We've gotten questions regarding where the Sustainable Airport Master Plan (SAMP) is at, state legislation, and possible next steps. We'll start with the SAMP today, where we don't know a lot and go into the state and local affairs next time.

The SAMP NEPA Draft EA

The NEPA Draft EA (documents) was expected by 'Q1 2025'. If there is delay, it most likely means that the FAA has concerns with the proposal and is working privately with the Port of Seattle to iron them out before issuing a ruling. Unfortunately, the FAA will not release your comments until that ruling - which further limits what the possible challenges might be.

There is still every reason to believe that they will make minor adjustments and still get to a finding of no significance (FONSI). For example, a major reason for the years of delay in publishing the 2024 Draft EA was to try to create a proposal that would pass muster.

City Preparedness

From what we've been able to learn, none of the involved cities are preparing to appeal the Draft EA should it be a FONSI. Obviously, that does not mean they won't appeal. We would like to believe that something more is happening in private, but we have no evidence.

When the ruling is published,  surrounding cities, or other entities with legal standing, have 60 days to file an appeal. Preparing any appeal is not cheap - costs start at $10,000 to do basic research and file. That assumes that one has already prepared a set of sound legal arguments - not what we think is 'fair'.

As the saying goes, "you can have it fast, good, or cheap—pick two." Airport law - meaning the entire airport, including land use and community impacts, not just 'airspace', is very specialized. In fact, 'noise and air pollution' - the ones you automatically think of - may be the weakest legal arguments. Frankly, our challenge has been to get people to stop focusing exclusively on noise and air pollution and instead focus on the broader community impacts of having one of the largest airports in the world right next to so many people.

The Importance of Both Federal and State Processes

Some cities (eg. Federal Way and Normandy Park have already said on record that the federal NEPA process is a foregone conclusion, so why bother?

Our reply is simple: because the ¹Port has made it clear that the federal process will be a model for the next (and final) environmental review under the State Environmental Policy Act (SEPA).

The initial reason for the SAMP being delayed in 2018 was a Port proposal to create a single, combined Federal/State environmental review. That is how confident they have been in this process. As of this writing, they are still talking about getting through both the federal and state processes by the end of 2025.

The SEPA process is more involved and will likely take somewhat longer. Yes there will be another public comment period. But if the federal process goes unchallenged, it will certainly speed the state process and allow the Port of Seattle to continue expansion that much faster.

The Need for Proactive Engagement

Unfortunately, cities usually wait for something to happen, and then react. Historically, this has always been the wrong approach. Because research and strategy takes times, waiting for a Public Comment period, and then a narrow Appeal Window, essentially gives up any chance to change the outcome. If cities take this approach it indicates pure virtue signaling. The idea is to appear like your government is doing something, but without actually doing anything useful.

But this is the reality. Cities, like most of the public, do not see an imminent threat because they do not see 'construction'. It has been extremely challenging to get people to understand the basic premise of the SAMP—that it will provide the same growth as building a new runway.

And we still hear city councils and state elected officials saying that 'the solution' for reducing our impacts involves 'moving traffic to Paine Field' or somewhere! These are myths. The Port and the FAA support a new airport in order to provide more flights, but not to reduce traffic at Sea-Tac Airport in any way.

Really being prepared

Only one city (Des Moines) has established a legal fund specifically allocated to the SAMP. That is only $69,000 - enough for an initial appeal, but nothing more. We have never suggested that cities engage in the ruinously expensive 'war' of the Third Runway. But doing nothing is equally bad. If anyone tells you there are only two choices ('war' or 'partnership'), walk away. There is a sensible middle path.

But we must be prepared for more than one appeal. For example, Burien won its law suit with the FAA in 2018. But because it did not have the resources to respond to the FAA's inevitable response, the entire community lost a major opportunity to change the trajectory of the SAMP. We will need likely need funds for three trips to court, not one.

Call to Action

It is up to you to make it clear that a second airport, electric planes, sustainable aviation fuel—they are all virtue signaling. It is up to you to get your local government to focus on the SAMP as being as big a threat to our area as the Third Runway was.

1. Write to your city council

• Burien: council@burienwa.gov
• Des Moines: citycouncil@desmoineswa.gov
• Federal Way: council@cityoffederalway.com
• Normandy Park: council.members@normandyparkwa.gov
• SeaTac: citycouncil@seatacwa.gov

"I am writing today because I am concerned that I do not see activity in our city regarding the SAMP. I urge you to developing a strategy to respond to the upcoming ruling effectively. What is our city doing to prepare for a potential appeal? What are our city's plans should an appeal fail? How will we respond to the SEPA process?"

2. Ask pointed, specific questions such as:
   • Are you developing a legal strategy in advance of the federal Draft EA ruling?
   • If so, what is it? If not, why not?
   • What cities are you working with? How?
   • What are your plans should an appeal fail?
   • What strategy do you have moving into the SEPA process?
   • What budget have you established for this?

   The more specific your questions are, the less chance officials have to wiggle out of committing to real action - no more virtue signaling.

3. Share the responses you receive. We all need to know what cities are thinking. Asking these questions, making sure we know where all our local governments really stand, is the way to make sure that all local governments are focused and speaking with one voice. That's the way to make sure the SAMP process gets us where we need to go: reducing harms where we can, and obtaining compensation for those we cannot.

Next time: state and local.