Airport mitigation for the twenty first century

A modern, community-based approach

A failed 50 year natural experiment

It has been axiomatic that transportation, land, sea, and air, will eventually accrue to the benefit of all–or at least the vast majority of stakeholders–including the communities through which they flow.

At bottom, the Port of Seattle is a transportation agency. All of its work as “The Economic Engine of King County” derives from transportation. Even the construction jobs and training it provides–a large part of their portfolio, as important politically as monetarily–exist to build more transportation capacity. The wheel of progress never stops.

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Mitigating transportation? So 1970

Governments have long recognized that transportation projects also have predictable (and unpredictable) downsides that can and should be ¹abated and/or mitigated. But rather than continue to regulate these impacts individually (eg. water, air, etc.), in 1970 Congress decided that an integrated framework was needed and the National Environmental Policy Act was born. Shortly thereafter, state versions, such as the Washington State Environmental Policy Act (SEPA) followed.

Despite the appearance of a very ‘holistic’ framework, NEPA was designed to be, and heavily relies on segmentation. We will continue to use the less technical word individual.

It was also axiomatic that in order to quantify and address any impacts, even the most complex systems can and should be broken into manageable pieces. The smaller the better.

Each project is generally considered individually. For example, the main permits for SR-509 were issued in 2003 and 2018. Despite their obvious ongoing interactions, the Sustainable Airport Master Plan (SAMP) NEPA was evaluated (and approved) separately in 2025.
Within each project, impacts are broken down into individual categories, and mitigations are usually framed within those categories.
Mitigations are generally considered to be a one-time affair, not any ongoing commitment. This assures the developer that they can proceed without any future ‘gotchas’. Think of it like an insurance policy.
Mitigations are generally provided to individual parcels. For example, SR-509 provided compensation to various properties owners along its alignment–including the City of Des Moines. But those calculations were based on each parcel. not on any cumulative impact for the entirety of Des Moines.

One seemingly unrelated, large-scale emitter of unregulated pollution may still be instructive: waste processing facilities. An agency that generates excessive odor has been required to provide a community (not individual) compensation for a unique impact, difficult to quantify, ¹abate or mitigate. ⁸But regardless of any ongoing impacts that compensation is still a one-time payment.

Cities = Community = 2026

For most people today, cities are their community–providing a broad range of ongoing shared services and commitments we all take for granted. When working properly, cities provide a powerful set of positive externalities. The benefits they provide are far greater than the sum of their departments.

School districts have long been considered slightly differently from other property-based mitigations. They cannot move and they are required to provide services to all–arguably ⁶the most important and vulnerable populations. Schools have thus been able to negotiate ⁷very large mitigation settlements at both the federal and state beyond the ‘normal’ (Part 150) process–although not beyond the traditional mitigations of noise, and not beyond the concept of individual properties.

Like schools, cities influence our quality of life, both in the short and long term; and they must continue to provide high quality services, regardless of any actual outcomes from from external actors–like a nearby airport.

Like the waste treatment facility, airport impacts go far beyond property boundaries. But unlike other types of large emitters, impacts from successful airports, like Sea-Tac, can never be capped–over time these are expected to grow in proportion to operations.

In short, airports represent unique challenges for cities because cities cannot move, airport impacts are constantly expanding, and eventually we’re all dead.

Eventually we’re all dead

About the same time NEPA and SEPA were created, airport operations everywhere–and especially at Sea-Tac–began to explode in the sam ‘move fast and break things’ manner of all modern tech booms.

This has allowed for an interesting natural experiment. For more than half a century we’ve been testing a basic assumption; that eventually the benefits of airport expansion will accrue to all–including nearby communities. We now understand that this was never true, because it was never possible.

Originally, NEPA had many unintended consequences, not least of which being that it actually allowed residents to essentially stop large airport projects; not properly mitigate them, stop them cold. In response, Congress quickly passed a series of bills which shut down community law suits, substituting the Part 150 program–yet another series of individual, property-based, one-time mitigations.

