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Donald Norman February 16, 2001 Mr. Jonathan Freedman Ms. Ann Kenny Re: Reference # 1996-4-02325 Port of Seattle's 404/401 Application to Construct Third Runway at Seattle-Tacoma International Airport. My name is Donald Norman. I have a Bachelors of Science in Biology and a Masters of Science in Environmental Studies with expertise in ornithology and wildlife toxicology. I also hold an undergraduate degree in chemical oceanography from the University of Washington and have lived in the Seattle area for almost 25 years. I have worked on many projects relating to birds in the Puget Sound Lowlands, as well as marine birds in Puget Sound. I have also performed numerous surveys for wildlife including breeding bird surveys (BBS), point counts, nest searches, and for the past 5 years have managed the Fort Lewis Military Reservation bird banding Monitoring Avian Productivity and Survivorship (MAPS) site addressing issues relating to the decline of migratory passerines birds. I am also active in monitoring great blue heron colonies and issues related to development and disturbance effects upon wildlife. My consulting firm is known as Norman Wildlife Consulting ("NWC"). I have attached my resume. Based upon my review of the relevant permit related documents and local wildlife related literature (Appendix A) and my expertise in the areas of ornithology and wildlife toxicology, my conclusions with respect to the Port's proposed project are as follows, with details following. 1. The Baseline Information on Threatened and Endangered Species is Incomplete for Bald Eagles and Especially for Marbled Murrelets. As a result, no mitigation for potential airplane strikes for both species was proposed and impacts of construction were not addressed relating to bald eagle nesting and foraging. There cannot be a proper assessment under ESA if the baseline information is incomplete to determine if any mitigation is needed. 2. The elimination of the large acreage of Puget Sound Shoreline Upland will reduce migratory bird nesting and migrating habitat in the area and should be mitigated. 3. The Port is using a non-existent wildlife hazard situation as an excuse for poor wetland mitigation and offsite mitigation. 4. The Port does not analyze or discuss the biotic impacts and results of the retaining wall which are likely to attract soaring birds and potentially increase plane strikes with raptors, crows, and gulls, including bald eagles.
5. Reductions in stream transport of organic carbon and detritus will impact nearshore bird populations. These conclusions are explained in detail below. In addition to the conclusions I have drawn from my review of relevant documents, I have assembled several points and data sets that provide information that clearly presents the need for a supplemental EIS to address wildlife issues and that further demonstrate that the Port's proposed project will cause harm to migratory birds and wildlife not recognized or mitigated by the Port. Because no historical survey work has been done in the impacted areas, mostly due to limited access, it is difficult to address the actual impacts of the project, but with the scarcity of habitat in the Puget Sound Lowlands, the size of this project with this much upland habitat destruction warrants its integration with the recently published management plan for the lowlands of Puget Sound from Partners in Flight (Altman 2000). This interagency initiative addresses the decline of migratory landbirds. NWC compiled a list of species of concern that occur in the STIA area to be impacted, or are of concern in the proposed offsite mitigation area (Table 1). A project of such large scale should include some management solutions for impacts to wildlife species, especially those migrating across international borders, and thus covered under the Migratory Bird Treaty Act. 1. The Baseline Information on Threatened and Endangered Species is Incomplete for Bald Eagles and Especially for Marbled Murrelets. As a result, no mitigation for potential airplane strikes for both species was proposed and impacts of construction were not addressed relating to bald eagle nesting and foraging. There cannot be a proper assessment under ESA if the baseline information is incomplete to determine if any mitigation is needed. 1.1.1. The Bald Eagle surveys that were performed for the EIS, and presented in the FEIS (July 1995) were performed in an inappropriate part of the year. The eagle surveys, performed in December 1994 and January 1995 (FEIS July 1995, Shapiro 1995) were the incorrect season for monitoring eagles. They did not address eagle movements during the breeding season, and especially did not address eagle movements during the post-fledging period. Not only are eagles making more foraging trips, because they are foraging for themselves as well as a growing chick or chicks, eagles are more likely to be foraging more widely for food for chicks during the nesting season. 1.1.2. The Biological Assessment neglects to study an eagle nest close to the proposed activity. There has been an exponential increase in the numbers of eagles in Puget Sound (American Birds, Christmas Bird Counts 1972-1997 Seattle WA) and this has led to more nesting in the vicinity of the airport, but no studies were performed in the intervening period from the EIS baseline work in December 1994-January 1995 to the Biological Assessment (BA) released in June 2000. In fact, even the BA notes occupancy of a nest site at Angle Lake, which is not even accurately located in the BA. The BA relied upon the WDFW general location of "1-3 miles" (Page 6-1) though a survey of the Lake performed in the 1994 original survey places the nest 0.75 miles from STIA. NWC has not studied this nest to determine where the eagles forage, but there is a large area for foraging at the open upland habitat and associated wetlands south and west of the runways. The increase in eagle population has been well known for many years (McAllister et al 1984) and should have been anticipated in the BA. In addition, future increases in bald eagles should have been anticipated and presented in a plan to mitigate for impacts. 