29 November 1999

Peter J. Eglick
Helsell Fetterman LLP
PO Box 21846
Seattle, WA 98111-3846

SUBJECT: Seatac Third Runway Mitigation Review

Dear Mr. Eglick:

Pursuant to your request on behalf of the Airport Communities Coalition, I provide the following comments on my review of several documents regarding mitigation of impacts to aquatic resources by the proposed third runway at Seattle-Tacoma International Airport (STIA). My review included the following documents:

BioAnalysts. 1999. Assessment of Spawning and Habitat in three Puget Sound Streams, Washington. Report to: Airport Communities Coalition. April 1999. BioAnalysts, Inc.

COE. 1999. Public Notice of Application for Permit. U.S. Army Corps of Engineers. Regulatory Branch, PO Box 3755, Seattle, WA 98124. Reference: 1996-4-02325. 30 September 1999.

Gower, C. 1999. Written testimony to U.S. Army Corps of Engineers Public Notice of Application for Permit. September 30, 1999. Reference: 1996-4-02325. 13 pp.

Parametrix. 1999a. Biological Assessment. Master Plan Update Improvements. Seattle-Tacoma International Airport. November 1999. Parametrix, Inc.

Parametrix. 1999b. Natural Resource Mitigation Plan. Master Plan Update Improvements. Seattle-Tacoma International Airport. Revised Draft. August 1999. Parametrix, Inc.

Parametrix. 1999c. Preliminary Comprehensive Stormwater Management Plan. Master Plan Update Improvements. Technical Appendix A. Seattle-Tacoma International Airport. Revised Draft. November 1999. Parametrix, Inc.

Port of Seattle. 1999. Wetlands Re-Evaluation Document. Seattle-Tacoma International Airport Master Plan Update Improvements. Draft. August 1999.

I confined my evaluation to issues relating to the three streams that will be impacted by the third runway project: Miller, Walker, and Des Moines Creeks. Walker Creek is a tributary of Miller Creek, and these collectively drain the watersheds to the immediate north and west of STIA. Des Moines Creek collects runoff from most of the STIA site and lands to the immediate south and east. All three streams originate on the plateau surrounding STIA, and flow generally west through areas of extensive residential and commercial development, to drain into Puget Sound. My evaluation also included site visits to all three creeks, though I was not able to access several reaches due to exclusions from private property. I have spoken with several residents and municipal employees knowledgeable of stream mitigation issues.

I have attached a resume for your information.

I provide the following comment points:

  1. Coho salmon found in Miller, Walker, and Des Moines Creek that possess an adipose fin are considered members of the Puget Sound/ Straight of Georgia Evolutionarily Significant Unit. Stream impact analysis and mitigation measures should acknowledge this "Candidate" species under the Endangered Species Act of 1973.

  2. Coho salmon are reported in the upper reaches of Miller and Walker Creek. These results contradict other documents that formulate impact analysis and mitigation measures on the premise that salmon do not access the upper reaches.

  3. No mitigation document mentions opening the upper creek reaches to adult salmon spawning.

  4. The habitat restoration work proposed for Miller Creek does not adequately address how upstream restoration and enhancement will impact resident cutthroat trout and coho salmon in the upper reaches, and downstream ecosystems.

  5. More than 50 percent of coho salmon died before spawning in 1998. Data collected ad hoc in 1999 indicate a similar occurrence.

  6. Impacts to the estuaries of Miller and Des Moines Creeks are discounted. The discovery of significant salmon die-off suggests that a water quality problem may exist in these streams, and may extend to the estuaries.

My detailed comments follow:

  1. Coho salmon found in Miller, Walker, and Des Moines Creek that possess an adipose fin are considered members of the Puget Sound/ Straight of Georgia Evolutionarily Significant Unit. Stream impact analysis and mitigation measures should acknowledge this "Candidate" species under the Endangered Species Act of 1973.

    The Washington Department of Fish and Wildlife lists coho salmon as occurring in Miller, Walker, and Des Moines Creeks. Bioanalysts, Inc. (1999) documented 148 salmonid redds (nests) during the 1998-1999 spawning season in all three streams, the bulk of which were likely produced by coho salmon. These findings are consistent with those of Parametrix, Inc. (1999b). Both investigations properly identify coho that are of hatchery origin (adipose fin-clipped), and wild (adipose fin intact) as inhabiting these streams.

    NMFS (1999) defines the Puget Sound/Strait of Georgia Evolutionarily Significant Unit (ESU) coho salmon as:

    "…all naturally spawned populations of coho salmon from drainages of Puget Sound and Hood Canal, the eastern Olympic Peninsula (east of Salt Creek), and the Strait of Georgia from the eastern side of Vancouver Island and the British Columbia mainland (north to and including the Campbell and Powell Rivers), excluding the upper Fraser River above Hope."

