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RCAA Comments on Sea-Tac Master Plan (SMP)
Draft Environmental Impact Statement (DEIS)
Chapter IV, Section 9 : Air Quality

Chapter 4 Section 9 Air Quality
      Comment: 9-I: Introductory comment.  The reader wishing  to
understand  Chapter IV, Section 9, Air Quality in the  DEIS  must
also  read and consult Appendix D  Our comments address both  the
discussion in the main text and relevant parts of the Appendix.
                             ***
     Comment 9-1:        The discussion of the impacts on air
pollution are based on two theoretical models: 1) the EDMS
inventory model , and 2)a dispersion model. apparently unique to
this E.I.S.
     Comment 9 2:        It is not possible to fully evaluate the
results of the EDMS inventory modelling and provide correct
comment because the assumptions and inputs used for the inventory
model are not given in the  DEIS.
     Comment 9-3:   I    It is not possible to fully evaluate the
results of the dispersion model and provide correct comment
because the assumptions and inputs used for the dispersion model
are not given in the DEIS.
     Comment 9-4:        While computer models are a useful
supplement, they cannot subsitute for actual measurement  and
monitoring of  pollutants in the community.
     Comment 9-5:        The inventory model as presented does
not inventory all the pollutants emitted, particularly from
aircraft (e.g., formaldehyde and 1.3 butadiene, benzene.  The
inventory model does not separate particulate matter from piston
engines from that for turboprop/turboject engines. )  Their
absence is especially egregious because they are indicators for
carcinogens from aircraft noise.  These pollutants were included
in the Midway Study which was referenced in Section 7 of the
DEIS. and used to calculate health risks.
     Comment 9-6:        Without validation, no computer model
rises above the level of refined speculation, and we can find no
evidence in the DEIS or elsewhere that either one these models
have been validated with appropriate measurement & testing
against model predictions, nor has there been any review of the
quality of the model in the professional literature.  Indeed, the
Department of Ecology disclaimed the EDMS inventory model as
being a rough estimate only.  (See, "Airport's Air:  How bad?
Seattle Times, 1/3/92.)
     Comment 9-8:        In addition, the findings reported here
are proportionally out of line with  previous uses of this same
model at Sea-Tac by the DOE & PSAPCA (p. IV-9-10B) and with
actual measurements taken in the Sea-Tac area in studies done for
the Port of Seattle (Appendix p. D-92-D128.)
     Comment 9-9:        The DEIS incorrectly assumes in the air
quality section that, unless the pollution from pushes the region
outside of legal compliance, it has no impact.  Impacts  well
below this level have a substantial impact & should be covered.
     Comment 9-10:       This FEIS should point out that
measurements shown in Appendix D do indeed violate the standards.
For example, the 8 hour standard for carbon monoxide (CO) is 9
ppm, but measurements at the Upper Level Deltas [sic] departure
gate shown on p. D99 is 10.0 ppm, well over the standard.  The
FEIS should identify measurements over the standards, along with
modelling, and not make the faultly assumption that only illegal
levels of pollution have an impact.
     omment 9-11:        Although the DEIS mentions measurements
taken in the Sea-Tac area in the Appendix D, pg. D92 to it fails
to incorporate them into the analysis and relies solely on the
unvalidated modelling.
     Comment 9-12:       The EDMS Model uses departures* to
calculate peak-periods at the airport , and the DEIS presents a
table of assumptions used for departures at p. D3.  This table
explains why comment & evaluation requires that readers know the
assumptions & inputs to the models.  (*Departures are used
because arrivals take longer than departures.  If an airport can
achieve 60 departures during a peak hour, it will always have <60
arrivals.)
     (a)  Those running the model used only 43.9 as the assumed
     peak-hour departure level for 1994 ("Existing"), even though
     normal peak departures at Sea-Tac are greater than 60 per
     hour.  The State's 1991 EDMS survey uses a more realistic 72
     peak-hour departure level.  However, peak hour departure
     levels of 90 are possible at Sea-Tac, as was demonstrated
     during the Goodwill Games.  Use of the 43.9 figure does not
     reflect the potential peak period capacity of the existing
     airport and is highly questionable.  The DEIS EDMS inventory
     greatly underestimates the levels of air pollution --
     especially those from aircraft -- because of this low
     assumption.
     (b)  The model makers apparently used the same peak hour
     departure levels for "do-nothing" and "with project,"
     showing peak departure levels of 46.58 for both "do-nothing"
     and "with project" in 2010, and 50.67 peak departure levels
     both "do-nothing" and "With project" for 2020.  "Do Nothing"
     and "With Project" have precisely the same result?  Then why
     are we wasting money on this EIS?  The FEIS needs to clarify
     this and reconcile these numbers with those used in Chap. 2,
     Purpose and Need, to justify the project.
