15 April 1998

Subject : Third Set of Comments on "Port of Seattle File Number 96-4-02325", Wetlands Permit, Notice of Application for Water Quality Certification and For Certification of Consistency with the Coastal Zone Management Program

These comments are in addition to those supplied at the April 9, 1996 hearing and those mailed in January of 1998. As indicated in an e-mail already sent to you, CASE would appreciate a technical forum. We can't mail our library and we would like to make sure we convey to you information on whatever subjects you have the greatest concerns. We believe that you will deny this permit if you have accurate data and realistic cost/benefit projections. Even if all the money in the FAA trust fund was diverted to this project, there still would not be enough money to fund it to completion.

This provides new barging capacity information, and summarizes the alternatives comparisons in a more succinct manner than my prior submittals. In addition I would like to reiterate key points from the hearing:

1. The wildlife advisory relates to garbage landfills, not wetlands
2. Taxing across two live runways is far more dangerous than wetlands. The pilots association, ALPA, sent a petition earlier in the process that states they did not endorse the Third Runway due to its "marginal safety"
3. The required safety areas appear to be missing from the runway ends
4. The NPDES 24 hour max. rainfall design limit is too low
5. Allowing Third Runway construction prior to the approval of the AKART plan REQUIRED by the NPDES permit, may eliminate the possibility of implementing the DOE preferred pollution control processes such as de-icer pads.
6. The quantity, cost , transportation mode and schedule for fill are UNDEFINED

Fill EIS Needed to Evaluate Feasibility of Third Runway The amount of off-site fill has grown tremendously over time as potential on-site sources have been eliminated due to contamination, wetlands or deemed to be off-site. The Dept. of Natural Resources after the issuance of the SEIS revised their position on Des Moines sites 1 , 2 and 3 and now considers them to be off-site and subject to surface mining permit process. Sites 5 and 8 had already been eliminated. That leaves only site 4 which is right beside a creek. Logically, the use of on-site borrow source 4 should also be denied. Why risk the creek for only 2.2 million cubic yards when you need more than 27 million cubic yards anyway?

The real amount of fill needed is unknown for numerous reasons including

1. two undefined seismic anomalies must be removed,
2. some contaminated fill needs to be removed
3. the unsafe retaining wall design may lead to moving highway 509 or putting a tunnel over the highway,
4. there are no provisions for pollution mitigation such as de-icers pads even though the DOE has stated they are the best way to control de-icers and experiments to vacuum at Sea-Tac have failed.
5. there appears to be no provisions for the FAA REQUIRED safety areas, and
6. according to Univ. of Florida the EIS calculations are incorrect.

If trucks continue to haul at the current airport construction rate it will take over 50 years to complete the construction project. Increasing over the current rate is unrealistic considering traffic volumes, the number of truck accidents and high particulate volumes to date. The "22 week" runway safety area construction took over a year since they were only able haul 350,000 cubic yards instead of the 450,000 in 1996 as planned. At the 1996 rate it would take over 77 years to haul 27 million cubic yards. In 1997 they hauled more than 350,000 cubic yards but hauled to multiple locations during the wet period creating health and environmental hazards significantly greater than the year before.

Barging has been proposed instead. However, as the chart shows on the next page this will require operating Maury Island at about 540,000 times the normal mining rate of 10,000 cubic yards a year. It will require barging at about 5 times their previous all time record for a period of about 5 years assuming they haul 24 hours a day year round. If the FEIS 270 day mitigation limit of hauling in dry weather is imposed as well, it will take NINE years assuming round the clock barging, six days a week, 25 tons per day. Twenty-five tons per day will require three to four barges per day (see references listed under chart on next page).

³ Quantity needed in mining correspondence (ref. (4)) indicates only 24 tons needed. 24 tons equates to 16 million cubic yards (myc) assuming 3000 lbs per cubic yard. Quantity for total Project now exceeds 27 million cubic yards

Where will they unload the fill? Then, how will it get to the airport? Will wetlands be impacted by conveyer belts or new piers? Whether the foreign owned company can get permission to mine arsenic laced fill jeopardizing Maury Island aquifer, Highline Aquifer and possibly the Vashon Island aquifer also needs to be established to determine feasibility.

