February 9, 2001

U.S. Army Corps of Engineers

Regulatory Branch

PO Box 3755

Seattle, WA 98124

Attn:  Jonathan Freedman, Project Manager
Washington State Department of Ecology
Shorelands & Environmental Assistance Program
3190 – 160^th Ave. S.E.
Bellevue, WA  98008-5452

Attn:  Ann Kenny, Environmental Specialist
Re:  Assessment of Public Interest & Economic and Social Impacts of the Port of Seattle’s Section 404 Permit Application,
Ref. No. 1996-4-02325

Dear Mr. Freedman/Ms. Kenny:

I am a Principal in the firm of Thomas/Lane & Associates (TLA).  I have a Ph.D. in regional economics, and I specialize in economic assessments of public policy alternatives.  I have extensive experience in both airport and aviation economics (see attached resume).  In 1995, I was given an assignment by the City of Burien to study the economic and social impacts on the Cities of Burien, Des Moines, Federal Way, Normandy Park and Tukwila, and the Highline School District associated with expansion of Seattle-Tacoma International Airport (Sea-Tac) through construction of a proposed third runway and related facilities.  Helsell Fetterman, LLP, has asked me to comment on the latest application by the Port of Seattle for a Section 404 Permit related to construction of a proposed 8,500 foot third runway at Sea-Tac(Public Notice Date: 27 December 2000).

In preparing my comments, I reviewed the Port’s December 27, 2000 Section 404 Permit application; the October 16, 2000 Part 150 Noise Compatibility Plan; property value and property tax records available from the King County Assessor, real estate research reported in the Seattle Times, John L. Scott, the Puget Sound Real Estate Research Reports and WSU’s Washington Center for Real Estate Research; the Port’s FEIS for the proposed third runway; municipal tax rate and tax collection data available from the Washington State Department of Revenue; and population projections and economic data available from the Washington State Office of Financial Management.  I also reviewed the notes, working papers and spreadsheets prepared as part of my past assignment with the City of Burien.

A summary of my findings and conclusions vis á vis the Ports Section 404 Application is as follows:

·       The Port’s contention that the proposed third runway will have no economic or social impacts contradicts its own claim that not building the runway will hurt the local and regional economy. 

·       My analysis shows that the Port has argued at different times that the proposed third runway is only needed to reduce the cost of poor weather delays to airlines using the airport, while at other times it has argued that the proposed third runaway is needed for the growth and vitality of the regional economy.  The Port’s contention that the third runway will have no economic or social impacts on surrounding communities is based exclusively on the first argument.  Its contention that the proposed third runway will generate positive National Economic Development (NED) benefits is based entirely on the second argument.  While either argument can be made, it is indefensible to assert both at the same time.

·       The unconstrained forecast of future operations and enplanements at Sea-Tac used by the Port assumes the proposed third runway and additional needed facilities are in place.  Its use by the Port results in a finding of no economic and social impact that is based on assumption rather then analytical or empirical findings.

·       The Port’s contention that no noise impacts will result from the proposed third runway results in part from the Port using the wrong baseline for measuring impacts.

·       The Port’s consultants have consistently stated that Sea-Tac’s existing infrastructure ands facilities are at capacity and cannot accommodate the 2020 forecast of 441,600 operations.  These findings are consistent with the Port’s argument that the proposed third runway is needed to support future regional economic growth.  They contradict the Port’s argument that the only purpose of the proposed third runway is the elimination of poor weather operating delays. – yet, it is this argument that is the basis of the Port’s contention that there will be no economic or social impacts.

·       The underlying economics of the entire concept of project mitigation is that projects with positive NED benefits may be required to reallocate some of those benefits to offset place-specific or population-specific resource losses such as will occur to the communities surrounding Sea-Tac if the proposed third runway is built.

·       There is little empirical or analytical support for the Port’s public statements that the airport’s expansion will generate a special bundle of benefits to the surrounding communities.

