The neighborhood organization has expressed its agreement with the need to revise Circular 2/2006, but insists that the modification must be an effective instrument for the prevention, control, and reduction of noise pollution, based on the principle of non-regression.
The FRAVM denounces regulatory dispersion and citizen defenselessness, pointing out that Circular 2/2006 is outdated and fragmented across various documents, making it difficult to track obligations and the consequences of infringements. They warn of the risk that operational modifications with direct acoustic impact may be made through technical updates to the AIP, thus avoiding environmental assessment and public participation procedures.
They criticize the weakness of current control systems and the exception regime, arguing that the existing regulation does not objectively allow for knowing how aircraft deviations are managed. They request that the new regulation clearly distinguish justified cases for safety or emergencies from those arising from commercial scheduling, as the latter should not exempt environmental restrictions.
The federation emphasizes that the acoustic impact also includes ground activities such as taxiing or engine testing, demanding precise definitions for terms like "movement" or "operation." They also call for a strict correspondence between the current runway design and the commitments of the 2001 Environmental Impact Statement (DIA), especially regarding nighttime restrictions.
Regarding the nighttime regime, they consider current limits insufficient and demand a restrictive framework that prohibits or limits engine startup, maneuvers on platforms near homes, and the operation of the noisiest aircraft. They request the initiation of procedures to evaluate a complete nighttime closure of the airport.
Finally, they question the acoustic evaluation system for masking noise peaks and overflights, calling for indicators that reflect the real impact on health and sensitive facilities. They request independent oversight by AESA and stable participation mechanisms for citizen entities.
