Des Moines City Council File Appeal against Port of Seattle

The grounds for appeal are as follows:

* The Port of Seattle is unclear whether the Hardstand Holdroom gates are temporary or will in fact be long term. While the Port says there will be 5 gates "offline" as a reason to fast track the Handstand, (they say nothing about discontinuing use of the Hardstand 6 gates, effectively more than doubling gate capacity without any proper analysis). NEPA (see original DNS for the NEPA DNS issued by FAA) requires that when projects are within the same geographic area and closely enough related to one another with reasonably foreseeable impacts, they should be analyzed together in the same document.) When those gates are back online they will effectively double the gates without proper NEPA/SEPA by once again setting up a piecemeal project. This has been a standard practice of the Port for far too long and leaves our City no other choice but to appeal. Which we believe is this Councils sworn duty to best protect the citizens and City in which they were elected to serve.

*The purpose and need for the project is to facilitate increased operations and passengers, even the Port's own documents state this project "may" be long term; yet in the Port’s own documents, nowhere do they address the actual airport growth, nowhere does it address that more gates will add more noise, more emissions, more traffic, more environmental impacts. More gates is the purpose of the SAMP (Sustainable Airport Master Plan). It is impossible to escape the obvious connection of the Hardstand impacts to the SAMP impacts. For that matter, the North and South Satellite projects accomplish the same exact thing, they add gates. If the SAMP additional gates have an impact then the Hardstand has impacts.

*Overall the Port is falling short on exactly why they are taking short cuts and fast tracking the Hardstand Holdroom when the SAMP closely relates to overall project impacts, yet the relationship between the SAMP and the Hardstand Holdroom is unclear.

*NEPA requires that cumulative impacts past, present and reasonably foreseeable future actions be considered and evaluated together. Approval of this DNS without appeal will deny agencies, public and the City of Des Moines the opportunity to know, review and understand the entire impact of said project. The Public will be denied the necessary ability to define substantial analysis data, beyond what the Port has traditionally offered: just a verbal promise “we won’t use this project to grow.” In fact this particular plan is in the direct opposite to principles of sustainability. As stated in the Port’s own 2017 Long Range Plan to grow in capacity of 65 million passengers yearly. The Port’s Hardstand Holdroom plan supports the Port’s intention to grow regardless of their occasional promise to the contrary.

*The Port has demonstrated a persistent pattern of failure to uphold their verbal agreement or mitigate impacts after the fact. We simply can no longer afford to trust the Port to take the communities best interest into consideration when history has proven them to do otherwise. If the Port of Seattle truly cared about the surrounding communities of Sea-Tac International Airport they would stop with all construction plans that pave the way for further growth and be requesting the State of Washington & FAA step up in efforts to site another Regional Airport. The Port is failing to do this. No matter how you look at it, it is this authors belief the reason for the fast tracking of recent piecemeal plans is simply due to the fact that in February 2018 the inter local agreement with the City of Seatac will be transferring back into the hands of the City of Seatac. The City of Seatac will then govern growth at Sea-Tac International Airport where the impacts to human health and environmental devastation will be considered first and foremost, unlike now where the Port of Seattle simply does not address them at all.

We respectfully ask our Mayor and City Council to find our citizen-signed petition as a show of support to file an appeal against the Port of Seattle Final SEPA Determination of Non-Significance (DNS) of Proposed Hardstand Holdroom, SEPA file 17-06.

We need to make full use of the rights provided to us by this FAA requirement.

Specifically:
6. Consistency with Local Plans.
The project is reasonably consistent with plans (existing at the time of submission of this application) of public agencies that are authorized by the State in which the project is located to plan for the development of the area surrounding the airport.

7. Consideration of Local Interest.
It has given fair consideration to the interest of communities in or near where the project may be located.

8. Consultation with Users.
In making a decision to undertake any airport development project under Title 49, United States Code, it has undertaken reasonable consultations with affected parties using the airport at which project is proposed.

from:
https://www.faa.gov/airports/aip/grant_assurances/media/airport-sponsor-assurances-aip.pdf