·       Both academic and FAA sponsored studies of airport noise impacts conclude that housing values are reduced in communities surrounding airports, with the greatest reductions occurring in areas where the average value of the housing stock is greatest.

·       Informed opinion in the Seattle area is that residential land values are reduced around Sea-Tac.

·       A 1996 report by TLA, Inc. used accepted statistical methods to analyze the expansion of Sea-Tac that would occur from construction of the proposed third runway and concluded that there will be significant adverse economic and social impacts on surrounding communities.  Updating the1996 analysis using data from the King County Assessor’s Office and information reported in the Seattle Times, I conclude that in the year 2020 after the forecast increase in Sea-Tac operations that construction of the third runway will allow, the property-value losses in the five surrounding communities from increased noise and related pollution will cost owners of single-family residential properties an estimated $2.3 billion dollars.  If levy rates remain the same as they were in year 2000, the five communities will loose $ 4.0 million annually in foregone property tax revenues

The analysis and research on which the above findings and conclusions are based is as follows.

1.1. The Port of Seattle contends that the proposed third runway will have no economic or social impacts.

The Sea-Tac Master Plan Update Final EIS states (Volume 4, Appendix R, page R-5):

“if the proposed new runway and other facility improvements [emphasis added] are not constructed, the growth in demand for air travel would continue to occur as would the number of aircraft operations, because it is expected that the Region will continue to experience growth in population and income”  and that  “it is reasonable to assume for purposes of this environmental analysis [emphasis added] that the same number of operations would occur with and without the proposed new runway.”

The Port explicitly states in the FEIS that there is no need to expand airport capacity to accommodate the airport’s forecasted growth of operations and enplanements.  It contends that current runways, terminal and support infrastructure are sufficient to accommodate the year 2020 forecast of 441,600 operations and 19,100,000 enplanements, and that the third runway is only being built to reduce delays caused by weather conditions that prevent parallel use of existing runways.  The Port insists that even with these delays, not a single operation or enplanement between now and the year 2020 will be affected if the airport is not expanded.  The Port consequently asserts (in the FEIS) that third runway will have no socio-economic impacts other than those caused by the purchase of land for airport expansion. 

2.2.    The Port’s contention that the proposed third runway will have no economic or social impacts is both flawed and inaccurate.

2.1  The Port’s contention that the proposed third runway will have no economic or social impacts contradicts its own claim that not building the runway will hurt the local and regional economy.

Third runway (and related facility) impacts contained in the FEIS are based on Technical Report No. 5, Final Forecast Report, Airport Master Plan Update for Seattle-Tacoma International Airport (P&D Aviation, August 30, 1994).  P&D’s forecast equations say that Sea-Tac’s domestic enplanements are positively related to personal income in the Puget Sound Region (page 5-6, Final Forecast Report) while  international enplanements are positively related to gross state product in the 3-state region (page 5-11).  When personal income in the region goes up, domestic enplanements rise; when gross state product in the 3-state region goes up, international enplanements rise.  The Port’s Master Plan consultant consequently finds that a positive relationship exists between airport operations (measured by enplanements) and business activity in the region (measured by personal income and gross state product).

Since the Port contends that business activity in the region will be hurt if the third runway is not built, the findings of its consultant lead to the conclusion that airport enplanements and operations will also be hurt.  Yet, the FEIS denies this by contending that the same number of enplanements and operations will occur at Sea-Tac whether or not the proposed third runway is built. 

The Port cannot have it both ways.  Given its consultants research findings, either one of the following two statements can be consistently argued,

·       Not building the proposed third runway will hurt local business activity, and therefore not building it will also reduce airport enplanements and operations. 

·       The same number of enplanements and operations will occur with or without the proposed third runway, and therefore building or not building it will have no effect on local and regional business conditions.

What is not tenable is to combine the first part of bullet one with the first part of bullet two.  Such a combination violates the research-based forecast equations used in Sea-Tac’s Master Plan update, and thus violates the empirical basis upon which the entire FEIS economic analysis rests.