1.1.3. The eagle territory at Angle Lake could be directly impacted by the construction of the 3rd runway, from noise, disruption of foraging for food by increased activities in the areas to be impacted by construction, and loss of upland habitat. The BA does not present adequate information to address these impacts, citing only one study that measured "lack of response" of eagles to planes (Page 6-2). Since controversy often exists about the impacts of disturbance, such as noise and disturbance from plane activity, the BA should demonstrate an expert assessment of the situation. It is my opinion that the BA does not provide evidence from field or professional studies that eagles will be able to alter their foraging areas to compensate for areas that will be removed in the construction of the habitat, and thus directly impacting survival of chicks. A cursory search of the literature would indicate many more studies: a list of over 130 relevant studies are shown in the attached Appendix B, including several peer reviewed studies which could provide direction for the consultants to design an efficient study to answer the more biologically important question (Curry and Murphy. 1995, Grubb and King. 1991, Grubb and Bowerman 1997, White and Thurnow 1985). The one study cited in the BA indicates that bald eagles do not appear to be impacted by noise from the Bellingham airport, ie that bald eagles do not react to commercial jets (Fleischner and Weisberg 1986), but this study does not relate this reaction to any biological endpoint important to an individual bird, such as weight, longevity, reproductive output etc. This cited study does not meet recently proposed criteria for linking disturbance to biological impacts in waterbirds (Nisbet 2000). It is clear from the amount of upland habitat being removed that there will be reduction in foraging habitat for the eagles. Eagle prey items appear to be shifting, especially in urban settings away from fish and towards mammals and birds, and especially scavenged animals (Knight et al, Norman et al 1989, D. Norman, unpublished data). It is my professional opinion that an additional study is necessary to determine if bald eagles (as well as red-tailed hawks, see Section 2) are impacted by the development of the hundreds of acres of upland habitat. This study should not be limited to the winter season, but should include studies of the nesting season. A current literature search should be developed to assess relevant potential impacts of the proposed project upon foraging areas. 1.1.4. The BA also fails to address whether there are migration corridors that occur in the STIA, and whether eagles may be killed in airplane collisions. Hundreds of eagle migrate into and out of Washington relating to salmon runs. The Port asserts that there will be no increased risk to bird-strikes because "Future flight paths associated with the new runway are not expected to be significantly different from current approach and departure zones (Port of Seattle) - [Page 6-2 of BA June 2000]. I disagree with that premise. It is obvious that increased air traffic will increase potential bird-plane strikes, which is the Port of Seattle's contention for off-site mitigation in the NRMP (Dec 2000) and Offsite Mitigation Position Paper (Port of Seattle 1998). It is inconsistent in one part of the application to say collisions are a problem and in other parts say they are not. The Port also asserts that "Eagle-aircraft collision is very unlikely due to the eagle's relatively slow flight and high visual acuity, which allows them to avoid collisions" (Olendorff et al 1981). Again, I disagree with the Port’s assertion. The Olendorff report does not address aircraft but power lines. Though no eagles have been reported killed at STIA, several red-tailed hawks have been reported killed (BA June 2000), and they have equal flight and visual skills. As discussed in Section 3 of my comments, no survey designs or areas of surveys have been released in any of the Port documents. It is likely that the potential collision area for eagles may be further away from the airport, in the 3 to 5 miles out from either end of the runway as indicated in the BA (June 2000) where planes are descending to 500 feet or less (Page 6-7), but there is no mention whether Bird surveys of these areas have been conducted. Bald eagles have been killed at the Vancouver BC airport since its expansion (Vancouver Sun 2000). The construction of the retaining wall could encourage eagles to use thermals created by the wall, thus increasing the risk of plane strikes. This issue will be discussed in section 4 of my comments. 1.2. The Biological Assessment does not present information demonstrating that Marbled Murrelets, an ESA listed species, do not occur along the marine shoreline adjacent to the STIA, and also does not confirm that Marbled Murrelets are not flying from nesting sites in the Cascades across the flight path of the STIA. In the June 2000 Biological Assessment, a lack of information was used to "demonstrate" that no problem existed. This is an incorrect methodology and continues a pattern from previous EIS documents. Marbled Murrelets were listed by the USFWS in September of 1992 for the states of California, Oregon, and Washington (USFWS 1992), and yet they were not considered in the EIS and SEIS. This is a serious omission. Based upon my experience with "at sea" surveys for Marbled Murrelets as an observer during the fall of 1993 and the summer of 1994 to determine the impact of the purse seine and gillnet fleets upon marbled murrelets (Natural Resources Consultants, 1994), I know that there was concern in Puget Sound even at the time when the original EIS was prepared concerning Marbled Murrelets. The Zone 1 Recovery Area includes all of Puget Sound ( personal communication Martin Raphael, USFS, February 14, 2001). There is adequate evidence presented below that should have triggered surveys for Marbled Murrelets along the shoreline of King County and surrounding foraging areas. Such surveys should also have determined flight path of birds to indicate whether they were crossing STIA. In addition to "at sea" surveys, land surveys provide information about the status of this marine bird nesting in the Cascades to the eas |