The Port of Seattle’s Sustainable Airport Master Plan (SAMP), a proposal to expand Sea-Tac Airport with 31 construction projects, is facing significant criticism from federal agencies, local governments, and community groups.
Critics of the plan argue that the environmental assessment (EA) supporting it is inadequate and fails to address the cumulative impacts of increased airport operations on nearby communities.
The U.S. Environmental Protection Agency (EPA) and the cities of Burien, Des Moines, and Tukwila have joined numerous advocacy organizations and citizens in urging the Port to conduct a full Environmental Impact Statement (EIS) to address concerns about air quality, noise pollution, and environmental justice.
“This should not be about ‘checking a box’ but rather respecting the communities and environment that are directly and indirectly affected,” said the City of Des Moines in its comments.
South King Media has obtained copies of comments submitted by a number of agencies, non-governmental organizations, citizen groups, and individual citizens, which we have published below.
Concerns Highlighted by the EPA
The EPA’s review of the draft EA, released on Oct. 21, identified major shortcomings, including insufficient analysis of air quality, climate change, and cumulative impacts on vulnerable populations.
“The historically overburdened nature of the area, coupled with any increase in emissions and noise exposure, could result in significant disproportionate adverse impacts on communities with environmental justice concerns,” the EPA said, recommending more robust mitigation measures and engagement with impacted groups.
Here are more excerpts from the EPA review:
“After reviewing the DEA, the EPA has identified public health and environmental quality concerns about potential project impacts to communities with environmental justice concerns and is providing recommendations to improve the assessment and environmental outcome of the proposed action. In addition, the EPA recommends providing more clarifying information in the Final EA on analysis of impacts related to air quality, climate change, and wetlands.
“The EPA has concerns that the historically overburdened nature of the area coupled with any increase in emissions and noise exposure could result in significant disproportionate adverse impacts on communities with EJ concerns. The EPA, therefore, recommends the FEA further consider cumulative effects in the EJ analysis and implications for the proposed projects.
“Studies also indicate that proximity to airports and airport activities may cause adverse health effects including increased rate of premature death, pre-term births, and decreased lung function. The EPA also notes local ongoing studies at the University of Washington with assistance from surrounding cities and the Port of Seattle are examining impacts from ultrafine particulate matter. To fully identify and evaluate public health impacts, the EPA recommends partnering with public health experts including local and state health departments, tribal health agencies, or federal public health agencies. We recommend the analysis consider the cumulative effects of increasing and existing exposures on the affected communities. This is consistent with the Council on Environmental Quality’s (CEQ) EJ Guidance which states that “agencies should consider relevant public health data and industry data concerning the potential for multiple or cumulative exposure to human health or environmental hazards in the affected population and historical patterns of exposure to environmental hazards… Agencies should consider these multiple, or cumulative effects, even if certain effects are not within the control or subject to the discretion of the agency proposing the action.
“The EPA recommends developing specific mitigation measures to address the potential disproportionate EJ impacts. In developing mitigation measures, consider mechanisms to minimize impacts of the proposed project to communities. It is important to shape mitigation efforts through engagement with each uniquely impacted group.
“Children’s Health…. We recommend the FEA include a discussion of children’s susceptibility to noise. For example, young children are more susceptible than adults to the effects of background noise on spoken communication. Short-term noise exposure can hinder classroom learning, while long-term noise exposure correlates with decreased reading comprehension and motivation…. In addition, children are especially vulnerable to air emissions due to higher relative doses of air pollution, smaller diameter airways, and more active time spent outdoors and closer to ground-level vehicle exhaust sources. We recommend the FEA include a discussion about reducing child exposure and identify any additional mitigation. As identified above, the GSA has a higher percentage of asthma rates than the state average. We recommend the FEA include a discussion of existing asthma rates and severity among children and the community and identify mitigation measures such as air filters for schools.“
Cities Demand Stronger Accountability
Local cities expressed frustration with the Port’s narrow scope of analysis. Burien criticized the EA for excluding the long-term impacts of increased flights, projected to grow by 20% to 511,800 annual operations by 2032. Des Moines noted that the increase in nighttime arrivals would exacerbate sleep disturbances and other health impacts for its residents.
“While we acknowledge the socio-economic benefits the airport brings to the region, it is crucial that growth is sustainable and does not disproportionately burden close-in communities,” the City of Des Moines wrote.
Tukwila also called for a full EIS, stating that the EA fails to meet the Port’s commitment to equity and social justice.