A related (and equally untenable) point is, if there will be no change in airport enplanements and operations whether or not the proposed third runway is built, why build it?  The costs to the airlines cannot be critical since the Port states in its FEIS that the airlines will not reduce so much as a single forecast flight due to delays.  And the time delays cannot be critical to passengers since the Port also states in the FEIS that the forecasts will not be reduced by a single enplanement as a result of the delays. The Port’s response is that building the proposed third runway will save privately owned commercial (so called “public carrier”) airlines using Sea-Tac the costs associated with poor weather delays.  In fact, the only third runway benefits data presented by the Port are the fuel and related cost savings associated with aircraft not having to circle Sea-Tac during poor weather.  If these are the only benefits, they certainly are well below the proposed third runway’s costs of construction. 

The importance of these points is that the only basis for the Port’s contention that there will be no economic or social impacts from the proposed third runway, other then the acquisition of property needed for its construction, is that there will be no additional enplanements or operations at Sea-Tac whether or not the proposed third runway is built.  Yet, this claim directly contradicts both the research and analysis upon which the need for third runway is predicated, clearly implies that the proposed third runway will generate no NEDs and denies the benefit-cost rational used to assert its worthiness as a public policy choice. 

2.2  The Port’s use of an FAA “unconstrained forecast” in the FEIS assumes what it claims to be proving

The Port states that it uses its consultant’s “unconstrained forecast” of Sea-Tac operations and enplanements as the basis for determining impacts.  It states that because the unconstrained forecast does not change whether or not the proposed third runway is built, Sea-Tac operations and enplanements will not be affected by its being built or not built.  Since there will be no change in enplanements and operations, there will be no economic or social impacts.

An unconstrained forecast is the methodological baseline recommended by the FAA for airport master planning.  It is a forecast made under the assumption that there are no facility or infrastructure bottlenecks that will limit growth.  Existing facilities and infrastructure are then compared with the needs implied by the unconstrained forecast to determine an airport’s capital improvements requirements.  In the case of Sea-Tac, the Airport Master Plan Update report states (Technical Report No.5, Final Forecast Report, August 30, 1994, page 5.1), that the unconstrained forecast was prepared, “...to be used to develop airport facility requirements and to estimate the timeframes when future improvements are needed;” and that, “the objective of the forecast task [was] to develop updated master plan forecasts which ... provide a sound basis for guiding the development of future facility improvements at the airport.” 

Based on the unconstrained forecast, the Airport Master Plan Update  found that a new 8,500 foot runway (the so-called third runway, or runway 16X-34X) was needed, along with the following additional facilities:

·       a mid-field overnight parking apron between runways 16R-34L and 16X-34X

·       limited expansion of 4-6 gates on Concourse A and the Main Terminal, including expansion of the Central Parking Garage

·       development of a [new] north unit terminal

·       development of a cargo warehouse

·       construction of a new Air Traffic Control Tower and TRACON

·       installation of a CAT III ILS on runway 16L

·       extension of duel parallel taxiways A and B the full length of runway 16L-34R and a taxiway bridge over 188th Avenue South

·       extension of runway 34R by 600 feet and relocation of the glideslope

In other words, the proposed third runway did not change the unconstrained forecast because it already assumed the runway and additional needed facilities were in place.

The use of an unconstrained forecast as a methodological device for estimating required capital improvements at an airport may be appropriate for planning.  It is totally inappropriate for impact analysis.  In the case of the proposed third runway, its use by the Port results in a finding of no economic and social impact that is based on assumption rather then analytical or empirical findings.

2.3  The Port’s analysis of noise impacts uses the wrong baseline for estimating impacts

The Port contends that there will be no noise impacts from the proposed third runway.  The FEIS makes this contention based on a comparison between the airport’s “noise contours” contained in its Part 150 study and the noise contours projected for the 2020 forecast of 441,600 operations. 

