Comments from the Airport Communities Coalition (ACC)
to the U.S. Army Corps of Engineers and the
Washington State Department of Ecology
Concerning the Application of the Port of Seattle for
Section 401-404 Permits to Fill Wetlands Near Sea-Tac International Airport
In Order to Build a Third Runway, Reference #Ref. No. 1996-4-02325

February 16, 2001

Expert Subject(s) Summary
Azous, Amanda Wetlands, streams, fisheries Essential data & analysis remain missing.
Azous, Amanda (1 Sept. 2000) Wetlands mitigation issues Important data missing
Azous, Amanda 16 Aug. 2000) Wetlands mitigation issues Mitigation plans inadequate in several ways
Bioanalysts, Inc. Streamflow, water quality, & impact on fish Streamflow, water quality, & impact on fish: no assurance that low & high peak flows will be mitigated, or fish and water quality protected.
Eglick Peter & Kevin Stock Attorney's comment No "reasonable assurance" that project will comply with State water-quality standards
GeoSyntec Consultants MSE Walls MSE walls: "significant deficiencies in the field and laboratory investigation, and in the analysis." (Raises serious safety concerns, esp. as to earthquake risks.)
Gosling, Geoffrey D. Aviation Technology & Safety Issues Advanced air-traffic control technologies could enhance existing capacity; three-runway operations unsafe; more study needed
Norman, Donald Bird Issues Port analysis of bird issues inadequate; impacts on birds much underestimated; bird-strike hazard "nonexistent"
Northwest Hydraulic Consultants Stormwater, Hydrology Stormwater Management Plan inconsistent; independent (ongoing) review needed; "unsupported assumptions" re IWS; plan provide inadequate streamflow augmentation; flow modeling inadequate; other hydrology issues
Osborn, Rachel Water Issues Port's analysis of plan's impacts on base flows not credible, plan does not meet requirements of state water-quality requirements or Clean Water Act; Port has no assured water rights for required streamflow augmentation. (attorney)
Pacific Aviation Consulting, Inc. Alternatives to proposed 3rd runway layout and to 3rd runway construction, wetlands work; efficiency, safety, and ticket prices Justification for project insufficient
Sheldon & Associates, Inc. Review of Port's Natural Resources Mitigation Plan Water movement not accurately delineated, esp. through the "walls"; wetlands mitigation unlikely to succeed; construction impacts on wetlands underestimated (Commenter was first Wetlands Planner for King County)
Strand, John
dba Columbia Biological Assessments
Potential harm to fish & fish habitat, exp. Chinook salmon Not enough information to permit "on a scientifically defensible basis" that construction & operation will not harm wetlands, streams, fish resources; problem of existing contaminated fill has not been properly addressed
Thomas/Lane Assoc. Critique of Port economic arguments for the project Benefits overstated, adverse impacts understated; claim that business activity will suffer if 3rd runway not built is contradictory of Port's arguments that no adverse impacts will result from construction (because same number of aircraft will arrive, 3rd runway or not--can't be both at the same time); Port's benefits analysis does not comply with federal regulations applicable to sec. 404 analysis. (Excellent summary of property value issue.)
Water Resources Consulting, L.L.C. Water quality and water management aspect of Port plan Little improvement in Stormwater Plan since August 2000 (inadequate) version; Plan violates Governor's 1997 certification to USDOT re water quality; BMPs at Airport not working, "there is no basis for ... Section 401 certification of Section 404 approval"