Class "B" Intervenors
GERALD A. SILVER, Class Representative
HOMEOWNERS OF ENCINO
(dba Stop the Noise!)
P. O. BOX 260205
ENCINO, CA 91426-0205
In Pro Per for Intervenors
BEFORE THE DEPARTMENT OF TRANSPORTATION STATE OF CALIFORNIA
In the Matter of the
)
Case No. OAH No. L-1998040119
Application of: CITY OF LOS ANGELES, DEPARTMENT OF AIRPORTS (VAN NUYS)
Respondent.)
CLASS "B" INTERVENORS' DISCOVERY REQUEST
Set No. One
Pursuant to Government
) Code section 11507.6
Discovery Cutoff Date: 3/1/99
Trail Date: Unknown
PROPOUNDING PARTY: Class "B" Intervenors
RESPONDING PARTY Los Angeles Dept. of Airports
SET NUMBER: One
To the Respondent, Los Angeles Department of Airports and to their counsel of record herein:
Class "B" Intervenors hereby propound their first Discovery Request, pursuant to the provisions of Government Code section 11507.6. Said inspection shall take place at the Van Nuys Airport Administration Office, 16416 Sherman Way #300, Van Nuys, CA 91406. All documents requested in Exhibit "A" attached hereto, shall be produced by those in custody or control of Department of Airports officials, staff, employees, contractors, agents or representatives of the Department of Airports.
Within fourteen (14) days of service of this request, the Department of Airports shall respond in writing, indicating whether or not the Department of Airports and Class "B" Representative shall enter into a stipulation setting a date by which the Department of Airports will respond.
Dated: December 16, 1998
Class "B" Intervenors
Gerald A. Silver, President Homeowners of Encino
EXHIBIT "A"
1. Any and all documents reflecting operations and maintenance records of noise monitoring equipment for all sites surrounding Van Nuys Airport from their dates of installation to the present. Such document shall include, but shall not be limited to, for each monitoring device: date of installation, date of maintenance, type of maintenance provided, name of person rendering maintenance, inclusive dates and reasons equipment was in need of repair or inoperative.
2. Any and all "noise contour maps" drawn from their first existence to the present.
3. Any and all studies, reports or other writings utilized or relied upon in determining the number and location of noise monitors surrounding the Van Nuys Airport. Such documents shall include, but are not limited to: name of person/entity contracted with or otherwise hired to conduct said studies, certification/credentials possessed by persons/entities conducting such studies, acoustical models utilized as well as other information relied upon in determining the number and location of such devices.
4. Board of Airport Commissioners Resolution 12271 (10/8/80) - Van Nuys Airport policy; Scheduled aircraft carrier operations prohibition reaffirmation.
5. Van Nuys Airport Noise Abatement/Curfew Regulation (Ordinance 155,727, 8/31/81) as amended in Ordinance 171889.
6. Any and all economic impact reports regarding Van Nuys Airport prepared by any independent/in-house agency/company for the years 1990 to the present. Such documentation shall include, but is not limited to: final reports, all subsequent updates, all existing "drafts" under preparation, all submitted reports ultimately rejected in part or in whole. Such reports shall further include, but are not limited to those prepared by Wilbur Smith Associates (1992) and the Kennedy Report.
7. Any and all documentation between the Federal Aviation Administration and DOA regarding "grand fathered" rights to implement Stage II restrictions.
8. Any and all documentation regarding FAA sponsored studies on reduced property values due to noise near airports, including but not limited to "The Effect of Airport Noise on Housing Values: A Summary Report", by Booz-Allen and Hamilton, Inc., September 15, 1994.
9. Any and all documentation regarding a Part 161 study, including but not limited to status of conducting such study, research conducted, preliminary findings, and other similar types of information.
10. Any and all reports or other writings documenting aircraft accidents on Van Nuys Airport property or relating to operations into or out of Van Nuys Airport between 1990 and the present.
11. A listing of any and all Stage II fixed based operators with landing rights at Van Nuys Airport for the years 1989 to the present. Such listing shall include, but is not limited to: dates such rights were granted, type of applicable aircraft, nature of agreements executed, documents executed pertaining to noise abatement measures.
12. A listing of any and all Stage II transient jets landing at Van Nuys Airport between 1989 and the present, including, but not limited to: dates/times of each arrival and departure, length of stay, purpose of stay
13. A listing of any and all Stage III fixed based operators with landing rights at Van Nuys Airport for the years 1989 to the present. Such listing shall include, but is not limited to: dates such rights were granted, nature of agreements signed, documents executed pertaining to noise abatement measures.
14. Any and all documentation identifying the numbers and types of aircraft operating out of Van Nuys Airport, including, but not limited to: classification of each aircraft (i.e. as Stage II, Stage III, helicopter ), the year the aircraft came into service/operation for the years 1989 to the present.
15. Any and all correspondence or other writings directed to Van Nuys Airport management regarding noise abatement measures to be taken, pursuant to State of California regulations surrounding the 65 CNEL from the years 1989 to the present.
16. Any and all writings/documents directed to Van Nuys Airport management regarding enforcement of noise violations, including, but not limited to: remedial actions to be taken, fines to be levied, operating status penalties, referrals to the City Attorney's office for prosecution.
17. Any and all documentation of any and all noise violations levied on aircraft operators at Van Nuys Airport between the years 1989 to the present.
18. Any and all documentation of any and all curfew violations levied on aircraft operators at Van Nuys Airport between the years 1989 to the present.
19. Any and all documentation reflecting aircraft noise complaint analysis policies for the years 1989 to the present, including all changes in noise complaint policies, and their effective dates.
