11a. Attachment

02 SEA Stakeholder 2022 Annual Report

December 5, 2022

The Honorable Patty Murray                         The Honorable Maria Cantwell
United States Senate                                  United States Senate
The Honorable Adam Smith                         The Honorable Pramila Jayapal
United States House of Representatives                United States House of Representatives
The Honorable Rick Larsen                            The Honorable Marilyn Strickland
United States House of Representatives                United States House of Representatives
Dear Senator Murray, Senator Cantwell, Representative Smith, Representative Jayapal, Representative
Larsen, and Representative Strickland,
On behalf of the Port of Seattle and the six cities surrounding Seattle-Tacoma International Airport
(SEA), we are pleased to write to share our aircraft noise and emissions policy priorities for inclusion in
next year’s Federal Aviation Administration (FAA) Reauthorization legislation.
Prior to the COVID-19 pandemic, SEA was not only the 8th busiest airport in the country in terms of
passenger volumes, but also one of the fastest growing – increasing from 31 million passengers in 2010
to almost 52 million passengers in 2019. This growth – and the associated number of operations and
overflights in near-airport communities – has elevated aircraft noise and air emissions as one of the
highest community priorities for the Port and the cities of SeaTac, Burien, Des Moines, Normandy Park,
Tukwila, and Federal Way.
The Port and these six cities work closely together to identify new mitigations and abatements for
aircraft noise and emissions in our community; in fact, we have jointly created the SEA Stakeholder
Advisory Round Table (StART) to provide a forum for collaborative efforts on this front. We are proud
that this partnership has resulted in specific changes which have resulted in measurable changes todate
, such as reduced late night noise and less use of the 3rd runway (closest to the local neighborhoods)
for late night landings).
There is only so much we can do on our own, however; the Port is extremely limited in its ability to
directly impact these issues, and so we need federal partnership to provide new tools, new authorities,
new resources, new approaches and new FAA engagement that can make a tangible difference. To that
end, StART has been able to develop a significant list of jointly supported federal policies that we believe
will move us toward this vision. The 2023 FAA Reauthorization is the best vehicle for us to make
progress in implementing these priorities.

                As you begin conversations regarding the development of the 2023 legislation, we ask that you work to
include the following seven (7) aircraft noise and emissions policies in the final bill:
I.   Reducing the impact of overflight noise on near-airport communities: The Port has received an
increasing number of complaints from local residents over the last decade regarding overflight
noise. In addition to the work of StART to identify voluntary FAA and airline measures to reduce
noise, the Port has also doubled down on implementation of its noise program – insulating not
only homes and schools but also now apartments, condominiums, and places of worship. Yet,
there are additional ways that the federal government can be helpful on this front: 
1)   Secondary insulation for "failed" packages: Over the past 40 years, the Port has installed
noise packages in approximately 9,500 homes. However, current FAA policy restricts
airports from using federal funds to upgrade or repair noise insulation other than in those
homes that received packages pre-1993. We believe strongly that homes located within the
airport’s current FAA-recognized noise contours that meet broader criteria for “failed”
insulation should be eligible for secondary investments – particularly those homes where
the warranty has expired, or the product manufacturer is out-of-business and therefore
unavailable to honor warranties. 
2)   Aviation Noise and Emissions Mitigation Act: The Port and the airport cities share a belief
that the U.S. Environmental Protection Agency (EPA) can play a productive role in
addressing community concerns about aircraft noise and emissions. While the FAA is
excellent at maintaining the safety and efficiency of the national airspace system, the EPA’s
core mission around protecting human health and the environment makes them a natural
partner in such efforts. US Representative Adam Smith’s legislation would support the
collection of data and then fund initiatives to mitigate aircraft noise and emissions. These
new tools could make a significant difference, particularly in terms of environmental justice. 
3)   Deadline for action on FAA Neighborhood Environmental Survey: In April 2020, the FAA
released its report1 – as required by Sections 173 and 188 of the 2018 FAA Reauthorization –
evaluating alternative metrics to the current 65db day-night level (DNL) standard. The
conclusion of that report was that “DNL is the recommended metric and should continue to
be used as the primary metric for aircraft noise exposure.” 
However, in March 2021, the FAA released the results of their Neighborhood Environmental
Survey (NES)2, which found that noise annoyance extends far beyond the current FAA noise
contour. In response to the public comment period following the release of the NES, the
Port and the airport cities submitted a joint letter stating that “years of additional research
to make policy decisions seems both unnecessary and detrimental” and that “[a]t the very
least, the FAA should be very clear as to what it considers to be the current gaps in
knowledge that prevent immediate policy decisions, and the timeline for completing
additional information gathering and analysis before policymaking can be conducted.”

