Jordan Louie v. Stephen Dickson, 964 F.3d 50

The Airport and Airway Improvement Act requires airport owners to keep a current layout plan; FAA has delegation authority but States in the FAA block grant program (like GDOT) assume many administrative/environmental responsibilities.
Paulding Northwest Atlanta Airport received an EA and FONSI in 2005; an expansion prompted a GDOT supplemental EA and FONSI in 2011 after GDOT joined the block grant program in 2008.
The Airport Authority later sought a Part 139 Airport Operating Certificate (commercial service), prompting an FAA EA (notice 2014; draft EA 2015) that initially included the expansion among listed actions.
Because more than three years had passed since 2011, the Airport Authority issued and GDOT approved a written re-evaluation in 2017 concluding no new EA was required; FAA concurred and withdrew the expansion from the pending FAA EA.
Petitioners (local residents) challenged FAA’s concurrence; FAA denied reconsideration in Jan 2018 (leading to Case No. 18-1022). In Oct 2018 FAA then withdrew its concurrence (leading to Case No. 18-1336); the petitions were consolidated.
While litigation proceeded, FAA administratively closed the Part 139 application (deeming it withdrawn), so FAA no longer plans to prepare a commercial-service EA for that application.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge FAA's withdrawal of concurrence in GDOT's re-evaluation	Petitioners: FAA withdrawal perpetuates federal action that leads to expansion and environmental injury	FAA: Withdrawal removes FAA endorsement and does not authorize the expansion; injuries stem from GDOT/Airport Authority actions	Dismissed for lack of standing—petitioners' alleged injuries not fairly traceable to FAA withdrawal
Mootness of challenge to FAA's concurrence in GDOT's re-evaluation and denial of reconsideration	Petitioners: Relief could vacate FAA's actions and require further analysis	FAA: Withdrawal of concurrence during litigation renders those challenges moot because the agency already provided the requested relief	Moot—FAA's withdrawal of concurrence mooted challenges to the concurrence and denial of reconsideration
Mootness of challenge to FAA's decision to remove expansion from the pending commercial-service EA (segmentation/NEPA)	Petitioners: FAA improperly segmented the expansion from the commercial-service EA, avoiding cumulative review	FAA: The Part 139 application was withdrawn and FAA closed the file; no pending related action makes segmentation argument speculative	Moot—no pending application or interrelated action; issue not live or likely to recur

Village of Bensenville v. FAA, 457 F.3d 52 (D.C. Cir. 2006) (discussing FAA delegation and approval roles)
Friends of the Earth v. Laidlaw Envtl. Servs., 528 U.S. 167 (2000) (standing measured at commencement of suit)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (constitutional standing requirements)
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (standing for equitable relief)
J.D. v. Azar, 925 F.3d 1291 (D.C. Cir. 2019) (mootness doctrine in D.C. Circuit context)
City of Waukesha v. EPA, 320 F.3d 228 (D.C. Cir. 2003) (courts should not decide merits when resolving standing)
Cierco v. Mnuchin, 857 F.3d 407 (D.C. Cir. 2017) (withdrawal of agency notice can moot challenge)
County of Los Angeles v. Davis, 440 U.S. 625 (1979) (mootness when issues are no longer live)
Transwestern Pipeline Co. v. FERC, 897 F.2d 570 (D.C. Cir. 1990) (effectual-relief standard for mootness)
Church of Scientology of Cal. v. United States, 506 U.S. 9 (1992) (appeal moot if no effectual relief available)
Taxpayers Watchdog, Inc. v. Stanley, 819 F.2d 294 (D.C. Cir. 1987) (anti-segmentation principle under NEPA)