City of Des Moines:
“[T]he amount of information contained in the Environmental Assessment combined with the highly technical nature of the content would require months to review thoroughly. The period, even with the extension, does not provide ample time for staff, let alone the public, to review areas of interest to ensure their concerns are satisfactorily addressed. It is very disappointing that the FAA offered such a short timeframe, especially considering the magnitude of the SAMP and Environmental Assessment. In many ways it seems allowing the public to review the assumptions, analyses, and conclusions, was more about “checking a box” rather than truly seeking input…. This should not be just about “checking a box” but rather respecting the communities and environment that are directly and indirectly.
“By 2032, annual operations are forecast to reach 511,800. This is an increase of nearly 20%, resulting in more overflights, more noise events, and more disruptions to conversations, learning, working, and sleeping.
“Global research indicates that elevated levels of noise exposure can result in health impacts, sleep disturbance, and impact learning. While we acknowledge the socio-economic benefits the airport brings to the region, it is crucial that growth is sustainable and does not disproportionately burden close-in communities with environmental impacts and reduced quality of life. With no mitigations identified in the Environmental Assessment, it is imperative that the Port’s update of the Part 150 study includes both noise abatement measures to reduce noise exposure and mitigation efforts, such as sound insulation for eligible homes and schools. Additional studies, including but limited to, ongoing monitoring and testing in the City of Des Moines.
“A comparison of the existing conditions (2022) versus future conditions with the Proposed Action will result in an increase in daily arrivals of 14% and a 25% increase in nighttime arrivals. Nighttime operations are particularly impactful for close-in communities as this results in sleep-disturbance and awakenings which add to the health effects of aircraft noise exposure. And while the DNL 65 dBA threshold may not be exceeded for all close-in communities and residents, the effects will extend far beyond those contours and should be considered when planning for impact mitigation.
“The DNL noise metric does not adequately reflect residents’ experiences with aircraft noise.
“The increase in aircraft operations will result in an increase in aircraft noise and emissions, both of which are known to have health effects in nearby communities. The concentration of operations over Des Moines results in greater exposure to aircraft noise and emissions for residents of Des Moines resulting in an unfair burden for our community.
“And while federal regulations cite DNL 65 dBA as the threshold of what is “compatible”, the growth in daily aircraft noise events are likely to be disruptive and to impede learning, affecting many more than the 12 schools within the DNL 65 dBA contours. Health and well-being for our communities, as well as our children’s education should all be carefully considered as the Port plans for growth in SEA operations and strives to sustainability when collaborating with neighboring communities.
“Air quality is another major concern for communities surrounding the airport. The Environmental Assessment indicates increases in all critical air pollutants… they will impact our residents, particularly vulnerable populations such as those with asthma, other respiratory conditions, and the elderly.
“In light of the recent ruling by the DC Circuit Court, which invalidated the authority of the CEQ to issue binding regulations under NEPA, and because FAA relies on CEQ’s baseline for their environmental analysis related to SAMP, the City of Des Moines requests that FAA reevaluate the finding of no significant impact outside of CEQ’s NEPA regulation. Alternatively, FAA is asked to take no further action until there is clarity on what is the proper environmental assessment in relation to SAMP.“
City of Burien:
“It is the City’s position that [the EA’s] deficiencies may only properly be resolved through development of an Environmental Impact Statement and not the Environmental Assessment currently in process for the Port of Seattle.
“The General Study Area—the Port’s boundaries for its Area of Potential Effect—is drawn very tightly around the airport campus. The Port is attempting to force evaluation of the 31 “Near Term Projects” (NTPs) that make up the SAMP largely for impacts that will occur while those projects are under construction. This tactic ignores the impact—noise and other forms of pollution—that would occur in surrounding communities once additional aircraft and vehicles accommodated as a result of the SAMP projects leave the airport grounds.
“Cumulative impact: SR-509:
“This is especially alarming when taken with one of the most critical omissions from the SAMP: Consideration of cumulative impact from the impending connection of SR-509, which runs through Burien for approximately four miles, southward to Interstate 5….
“Cumulative impact: Third runway:
“The SAMP itself forecasts a 28 percent increase in annual aircraft operations, to 540,000 takeoffs and landings, by 2034. This makes more significant the SAMP’s omission of the 2008 opening of the third runway at Seattle-Tacoma International. The Port’s SAMP timeline only goes back to 2017, despite the fact the projected number of takeoffs and landings for 2024—about 423,000 annually—is about 16.5 percent greater than levels in the early 2000s before the third runway opened.
