Make airlines ‘pay to play’
Supporters of scheduled air service at Paine Field want the Federal Aviation Administration (FAA) to finalize the draft Environmental Assessment that was first issued back in 2009. The FAA now says that they should have an answer by September.
We should review the issue, since we must understand how the law works and how it impacts us.
The National Environmental Policy Act (NEPA) requires an evaluation of relevant environmental effects of a federal project or action, including a series of pertinent alternatives, such as the “Take No Action” alternative.
Once a federal agency determines NEPA applicability, the agency may undertake three levels of analysis: preparation of a Categorical Exclusion (CE), preparation of an Environmental Assessment (EA) and Finding of No Significant Impact (FONSI), or preparation of an Environmental Impact Statement (EIS).
In 2009, two airlines asked to start service at Paine Field. That request triggered a review of reasonable, potential and foreseeable impacts resulting from the proposal. Assessed impacts include environmental, health, traffic, schools, noise, and so on.
The FAA chose to use the less comprehensive Environmental Assessment option and issued a draft EA in December 2009. Public comment took place in January and February 2010. The FAA has been reviewing these comments ever since.
According to the law, the FAA could have chosen a comprehensive EIS option but instead chose the EA option, which minimizes mitigation requirements. The FAA could "upgrade" an EA to require an Environmental Impact Statement (EIS) but they stated they have never upgraded an EA to an EIS.
After all, an EIS would require documentation of the full impacts of scheduled air service and make FAA actions more difficult by requiring mitigation. This would then require the parties creating the problem – the airlines that want to fly out of Paine Field –to pay mitigation costs (or seek county taxpayer subsidies).
Even if we cannot legally prevent scheduled air service, we should fairly make the airlines "pay to play." If mitigation makes it too expensive to fly from Paine Field, then the airlines probably won't even show up.
If the FAA does not upgrade an EA to an EIS, it can downgrade the EA to a “Finding of No Significant Impact,” or FONSI. The FAA can determine that airlines will NOT cause any significant pollution, traffic congestion, health, noise or other impacts to communities.
By issuing a FONSI, the FAA would literally give the airlines a free pass to come in without paying mitigation costs. However, an official “Finding of No Significant Impact” doesn’t mean we won’t actually have problems.
Based on growth rates of other airports around the country, over the next 20-30 years, we expect significant impacts from pollution, noise, traffic congestion, health, property values, the environment and our children’s learning.
In short, a FONSI ruling effectively forces taxpayers to subsidize the airlines. We get things like diminished quality of life and decreased home values AND we get to pay for it!
The FAA’s draft EA fails to address important issues, uses incorrect assumptions, and uses poor or incomplete data. As a result, the draft EA includes a (flawed) tentative FONSI conclusion.
In our opinion, the old maxim holds true: “Garbage In, Garbage Out.” That's why SOC responded with more than 50 pages of comments back in February 2010.
The FAA’s announcement that they will issue an “announcement” in September should be taken more like a warning. A flawed FONSI combined with a 1990 federal law that prevents local communities from issuing curfews or otherwise limiting scheduled air service would spell big trouble for us over the next 10-20 years.
Like a slow cancer, we will have no problems at first, but over time it will eat away at our beautiful communities. We need to fight this.
What can we do? Here are a few simple action items:
• Please write to Cayla Morgan at the FAA: firstname.lastname@example.org. Tell her we want an Environmental Impact Statement! The airlines, not the taxpayers, should pay the full mitigation costs for all "reasonable, potential and foreseeable activity."
Go to SOC’s website at http://socnw.org and click on the tab marked “Environmental Assessment” to see our full comments as submitted to the FAA in 2010.
• Support our mayor and City Council. Mayor Joe Marine has remained actively involved in this issue, and councilmembers said they would challenge the FAA if they issue a FONSI conclusion. We need to thank them and support their efforts, since the heavy lifting is still in front of us.
• Tell your friends. Go to the http://socnw.org website and sign up for our newsletter and our petition to stay informed. Go to our "Save Our Communities" page on Facebook to chat with others on this!
Since 1978, Snohomish County designated Paine Field’s primary role to support general aviation and our aerospace industry while scheduled air service has been “strongly discouraged.”
That role has worked very well because we now have a worldclass aerospace presence and a great community. Let us fight to retain that role and keep scheduled air service out.
Greg Hauth is vice president of Save Our Communities, a single issue group fighting for our communities by opposing scheduled air service at Paine Field.