Cumulative impact analysis of the Burien Turn and Sea-Tac Airport development actions under NEPA

A legal and regulatory analysis arguing that the FAA must conduct a broader cumulative environmental impact review of Seattle-Tacoma International Airport expansion, following a 9th Circuit Court ruling that remanded the 'Burien Turn' flight path back to the FAA. The document contends that multiple airport expansion projects—including the addition of 14 new gates and the extension of Highway 509—were each approved individually under categorical exclusions (CATEXs) without properly accounting for their combined effects on noise, air quality, and environmental justice communities. The author argues that under NEPA regulations, the FAA is required to analyze these past, present, and future actions together to determine whether their collective impact is significant.

Notes

This document analyzes the 9th Circuit Court’s remand of the Burien Turn flight path to the FAA for cumulative impact analysis under NEPA, referencing 40 CFR §§ 1508.7 and 1508.4. It lists Port of Seattle projects including North Satellite Modernization and Hardstand Holdroom that received CATEX determinations, arguing these should be analyzed together with the SAMP and other past and present actions. The document contends that FAA failed to properly assess extraordinary circumstances and cumulative significance across all 16 environmental impact categories in FAA Order 1050.1F.

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