City of Naples Airport Authority v. Federal Aviation Administration

After receiving noise complaints, the City of Naples Airport Authority (airport) (plaintiff) conducted a noise study to measure sounds in the local area. The study showed that (1) the area was quiet, (2) the area was used mostly by retirees and for outdoor enjoyment, and (3) noise above an average threshold of 60 dB significantly disturbed local uses. In response, the City of Naples (city) banned noises above 60 dB, and the airport banned aircraft that emitted noise above 60 dB. These actions meant that the airport completely banned what were known under the Airport Noise and Capacity Act of 1990 (1990 Noise Act) as Stage 2 aircraft. Although the airport’s ban satisfied the 1990 Noise Act’s requirements for restrictions on Stage 2 aircraft, the Federal Aviation Administration (FAA) (defendant) determined that the airport’s ban was based on an unreasonable noise threshold and was, therefore, an unreasonable restriction on the public’s use of the airport. The FAA then disqualified the airport from receiving grants under the Airport and Airway Improvement Act (Improvement Act). However, the FAA made its determination without acknowledging the findings from the airport’s study or collecting any substantial evidence of its own. Instead, the FAA based its determination on its beliefs that (1) the city had not banned all noise in excess of 60 dB and (2) the area was not uniquely quiet. The airport sued, challenging the FAA’s grant-disqualification determination.