20. Any and all documentation of pilot noise reduction education/in-service training programs in existence between the years 1989 to the present. Such documentation may include, but is not limited to: handouts, pamphlets and other instructional materials utilized for the purpose of educating aircraft operators in >noise reduction matters.
21. Documentation of any and all fixed-based helicopter operators based at Van Nuys Airport for the years 1989 to the present. Such documentation shall include, but is not limited to: dates individual operators came to Van Nuys Airport, agreements entered into between the parties.
22. Documentation of any and all transient helicopter operators based at Van Nuys Airport for the years 1989 to the present. Such documentation shall include, but is not limited to: dates individual operators came to Van Nuys Airport, agreements entered into between the parties.
23. Documentation of any and all written policies in effect between the years 1989 to the present regarding arrival and departure routes for helicopters (both fixed based and transient).
24. A listing of all complaints registered against helicopter operators out of Van Nuys Airport for the years 1989 to the present. Such documentation shall include but is not limited to: type of complaint lodged, investigative efforts undertaken, actions taken to correct such complaint, fines levied (if any), and whether revocation of landing privileges resulted.
25. Any and all documentation regarding criteria utilized or relied upon to make a revocation of landing privilege for any helicopter operator based upon repeated noise complaints for the years 1989 to the present
26. Documentation regarding any and all refueling/maintenance contracts entered in between helicopter operators not based at Van Nuys Airport and the DOA for the years 1989 through the present.
27. Documentation of any and all public hearings held at Van Nuys Airport regarding community concerns about airport noise for the years 1989 to the present.
28. Documentation of any and all policies in effect for the years 1989 through the present governing responses to community communications of noise complaints. Such documentation may include, but is not limited to: personnel assigned to speak with, communicate by writing to, or otherwise acknowledge lodged complaints.
29. Documentation of definable/measurable noise reduction achieved by Van Nuys Airport in response to the "Fly Friendly Program" instituted.
30. Documentation of definable/measurable noise reduction achieved by Van Nuys Airport in response to the imposed curfew.
31. Documentation of any and all aircraft operators participating in the "Fly Friendly Program" since its inception. Such documentation shall include, but is not limited to, dates operators received information/instruction in said program, agreement to comply documents executed, dates citations issued as a result of violations, and any written or otherwise communicated recommendations to the City Attorney prosecution for violations.
32. Any and all documentation or other writings regarding non completion of the Part 150 Study initiated for Van Nuys Airport. Said documentation may include, but is not limited to: person(s) with authority to cease completion of said study, documentation relied upon or utilized in making such decision, all persons consulted in anticipation of such a decision, and justification for such non-completion.
33. Any graphic depiction of helicopter routes in existence between the years 1989 and the present, also described as "helicopter route charts."
34. The VFR Terminal Area Chart for Los Angeles in existence for the years 1989 to the present.
35. Any and all "marketing" or "enticement" programs in existence or initiated for the years 1989 to the present aimed at Stage II aircraft operators. Such programs may take any form of communication to the aircraft industry; for example, utilizing written pamphlets, phone calls, magazine or trade advertising, television, radio, Internet sites, trade shows.
36. Documentation of the number of Stage II and Stage III aircraft based at Van Nuys Airport for the years 1990 through the present.
37. Documentation of the number of transient Stage II and Stage III aircraft utilizing Van Nuys Airport for the years 1990 through the present.
38. A written/graphic summary of all noise complaints received pertaining to aircraft at Van Nuys Airport for the years 1990 through the present.
39. Documentation reflecting the 1998 (or most recent) change in lodging noise complaint procedures for the Van Nuys Airport. Such documentation shall include, but is not limited to: date change of procedure went into effect, names/titles of persons involved in policy change, persons/entities relied upon or consulted with in regards to making said procedural change, justification for such change, communication of such change to community members/organizations affected by such change.
40. Documentation to support DOA's verbal assurance to the residential community surrounding Van Nuys Airport that 737 aircraft would NOT becoming to the airport for any purpose at any time.
41. Documentation to support DOA's assurance that hangar construction at Van Nuys airport wherein the door height was elevated to a footage which would accommodate 737s would not result in bringing 737 aircraft to Van Nuys Airport.
42. Copies of all Van Nuys Airport generated logs/compilations pertaining to helicopter noise complaints received for the years 1989 to the present.
43. Aerial View of Van Nuys.
44. Van Nuys Airport Layout.
45. Van Nuys Operations Summary.
46. Chronology of Van Nuys Noise Mitigation and Monitoring Actions (updated).
47. Van Nuys Pilot Information Booklet.
48. Copy of Van Nuys Airport 1994 Noise Exposure Contour Evaluation (Prepared by Landrum & Brown, Inc., March 1995).
49. Integrated Noise Model (INM) input run stream data for all noise contours developed since 1988 by DOA.
50. Any and all documentation or other writings regarding the VNY Master Plan, including but not limited to "drafts" or other records addressing the long term impacts of future airport development on the 65 CNEL contour.
51. A list of each and every witness you intend to call to testify at the hearing in this proceeding.
52. A list of all writings and other things you propose to offer into evidence at the hearing in this matter.
53. Any and all investigative reports made by or on behalf of
you or on behalf of any of your witnesses pertaining to
the
subject of this proceeding, to the extent such reports (1) contain the names and addresses of witnesses or persons
having
personal knowledge of the acts, omissions or events that are the
basis for the proceeding, (2) reflect matters perceived by the investigator or witness, or (3) contain or include by attachment
any statement or writing describing in subsections (a) through
(e), inclusive, of California Government Code section 11507.6
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