This letter from Debi Wagner, former Burien Councilmember, describes Seven Significant Areas where the Sustainable Airport Master Plan (SAMP) and the FAA’s Environmental Assessment fail to protect the surrounding airport communities. The deadline for submitting comments to the Port of Seattle is December 13, 2024, so she encourages everyone to review the Airport Plan and send their personal comments.
by Debi Wagner.
I want to encourage all community members to comment on the FAA’s Environmental Assessment for the airport SAMP (Sustainable Airport Master Plan) expansion. Because it is the holiday season and everyone is busy this time of year and I’ve been preparing for this EA for years, I thought it might be helpful to share a summary of my seven major points of deficiency of the document for anyone to use some or all. I have developed each point more fully in my formal comment letter also enclosed.
1) Growth is based on a false premise. The document asserts the same amount of growth with or without the expansion which is impossible to accomplish. The airport is constrained by size, location of runways and gates. Since landings take the lions share of time, this is where the major constraint happens. According to FAA’s own documents, theoretical capacity with landing constraint of close runways and staggered thresholds allows for 560,000 (worse conditions) to 630,000 (average). This leaves tarmac and gates as the bottleneck. Gates can accommodate 1 operation per hour so adding a total of 33 gates can push the numbers of operations into the 560,000 to 630,000 area. The tarmac is far too constrained to park or hold aircraft waiting for gates. At 56 to 96 landings per hour, they have to go somewhere and this is where the need for new gates come in. Allowing an unreasonable congestion on the tarmac is a safety risk FAA could never allow so for that reason, the purpose and need of alleviating congestion and constraint is false. This expansion is for growth so the airlines can continue to grow their profits.
2) Health impacts in the communities are already disproportionate and adverse. The narrative surrounding the EA suggested that the lack of significant health impacts means the study of causative factors like excessive noise and emissions (which the airport delivers into the communities every day) that FAA is required to take a “hard look” into might be unnecessary. This narrative predates the 2020 Community Health analysis which found profound or significant disease and death rates in a 10 mile area around the airport. But this report has been ignored in the EA and the National Environmental Policy Act does not allow a proponent to not do their due diligence on these now known risk factors.
3) The air pollution calculations are untrustworthy. Various independent analysis that pre-date the EA disagree to such a wide degree it calls into question the accuracy of any information to date. One of those prior analyses was done by EPA and another by the State Department of Ecology, two independent, credible and trustworthy sources that have figures twice as high or more than what the EA presents. At levels used by the EA, although much lower than these other sources of similar modeling exercises, one of them found violations of the Clean Air Act. At twice as high it is likely that even more violations would be found. But without the kind of analysis like dispersion modeling, the community, agencies, regulators and researchers have no assurance of compliance with the Clean Air Act or even any confidence in the data.
4-7) The cumulative impact analysis, children’s health, environmental justice and climate sections reflect the lack of data, lack of analysis, lack of acknowledgment of the inadequacy of the DNL noise metric currently under debate at FAA due to congressional mandate, failure to acknowledge the health status report, so remain silent on impacts or find no significant impacts-a completely wrong conclusion.
Nobody who lives here with the jet fuel fumes, soot, noise, traffic, poverty and disproportionate impacts believes this is not significant. Not only is the expansion significant, the existing airport is already significant. With the kind of operations increases planned at 30 to 40% more aircraft, thousands more vehicles on 509, hundreds of more planes over our homes each day, it is unconscionable for the industry to make our current problems worse.
Please send comments to: SAMP@portseattle.org
And send a cc to: Kandice.Krull@faa.gov
And EPA at: Bitalac.emily@epa.gov
2 Responses
I didn’t expand too much on the noise issue but the way FAA measures noise with their DNL (Day-night level – an average) is unsettled and in flux. Congress has tasked FAA with researching/developing a different metric(s) which more closely matches public perception of harm. So any dismissal of noise impact by the FAA EA based on their modeling of DNL may be subject to underestimation and at least, premature.
For information on how FAA measures noise impact and the current controversy surrounding the need for a new, more representative noise metric see: https://aviationimpactedcommunities.org/faa-fmcs-interagency-agreement-noise-policy-review-october-2022-current/