The Part 150 study however used Sea-Tac’s noise contours before the FAA’s Stage-3 noise requirements took effect.  These requirements resulted in a significant reduction in allowable aircraft noise, and produced sharply reduced airport noise contours – holding the level of operations constant.  In fact, the Port’s Sea-Tac International Airport Noise Exposure Update Report (June, 1982), projected that noise generated by Sea-Tac operations would be reduced by 45 percent between 1990 and the year 2000 as a result of the FAA’s Stage-3 requirements.

The appropriate baseline for assessing whether or not the third runway would cause noise impacts would have been the noise contours for the year 2000 when the FAA’s State-3 requirements went in to effect.  A comparison between the noise contours projected for Sea-Tac’s 2020 forecast of 441,600 operations and such an appropriate Stage-3 year 2000 baseline would show the increase in the area under Sea-Tac’s noise impact contours related to its growth of operations.

The Port’s contention that no noise impacts will result from the proposed third runway, consequently, results in part from the Port using the wrong baseline for measuring impacts. 

2.4  The Port’s consultants have consistently stated that Sea-Tac’s existing infrastructure ands facilities are at capacity and cannot accommodate the 2020 forecast of 441,600 operations.

The Airport Master Plan Update done by P&D Aviation for the Port forecast Sea-Tac’s operations to reach capacity (379,000 operations) in the year 2000; and it therefore recommended building the third runway and expanding the Main Terminal’s Concourse A between the years 2001 and 2005, with additional facilities expansion to occur between 2005 and 2020.

The following research and planning studies also concluded that a third runway was needed to accommodate Sea-Tac’s forecast growth of operations and enplanements for the year 2020.

¨     Air Transportation Demand, Aviation Industry Trends, and Air Capacity in Washington Through 2020, prepared for the Washington State Air Transportation Commission

¨     The Puget Sound Air Transportation Committee Final Report to the Puget Sound Regional Council

¨     The Phase I Forecasts: Flight Plan Study conducted by KPMG Peat-Marwick for the Port of Seattle and the Puget Sound Conference of Governments

¨     The Analysis of Maximum Passenger Limits at SEA-TAC Airport Under the No New Runway Alternative, a working paper prepared by P&D Aviation for the Port of Seattle

The Port of Seattle stands alone in its assertion that Sea-Tac could accommodate the forecast of 441,600 operations and 19,100,000 enplanements in 2020 without any increase in capacity or expansion of its infrastructure.  Yet, it is on the basis of this assertion that the Port contends there will be no economic or social impacts because the same levels of activity would occur with or without the third runway. 

It may be questionalable if adding a third runway is the appropriate or cost-effective technology to use if Sea-Tac’s only problem is operational delays caused by poor weather.  If the Port’s consultants are correct, however, and there is a need to address a capacity problem, then future operation and enplanement levels will require a third runway.  In that case, higher future operation and enplanement levels at Sea-Tac will have economic and social impacts on surrounding communities.

Some regional agencies, such as the Puget Sound Regional Council (PSRC), have expressed the opinion that air transportation growth will be so great that Sea-Tac’s operations and enplanements capacities will be reached before 2010.  If that occurs, a new regional airport will be required.  Analysis of the third runway’s benefits should include an assessment of the operations and enplanements that would likely be shifted to a new regional airport, and whether or not a long-term flow of benefits from a third runway would justify its construction at this time.

3.3.    The Port seeks to ignore actual impact issues by contending that communities surrounding the airport are simply being NIMBYs when they oppose Sea-Tac’s expansion

3.1  The Port argues that the benefits of airport expansion far outweigh its costs

The Port has consistently made public statements that the benefits from expanding the airport exceed its costs, and that the airport consequently should be expanded.  The basis for the Port’s assertion is a study by Martin O’Connell Associates (The Local and Regional Economic Impacts of the Port of Seattle, May 31, 1994) that was done for all Port properties and was not done for the EIS.  It was a general public relations type report which the Port periodically commissions showing its importance to the regional economy.  The report contained no reference to specific communities surrounding Sea-Tac.  Under no acceptable professional standard would the O’Connell report qualify as an analysis demonstrating that Sea-Tac’s expansion would have positive NED benefits (as defined in 33CFR320.4(q)).