    According to this definition, wild coho found in Miller, Walker, and Des Moines Creek are considered members of the Puget Sound/Strait of Georgia ESU, a candidate species under the Endangered Species Act. The distinction between hatchery and wild coho is significant, as hatchery fish are excluded from consideration (unless specified) under the ESA. As a candidate species, no specific protections are afforded Puget Sound/Straight of Georgia ESU coho salmon, though the National Marine Fisheries Service encourages that mitigation measures consider this ESU (Federal Register, 1999). The mitigation documents should acknowledge that wild coho salmon in Miller, Walker, and Des Moines Creeks are members of the Puget Sound/Strait of Georgia ESU.

  2. Coho salmon are reported in the upper reaches of Miller and Walker Creek. These results contradict other documents that formulate impact analysis and mitigation measures on the premise that salmon do not access the upper reaches.

    Several documents cite natural barriers to upstream migration in each of these three streams. For their study, Bioanalysts (1999) stratified their sampling efforts according to stream reach. A convenient separation between sampling strata occurs where each stream flows off the upper plateau, to the lower reaches of each stream. Surveys of salmon habitat by WDFW (1994) report that each of the three creeks draining STIA flow over falls or cascades that are "impassible" to salmon migration. In addition, Parametrix (1999a) states that coho occur "…in Miller Creek up to about the waterfall location [RM 2.8], but not beyond" (Parametrix at 5-2, paragraph 2).

    Parametrix (1999a) provides a review of several apparent migration barriers, including a comprehensive description of the falls at RM 2.8. That examination of the falls configuration, and a comprehensive comparison of known physical requirements that allow coho salmon to surmount such a barrier, allows the conclusion that "…coho salmon may be physically capable of ascending the waterfall…" (Parametrix at 5-2, paragraph 4). Coho are capable of reaching the falls, as Parametrix (1999b) cites a study (Aquatic Resource Consultants 1996) that found "One coho smolt…downstream of the culvert under S 160th St…." (Parametrix at 2-10, paragraph 3). Provided the proper circumstances, the falls upstream of South 160th Street would not preclude coho salmon from reaching the upper Miller Creek. Indeed, a portion of the expense of improving upstream habitat could provide a fish pass around the falls (See item #3 below).

    BioAnalysts (1999) also found coho salmon spawning activity confined to the lower basin of Miller and Des Moines Creek, but noted spawning throughout Walker Creek.

    These ground-truth studies disprove previous assertions that salmon spawning and rearing is precluded in upper Walker and Miller Creeks, respectively. Accordingly, mitigation measures to upper Miller and Walker Creeks predicated on resident cutthroat trout should be evaluated to protect the salmon resources, especially in Walker Creek where coho salmon were found to spawn in the entire stream.

  3. No mitigation document mentions opening the upper creek reaches to adult salmon spawning.

    Parametrix (1999) cites a previous study (Aquatic Resource Consultants, 1996) that reported finding a "coho smolt… downstream of the culvert under S 160th St." Although, Miller Creek flows through several culverts and steep gradients, downstream of the 160th Street crossing, coho are able to access and use the upper portion of the stream.

    Further, Parametrix (1999a) state that "Several natural and man-made barriers appear to limit fish access to the upper basin…The most prominent barrier on Miller Creek is a natural 8-ft. waterfall about 0.2 mi upstream of S 160th Street…". No mention is made of grading through the clay substrate to open the upper creek reaches to adult salmon spawning. An alternative to grading the falls is the installation of a fish passage structure. Parametrix (1999a) cites speculation that Miller Creek could support between 700 and 1,200 coho per year. With the restoration of much of Miller Creek upper reaches, the stream could likely support a self-sustaining population of coho salmon if similar efforts were expended to remove or renovate the barriers.

  4. The habitat restoration work proposed for Miller Creek does not adequately address how upstream restoration and enhancement will impact resident cutthroat trout and coho salmon in the upper reaches, and downstream ecosystems.

    Parametrix (1999b) states "The instream habitat criteria used in the relocated channel design are based on general habitat requirements of the resident salmonid cutthroat trout." (Parametrix at 5-11; paragraph 3). The identification of coho in the upper reaches, and the potential for coho to surmount the falls near South 160th Street, requires that this assertion be re-evaluated.

    Three documents provide explanations of mitigative efforts for the upper reaches of Miller Creek (Port of Seattle, 1999; Parametrix, 1999a-1999b). Conclusions of construction effects by Parametrix (1999a-1999b) are premised on the assumption that coho do not inhabit the upper reaches. The evidence of coho usage up to South 160th Street cited by Parametrix (1999b), however, contradicts the conclusions of "Insignificant" effects to Habitat Elements (Parametrix 1999a; Table B-1). Furthermore, conclusions of "Insignificant" effects to Habitat Elements, Channel Condition/Dynamics, Flow/Hydrology, and Watershed Conditions listed by Parametrix (1999a; Table B-1) are puzzling since the proposed mitigation will eliminate and replace all of these factors from more than 1,080 feet of stream reach, and result in an altered ecosystem. Such extensive alteration of the upstream environment has the potential to create episodic increases in turbidity and sediment loading downstream.