Many people, even those who built the modern airport system, are now willing to admit this failure. Their answer is not to consider a community-based mitigation approach. It is to continue to rely on the word ‘eventually’. Eventually we will have electric aviation. Eventually we will have biofuels. Eventually we will have high speed trains. Unmanned aerial vehicles. Second airports. Eventually is simply an unearned discount; a way to continue to avoid ever paying for the externalities.

We have met the enemy

The really uncomfortable discussion is how complicit those living under the flight path, both residents and elected representatives, have been in this failure. We need to be able to look at this objectively without accusations of ‘victim-blaming’.

The constant, narrow focus on the individual (there’s that word again) has been a primary driver in making things worse for cities; which in turn makes life worse for residents; now and into the future.

For any number of reasons, a certain number of people will always be uninterested either in health or civic harms. “Don’t like it? Move!”
Those who are concerned may suspect that any discussion of better mitigation is some form of ‘sell out’. For them all energy should focus on ‘stopping’ something or changing flight paths or getting a check so they can move!
As people who don’t like it do move, they are easily replaced because people choose to move to airport communities for ¹¹the Airport Discount.
And of course, the Port of Seattle is constantly promoting more growth as the cure for all ills.

The distraction

Airports do not expand because people love to fly. Airports expand because people have come to expect convenient, low cost ways to get places. Especially in the US, air travel has been, by far, the most economic option. To quantify that, even with a 400% cost overrun, the Third Runway was many times less expensive than the mythic “high speed rail.” For regional planners, time after time, it has proven easier simply to weather the relatively few complaints from locals, than to build other alternatives.

The Port of Seattle spends about two million dollars a year to staff their ¹⁰Noise Department–essentially a customer-complaint center with no efficacy. ⁵It would cost far more to provide the real mitigations that were always possible.

Ironically, the lack of positive incentives for residents, electeds, airport communities writ large, creates an ongoing and slow race to the bottom. This gives regional actors, and airlines, massive operational discounts–and every reason to keep acting like it’s still 1970.

One does not get, if one does not ask…

The Port’s public image was scarred by the Third Runway. For the past decade they have pursued a highly effective reputational management strategy relying on small community and city grants. These one-time efforts provide tremendous public relations benefit, but minimal community value. Unfortunately, they have unnecessarily limited those dollar amounts and use cases based on several false narratives including the ⁹gift of public funds doctrine. Cities have not been blameless. As the saying goes, one does not get if one does not ask. Until recently, no city (other than SeaTac) seems to have questioned this system in any way.

A Four-Phase Approach

To address all these defects in airport mitigation will require four types of ongoing effort from local governments. The specifics of each phase is beyond the scope of this overview and must be considered according to the needs of each city. But all must begin immediately, and in order to be successful, cities must begin thinking in a new, way. NEPA may still be stuck in 1970, but cities cannot be. Much can be accomplished in the near term. But persistence and continuity are key.

Changing this mindset will not be easy. Even the most forward-thinking administrators have spent their entire careers steeped in the current system. They may not like it, but it is the world they inhabit. And old habits die hard.

Phase 1: Project alignment

Cities should carefully study the Port’s Century Agenda in all its iterations and immediately begin identifying needed projects that align with that mission along near, mid and long-term timelines. It may take time to see your city through that lens. But the Port of Seattle lives up to its slogan–the more one looks, the more one will see transportation, environment, and workforce interfaces everywhere in your community–and thus opportunities for mutually beneficial partnerships which address concerns over ‘quid pro quo’ and ‘gift of public funds’.

The real ‘trick’ is to make the (correct) public case that cities are orders of magnitude more efficient in leveraging these alignments than the private organizations pushed by small Port grants.

Phase 2: Structural funding

At the same time, every city should also be pursuing structural funding. This ²analysis is largely the same and also straightforward–although the negotiation process may not be. However, in no case, should the ‘quo’ involve any incentives that support airport expansion.

The City of SeaTac has developed their Inter-Local Agreements (ILA) iteratively, over several decades, leveraging concerns and assets that made sense for them. Negotiating permitting, parking, utilities, public safety among other impacts common to all large airports.

