using ANOMS
    data, the airport can readily provide local residents with detailed
    information about the particular noise event, including whether the flight
    took off from or was landing at Denver's airport or nearby military
    facilities. Second, under the intergovernmental agreement that governs noise
    abatement at Denver, violations are generally defined in terms of the total
    amount of noise averaged over a period of time. Consistent with federal
    measurements of noise levels, single high-decibel events are not themselves
    subject to legal action. Denver's ANOMS is designed in part to capture the
    data needed to make these determinations.

    Airlines' compliance with two important noise abatement procedures--limiting
    nighttime aircraft operations and capping the number of hourly slots in
    which airlines may operate--appears to have been high during recent years.
    Nevertheless, we believe that MWAA's and FAA's statistics on violations of
    these measures may understate the actual number because not all violations
    are likely to have been detected, reported, or investigated. For example,
    MWAA has not checked to determine whether certain aircraft types comply with
    its nighttime noise procedure and FAA has not systematically monitored
    compliance with the slot rule. If MWAA and FAA were to police these
    requirements more aggressively, they may find more situations that should be
    investigated, reported, and enforced. At the same time, while airlines'
    compliance with two other procedures--flight path and engine power
    management--also appears high, several matters create uncertainty for MWAA
    and FAA in their efforts to determine whether airlines and their pilots
    comply in practice. To achieve certainty on flight path compliance, FAA's
    radar data would need to be combined with a controller's recall of a single
    flight event, which is difficult or impossible, as shown by experience.
    Moreover, because there are no flights into or out of Reagan National of
    less than 30 minutes' duration, it is impossible to retrieve engine thrust
    information from flight data recorders. As a result, it is impractical to
    determine the extent to which pilots reduce power shortly after takeoff.

    More advanced noise detection technology would be able to provide residents
    who complain about particular noise events with greater amounts of
    information. However, MWAA would still be hampered in its efforts to
    disseminate this information by FAA's obligation to clean raw radar data
    pertaining to national security flights. This exercise delays MWAA's ability
    to analyze these data by at least 1 week. MWAA may also be hampered by its
    inability to position monitoring stations as Denver did because the Potomac
    River covers much of the noise-sensitive area around Reagan National.

    To ensure that airlines operating at Reagan National during nighttime hours
    do so in compliance with the local nighttime noise rule, we recommend that
    the President/Chief Executive Officer, Metropolitan Washington Airports
    Authority, commit to a schedule of randomly verifying that arriving and
    departing aircraft are being operated in a manner consistent with the terms
    of legally binding agreements that some airlines have reached with MWAA and
    FAA. We also recommend that the President/Chief Executive Officer,
    Metropolitan Washington Airports Authority, study the relative benefits and
    costs of procuring a more technologically advanced noise-monitoring system.

    To improve oversight of the federal slot rule, particularly in light of the
    addition of 24 flights at Reagan National, we recommend that the Secretary
    of Transportation direct the Administrator, Federal Aviation Administration,
    to (1) develop a reliable method (including definitions and procedures) for
    consistently determining whether airlines are complying with the federal
    slot rule and (2) maintain a system of records of the violations identified
    and FAA's disposition of them in a form that will enable FAA to evaluate its
    overall monitoring and enforcement effort.

    We provided MWAA, FAA, and DOT with a draft of our report for review and
    comment. We met with officials from FAA, including a senior attorney from
    the Office of the General Counsel, officials responsible for monitoring
    airlines' compliance with the slot rule, and a manager from the Flight
    Standards District Office that oversees Reagan National's flight operations.
    FAA generally agreed with our findings but asked us to clarify technical
    issues concerning slot use and engine power management. We incorporated
    these remarks as appropriate. FAA did not comment on our recommendations.
    DOT did not comment on the facts, findings, or recommendations contained in
    our draft report.

    MWAA generally agreed with our findings but said we should clarify our
    presentation on several matters, including the purpose of the airport's
    perimeter rule and nighttime noise procedure, which we incorporated as
    appropriate. MWAA did not comment on our recommendations. MWAA's comments
    and our responses are included as appendix II.

    We conducted our review from October 1999 through June 2000 in accordance
    with generally accepted government auditing standards. (For a detailed
    description of our scope and methodology, see app. I.)

    As arranged with your office, unless you publicly announce its contents
    earlier, we plan no further distribution of this report until 30 days after
    the date of this letter. At that time, we will send copies of this report to
    the Honorable Rodney E. Slater, Secretary of Transportation; Ms. Jane
    Garvey, Administrator, Federal Aviation Administration; Mr. James Wilding,
    President/Chief Executive Officer, Metropolitan Washington Airports
    Authority; and the Honorable Jacob J. Lew, Director, Office of Management
    and Budget. We will make copies available to others on request.

    If you have any questions, please call me at (202) 512-2834. Key
    contributors to this report were Steven C. Martin, Aaron Casey, and David
    Hooper.

