February 16, 2001

Mr. Jonathan Freedman, Project Manager
U.S. Army Corps of Engineers (USACE)
Regulatory Branch
Post Office Box 3755
Seattle, Washington 98124-2255

Ms. Ann Kenny, Environmental Specialist
Washington State Department of Ecology
Shorelands and Environmental Assistance Program
3190 - 160th Avenue Southeast
Bellevue, Washington 98008-5452

Reference:  Seattle, Port of, 1996-4-02325    Comments on impacts to wetlands, streams and fisheries resources resulting from proposed 3rd runway and related development actions at Seattle-Tacoma International Airport.

Dear Mr. Freedman and Ms. Kenny,

Azous Environmental Sciences (AES) has been retained on behalf of the Airport Communities Coalition to review the impact of the Port of Seattle’s proposed development at SeaTac airport on wetlands, streams and fisheries resources.  Comments were submitted on the 1999 Wetlands Delineation and Wetland Functional Assessment documents as well as the June 2000 Natural Resources Mitigation Plan and related documents in letters dated August 16th and September 1st of 2000 to the Department of Ecology and the U.S. Army Corps of Engineers.  The purpose of this letter is to provide comments and analyses of the December 2000 updates of these documents.  A complete list of materials examined in preparing this critique is provided below.

List of Documents Reviewed:

·         Natural Resource Mitigation Plan (NRMP); Seattle-Tacoma International Airport; Master Plan Update Improvements dated December 2000, Parametrix, Inc.

·         Natural Resource Mitigation Plan (NRMP) Appendices A-E Design Drawings dated December 2000, Parametrix, Inc.

·         Natural Resource Mitigation Plan (NRMP) Revised Implementation Addendum dated August 2000 Parametrix, Inc., Number 556-2912-001 (03).

·         Wetland Functional Assessment and Impact Analysis; Master Plan Update Improvements; Seattle-Tacoma International Airport, December 2000 by Parametrix, Inc.

·         Wetland Delineation Report; Master Plan Update Improvements; Seattle-Tacoma International Airport, December 2000 by Parametrix, Inc.

·         Pacific Coast Salmon Essential Fish Habitat Assessment; Master Plan Update Improvements;  Prepared for FAA and Port of Seattle by Parametrix, Inc., December 2000.  Number 556-2912-001 (01) (48).

·         Biological Assessment, Master Plan Update Improvements; Prepared for FAA and Port of Seattle by Parametrix, Inc., June 2000.

·         Supplement to Biological Assessment, Master Plan Update Improvements; Prepared for FAA and Port of Seattle by Parametrix, Inc., December 2000.

·         Seattle Tacoma International Airport (SEA) Wildlife Hazard Management Plan, developed by Seattle-Tacoma International Airport in cooperation with US Department of Agriculture, Animal and Plant Health Inspection Service Wildlife Services, August 2000.

·         Comprehensive Stormwater Management Plan, Master Plan Update Improvements; Technical Appendices J, Q and R, by Parametrix, Inc., December 2000.

·         Feasibility of Stormwater Infiltration, Third Runway Project Sea-Tac International Airport, Sea-Tac, Washington, prepared for Port of Seattle by HartCrouser, December 6, 2000. J-4978-06

I am an environmental scientist, founder of Azous Environmental Sciences and a professional wetland scientist (SWS 001067).  I am co-editor and co-author of Wetlands and Urbanization (CRC/Lewis Press 2000), a professional reference book on how best to protect and manage wetlands in an urbanizing environment.  I hold a Masters degree in environmental engineering and science and a Bachelor of Arts in landscape architecture, both from the University of Washington.  I have worked as a scientific analyst for over 20 years and have specialized in natural resource science since 1991.  A package describing my background and experience is attached to this report. 

Activities that degrade or destroy special aquatic sites, such as filling wetlands, are among the most severe environmental impacts the Clean Water Act and Section 404 Guidelines are intended to prevent. [1]   The stated principle guiding decision-making for Section 404 permits is that degradation or destruction of special sites may represent an irreversible loss of valuable aquatic resources.  Under the Act, dredged or fill material may not be discharged into the aquatic ecosystem unless it can be demonstrated that the discharge will not have an unacceptable adverse impact, either individually or in combination with known and/or probable impacts of other activities affecting the ecosystem.  Accurate determination of the adversity of an impact and identification of commensurate acceptable mitigation to offset adverse impacts depends on careful analysis of the following factors:

·         The physical area of the wetland loss.

·         The functions provided by the wetland loss.

·         The cumulative effect of all identified losses including area and functions.

Without this information, it is simply not possible to determine the effectiveness of mitigation.  Without this information, the acceptability of adverse impacts cannot be decided.  Although these requirements were clearly pointed out in comments made in my September 1, 2000 letter, essential data and analysis remain missing:

·         The keystone of the mitigation proposal, the analysis of wetland functions being eliminated, is still unaccountably absent, and the wetland assessment is unsupported as a result.  This omission has apparently led the Port to propose a mitigation package that offers to replace the wrong functions.

·         Calculations of the extent of permanent and temporary wetland area losses remain unscientific and are contrary to common sense.

·         Astoundingly, there continues to be no analysis of cumulative effects.  Simply listing other projects and identifying project level adverse impacts does not constitute an analysis of the cumulative effects of all the projects. 

