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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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.

ï¿½ 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. ***