I have worked on other projects requiring Corps approval and I am familiar with its requirements to separate National Economic Development (NED) benefits from Regional Economic Development (RED) benefits, to quantify the flow of NED benefits by year, and to estimate the net present value (NPV) of future NED benefits by discounting with an interest rate provided by the Corps.  To my knowledge, the Port has never undertaken such an analysis.  The is no evidence that the Port has separated Sea-Tac’s NED and RED benefits, estimated the NPV of future benefits, or demonstrated that the proposed third runway’s NED benefits exceed it costs.  The Port has made statements to this effect, but has never undertaken an analysis following Corps methodology that demonstrates it.

In fact, it is questionable if an analysis based on the Corps methodological guidelines would reach such a conclusion.  The costs of the proposed runway keep climbing and it’s questionable if the Port knows the precise dollar cost of the proposed third runway’s construction at this time.  Its assertion - in the FEIS - that building or not building the proposed third runway will have no impact on Sea-Tac’s future enplanement or operation levels; and that the only economic impact (aside from taking property needed for the expansion) is the cost saving by private commercial public carrier airlines from reduced poor weather delays is difficult to defend given its own consultants’ findings. 

However even if the Port’s assertion that benefits from Sea-Tac’s expansion will exceed its costs is true for the multi-county central Puget Sound Region, it is not true for the several communities that surround the airport.  For these communities, building the third runway and expanding the airport will result in a relative loss of property values, a relative reduction in tax revenues and a loss of community cohesion.  These impacts (discussed in detail in Section 5, below) of airport expansion fall uniquely on these surrounding communities. 

For the Port to claim that the benefits of Sea-Tac expansion exceed its costs while ignoring the disproportionate distribution of the costs and benefits is not acceptable economic analysis.  Economic analysis requires an explicit consideration of both efficiency criteria (benefits exceeding costs) and equity criteria (rough proportionality in the distribution of benefits and costs).  In fact, the underlying economics for the entire concept of project mitigation is that projects with positive NED benefits may be required to reallocate some of those benefits to offset place-specific or population-specific resource losses (33CFR320.4(r)\1\(1)). 

3.2  The Port argues surrounding communities receive higher benefits from the airport

At various public meetings, Port representatives have stated that surrounding communities receive benefits such as more jobs, reduced commuting time/distance and air travel access then do communities in the rest of the region.  An analysis of PSRC origin/destination data for work trips (PSRC, 1990 Census Transportation Planning Package (CTPP)) indicates that few residents in the surrounding communities have jobs or commute to work at Sea-Tac.  Analysis of data from a traveler survey conducted at Sea-Tac (Sea-Tac O/D survey, Evans-McDonough Company (EMC) for the Port of Seattle) shows that air travel is closely correlated to household income, and that residents of most of the surrounding communities get little benefit from access to air travel since they use it infrequently.

There is little to no empirical or analytical support for the Port’s public statements that the airport’s expansion will generate a special bundle of benefits to the surrounding communities.  On the other hand, there is a large body of research, analysis and informed opinion that communities surrounding Sea-Tac already absorb significant impacts, and that these impacts will increase if the third runway is built and airport expands its capacity.

4.4.    Noise pollution and related impacts negatively impact the value of land surrounding Sea-Tac

4.1  Academic and FAA-sponsored studies all agree that airport noise and related impacts negatively affect the value of adjacent land

The impact of noise on the value of residential property immediately surrounding an airport has been investigated around the United States.  The results have generally shown an inverse correlation between noise levels (measured by L_dn contours) and residential property values.  The academic studies all found a positive relationship between the noise, and related pollution, caused by airport operations and reduced residential property values.

