MEMORANDUM DECISION AND ORDER I. INTRODUCTION Plaintiffs commenced this action seeking to annul the approvals issued by Defendants Federal Highway Administration (“FHWA”) and Richard J. Marquis in his official capacity as Federal Highway Administration New York Division Administrator (the “Administrator,” and collectively with FHWA, “Defendants”), of the May 31, 2022 Joint Record of Decision and Findings, published on June 2, 2022, and the Final Design Report/Final Environmental Impact Statement/Final Section 4(f) Evaluation (the “FEIS”), by which Defendants have decided to proceed with the Interstate 81 Viaduct Project P.I.N. 3501.06 (the “Project”). See Dkt. No. 1. Currently before the Court is Plaintiffs’ motion for a preliminary injunction, which Defendants and the New York State Department of Transportation (as an interested or necessary party) oppose. See Dkt. Nos. 28, 32-34. For the reasons set forth below, Plaintiffs’ motion is denied. II. BACKGROUND A. Statutory Framework Plaintiffs seek an injunction based on purported violations of the National Environmental Policy Act (“NEPA”), 42 U.S.C. §§4321 et seq., by the FHWA. NEPA requires that federal agencies conduct environmental reviews of proposed agency actions. In particular, before undertaking a major federal action, such as approving funding for a project, that would “significantly affect[ ] the quality of the human environment,” an agency must prepare an environmental impact statement. See 42 U.S.C. §4332(C). The environmental impact statement must describe, among other things, the reasonably foreseeable environmental effects of the proposed action, any unavoidable adverse environmental effects, and alternatives to the proposed action. See id. New York agencies have similar, but not identical, environmental review obligations under the State Environmental Quality Review Act (“SEQRA”). See N.Y. Envtl. Conserv. Law §§8-0101 — 8-0117. Before undertaking or approving action that “may have a significant effect on the environment,” the agency must prepare or cause to be prepared an environmental impact statement that describes, among other things, the environmental impact of the proposed action, any unavoidable adverse environmental effects, and alternatives to the proposed action. See id. §8-109(2)(b)-(d). If a proposed project requires approval by both federal and state agencies, SEQRA review and NEPA review are coordinated “in a single environmental reporting procedure.” Id. §8-0111(1). B. The I-81 Viaduct Project Interstate 81 (“I-81″) runs through downtown Syracuse on an aging viaduct whose construction in the 1960s, before enactment of modern environmental laws, led to the fragmentation of Syracuse’s Southside neighborhood. Dkt. No. 28-5 at 2. The viaduct does not comply with modern design standards and is increasingly unable to adequately accommodate daily traffic that flows through the City, leaving the viaduct prone to congestion and high accident rates. See id. at 3-4. In 2008, the FHWA and the New York State Department of Transportation (the “Department”) recognized that the viaduct was nearing the end of its useful life and began planning for its repair or replacement. Over the next five years, the agencies conducted a study that examined the section of the highway that runs through Syracuse and identified strategies to better meet local needs. In 2013, the FHWA published a notice of intent to prepare an environmental impact statement. See 78 Fed. Reg. 52, 819 (Aug. 26, 2013). Throughout the ensuing environmental review, the Department and FHWA served as joint lead agencies for purposes of their NEPA and SEQRA obligations. See Dkt. No. 28-5 at 2. C. The Environmental Review Over the next nine years, the Department and the FHWA conducted an extensive environmental review. During the initial scoping phase, the agencies considered a wide range of alternatives, including the repair and continued maintenance of the existing viaduct, the replacement of the current viaduct with a new viaduct that would meet modern design standards, and the removal of the viaduct and re-routing of I-81 through a tunnel, via a depressed highway, or on surface-level streets. To determine which alternatives warranted further analysis, the agencies applied a variety of screening criteria, including consistency with the purposes and objectives of the Project, the amount of property that would need to be acquired, constructability, and estimated cost. Ultimately, the agencies selected three alternatives for full evaluation: (1) the “no-build alternative,” which would include repair and maintenance of the existing viaduct; (2) the “viaduct alternative,” which would replace the existing viaduct with a new, larger viaduct at a higher elevation to meet modern design standards; and (3) the “community-grid alternative,” which would demolish the viaduct, re-route local traffic to a street-level highway, and re-route some through-traffic to the existing Interstate 481 (“I-481″), a part of which would be improved and redesignated as I-81. The agencies prepared a joint draft environmental impact statement that compared the impacts of the three selected alternatives. That draft statement identified the community-grid alternative as the preferred alternative, based on the project purpose, needs, and objectives; the comparative social, economic, and environmental effects of the alternatives; and the relevant environmental protection goals. D. The Final Environmental Impact Statement and the Record of Decision In April 2022, the Department and FHWA released a final environmental impact statement (“FEIS”) that adhered to their conclusion that the community-grid alternative was the best option. This decision was made after analyzing the impacts of all three alternatives and considering public comments. Regarding potential air-quality impacts of the three alternatives, the agencies examined such impacts from a variety of pollutants. The agencies examined these potential impacts throughout the project area, including along the existing I-81 corridor and along the I-481 corridor. For this purpose, the agencies created traffic models that studied traffic flow for each alternative, identifying likely future “hot spots” of pollutants. Ultimately, the agencies concluded that the community-grid alternative would have no significant adverse air-quality impacts. In fact, they concluded that the community-grid alternative would actually improve long-term air quality in the area of the existing viaduct, while reducing emissions in the study area overall. Regarding the potential water-quality impacts of the three alternatives, the agencies considered the potential impacts on surface waters, including Onondaga Creek and Lake. Stormwater from and around the viaduct currently flows into the existing combined sanitary and storm sewer system, which overflows in certain