1 https://www.faa.gov/about/plans_reports/congress/media/Day-
2 https://www.faa.gov/regulations_policies/policy_guidance/noise/survey

                             The Port and the airport cities are very aware that any potential changes to the current 65
DNL metric – whether a lower decibel level and/or additional or alternative metrics –
require careful consideration of the costs and benefits of various options, including the
possibility of billions of dollars of newly eligible investments in noise insulation for homes
and buildings outside the current noise contour. Yet, without a clear timeline and deadline
for whether and how FAA may act on the results of the NES, airports and communities are
stuck in a frustrating limbo of uncertainty. We also believe that FAA could use a wider range
of input on this challenging and complicated topic.
To that end, we propose two policies for inclusion in the 2023 FAA Reauthorization:
   Creation of an Aircraft Noise Advisory Committee (ANAC): Congress should direct the
FAA to convene – within 60 days of passage – an aircraft noise advisory committee to
evaluate existing research on aircraft noise impacts and annoyance; the costs and
benefits of a wide variety of noise metrics; and other factors related to this topic. The
ANAC should consist of representatives from key federal agencies such as EPA and the
National Aeronautics and Space Administration (NASA), airports, airlines, aerospace
manufacturers, and community groups from airport cities. Within one year of creation,
the ANAC should submit its recommendations on the question of whether and how
current aircraft noise policy should change.
   Deadline for action on ANAC recommendations: Congress should set a statutory
deadline six months after the submission of the ANAC recommendations. During that
period, FAA should consult with Congress on the recommendations, conduct a public
comment period to solicit stakeholder input, and then make a final determination on
next steps.
II.   Reducing aircraft emissions: Ensuring continued progress on reducing aircraft emissions of
carbon and other air particulates is key to not only preventing the worst impacts of climate
change but also protecting human health. A transition to sustainable aviation fuels (SAF)
represents the most tangible, near-term opportunity to achieve these goals; SAF not only
reduces carbon emissions from aircraft, but also a wide range of additional air emissions
including ultra-fine particulates (UFPs). Spurring the development and implementation of SAF
must be a top priority for the 2023 FAA Reauthorization. 
4)   SAF incentives and investments: The Inflation Reduction Act contained two key policies that
will make a substantive difference in SAF implementation – a SAF Blender's Tax Credit and a
SAF infrastructure grant program. The former will help create price parity between SAF and
traditional Jet A fuels, while the latter will help ensure the necessary construction
investments to refine, blend and transport the fuels; for example, the Puget Sound region
could benefit from such funding to invest in any required infrastructure to spur increased
adoption of SAF at SEA. We urge the 2023 FAA Reauthorization to direct the FAA to do
everything possible to successfully implement these policies in ways that move the United
States toward the Biden-Harris’ Administration’s SAF Grand Challenge goal of producing at
least 3 billion gallons per year of sustainable aviation fuels by 2030. Similarly, we support
additional, complementary programs, policies, and investments that the FAA can undertake
to facilitate progress – including but not limited to collaboration with other federal agencies
such as the US Department of Energy, the US Department of Agriculture, and the US
Department of Defense.


                           5)   Environmental Mitigation Pilot Program: Section 190 of the 2018 FAA Reauthorization
directed the creation of this fund, which was implemented as a one-time competitive grant
opportunity in 2021. While SEA’s application for funding through this program was not
successful, we support the permanent authorization of this program at $6 million per year,
because of its potential to support innovative technology solutions to reduce aircraft noise
and emissions issues.
6)   Protecting Airport Communities from Particle Emissions Act: While most of the above-listed
Port-Cities priorities are actions rather than studies, we understand that additional research
at the federal level is necessary to lay the groundwork for future decisions around UFPs
from aircraft engines. We strongly support US Representative Adam Smith’s legislation,
which would bring more federal attention and engagement on the sources, characteristics,
dispersion, and potential health effects of UFPs.
III. Addressing regional airport capacity needs: The Port and the airport cities have all publicly
recognized that the Puget Sound region needs additional airport capacity beyond SEA, which is
why we have endorsed the Washington State Department of Transportation’s Commercial
Aviation Coordinating Commission (CACC) siting process. The CACC’s mission to identify a new
regional airport outside of King County and/or expansion of other, smaller airports in the region
will not only ensure that our economy can serve future air travel demand, but also that
overflights will not be fully concentrated around SEA. However, while the CACC is tasked by the
Washington State Legislature with identifying a site outside of King County where future
regional air travel capacity should be located, there is no current funding or implementation
plan once their work is complete. The federal government can support this process by: 
7)   Ensuring FAA support for new regional airport capacity: We would like to see policy
language in the FAA Reauthorization legislation that accomplishes three goals: 1) clarifies
the process for FAA regulatory review and agency collaboration with cities and states in high
air travel demand regions looking to invest in new airport capacity; 2) dedicates funding for
new airport capacity in high demand regions; and 3) provides additional FAA guidance on
necessary steps to implement any final decisions from the CACC. While we do not know a
specific timeline or strategy for regional airport capacity growth, it is essential to take the
steps now that will smooth the path to meeting regional air travel demand over the coming
Thank you again for the opportunity to share our FAA Reauthorization aircraft noise and emissions
priorities, and we look forward to working with you over the next year to ensure that these policies are
signed into law. We deeply appreciate all that you do for the Port and our communities, and please do
not hesitate to contact us if we can provide any additional details.
Yours truly,

Commissioner Ryan Calkins                                  Mayor Jim Ferrell
President                                                    City of Federal Way
Port of Seattle Commission

               Mayor Allan Ekberg                                         Carl Cole
City of Tukwila                                                   City Manager
City of SeaTac

Adolfo Bailon                                                 Michael Matthias
City Manager                                              City Manager
City of Burien                                                     City of Des Moines

Amy Arrington                                            Lance Lyttle
City Manager                                              Aviation Managing Director
City of Normandy Park                                       Seattle-Tacoma International Airport



Limitations of Translatable Documents

PDF files are created with text and images are placed at an exact position on a page of a fixed size.
Web pages are fluid in nature, and the exact positioning of PDF text creates presentation problems.
PDFs that are full page graphics, or scanned pages are generally unable to be made accessible, In these cases, viewing whatever plain text could be extracted is the only alternative.