·       Greenberg, Michael and Schneider, Dana, 1996, Environmentally Devastated Neighborhoods: Perception, Policies and Realities  (Rutgers University Press).

·       Frankel, Marvin, 1991,"Aircraft Noise and Residential Property Values, "The Appraisal Journal.

·       Nelson, J. P., 1980, "Airports and Property Values: A Survey of Recent Evidence," Journal of Transportation Economics and Policy.

·       Mieszkowski, P. and Samper, A.M., 1978, "An Estimate of the Effects of Airport Noise on Property Values," Journal of Urban Economics.

·       Crowly, R.W., 1973, "A Case Study of the Effects of an Airport on Land Values," Journal of Transportation Economics.

The following two studies were done for the FAA and both found a positive correlation between noise, and related pollution, caused by airport operations are reduced property values.

·       Booz-Allen & Hamilton, Inc., 1994, The Effect of Airport Noise on Housing Values (FAA, Office of Environment and Energy, September).

·       Newman, J.S. and Beattie, K.R., 1985,. Aviation Noise Effects (FAA Report EE-85-2).

The Booz-Allen study used both statistical regression analysis and on-site appraisals to analyze noise impacts at five airports around the country.  It concluded that housing values were reduced at all the airports, with the greatest reductions occurring in areas where the average value of the housing stock was greatest.

4.2  Informed opinion in the Seattle area is that residential land values are reduced around Sea-Tac

Elizabeth Rhodes wrote in the Seattle Times of March 8, 2000:

The proximity of Seattle-Tacoma International Airport has helped keep nearby housing more affordable.  Burien, Sea-Tac, Boulevard/Riverton and South Park/Georgetown had median per square-foot prices of less than $125 in 1999, making them the most affordable neighborhoods in the Greater Seattle area.  Why are they so low?  Realtors say one possible reason is buyer concern about noise from Seattle-Tacoma International Airport coupled with uncertainty over the effects of the airport’s new third runway.

An article contained in the Seattle Times of March 7, 2000, contained the statement, “The Seattle Times analysis of single family-home sales for King County shows that while house prices have taken off in most Seattle neighborhoods, communities in South King County have stayed in last place.”

Interviews conducted with local realtors during my assignment for the City of Burien showed a widespread consensus that single family home prices and land values in the immediate vicinity of Sea-Tac increase less rapidly than elsewhere in King County because of the airports noise and related impacts.

5.5.    Expansion of Sea-Tac through construction of the proposed third runway will have significant adverse economic and social impacts on surrounding communities

5.1  TLA’s 1996 study used sound statistical methods for estimating the adverse economic impacts of constructing the proposed third runway

Economic impacts were estimated two separate ways.  First, the impact of proximity to the airport was evaluated using average property values obtained from the King County Assessor ten census tracts immediately around Sea-Tac and ten comparable census tracts in the City of Shoreline – the area in NW King County that has the same general geographical, topological and urban characteristics as the communities surrounding Sea-Tac.  The cluster of ten census tracts around the airport contained 17,046 housing units, of which 11,526 (67.6 percent) were single family.  The cluster of ten census tracts in Shoreline contained 19,523 housing units, of which 12,683 (65.0 percent) were single family.  Standardized for view, condition of structure, size of structure, lot size, number of bedrooms, number of baths, zoning, land use, county/state development policies, and similarity of neighborhoods, a single family housing unit selling in 1995 for $ 141,400 in the immediate vicinity of the airport would have sold for $ 155,700 if it were located elsewhere - a difference of $ 14,300 (or 10.1 percent).

The second way economic impacts were estimated was by use of an econometric regression model that normalized housing values around the airport for lot size, structure size, number of bedrooms, number of bathrooms and community amenity factors.  The model’s parameters were estimated from Assessors data on 3,026 properties in the immediate vicinity of the airport. All of the independent variables in the model were statistically significant at the 90 percent level, seven were statistically significant at the 99 percent level.  The multiple regression coefficient was 0.65.  The variable measuring a property's distance from one of Sea-Tac’s flight paths was significant at the 99 percent level.  The model indicated that the value of a single family residence increased by about 3.4 percent ($4.450 on an average valued house of $129,900) for every quarter of a mile it was farther away from the flight path of departing/approaching jet aircraft.