These serious voids leave USACE and the Department of Ecology with insufficient information to make a reasonable judgment as to whether the proposed discharge will comply with the intent and purpose of the Clean Water Act.  To illustrate better what is missing from the NRMP, the Biological Assessment, and the Wetland Functional Assessment documentation, I have prepared a series of analyses that address these voids using the data provided by the Port’s documents.  The following new analysis of data will illustrate why the agencies must find either that there is insufficient information to have reasonable assurance of no significant adverse impacts, or that there is inadequate mitigation to offset the significant adverse impacts of this project.

Wetland Functional Assessment of Losses in the Miller Creek and Des Moines Creek Watersheds

Although theDecember 2000 NRMP appears at first to have increased proposed mitigation of losses from constructing the Thirdover previous plans, the appearance is false because the mitigation actually proposed remains largely unrelated to the environmental functionsthat will be eliminatedby loss of watershed systems.  To illustrate the kinds of information missing from the assessment of functions performed by Parametrix for the Port of Seattle, I assembled data provided in Table 1-2 of the December 2000 Wetland Functional Assessment, and Tables 3-1 and 3-3 of the December 2000  NRMP into a spreadsheet and produced Figures 1, 2 and 3 showing the wetland functions affected by the project.

Table 3-3 gives one of five rankings (low,low-to-moderate, moderate, moderate-to-high, or high) to each functionof the wetlands to be eliminated.  All rankings of low,-to-moderate, and moderate were placed in one category (“Low-Moderate”), and all rankings of moderate-to-high and high were placed in a second category (“Moderate-High”).  Figure 1 is a bar chart illustrating the functional rankings of the acres of wetlands to be eliminated from both Miller and Des Moines Creek watersheds, using the two categories.

Figure 1.  Functional rankings assigned to wetlands being eliminated for the Third Runway Project.

Figure 1 shows that the highest-ranking functions being eliminated from the watershed in the greatest proportion are habitat for passerine birds (68%), small mammals (70%), groundwater discharge/recharge (71%), and nutrient sediment trapping (76%).  Forty-three percent of the wetland acres being eliminated are rankedmoderate-to-high for anadromous fish habitat,forty-eight percent are rankedmoderate-to-high for providing amphibianhabitat, and fifty percent are highly valued for export of organic material.

Significantly, 92 percent of the eliminated wetlands arelow-to-moderate for waterfowl habitat, and 80 percent arelow-to-moderate for flood storage.  These areproportionally the lowest-ranking functions among all the wetlands being eliminated, yet waterfowl habitat and flood storage are the primary functions targeted for replacement in the NRMP. [2]   The grossly misplaced emphasis makes no environmental sense at all and serves to create the impression of mitigation where no effective mitigation in fact exists.  The mitigation proposal appears to be tailored to the needs of the project rather than the requirements of the Clean Water Act.

Figure 2 shows the ratingsof wetlands in the Miller and Des Moines Creek watersheds, using Department of Ecology’s (DOE) Wetland Rating System.  Starting at the left of each chart in Figure 2, the first barshows the proportion of wetlands being eliminatedfor each of the three pertinent DOE ratings.  The second bar shows the percent of wetland acres in the Port’s entire project area that have that rating and are being eliminated.  For example, the Miller Creek Basin chart in Figure 2 shows that 58 percent of the wetlands eliminated by the Third Runway in the Miller Creek watershed are rated Class II. It also shows that 45 percent of all the Class II wetlands identified within the Miller Creek Basin project area will be eliminated. [3]

Figure 2.  Department of Ecology (DOE) ratings for wetland acres eliminated. [4]

The bar charts in Figure 2 illustrate that the majority of wetland acres being eliminated for the Third Runway project in the Miller Creek watershed are more highly rated Class II wetlands, rather than lower quality Class III and IV wetlands. This evidence directly contradicts the repeated statements made in the NRMP and Wetland Functional Assessment that the wetlands to be eliminated are degraded to the extent that they provide few valuable functions. [5]

Another importantmeasure of wetland function is proportion of habitat types , such as emergent, scrub-shrub , or forested wetlands. Figure 3, below, identifies the types of habitat that will be eliminated in the Miller Creek and Des Moines watersheds. The charts show that the majority of wetland acres to be eliminated in Miller Creek are forested wetlands, followed by emergent habitats. Shrub wetlands constitute the smallest component of habitat types being eliminated.

Figure 3.  Proportion of wetland habitats eliminated.

Based onthe results revealed in Figures 1, 2 and 3, commensurate mitigation for these lost functions would require replacement of habitat for passerine birds, small mammals, and amphibians.  It would require assurances that the sediment and nutrient trapping functions be compensated for, as well as groundwater exchange functions.  To comply with Section 404 Guidelines, a plan wouldhave to ensure that sources of organic export within the affected watersheds be maintained and that there be no net loss of fisheries habitat (resident or otherwise), particularly in light of recent and proposed Environmental Species Act (ESA) listings.  An acceptable plan would include creation of wetlands rated Class II or greater and would provide habitat dominated by forested and emergent wetland systems.

In contrast, the in-basin mitigation being offered within Miller Creek watershed ignores these key requirements. Instead, the Portproposes to replace the existing wetland functions, identified clearly in the data gathered byits own consultants, with a questionable restoration of a scrub-shrub wetland, the least common habitat type found in the watershed.  Further, the restoration is designed to replace “lost” flood plain, which is not identified anywhere in the wetland functional assessment as a significant function provided by the impactedwetlands. 

Determining the Extent of Permanent and Temporary Wetland Losses

I pointed out the Port’s unrealistic approach to determining what constitutes permanent versus temporary wetland impacts in my August 16th and September 1st commentletters. The December 2000 Wetland Functional Assessment<in