     (c)  Amazingly, the air pollution estimates assume that the
     projects would only add 6.77* flights per hour by the year
     2020--even with the third runway and other projects.  It is
     astonishing to think of spending a billion dollars or more
     on just 6.77 flights per hour.  The FEIS needs to clarify
     this and reconcile these number with those used in Chap 2,
     "Purpose & Need" to justify the project.  (*To get the 6.77/
     hr. figure we subtracted 4093 peak departures given for
     "existing from 5067 peak departures given for "with project
     in 2020" on page D-3, DEIS Appendix D.)
     Comment  9.13:      According to the State Department of
Ecology, Air Quality Program, Sea-Tac airport is one of the
largest source generators of air pollution in King County,
producing 8% of the carbon monoxide and 5% of the nitrous oxides
in the county.  Please explain the apparently contradictory
assertion on pg. IV.9-1 of the DEIS that "Aircraft operating at
Sea-Tac contribute less that 1% of  the carbon monoxide
emissions, nitrogen oxides, and volatile organic compound for all
mobile sources within the Puget Sound Region."
     Comment  9.14:      Air emissions from Sea-Tac come from
both aircraft emissions and ground transport emissions from cars
& buses,  for both passenger and freight.  According to the DOE
study referenced in question 9.2, aircraft emissions constitute
approximately 88.3% of the emissions and ground traffic the
remaining 11.7%.  Please explain the apparently contradictory
assertion in the DEIS on pg. 9-1 that "The majority of the
pollutant emissions in the Puget Sound are generated by motor
vehicles (i.e., cars, trucks, buses, taxis, motorcycles.)"  This
quote prompted several other questions:
     (1)  Which pollutant emissions are referred to in this
     quotation?
     (2)  Doesn't the percentage depend upon which pollutants are
     being measured?
     (3)  Does it include NOx, PM2.5, and benzene and aldehyde
     whose contributions come more heavily from jet exhaust than
     others.
     (4)  What is the majority pollutant in the affected
     communities?  The FEIS should give this figure.
     (5)  Isn't this simply a product of the assumptions fed into
     to the models?  Could we not state the the primary pollutant
     was almost anything -- swiss cheeze molecules -- if we fed
     that assumption into the model?
     Comment 9.15:       Emissions from fire tests emit
significan levels of pollution, although their percent of
contribution has never been measured.  These are not included in
the "inventory" and their contribution to the existing
conditions.  Although the DEIS appears to assume that this test
will stop, the DEIS should explain why the Port of Seattle got an
exemption from the air quality standards from the State
Legislature to continue and when and under what conditions it
will stop.  It should also give the results if the the fire
testing is not stopped, so that its contribution can be
evaluated.
     Comment  9.16:      Because Sea-Tac sits on one small site,
unlike other comparable air pollution sources (i.e., freeways)
where the source is spread, pollutants reach very high
concentrations in the three mile area just around the airport.
How do the models presented in the EIS account for this?
     Comment 9-17:       The "brown cloud" sitting over Sea-Tac
is visible the I-5 freeway and from downtown Seattle on clear
days.  The primary culprit in this kind of smog is ozone.  Jet
aircraft have contribute heavily to the ozone factor because they
generate such large quantities of NOx, which contributes to ozone
formation.  Newer jets create less CO but more NOx.  However,
ozone was not measured
     Comment  9.18: Full analysis of existing conditions is
explicitly required under the SEPA rules. (WAC 197-11-440(6)(a).
That should include all conditions for which there is a known
standard and all other conditions which might have and impact--
such as toxic chemicals in jet exhaust.  It whould be verified by
acutal measurements.  The DEIS analysis of existing conditions
fails to meet these tests.
    Comment 9-19:        The E.I.S. must contain a sufficiently
detailed analysis to permit a comparative evaluation of the air
quality impacts that the proposal would create for each
alternative, as required by the SEPA rules at Sec. 440 (5) (c)
(v).  The  DEIS does not contain any comparative anyalysis at
all.  It assumes that the peak hour demand will be the same under
all alternatives, doesn't reconcile its projected operations with
those used elsewhere in the EIS and is grossly inadequate in the
depth of its analysis--most particularly with regard to ozone.
     Comment 9-20:       The E.I.S. must contain alternatives to
attain the proposal's objectives at a lower environmental cost as
required by SEPA, Section 440(5)(B).  We can find no analysis of
this in the DEIS.
     Comment 9-21:       The E.I.S. must investigate & fully
disclose nitrogen oxide emissions at takeoff.  The  NOx standard
is an annual standard, but given that NO is an important by-
product of jet exhaust, there was certainly time to monitor these
emissions for a year in the airport communities.  A monitor in
Beacon Hill, far from the brown cloud sitting atop Sea-Tac ,is
not adequate monitoring.
     Comment 9-22:       The E.I.S. must investigate and disclose
air, water, and health impacts from emergency fuel dumps within
15 miles of the airport.   Many citizens complain about seeing
and smelling fuel dumps, but the air quality analysis neglects
the subject entirely and should not.
