SAMP Draft EA: Our running list of questions

The one thing we hear over and over from community members re. the SAMP Draft EA is “What do I say?” “How do I get started?” We get it. One way we want to help is to provide some of our questions, which we’ll be updating frequently before submitting our full comment before the December

The Cost/Benefit Analysis

The 1994 DNL65 from the Third Runway overlaid on the 2024 SAMP Area of Potential Effect (APE) How can 30 years of growth yield no more noise, air quality or community mitigations?

Beyond the usual suspects in the SAMP Draft EA Comment Period During the Sustainable Airport Master Plan Draft EA Comment Period (SAMP) we know most people will focus on the noise and pollution. However, we also hope that readers, and especially cities, will focus on other areas which may prove just as useful in obtaining

Burien City Council October 28 (SAMP Draft EA)

Good questions. But the same questions.

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Some excellent questions from councilmembers after the presentation (27:54). Followed by a pointed comment from Burien Airport Committee vice-chair Brian Davis (52:20).

Our take

The Burien City Council is currently facing the same challenges as everyone else in knowing how to respond to the SAMP. To a certain extent, this is understandable. Only one member of that council remains from 2018 when the SAMP was put on hold. There are none from 2012 when it was introduced by the Port. Burien also has a new City Manager and staff. All the airport communities are like that. The Port, on the other hand, has the only continuity.

But at least the councilmembers were asking the right questions.

EA vs. EIS

One thing they were getting a feel for is the difference between an Environmental Assessment and an Environmental Impact Statement. An EA is not simply ‘EIS-lite’. It’s far less specific. When people find it hard to understand what the projects are about or how to comment, that is in large part because there are no specifics as to each project. That’s an EA. The EA assumes that the project is a known quantity and thus does not require deeper examination.

Micro-Management

Another issue they raised is the lack of regard for area-wide projects that are obviously inter-connected, eg. the Part 150 program (sound insulation) and how important SR-509 will be in adding cargo capacity. Those are not part of the SAMP. For example, the freeway had its own separate environmental review in 2003 (and 2018).

Loopholes

Are these ‘fair’ to airport communities? No. But the SAMP is a legal process. It’s like a tax return, with thousands of possible ‘deductions’. Some are very hard and fast rules. Many, many others are subject to the interpretation of the FAA official who will review the Draft EA. The Port is following what it considers to be a valid interpretation of FAA rules.

It’s just business

However, the one point we keep trying to drive home: there is nothing preventing the Port of Seattle from addressing these concerns using its own money. The FAA’s authority largely comes from giving and withholding money in order to make sure that airports provide proper levels of service to passengers and cargo shippers.

The Port of Seattle is a business that happens to look like a government. All businesses work hard to keep their costs to a minimum–including looking for every possible loophole in the SAMP. One might wish they would be otherwise. However one can at least understand why they might choose to create the impression that ‘FAA rules’ are making it impossible for them to do more for communities.

But the Port is a business. A business experiencing record profits. It can afford to do more. The question is: Will we graduate from ‘good questions’ and start asking for it? Or will we continue to ask the same good questions every few years and allow the distractions to continue.

SAMP Draft EA: How to provide a great public comment

How to provide effective public comment by December 5, 2024 Because new ways for you to participate will likely become available, this article may be subject to updates. Introduction This is the second of a two-part article concerning the Sustainable Airport Master Plan Draft Environmental Assessment (SAMP Draft EA). If you’re looking for the short

Port Commission Meeting features SAMP EA and Tax Levy

Four hours, 700 pages

Meeting Agenda

It is difficult to get a man to understand something, when his salary depends on his not understanding it.

 

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Sustainable Airport Master Plan Draft EA Presentation

(Item #11a SAMP EA Presentation)

Sarah Potter: Landrum & Brown, Steve Rybold and Sarah Cox: Port of Seattle

Today’s Commission meeting was the Port’s first presentation concerning the Draft EA published yesterday. To summarize the 4,500 page document in one sentence, the only required mitigation will be for construction impacts. There is nothing for Air Quality, Noise, Environmental Justice, Cumulative Impacts. None.

