Comments regarding the transportation and general conformity determination for the Sea-Tac Airport Master Plan Update Draft, Final and Draft Supplemental Environmental Impact Statements

A 1997 public comment letter to the FAA challenges the environmental review of the Sea-Tac Airport Master Plan Update, arguing that the agency improperly claimed exemption from Clean Air Act General Conformity requirements and used manipulated air pollution data to avoid regulatory thresholds. The author contends that nitrogen oxide (NOx) emission figures in successive environmental impact statements were inconsistently reported—sometimes decreasing even as projected aircraft operations increased significantly—suggesting the modeling inputs were skewed to produce predetermined results. The letter calls on the FAA to justify its findings under NEPA and warns that predicted exceedances of federal air quality standards for NO2, carbon monoxide, and particulate matter should prevent the agency from funding or approving the expansion project.

Notes

A March 1997 letter to the FAA’s Northwest Mountain Region challenging the FAA’s assertion that it is exempt from a General Conformity determination under the Clean Air Act for the Sea-Tac Airport Master Plan Update. The author argues that FAA’s air pollution modeling data is flawed and manipulated, pointing to inconsistencies in NOx emissions calculations across the DEIS, FEIS, and SEIS despite significant increases in projected aircraft operations. The letter contends that predicted exceedances of NAAQS standards for NO2, carbon monoxide, and PM10 should prevent FAA from funding or approving the project.

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