Vaughn v. Federal Aviation Administration

In an unpublished judgment, the D.C. Circuit Court of Appeals rejected challenges to the Federal Aviation Administration's (FAA's) environmental analysis of the SoCal Metroplex project, which involved redesigned air-traffic control procedures and flight paths at several airports in Southern California. The court found, among other things, that the FAA had reasonably concluded that the project would not have a significant effect on climate, rejecting petitioners' argument that the FAA had improperly used a de minimis standard to determine that greenhouse gas emissions associated with the project would not have a significant effect. The court noted that the 42 metric tons of expected emissions was "far less" than the 25,000 metric ton threshold for disclosure suggested by the Council on Environmental Quality guidance. The court said it was "not clear the FAA had a duty even to quantify the increase in emissions."