Select Committee Recommendation 2.5r2

Here’s what you need to know about Select Committee Recommendation 2.5r2:

  • It is a “plausibly deniable” re-phrasing of the Palo Alto plan to shift SFO arrivals to over Mountain View or Sunnyvale. (See a forensic line-by-line comparison below)
  • It was introduced into the draft report by committee chairman Joe Simitian AFTER the last working meeting, and without being discussed by the committee.
  • It passed since there was no time to organize opposition, as the chairman was concurrently also opposing (behind the scenes) the DAVYJ solution.
  • It directly affects cities that were not represented in the committee, such as Mountain View and Sunnyvale.

Line-by-line analysis

Here’s item 2.5r2 (recommendation 2), as it appears in the report:

So first – the smoking gun.  Waypoint DUMBA was never mentioned in committee. The only place where it was used was in the letter from the city of Palo Alto to the FAA, authored by Palo Alto’s consultants – Freytag and Associates. This shows Palo Alto had direct access into the process of drafting the report.

Second, the parallel between the wording here (“i.e. over water or sparsely populated land masses“) and the one in the Palo Alto Plan (“over salt evaporators and bay water“) – are all too obvious. In the context of the maps they attached, we’re talking about the marshlands near Moffett Field.

Here it is again, side-by-side, color coded:

Palo Alto Plan’s “Mountain View” route Select Committee Recommendation 2.5r2
at DUMBA, on the east shoreline of the Dumbarton Bridge. Aircraft on this transition route would cross EDDYY between 7000’ to 9000’ (current procedure is 6000’), in a shallow descent primarily over salt evaporators and bay water, so as to cross DUMBA (WP) above 4500’… …ROKME or DUMBA. The new waypoint should be at a location that allows flight over compatible land uses (i.e., over water or sparsely populated land masses) and at a high enough altitude…

revise the San Jose International Airport Class C airspace

Third, there are the weasel words used to allow the shift

Palo Alto Sky Posse’s argument always hinged on the word “simply“, since they argue that because their route is a little bit higher, it is not longer “simply” shifting noise, and so is allowed.

Funny how how that key word “simply” found its way into the recommendation language.

As a reminder, here’s how Joe Simitian characterized the draft report:

  • “This is not a set of proposals from either me or my office …”
  • “Our best effort in my shop to collect areas where we think consensus has been developed based on the conversations that we have already had…”
  • “It’s coming out of my shop because someone has to produce it…”
  • “Our best effort to put down in writing what we think we heard from this committee..”
  • “Document has to reflect the consensus of this committee…”
  • “Again not from me or my office…”


These promises directly contradict the introduction of recommendation 2.5r2 in the last minute.

2.5r2 additionally flies in the face of any regional approach to noise abatement, and clearly exceeds the authority of the Select Committee, as it tries to shift flight patterns to other districts.


ROKME and DUMBA are the two waypoints discussed in the Palo Alto Plan (charted below).

No matter how much analysis Freytag and Associates puts together, the route through DUMBA is only two nautical miles longer, and given the known airplane descent rates (of roughly 2.7 degrees on average), this translates into an altitude difference of 570′.

Even if it was 1000′, that is hardly any justification to move flights to a neighboring town.

Item 2.5 discusses “low usage land masses”…  in the peninsula?!  I can only imagine this means flying over Moffett into Sunnyvale (The right-most pink path below) – which explains the discussion about SJC airspace, since such a route runs into the buffer zone around the SJC LOUPE departure, shown below.

The FAA, in previous meetings, was more concerned about this buffer zone than about the Class C boundary, but the main point here is not the modification of the airspace… It’s that if you encroach on the LOUPE, you need to move the entire LOUPE pattern.

And if you were to do move it – where to?  Who will be the lucky recipient of those ~150 daily departures? Was San Jose consulted on this?

Once you start shifting flight paths – it never ends.

Meanwhile, returning to Sunnyvale…

It is not clear from 2.5r2 which flavor of the Palo Alto Plan they have in mind. It is vague, just like the Palo Alto plan.  “Somewhere between Mountain View and Sunnvale” – depending on the iteration of the plan.

Measuring the track length, an overflight of Moffett will allow traffic to be about 1500′ higher than it is over Palo Alto – which is where the word “minimize” kicks is.

If you follow the “minimize TPA” concept (TPA = Total People Annoyed), then it says that it’s perfectly ok to shift these flight over to Sunnyvale.

I don’t think the people of Sunnyvale see it that way.

Sunnyvale is already affected. On reverse flow days, Sunnyvale gets practically all of SJC incoming traffic at about 2500′ – one of the worst impacts in the bay area.

Sunnyvale is impacted by Moffett flghts, and recently by a new Surf Air route.

And most importantly, neither Mountain View nor Sunnyvale signed up for this. Just because Palo Alto feels others will have “less impact”, doesn’t give them the right to gift these cities with something they don’t like, even in a slightly more benign form.

SERFR is 160 flights per day (straight line and vectored), which according to this scheme will overfly Sunnyvale at about 5500′ – the same altitude they cross Los Altos at today.

The vectoring cloud will shift to cover Mountain View.

People who are currently affected by SERFR know what it’s like to be at the receiving end of a flight-path shift.

They built their homes, they thought they understood their environment, and overnight – it has changed.

The recent vote by the Select Committee for a return to the BSR/DAVYJ track is a good precedent against overflight of Mountain View.