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Formal Comment of Jeffrey Bogen: SAMP Draft EIS Noise Analysis Deficiency — Inadequate Metric and Health Impact Assessment

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Cities
Des Moines
Airport Committee 2025
Jeffrey Bogen

A Des Moines resident's formal comment argues that the Seattle-Area Metroplex Environmental Impact Statement's noise analysis is legally inadequate because it relies solely on a federal FAA noise threshold rather than Washington State's own multi-factor significance standard. The comment contends that the standard noise metric used (DNL) masks the real impact of roughly 96 additional daily flights projected by 2037, since it averages out individual disturbance events rather than counting them. The commenter calls for supplemental analysis using alternative metrics—such as single-event sound levels and nighttime averages—supported by peer-reviewed health studies linking aircraft noise to sleep disruption and cardiovascular harm.

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Formal SEPA comment filed 2026-05-28 by Jeffrey Bogen, Des Moines resident, challenging the Seattle-Area Metroplex (SAMP) Draft Environmental Impact Statement noise analysis as legally insufficient under WAC 197-11-794. Bogen argues the Port Of Seattle improperly imported the FAA’s 1.5 dB/65 DNL significance threshold from the federal NEPA process in place of Washington’s multi-factor significance standard. By 2037, the Proposed Action adds approximately 35,000 annual aircraft operations (96 flights/day) above No Action. Comment cites peer-reviewed literature including Basner et al. (2023) FAA National Sleep Study (LAS,max metric), Philadelphia and Atlanta Pilot Studies, WHO Environmental Noise Guidelines (Lnight < 40 dB), Neimann et al. (2013) European Heart Journal endothelial function study, and Baczalska et al. (2022) Frontiers in Public Health cardiovascular review. Demands supplemental analysis using SEL, LAS,max, N-above thresholds (N60, N65), and Lnight for receptor locations in Des Moines, Burien, and SeaTac.

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