5.2  The 1996 study was updated using the best available data

Data on property value assessment appreciation in King County and sub areas of the county was obtained from the King County Assessor.  Data on the appreciation of single family residential sales was obtained from the Seattle Times, John L. Scott, Puget Sound Real Estate Research Reports and WSU’s Washington Center for Real Estate Research.  These data were used to calculate average annual rates of change in residential property values between 1993 (the base year for the analysis undertaken for the City of Burien) and 2000.  Some sources only provided data for the entire SW King County area.  Some for specified real estate analysis areas.  Others for each incorporated place.  All together, these sources provided a reasonable basis for adjusting the original 1996 impact estimates to the year 2000.

Data from the King County Assessor’s Office and the Washington State OFM were used to update the property tax levy rates for each of the five communities surrounding the airport.

5.2  updated Economic Impact Estimates

The estimated value of a representative single-family residence in each of the communities surrounding Sea-Tac was obtained from the King County Assessor’s Office.  TLA’s assignment for the City of Burien estimated the average loss of value for a single-family residence surrounding the airport was 10.1 percent.  Using this loss ratio, the dollar loss of a representative single family residence in each community surrounding Sea-Tax was estimated as follows.

Source: King County Assessor’s Office; TLA

The Seattle Times (March 7, 2000, page A8) reported the following 15-year average annual rates of growth for representative single-family residence in the communities surrounding Sea-Tac [1] .

Source: King County Assessor’s Office; TLA

Applying the average annual rates of growth over the past 15 years to the period from 2000 to 2020 provides the following estimate of the loss of value for a representative single-family residence in each of the communities.

Source:  TLA

Not all residences in the surrounding communities will be impacted by Se-Tacs expansion.  Residences located more then a couple of miles from the airport’s approach and departure flight paths will be slightly impacted, if at all.  As part of its assignment for the City of Burien, TLA estimated the following number of single family residences will be impacted by expansion of the airport.

Source:  TLA

Multiplying the number of impacted single-family housing units by the estimated average loss suffered by a representative unit, on a community-by-community basis, provides an estimated loss of property values associated with expansion of Sea-Tac through construction of the proposed third runway.  Assuming that each communities levy rate remains unchanged in the future, the application of these rates to the reduction in property values provides an estimate of the likely loss of property tax revenues in each community.  These estimates are provided in the following table.

Source: King County Assessor’s Office; TLA

In the year 2020 after the forecast increase in Sea-Tac operations that construction of the third runway will allow, the property-value losses in the five surrounding communities from increased noise and related pollution will cost owners of single-family residential properties an estimated $2.3 billion dollars.  If levy rates remain the same as they were in year 2000, the five communities will loss $ 4.0 million annually in foregone property tax revenues.

These are minimum cost estimates.  They do not include costs borne by owners of multi-family residential units or businesses in communities surrounding Sea-Tac.  Nor do they include the costs imposed on the Highline School District by additional airport noise. 

In summary, my analysis shows the Port’s contentions about economic and social impacts related to its Section 404 Permit Application to be untenable and contradictory.  If there are no impacts, as the Port argues is some places, then there are no benefits that would provide a public policy basis for going forward with the third runway’s construction.  If there are NED benefits, as the Port argues in other places, they must be associated with increasing Sea-Tac’s capacity – which would also mean economic and social impacts will be imposed on surrounding communities.  A permit should not be granted until these issues concerning economic and social impacts and the public interest are clarified.  If it turns out that economic and social impacts will be generated, an appropriate mitigation plan should be prepared before approval is granted.

                                                 Sincerely

                                                 Theodore Lane, Ph.D.

Attachment:  T. Lane resume