wet-weather events when its capacity is exceeded and thus discharges polluted water directly into Onondaga Creek and thereby Onondaga Lake. Analyzing the three alternatives, the agencies concluded that the community-grid alternative would best address this problem, as it would permanently improve the water quality of the Lake. The environmental impact statement explains that the community-grid alternative includes plans to protect waterbodies from roadway runoff by diverting much of it to vegetative buffers and other infrastructure features that promote ground infiltration as well as other treatment methods, rather than allowing direct discharge of polluted water from the highway through the combined system. The agencies also considered other potential environmental impacts of the three alternatives, including potential impacts on, among other things, climate change, wildlife (including threatened and endangered species), historic and cultural resources, traffic patterns (including the frequency of crashes on the current and future I-81 and the availability of parking), neighborhood character, and the impact on minority and low-income communities (also known as environmental justice communities). All of these potential impacts and others were evaluated not only for the areas directly adjacent to the current I-81 viaduct, but also for areas around the sections of I-481 and I-690 that would be affected by alteration to the current I-81 viaduct. In June 2022, the Department and FHWA published the Record of Decision, which selected the community-grid alternative. The Record of Decision served as the final NEPA document and satisfied the Department’s SEQRA obligations. See 23 C.F.R. §771.127; 17 N.Y.C.R.R. §§15.9(b), 15.6(c)(1). E. The Micron Project Four months after the publication of the Record of Decision, in October 2022, Governor Hochul and other elected officials announced plans for Micron Technology to build a microchip facility in Clay, New York, ten miles north of downtown Syracuse. While touting the immense economic benefits the facility would bring to the region, the Governor’s press release made clear that the project would take “20-plus years” and involve “multiple phases.” See Governor’s Press Office, Press Release, Hochul, Schumer, McMahon Announce: Micron is Coming to Onondaga County!, available at https://www.governor.ny.gov/news/hochul-schumer-mcmahon-announcemicron-coming-onondaga-county-micron-will-invest-unprecedented. Following the announcement of the Micron facility, petitioners asked the Department and FHWA to supplement the environmental review to account for the facility’s possible impacts on traffic. See Dkt. No. 1-8. The FHWA declined to provide a substantive answer, and the Department has made no decision. See Dkt. No. 1-9. F. The State Court Litigation On September 30, 2022, a group of entities and individuals largely overlapping with the Defendants in this case filed an Article 78 proceeding in Onondaga County Supreme Court against the Department. See Renew 81 for All v. N.Y.S. Dept. of Transp., No. 007925/2022 (Sup. Ct. Onondaga Cty.). The petition alleged five causes of action, including a claim that the Department’s environmental review, including the joint Record of Decision and the joint environmental impact statement, was “illegal, arbitrary and capricious.” The specific factual allegations of the Article 78 petition concerned issues relating to greenhouse gas emissions, air quality, traffic, cumulative impacts, and project alternatives. The state court petitioners later filed a supplemental petition setting out a sixth claim alleging that it was “illegal, arbitrary and capricious” for the Department not to have decided to prepare a supplemental environmental impact statement to address potential traffic impacts due to the Micron project. The FHWA was named as a party to the state court action, but the court dismissed it on sovereign immunity grounds. In early November 2022, the state court petitioners filed a motion for a preliminary injunction. In February 2023, the Onondaga County Supreme Court issued a permanent injunction that banned the demolition of the I-81 viaduct pending some additional environmental review, but allowed construction to proceed on enhancements to existing I-481 and other parts of the overall I-81 project. In its order, the state court found in the state court petitioner’s favor on three merits issues under SEQRA relating to air pollution, stormwater, and supplementation to address the Micron project. On the remaining merits issues, the state court decision ruled in the Department’s favor. On February 2, 2024, the Fourth Department reversed the Onondaga County Supreme Court’s decision on the three rulings in the state court petitioner’s favor. In its order, the Fourth Department held that “respondents complied with their substantive obligations under SEQRA inasmuch as they took the requisite “hard look” at the relevant environmental factors, including air quality and stormwater management, and “made a ‘reasoned elaboration’ of the basis for [their] determination.” Dkt. No. 39 at 5-6. As to the issue of supplementation of the environmental review to address the Micron project, the Appellate Division ruled that the state court petitioners failed to establish a clear legal right to such supplementation in the absence of a nondiscretionary duty to perform such supplementation. See id. at 5. The Fourth Department further held that, even if the absence of such supplementation constituted the Department’s constructive denial of the state court petitioners’ request to perform such supplementation, that denial was not arbitrary or capricious given the absence of evidence in the record of information sufficient to perform such supplementation. See id. Accordingly, the Fourth Department modified the judgment by dismissing the petition in its entirety, thereby dissolving the state court injunction. See id. at 6. G. This Litigation On November 22, 2022, Plaintiffs commenced this action setting out two causes of action. See Dkt. No. 1. Using language parallel to the first cause of action in the state petition, the first cause of action in the federal complaint alleges that the FHWA’s environmental review, including the joint Record of Decision and the joint environmental impact statement, was “illegal, arbitrary and capricious.” Id. at 314. Like the state petition, the factual allegations in the federal complaint concerned issues relating to greenhouse gas emissions, air quality, traffic, cumulative impacts, and project alternatives. See id. at
5, 7-9, 11, 73, 129-73, 205-21, 253, 272-73, 302, 304-05. Plaintiffs’ NEPA claim also included allegations that it was unlawful for the FHWA not to have decided to prepare a supplemental environmental impact statement to address potential changes due to the Micron project. See id. at