¹ Max volume prior to Shoreline Act (see ref.(4)) ² Max volume after the Shoreline Act (see ref.(4), 1978 Terminal/Pier 37)
³ Quantity needed in mining correspondence (ref. (4)) indicates only 24 tons needed. Real quantify for entire Project exceeds 27 million cubic yards or 40.5 tons
(4) Calculations based on data from Hillis, Clark, Martin &Peterson," Re:Lone Star Northwest's Sand and Gravel Quarry, Maury Island", To Mark Mitchell, dated 24 February 1998 and Hillis, Clark, Martin &Peterson," Lone Star Northwest's Sand and Gravel Quarry, Maury Island", To Fred White, dated 19 February 1998. Also assumed pit run to be 3000 lbs per cubic foot.

Recent bids on Phase 1 of the Project came in 23 % to 48 % higher than the Engineer's recent estimate, another indicator that schedules and costs are underestimated. Considering all the cost and availability fill issues that have arisen subsequent to the release of the SEIS, other alternatives need to be seriously considered.

The following table compares alternatives using cost/benefit factors that need to be considered in addition to the number of acres of wetlands impacted. I believe the risk to the world's food chain is greatest when destroying Sea-Tac's wetlands due to their close proximity to Puget Sound and their already marginal functionality.

Although new technology at Sea-Tac can better fill the capacity gap than a Third Runway from a cost/benefit point of view, neither can provide the level of capacity increase desirable for the region.

* Airports should not exceed practical capacity. The new runway exceeds "practical capacity" before it opens using FAA projections. When airports reach "severely congested", airlines use other airports due to unacceptable delay times. Theoretical capacity is normally economically unacceptable. See my SEIS comments for references.

Misc. New Input - Supplements prior submittals
Summer of 1996 Angle Lake was lower than the residents have ever seen it and feared losing it. Was this related to the new fill construction project at the south end of the airport (350,000 cubic yards)?

While at Miller Creek between 8 PM and 9 PM on 11 April 1998, there was visible pollution on the surface. Foam like rings ranging from the 1/8 inch diameter to about 2 inches diameter were visible floating down stream to the Sound. By rocks it had accumulated into piles at least 1 inch by 14 inches wide. The creek was covered with these floating circles that were obvious in the moonlight. When we swished a stick in the creek a somewhat fluorescent foam head appeared in the wake of the stick. When the stick was swished under the water to minimize the wake effect, the same almost fluorescent foam appeared. The magnitude of the light colored wake depended on creek location and depth. The circles dissipated when touched by hand. It was a cold night and deicing operations would be required at the airport that night.

The 1997 water rate hike was attributed in part to the need to find more sources of water. While New York City is buying land in another part of their state for water, and Maryland is paying their farmers to leave their wetlands as pollution buffers, the Port of Seattle plans to destroy our pollution buffer and endanger the water underneath Sea-Tac airport (the aquifer). Seattle Water Dept. uses this water too, not just Highline. A Dept. of Ecology document admits to contamination of the uppermost aquifer. Some residents already complain of diarrhea that correlates with pollution events at the airport and will not drink beverages made with "airport" tap water.

This wetland mitigation of the Sea-Tac airport issue made front page news in the Sierra Club Cascade Sound April/May 1998 newsletter. It has been identified as one of the key areas for the South King County group to focus their efforts. The Sierra Club issued a resolution against the Third Runway a few years ago.

The expansion of Sea-Tac Airport is inconsistent with how other airports in heavily populated areas handle capacity increases and is inconsistent with preserving drinking water.

Thank you for this opportunity to comment. Please contact me if you want additional information. I am looking forward to the technical meeting COL Rigsby agreed to have the night of the April 9 hearing.

A. Brown