Re https://www.regulations.gov/docket/FAA-2025-0605
Our comment to https://www.regulations.gov/docket/FAA-2025-0605 on the negative impacts new FAA regulations will have on Sea-Tac and KCIA airport communities.
Although the new regulations are confined to the AIP grant program, because they are being implemented via Executive Order, it is likely that similar features will be tacked onto all FAA programs concerning leaded fuel, climate, and environmental justice standards – including the Sustainable Airport Master Plan and NEPA.
We also think it worth noting that neither the Port, or any local, state or federal elected has weighed in on the issue – despite numerous complaints re. any number of other Executive Orders issued by the Trump administration. Neither did the Four City SAMP ILA consultant team.
In fact, the only agency that commented was San Francisco International Airport and it is worth reading. It may be coincidental, but SFO implemented a working sound insulation update program five years ago – the one Sea-Tac could have done last year. On this issue, and many others, SFO walks the walk.
Delivered via email
Sea-Tac Noise.Info (STNI) strongly opposes the proposed revisions to the Airport Improvement Program (AIP) grant assurances outlined in Docket FAA-2025-0605-0001. These changes threaten to undermine decades of progress in environmental protection, climate action, and civil rights enforcement within aviation policy. We call for an immediate extension of the comment period and full, side-by-side redline comparisons of all proposed changes.
### Environmental Justice and Climate Commitments
The removal of references to Executive Orders 12898 (Environmental Justice) and 13985 (Advancing Racial Equity) is deeply concerning. These orders are pivotal in ensuring that federal actions do not disproportionately harm marginalized communities. Eliminating these references signals a retreat from the FAA’s commitment to equity and environmental justice.
### Leaded Aviation Fuel
The addition of a grant assurance that could perpetuate the use of leaded aviation fuel is alarming. Lead is a known neurotoxin, and its continued use in aviation poses significant health risks, particularly to communities near airports. This change appears to prioritize industry convenience over public health and environmental safety.
### Lack of Specificity and Transparency
In addition to the other injustices in these proposed changes, we note that the **summary of changes fails to include the actual change language**. While the Federal Register notice includes proposed language for General Assurance #1, it provides only justifications—without redlines or markups—for the remaining proposed changes. There is no side-by-side comparison of old versus new language, or even a clear presentation of the full revised text. This lack of specificity makes it **impossible for the public to meaningfully comment** and likely makes it difficult for AIP recipients to understand and comply with the proposed requirements.
We urge the FAA to **extend the comment period** and reissue the proposal with clear, transparent documentation—showing the existing and proposed language for every affected assurance. This is a minimum standard for open government and public accountability.
### Community Concerns
Public comments have raised a range of important concerns, including:
* The risk of increased lead contamination affecting communities under flight paths.
* The rollback of environmental and civil rights protections that safeguard vulnerable populations.
* The lack of meaningful public engagement in the rulemaking process.
### Recommendations
We urge the FAA to:
1. Retain the references to Executive Orders 12898 and 13985 in the grant assurances to uphold commitments to environmental justice and equity.
2. Remove or revise the new leaded fuel assurance to align with public health objectives and ongoing efforts to phase out leaded aviation gasoline.
3. Extend the comment period and provide full, side-by-side redline comparisons of all proposed changes.
4. Reengage the public and AIP recipients through a transparent, inclusive process before implementing any revisions.
The proposed revisions risk reversing critical advancements in environmental protection and civil rights. We call on the FAA to reconsider these changes in favor of policies that prioritize public health, environmental sustainability, and social equity.