“Air quality and noise: SAMP ignores emerging science and policy
“Of particular concern is the alarm [The report, written by Public Health—Seattle and King County} raised about the effects of ultrafine particles (UFPs) found in higher concentrations below aircraft flight paths. UFPs are not regulated but the report outlined significant health consequences associated with larger “fine particulate matter”and recommended additional study of UFPs and their effects on human health.
“It would appear the Port is disinclined to take a hard look at the emerging data on the health impacts of UFPs, which we believe the situation demands.
“Economic consequences: Outdated and unsupported data
“We are skeptical of the Port’s estimates of the airport’s economic benefit to Burien.
“Conclusion:
“A Finding of No Significant Impact under an Environmental Assessment, especially regarding the areas addressed in this document, would be not only erroneous but spurious.“
City of Tukwila:
“The City of Tukwila is disappointed that our comments raised during the Scoping Process1 were not considered or addressed in the SAMP Draft EA. In fact, except for a very small part of the City, impacts to Tukwila were not even considered in the SAMP Draft EA.
“The City believes that the SAMP Draft EA study area is too small, the mitigation measures are insignificant, and the SAMP Draft EA fails to meet the Port’s own commitment to equity and social justice. The City of Tukwila respectfully requests that a full Environmental Impact Statement be completed for the proposed Master Plan and that the General Study Area (GSA) be expanded to at least include all of the City of Tukwila.
“The Port of Seattle’s website notes that “it commits to taking a role in regional and national efforts to achieve equity and social justice.” Yet, the SAMP Draft EA does not demonstrate any commitment to addressing equity and social justice.“
Community Groups and Citizens Speak Out
Community groups like 350 Seattle, Quiet Skies Puget Sound, Defenders of Highline Forests, SeaTac Noise Info and No Added Harm highlighted the lack of climate-focused alternatives in the Port’s proposal.
“The airport is not addressing the environmental harms it’s causing at its current size. Expansion will only increase the damage to our climate and to the health of people living near the airport and under flight paths,” said 350 Seattle in its submission.
No Added Harm said:
“Aircrafts also produce noise pollution above 65 decibels, well above the World Health Organization guideline of 55 decibels of environmental noise during the day and 45 decibels at night. Most residents in airport-impacted communities are not eligible for noise mitigation. There is no mitigation for air pollution while ultrafine particles are both unmonitored and unregulated.”
“Life expectancy is lower by 5 years for those living within 1 mile of SeaTac Airport, 3.5 years within 5 miles, and 1.7 years within 10 miles. Air pollutants cause respiratory issues such as asthma, cancer, and central nervous system problems.”
“The 419,716 airport-impacted residents include: 64% people of color, 29% immigrants and refugees, 22% children, and 12% elders. These are overburdened and vulnerable communities that have not received any air pollution mitigation and very limited noise pollution mitigation. SAMP will only add more harm at a harder and faster rate.”
350 Seattle wrote:
“The EA incorrectly claims that the ‘anticipated increase in GHG emissions due to the Proposed Action in the context of the Airport’s sustainability efforts and climate goals is not anticipated to result in an adverse impact on climate.’ It is well-established that GHG from aviation have net warming effects. There is no evidence that the Port’s cited goal of achieving ‘Scope 3 GHG emissions to carbon-neutral by 2050’ can be met. A study is needed of the impacts of the increases in GHG due to the proposed actions.”
“The 2020 King County report found aircraft noise to cause cardiovascular disease and also sleep disturbance, which has its own health sequelae. Recent scientific investigations of airport noise have found associations with many other adverse outcomes, even accounting for other health risk factors. These include more studies on low student achievement, cardiovascular disease, and sleep disturbance, and new findings on metabolic health, preterm birth, depression, Alzheimer’s Disease, and mental health emergencies.”
“The EA incorrectly concluded that ‘Environmental justice populations would be exposed to increased air emissions, noise, socioeconomic impacts, and roadways that do not meet mobility standards as a result of the Proposed Action. However, none of the impacts were found to be significant with mitigation and none are considered disproportionate and adverse.’ This statement ignores the scientific consensus cited above about the adverse effects of aviation noise and pollution. Furthermore, the health impacts from SEA fall disproportionately on people of color, those with low income, children, and the elderly – populations already living in zones with the highest level of health disparities in the state.”
Defenders of Highline Forests wrote:
“The EA fails to account for the impacts of tree and forest removal from at least five of the proposed near-term projects. Dozens of acres of urban forest would be destroyed, exacerbating existing high levels of ambient air pollution (because trees provide important air filtering properties), and intensifying ‘heat island’ effects in an area that is already hotter than surrounding communities.”
