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Keywords

contractenvironmental justice
willenvironmental justice

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Communities Against Runway Expansion, Inc. v. F.A.A., 355 F.3d 678, 359 U.S.App.D.C. 383

Facts

The case arose from the FAA's approval of changes to the layout plan for Logan International Airport, including a new runway and improvements to existing taxiways, which were necessary for federal funding eligibility under the Airport and Airway Improvement Act. The petitioners, Communities Against Runway Expansion (CARE), claimed that the FAA's order violated the National Environmental Policy Act (NEPA) and was arbitrary and capricious due to improper contractor selection and lack of public information. The FAA and Massachusetts Port Authority had conducted an environmental review process, leading to the issuance of a Final EIS that supported the project.

In 1993, Massport and the FAA began to study options for addressing flight delays at Logan Airport. Various options were considered, including the construction of a new east-west runway designated “Runway 14/32,” construction of a new “Centerfield Taxiway,” and improvement of several existing taxiways.

Issue

Did the FAA's approval of the airport expansion project violate NEPA and the Airport and Airway Improvement Act, and was the environmental justice analysis in the EIS arbitrary or capricious?

Did the FAA's approval of the airport expansion project violate NEPA and the Airport and Airway Improvement Act, and was the environmental justice analysis in the EIS arbitrary or capricious?

Rule

The FAA must prepare an EIS for major federal actions significantly affecting the quality of the human environment, ensuring that the agency has adequately considered and disclosed the environmental impact of its actions and that its decision is not arbitrary or capricious.

Where FAA approval of funding for an airport improvement project constitutes a “major Federal action[ ] significantly affecting the quality of the human environment” for purposes of NEPA, the FAA must prepare an EIS analyzing the proposed project's environmental consequences and evaluating reasonable alternatives.

Analysis

The court found that CARE had standing to challenge the FAA's order and that the FAA had adequately considered the environmental impacts of the project. Even assuming the FAA erred in selecting the contractor for the EIS, the court determined that this did not compromise the integrity of the NEPA review process. The environmental justice analysis was deemed reasonable, as it compared the demographics of affected populations and concluded that significant noise impacts would not disproportionately affect minority populations.

We therefore conclude that CARE has standing to challenge the FAA order and the supporting EIS. We hasten to add that future petitioners will be well-advised to adhere carefully to the requirements of Sierra Club, as it will not always be possible to cure a defective initial submission so conclusively.

Conclusion

The court denied the petition for review, concluding that the FAA's actions were not arbitrary or capricious and that the environmental justice analysis was adequate.

We therefore deny the petition for review.

Who won?

Federal Aviation Administration; the court found that the FAA's approval process and environmental analysis were sufficient and not arbitrary.

The FAA determined in relevant part that the project was reasonably consistent with local land-use plans, as required under 49 U.S.C. § 47106(a)(1), and that fair consideration had been given to the interests of local communities, as required under 49 U.S.C. § 47106(b)(2).

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