Port Environmental Director Sarah Cox acknowledged this and gave the Commission hope for more mitigation options in the SEPA process, which will occur after the Federal assessment is complete in Q3 2025. However, given the fact that the Port self-permits (through an agreement with the City of SeaTac) we are skeptical.

45 Day Comment Period

The Port of Seattle had six years to prepare this document, totaling over 4,500 pages. 45 days for 4,500 pages. But 4,500 pages only skim over the 31 projects–each of which might require a thousand pages should the FAA ultimately decide that a full Environmental Impact Statement is needed.

Open Houses will begin in mid-November, half way through that public comment period. Public comments can be submitted online, by email, by regular mail, or in person at one of the four public meetings.

Public meeting dates:

    • November 12 (Tuesday) — 6 to 8 p.m. — Wildwood Elementary School (Federal Way)
    • November 13 (Wednesday) — 6 to 8 p.m. — Mount Rainier High School (Des Moines)
    • November 14 (Thursday) — 6 to 8 p.m. — Highline High School (Burien)
    • November 16 (Saturday) — 10 a.m. to 12 p.m. — McMicken Heights Elementary School (SeaTac)

Our Take

Given the Port’s recent focus on being “The Greenest Airport In America”, we consider this a high point in cynicism. Everyone is following the rules. Everyone is sincerely trying to work within those rules. But notice that no one at that meeting questioned those rules. One can say that it is the FAA’s responsibility for not doing more. But since the Port of Seattle will benefit so greatly from the economic benefits of airport growth, this creates an intrinsic conflict of interest that they cannot or will not see past.

Growth?

Before the SAMP, the Port would insist that it did not control demand. That was never true. It has done everything possible to grow airport operations and it has been very successful in that regard, going from 17th to 8th largest airport in America in twelve years. For a short time post-COVID it was refreshing to hear the Airport acknowledge that desire to grow.

Now that the Draft EA has been published, it has re-started this untrue statement. They are not and never were responding to ‘organic regional demand’. This is extremely disappointing.

Property Tax Levy Presentation

Also discussed  a proposed 2% increase to their Property Tax Levy. The Port uses that money in three broad manners:

  • Community grants. A relatively small amount of the Tax Levy is used to fund all their grant programs, including the annual $1.4M ILA with the City of SeaTac.
  • A larger amount is ongoing environmental mitigation for past bad acts, primarily the Duwamish Superfund cleanup. Zero of that is aviation community.
  • Over two thirds every year is used to accelerate bond re-payments. The Port finances many of its major capital projects through billions of dollars in ongoing bond sales. Using $50M of this money every year to pay off those bonds early saves literally hundreds of millions in interest over time. A way to think of it is how much money a homeowner can save on their mortgage by paying even a few dollars extra every month.

We’d like some answers

10 questions for the Port of Seattle Many people concerned about all the flights from Sea-Tac Airport rightfully think about “making the planes go somewhere else.” Changing the flight paths. That matters. But while we’re working on that,  we should also focus on a much easier task, which we don’t focus on: doing what we

SAMP NTP Comment Process

31 projects in 45 days? The SAMP Draft EA documents are now available here: The Sustainable Airport Master Plan Near Term Projects (SAMP NTP) is a collection of 31 construction projects that will increase flights over the next decade by as much as a new runway, but without building a new runway. The environmental review

Port of Seattle votes on Q3 2025 timetable for North Sea-Tac Park

Property leases at North Sea-Tac Park. Source City of SeaTac

Language of order still leaves ultimate ownership uncertain At the Tuesday, October 8 noon meeting of the Port of Seattle Commission, the Commission voted to approve an amended version of Order 2012: Amended Order #2024-12 (sub) The amended version, created by Felleman and Mohamed, does not make any firm decision. Instead, it directs Port staff

Port of Seattle to vote to permanently restrict North Sea-Tac Park for recreational use

1989 King County Ordinance setting aside land for North Sea-Tac Park

However, language of order leaves ultimate ownership uncertain At the Tuesday, October 8 meeting of the Port of Seattle Commission (Sea-Tac Airport Mezzanine 12:00pm), the following Order will be discussed and voted on: “The Port Commission hereby directs the Executive Director to undertake the Port activities necessary to meet the requirements described in Section 706