“The 2020 Public Health Seattle & King County study found that people living within 10 miles of SeaTac Airport, home to a majority of the county’s people of color, face disparities in health, resources, and risk factors compared to the rest of the county. Noise pollution contributes to hypertension and heart disease, while air pollution impacts numerous organ systems and is linked to cardiovascular and respiratory problems.”
“As local residents who live and/or work in airport-impacted neighborhoods, and as taxpayers whose money funds both Port operations and studies of aviation’s impacts, we have reviewed the Environmental Assessment and find it insultingly insufficient and callously irresponsible. We insist on an exhaustive and sincere review of the SAMP and these projects’ cumulative impacts through the lens of an EIS.”
SeaTac Noise Info wrote:
“The Draft EA’s segmentation of Near Term Projects (NTP) and exclusion of planned Long Term Projects (LTP) severely undermines its credibility. A comprehensive Environmental Impact Statement (EIS) is the only path to accurately evaluate the cumulative and interconnected effects of both phases of development on the environment and communities.”
“By relegating the analysis of Socioeconomics, Environmental Justice, and Children’s Health to an appendix and failing to assign a subject matter expert, the Draft EA neglects the disproportionate burden of environmental and health impacts on vulnerable populations, including children. A full EIS is essential to address these systemic inequities.”
“The exclusion of ultrafine particles (UFPs) from the Draft EA, despite their proven link to severe health conditions such as Alzheimer’s and cardiovascular disease, highlights a critical scientific oversight. A comprehensive EIS must integrate current methodologies to differentiate and measure aviation-specific emissions for a thorough impact assessment.”
Local activist/filmmaker/lawyer Steve Edmiston made these comments:
“The Port of Seattle (‘PoS’) and FAA appear to have used statistics ‘much like a drunk uses a lamppost: for support, not illumination.’ This EA has been crafted with a heavy thumb on the scale, ignoring readily available science on airport noise and pollution impacts to support an agenda of increasing flight operations by 87,000 annually.”
“By defining the Area of Potential Effect to essentially the airport itself, the Port has arbitrarily severed off any review of real-world impacts on the vast majority of Des Moines and other surrounding communities. This approach ignores the noise and pollution impacts that will be felt miles away from the airport campus.”
“After taking 12 years to develop this draft EA, the Port of Seattle provided the public with a mere 45 days—extended only slightly due to Thanksgiving—to review and respond to a 4,800-page document laden with technical data. This timeline is wholly inadequate and prevents community members from providing full and informed comments.”
Longtime airport activist and former Burien City Councilmember Debi Wagner made these:
“The fact that so many people living around the airport are currently experiencing statistically significantly more negative health outcomes compared to the rest of the county may be a direct result of the inaccurate or missing data, such as particulate matter (PM 10), that was provided for the air quality analysis for the third runway in 1996. These issues remain unaddressed even as emissions and airport operations continue to grow.”
“People living within 10 miles of Sea-Tac Airport face disparities in health, resources, and risk factors compared to the rest of the county, with significantly higher rates of asthma, heart disease, and other chronic illnesses—conditions that worsen the closer one lives to the airport.”
“The FAA’s current Environmental Assessment fails to provide a proper cumulative impact analysis or address significant public health concerns, including the documented statistically significant increases in illnesses such as cancer and asthma among residents in proximity to the airport.”
Local activist Elizabeth Burton wrote:
“The SAMP process ignored the fact that a functioning airport depends on a livable climate. It did not consider that by 2024, the world would already have reached 1.5℃ of warming or that at current rates of emissions, the global economy will shrink by one-third. A responsible determination of purpose and need would include consideration of broader concerns, including the need to maintain a livable climate.”
“The statement that the risks associated with climate change would be present whether or not the SAMP projects are implemented is not relevant to the discussion, and is not a legitimate reason for a finding of no significance. Implementing the SAMP projects will result in more emissions, more harm to the climate, and increased risk from climate change compared to not implementing the projects.”
“Collectively, these flaws are serious enough to warrant a more rigorous Environmental Impact Statement: one that relies on sound logic; avoids false, irrelevant, and misleading statements; and includes a serious consideration of cumulative impacts. An alternative in alignment with Port, county, and state climate goals should be included.”
Calls for Action
Critics have demanded that the Port conduct a full EIS to comprehensively evaluate the long-term effects of the proposed projects on health, climate, and equity.
The Port has not yet responded to these calls but is expected to review all public comments submitted by the Dec. 13 deadline.