Not all this should be emulated or encouraged. Some aspects relied on the perverse incentives intrinsic to that 1970 way of thinking. For example, the current permit system incentivizes more airport expansion and thus more negative impacts for the rest of the area. And in the case of the Third Runway–trading dollars for support–they were able to obtain significant environmental improvements paid for by other cities’ expensive lawsuits.

Phase 3: Independent research

There is plenty of suggestive evidence as to various airport harms–especially public health. However, as just two examples, the current regulatory environment does not recognize either ultrafine particles or a proper noise standard. The evidence to establish those better standards is not where it was when, for example, Lead or PM2.5 were added to the list of criteria pollutants.

However, the work that gets us there is done in large part by small teams doing independent work; not by ‘blue-ribbon commissions’ or top down initiatives. That falsehood has to be removed from the discussion.

Fortunately, a great deal of this work can be conducted by cities–especially around Sea-Tac Airport. In fact, cities are the only entities that can do this work given the political climate. Stakeholders that experiences only the benefits– including county, state, and federal–have strong incentives to avoid expediting regulatory improvements. Cities can do the work, with the long term benefits shared by all.

Phase 4: The different perspective

A common misunderstanding (some might say wilful), is that neither ‘cumulative impacts’ or ‘environmental justice’ currently mean what the public thinks they should. As we’ve seen the entire system relies heavily on segmentation. Categories like water and quality have had decades to establish clear definitions, and quantifiable costs and mitigations. We may strongly disagree with all those parameters, but that is because we know what they are. How can one achieve effective mitigations for categories until we obtain agreement on what they even mean? Words matter.

Except that the Port would say they have already answered all those questions: jobs. Their fundamental mission as job creator has been their response to any and all ‘cumulative’ impacts–especially ³equity and justice. Remember: negative impacts have always been mitigated at the individual level. Nothing is more individual than a job. In one of the few remaining represented work forces, even questioning that assumption is as fraught as questioning the notion of transportation as an intrinsic good.

Developing more equitable definitions for cumulative impacts–and how they should be mitigated for surrounding cities–will require ongoing effort, both legally and politically. This is a sea change in the way that people have thought of concerning any form of transportation mitigation and may not come easily. It cannot be resolved by any one-and-done intervention, be it legislative or legal.

Conclusion

Nevertheless, Phases 1, 2, and 3 can be developed in cooperation with the Port, or independently of it–and even then with its ⁴tacit support. That should be the approach: find common interest, research independently at the local level, and work politically and legally to change the concept of cumulative impacts to correctly align with the externalities of all nearby communities.

¹Abatement refers to reduction of harms at the source. Mitigation refers to reducing the effects of harms that cannot be prevented.

²The City of SeaTac’s ILA was developed with a initial logical quid quo; all major airports do generate well-studied negative public safety impacts.

³As one example, we note the Port of Seattle’s laudable WEMBE programs.

⁴If cities are willing to fund peer-reviewed research into all impacts of airports, surely that aligns with the Port of Seattle’s stated goal to be The Greenest Port in America?

⁵Considering how easily the airport absorbed those costs, it’s worth thinking about how differently fence line communities would be today given access to even a fraction of that money.

⁶The constitution refers to education as its paramount duty.

⁷Eg. 2001 and 2019 agreements for over $160,000,000 in sound insulation funding with the FAA, Port of Seattle and State.

⁸And these are based on the legal concept of ‘nuisance’–a civil tort. Annoyance, which is the term of art used in FAA regulations carries no legal force.

⁹The Port’s grant programs, both for cities and non-profits, is highly constrained to small amounts and a 3:1 or 2:1 matching system based on a debunked interpretation of the State Constitution known as the Gift of Public Funds Doctrine.

¹⁰These amounts also cover maintenance of items such as maintenance of the Permanent Noise Monitors–which serve no regulatory function.

¹¹While reserving the right to scream about lowered property values and high taxes. As the King County Property Tax Assessor has made clear: residents are receiving a significant airport discount in the form of lower monthly payments and lower taxes.