    The claim of "No Effect" on Riparian Reserves (Parametrix, 1999a; Table B-1) is questionable given the extensive alteration of the riparian environment that is planned. A determination of "No Effect" requires that there be an effectively zero percent probability of impact: a standard that is not met by these mitigation measures.

  5. More than 50 percent of coho salmon died before spawning in 1998. Data collected ad hoc in 1999 indicate a similar occurrence.

    BioAnalysts (1999) found that 66 percent, 50 percent, and 72 percent of coho salmon carcasses in Miller, Walker, and Des Moines Creeks, respectively, had died without spawning in 1998. This conclusion is based on estimated voidance of eggs or sperm. A November 2, 1999 site visit to Des Moines Creek resulted in similar findings, where 32 carcasses and 17 live coho salmon were enumerated in the lower reach. Subjective assessments of 23 carcasses indicate death occurred while the fish were in "ocean-bright" condition, i.e., before taking on the characteristics of spawning maturity. There were no indications of pre-mortem physical injury on any carcass. Unsystematic sampling of these carcasses (making a small incision in the vent and observing the body cavity contents) confirmed that the fish had died before expelling all sexual products.

    Inquiry to the WDFW area Habitat Biologist (Schneider, personal communication, 1999) and the District Fisheries Biologist (Cropp, personal communication, 1999), indicates that this is a previously undocumented phenomenon for these three creeks, but that a premature die-off of salmon has occurred in one other Puget Sound stream this season (Longfellow Creek in the West Seattle neighborhood). Under WDFW authority, several carcasses were collected and surrendered to the WDFW Pathologist at Soos Creek Hatchery (Thomas, personal communication, 1999). Results are not conclusive due to sample size and quality, but no evidence of unusual parasites or physical damage was noted.

    Further sampling and a stream survey by WDFW personnel have been conducted to investigate this phenomenon (Fisher, personal communication, 1999). Conclusions can not yet be drawn, yet it is conspicuous that the three streams that drain the STIA vicinity are experiencing this phenomenon simultaneously.

  6. Impacts to the estuaries of Miller and Des Moines Creeks are discounted. The discovery of significant salmon die-off suggests that a water quality problem may exist in these streams, and may extend to the estuaries.

The Biological Assessment concludes that impacts to salmonid species in the stream and estuaries will be "Insignificant" or "Discountable". These conclusions should be re-evaluated in light of the discovery of premature die-offs of coho salmon in Miller, Walker, and Des Moines Creeks. For the same reasons as expressed previously, the agent causing mortality within these creeks is likely to act in the estuary.

 

Sincerely,

Adolfson Associates, Inc.

 
Brian S. Bigler Lloyd Skinner
Senior Fisheries Biologist Environmental Services Director

 

REFERENCES

Cropp, T. 1999. WDFW District Fisheries Biologist. Personal telephone conversation with Brian Bigler, November 5, 1999, Seattle, Washington.

Federal Register. 1999. Department of Commerce. National Oceanic and Atmospheric Administration. Endangered and Threatened Species: Request for Information on Candidate Species List Under the Endangered Species Act. Vol. 64, No. 10. Friday, January 15, 1999. Pg. 2629.

Fisher, L. 1999. Larry Fisher, WDFW Biologist, Mill Creek office. Personal telephone conversation with Brian Bigler. November 18, 1999. Seattle, Washington

NMFS. 1999. United States Department of the Interior, National Marine Fisheries Service, Northwest Region Habitat Conservation Division, Northwest Region Species List http://www.nwr.noaa.gov/1salmon/salmesa/cohopug.htm. Updated 8/16/99.

Schneider, P. 1999. WDFW, Region 4 Habitat Biologist. Personal telephone conversation with Brian Bigler, November 5, 1999. Seattle, Washington

Thomas, J. 1999. WDFW Fish Health Specialist, Hatcheries Program. Personal conversation with Brian Bigler, November 5, 1999. Auburn, Washington.

USFWS. 1998. United States Department of the Interior Fish and Wildlife Service. A Framework to Assist in the Making of Endangered Species Act Determinations of Effect for Individual or Grouped Actions at the Bull Trout Subpopulations Watershed Scale (Draft). U.S. Fish and Wildlife Service.

WDFW. 1994. Washington Department of Fish and Wildlife, Washington State Salmon and Steelhead Stock Inventory. Appendix 1: Puget Sound Stocks, North Puget Sound Volume. Olympia, Washington. 371 pp.

Information supplied by the ACC.
Designed and coded by Richard T. Kennedy.
The Des Moines City Attorney would like you to read the disclaimer.
Last modified: 16 January 2000
URL: http://www.ci.des-moines.wa.us/acc/adolfson-2.html