    Sincerely yours,
    John H. Anderson, Jr.
    Director, Transportation Issues

    Scope and Methodology

    To describe the noise abatement procedure at Ronald Reagan Washington
    National Airport (Reagan National), we reviewed documentation from the
    Metropolitan Washington Airports Authority (MWAA) regarding the four
    methods--nighttime operating restrictions, flight path restrictions, engine
    power management, and the perimeter rule--on which it formally relies for
    abating noise at the airport. We reviewed applicable local procedures and
    federal laws and met with officials representing MWAA and the Federal
    Aviation Administration (FAA) to obtain an interpretation of these
    procedures and laws, including their purpose. We interviewed officials with
    both agencies to understand how each of these procedures and laws may limit
    aircraft noise. In addition, we interviewed officials with FAA's slot
    administration and general counsel's offices to obtain a description of how
    the slot rule may also serve as a noise abatement procedure.

    To determine whether airlines comply with Reagan National's noise abatement
    procedures, we interviewed MWAA and FAA officials, analyzed available
    enforcement data, reviewed case files, and independently assessed data on
    aircraft operations at the airport. Specifically, to assess the extent to
    which airlines comply with Reagan National's nighttime noise limits, we
    interviewed officials with MWAA's noise abatement and general counsel's
    offices and reviewed documentation from FAA and MWAA regarding how
    determinations are made about the noise emitted by new aircraft. To
    determine whether airlines are complying with federal regulations requiring
    pilots to follow air traffic controllers' instructions, we interviewed
    officials with FAA's offices of Air Traffic Services and Flight Standards
    Services. Additionally, we reviewed data from FAA on the number of reported
    and investigated pilot deviation cases during the past 4 fiscal years. To
    examine whether pilots comply with the procedure requiring reduced engine
    power during takeoff, we interviewed officials with MWAA and FAA's Office of
    Environment and Energy. To assess airlines' compliance with the federal
    perimeter rule, we interviewed staff with MWAA's Office of the General
    Counsel. Finally, to understand whether airlines are complying with the slot
    rule at Reagan National--and how FAA searches for slot use patterns--we
    interviewed officials with FAA's Office of the General Counsel and Office of
    Slot Administration. We independently reviewed and analyzed FAA's data
    comparing airlines' published schedules for the period between September 30,
    1999, and December 31, 1999, at Reagan National, against data on actual
    operations during the same period. We selected this period because it
    provided the most recent data available. In our analysis, we used FAA's data
    on the time that aircraft arrived at the gate, instead of the time that the
    aircraft's wheel touched down on the runway, as the arrival time. Similarly,
    for the analysis of departure times, we used FAA's data on the time that
    aircraft pushed back from the gate and not the time that aircraft wheels
    lifted off the runway.

    To assess the extent to which parties concerned with aircraft noise at
    Reagan National believe that existing procedures and penalties are effective
    in encouraging airlines' compliance, we interviewed staff representing the
    Metropolitan Washington Council of Governments' Committee on Noise Abatement
    at National and Dulles Airports. In addition, on several occasions, we
    attempted to contact another interested party--Citizens Against Aircraft
    Noise--that has campaigned for a reduction in aircraft noise at Reagan
    National. However, this party did not respond to our inquiries. Finally, for
    the purpose of comparison with noise abatement efforts at Reagan National,
    we met with officials representing Denver International Airport to assess
    that airport's own such efforts.

    We conducted our review from October 1999 through June 2000 in accordance
    with generally accepted government auditing standards.

    Comments From the Metropolitan Washington Airports Authority

    The following are GAO's comments on the Metropolitan Washington Airport
    Authority's letter of May 25, 2000.

    1. We have incorporated this change.

    2. We disagree with the change suggested by MWAA. Airport rules--and not
    FAA's noise abatement procedures--oblige pilots to reduce engine power after
    reaching an altitude of 1,500 feet. FAA does not establish noise abatement
    operating procedures for individual airports, although it does offer
    advisory guidance. Accordingly, we did not make this suggested change to our
    report.

    3. We agree that, technically, the perimeter rule was not originally
    established at Reagan National as a noise abatement provision, and because
    we discuss this in the body of the report, we made no change to the Results
    in Brief language.

    4. We do not agree that the noise created by an aircraft is unconditionally
    related to whether or not it is capable of flying beyond the 1,250-mile
    perimeter at Reagan National. Many large newer aircraft (e.g., the Airbus
    A-320), which typically operate at weights exceeding those of some older
    smaller aircraft (e.g., the Boeing 727), can easily fly to and from
    destinations located beyond the perimeter. These newer aircraft are equipped
    with engines designed to emit less noise than some older aircraft, even
    though they are heavier. Accordingly, we did not modify the report in
    response to this comment.

    5. Although we agree with MWAA that the major airlines have demonstrated a
    high degree of compliance with the airport's nighttime noise procedure, we
    do not agree that the major airlines have definitively complied in all
    cases. We believe that MWAA's proposed deletion of the word "generally"
    implies that the airlines have definitively complied.

    Related GAO Products

    Reagan National Airport: Capacity to Handle Additional Flights and Impact on
    Other Area Airports ( GAO/RCED-99-234, Sept. 17, 1999).

