Posted on

Summary of Comments from Debi Wagner on FAA Environmental Assessment for Sea-Tac Airport SAMP

A summary of Ms. Wagner’s comments to the FAA. Full document here

Key Concerns and Issues

1. False Premise of Purpose and Need

  • The FAA argues that expansion is necessary to accommodate inevitable growth. However, past FAA and industry statements indicate that airport capacity is constrained by existing infrastructure, including gate availability, runway capacity, and airfield congestion.
  • The expansion directly enables increased flight operations, contradicting the FAA’s assertion that growth would occur with or without the project.
  • The FAA has historically managed congestion by controlling aircraft throughput to maintain safety, meaning that an expansion is not inherently required to ensure safe operations.
  • The FAA has previously acknowledged that runway and gate constraints impose natural operational limits. This contradicts claims that the airport must be expanded to meet demand, as demand cannot exceed safe operational thresholds.

2. Severe Public Health Impacts

  • Public health data from the Washington State Department of Health and King County Public Health show disproportionately high rates of serious illnesses in communities near Sea-Tac, including lung cancer, chronic respiratory diseases, heart disease, stroke, and diabetes.
  • A 2020 King County Public Health Report confirmed that individuals living within 10 miles of the airport have significantly higher rates of asthma, high blood pressure, COPD, and premature births compared to the rest of the county.
  • Despite recommendations dating back to 2000, no comprehensive air quality monitoring program has been implemented to track exposure to airport-related pollutants.
  • The FAA’s Environmental Assessment fails to assess how ultrafine particulate pollution, a known byproduct of aircraft emissions, contributes to negative health outcomes.

3. Unreliable Air Pollution Calculations

  • FAA consultant estimates for air pollution emissions are significantly lower than those of the EPA and Washington State Department of Ecology, raising concerns about the accuracy of the data used in decision-making.
  • Jet particulate emissions were removed from FAA modeling in 1993, despite their known public health impacts. The failure to account for these emissions skews the Environmental Assessment’s conclusions.
  • Air quality compliance is assessed using monitoring stations located miles away from the airport, failing to capture the actual exposure of affected residents.
  • Independent assessments have found vastly higher emissions levels than FAA consultant reports, demonstrating the need for an impartial third-party review.

4. Inadequate Cumulative Impact Analysis

  • The 9th Circuit Court ruled in 2019 that the FAA had failed to properly consider cumulative environmental impacts, yet the SAMP Environmental Assessment still does not conduct a thorough analysis.
  • The EA does not include:
    • The increased emissions and traffic impacts from the State Route 509 freeway extension, which will funnel additional vehicles into an already overburdened corridor.
    • The cumulative effects of past expansions, including the 14 gates added without an Environmental Impact Statement.
    • The long-term exposure risks of airborne ultrafine particles, which research has linked to cardiovascular disease, lung damage, and cognitive decline.
  • FAA’s approach to assessing cumulative impacts violates NEPA requirements, as it fails to acknowledge how multiple projects together create significant environmental harm.

5. Environmental Justice & Children’s Health Impacts Ignored

  • The affected communities are disproportionately low-income and minority populations, which conflicts with Executive Order 12898 on Environmental Justice that requires agencies to address environmental burdens on marginalized communities.
  • The FAA’s own noise studies confirm that many residents near Sea-Tac have lived with unhealthful noise levels for decades. Yet, the Environmental Assessment does not propose adequate mitigation measures.
  • Despite well-documented research linking air pollution to low birth weight, developmental issues, and respiratory illness in children, the FAA’s Environmental Assessment fails to analyze or mitigate risks to children’s health.

Recommendations

  1. Require a Full Environmental Impact Statement (EIS), as the Environmental Assessment does not meet NEPA standards.
  2. Implement an independent air quality monitoring program, with a focus on ultrafine particulate pollution and site-specific exposure assessments.
  3. Conduct a rigorous cumulative impact analysis, accounting for previous and future expansions, roadway projects, and pollution sources.

Supporting Documents & Links