    Aircraft Noise at Memphis International Airport (GAO/RCED-97-37R , Dec. 17,
    1996).

    Transportation Noise: Federal Control and Abatement Responsibilities May
    Need to Be Revised (GAO/RCED-90-11 , Oct. 12, 1989).

    Aircraft Noise: Eight Airports' Efforts to Mitigate Noise ( GAO/RCED-89-189,
    Sept. 14, 1989).

    Aircraft Noise: Status and Management of FAA's West Coast Plan (
    GAO/RCED-89-84 , May 8, 1989).

    Aircraft Noise: Implementation of FAA's Expanded East Coast Plan
    (GAO/RCED-88-143 , Aug. 5, 1988).

    Airport Noise: FAA's Enforcement of Noise Rules at National Airport
    (GAO/RCED-88-117 , Apr. 15, 1988).

    (348191)

    Figure 1: Aircraft Flight Path at Reagan National 8

    Figure 2: Enforcement Actions for Violations of the Nighttime Noise
    Restriction Have Generally Declined 12

    Figure 3: Actual Arrival and Departure Observations Along Reagan National's
    Flight Path, October 25, 1999 16

    Figure 4: Example Indicating the Position of One Airline's Departing
    Aircraft Relative to the Flight Path at a Point 6 Miles
    Northwest of Reagan National 18

    Figure 5: Denver International Airport's ANOMS Provides Detailed
    Data on Noise From Individual Aircraft 22

    1. Until 1998, the airport was known as Washington National Airport.

    2. FAA's regulations define three classes of aircraft in terms of their
    noise levels. Aircraft certified before 1969 that do not meet the noise
    standards issued in that year are classified as Stage 1 aircraft (e.g.,
    early-model Boeing 707s and McDonnell-Douglas DC-8s). Aircraft meeting the
    1969 standards (e.g., most Boeing 727s and DC-9s) are known as Stage 2
    aircraft. Aircraft complying with more stringent standards issued in 1977
    (e.g., Boeing 757s and MD-80s) are classified as Stage 3 aircraft.

    3. Under federal case law, the abatement of aircraft noise is primarily the
    airport proprietor's responsibility.

    4. The noise levels for arrivals and departures are measured in accordance
    with FAA's procedures for aircraft certification. Noise levels for arrival
    noise and departure noise are not the same because measurements are taken at
    different locations relative to the airport.

    5. Under the flight path procedure for Reagan National, a relatively small
    number of flights that arrive from or depart for certain destinations to the
    northeast are to follow the Anacostia River.

    6. According to FAA officials, this procedure is consistent with safe
    operations and is considered to be a standard rate of climb for jet aircraft
    operating at Reagan National.

    7. The slot rule was established to reduce delay and congestion at Reagan
    National and other major airports. In 1969, facing increasing delays and
    congestion, FAA applied special air traffic rules to certain airports that
    it designated as high-density airports: Chicago's O'Hare; New York's
    LaGuardia and Kennedy; Newark, New Jersey; and Reagan National. (The
    Department of Transportation suspended Newark International Airport's
    designation as a high-density airport in October 1970.) Because of the
    restricted number of allowable operations, these airports are generally
    known as slot-controlled, and the special rules governing the allowable
    number of operations are referred to as slot rules. The total number of
    slots allowed at Reagan National has remained unchanged, although FAA
    reduced the number of air carrier slots from 40 to 37 per hour in 1981. For
    more information on the federal slot rule, see Reagan National Airport:
    Capacity to Handle Additional Flights and Impact on Other Area Airports
    (GAO/RCED-99-234 , Sept. 17, 1999).

    8. The term air carrier generally refers to large commercial jets. The term
    commuter refers to smaller jet- or propeller-powered aircraft that typically
    offer regional service. The term general aviation refers to nonscheduled
    operations by small aircraft; at Reagan National, it generally refers to
    corporate jets.

    9. See FAA Exemption No. 2927 (Feb. 24, 1984). FAA used its statutory
    authority, since amended, under 49 U.S.C. section 40109 to grant this
    exemption from its slot rules on the basis of a public interest finding.

    10. See FAA Exemption No. 5133 (Jan. 12, 1990).

    11. See P.L. 106-181.

    12. See 14 C.F.R. 121.189.

    13. At Reagan National, MWAA obtains these data only after a 1-week delay;
    national security considerations require the delay to allow time to strip
    out pertinent information, such as movements of the President's helicopter.

    14. See Airport Noise: FAA's Enforcement of Noise Rules at National Airport
    (GAO/RCED-88-117 , Apr. 15, 1988).

    15. The slot rule specifically exempts certain types of unscheduled
    operations--that is, operations that are not regularly scheduled--from the
    hourly limits. These exceptions include (1) charter flights, (2) extra
    sections of scheduled commuter or air carrier flights (e.g., the "shuttle")
    that may have been overbooked, and (3) the movements of empty aircraft to
    position them for future operations.
    *** End of document. ***