      Comment  9-23:       Sea-Tac should be treated as a  "major
stationary   source"  under  the  Washington  State   Clean   Air
Conformity  Act defines "major stationary sources."   It  clearly
qualifies  under  the definition.  Aircraft emit  many  different
chemicals, some of the highly toxic, which would be monitored  &,
if  necessary  for the public health, regulated if Sea-Tac  is  a
"major  stationary  source".  The DEIS  fails  to  discuss  these
chemicals  and  the  standards for them even though  few  sources
create  greater amounts of these types of pollutants that  modern
jet  airports.  The DEIS must discuss all chemicals which have  a
sufficient  impact  to be regulated under the  "major  stationary
sources"  provisions of the clean air act.  Port-owned facilities
are not exempt from the law.
     Comment 9-24:       The E.I.S. must consider no-build
alternatives or mitigations that would reduce aircraft
emissions..  For example, if the landside operations at Sea-Tac
were administered from the standpoint of reducing idling time,
this factor should be the same for all alternatives.  If delays
are predicted as a result of the airport reaching capacity, there
is no reason why aircraft must spend this delay time idling in
taxiways.  Both land based and airborne air carrier traffic is
highly managed.  Under such a system there is no reason why
aircraft must spend excessive amounts of time simply idling their
engines waiting for clearance to take off.  If the magnitude of
aircraft emissions is a result of idling time, that impact should
be addressed through alternatives and mitigations specifically
responsive to that impact.
     Comment 9-25:                                                    The E.I.S. must
analyze the indirect impacts caused by the proposal as required by Sec. 060(4)(d) of the
SEPA rules.  For example, the Flight Plan projects an expansion of office space of up to
2.3 million square feet and an additional 7,000 to 10,000 hotel rooms.  All this airport-
related activity is projected to occur in areas immediately surrounding the airport.  This
sort of secondary development would obviously produce very substantial increases in motor
vehicle trips.  The E.I.S. should quantify and discuss these induced transportation
impacts.  Assuming that the infrastructure exists to accommodate these additional trip
ends, substantial air quality emissions would result.
     Comment 9-26:       Because of the significant danger to the
biota inherent in air pollution, Sea-Tac's contribution carbon
monoxide in King County of the nitrogen oxides in King County
must be addressed because of the severity of pollution in such a
small area of land --less than 1/5 of 1% of King County. (May
1991 DOE Study -- Seattle Tacoma International Airport:  Air
Pollution Contribution).
     Comment 9-27:       The F.A.A. is responsible for
implementing standards for commercial passenger jets and it does
so through engine certification data provided by the
manufacturers.  The DEIS relies exclusive on this potentially
biased data to do its modelling and it should not.  The E.P.A. is
currently in the process of requiring aircraft engines to conform
to the standards of the Federal Clean Air Act in parts of
California which severely restricts the F.A.A.'s ability to
accept the manufacturer's word as the emissions certification.
Actual emissions should be used to study air quality impacts.
     Comment 9-28:       The E.I.S. models are based on new
engines, pertectly maintained.  In real life, older planes fly
and engines are not in perfect tune at all times.  There is no
air quality inspection and maintenance (I/M) program for aircraft
This will tend to underestimate pollutants.   The FEIS should
explain how this was addressed and how it will affect the
results.
     Comment 9-29:       It is not clear from reading the DEIS
whether or not international carriers are exempt from air quality
standards and thus not included in the air quality studies.  We
can find, for example, no Aeroflot jet equivalents in the Table ,
pg. D-3 calculating the peak departure levels, however.  The FEIS
should clarify this, as it will tend to understate jet emissions
in the models compare to real emissions.  There is am impact from
foreign exempt carriers on air pollution and noise pollution and
they need to be included in impact studies of international
airports.
     Comment 9-30:       The E.I.S. must set forth how the
proposed action would carry out the various commitments contained
within the SIP for improving air quality in the region.  The DEIS
fails to set out the requirements clearly and utterly fails to
show how they would be met.
     (a)  With regard to mobile sources and particularly motor
     vehicles, the SIP includes commitments to increase transit
     use and for demand management (See Appendix D to SIP.)
     Similar methods for aircraft use should be set out in the
     DEIS.
     (b)   Sea-Tac  meets  the definition  of  "major  stationary
     source" and a complex source and must be so treated in  this
     E.I.S.
     S.I.P, Pg. 7: (41)  "Major stationary source means any
               stationary source (or group of stationary sources
               that are located on one or more contiguous or
               adjacent properties and are under common control
               of the same person or persons under common
               control) which:
                    *emits or has the potential to emit one
                    hundred tons per year or more of any air
                    contaminant regulated by the state or Federal
                    Clean Air Act (Sea-Tac emits 5,125 tons per
                    year of pollutants into the air according to
                    the State Implementation Plan.)
                    *is located in a marginal or moderate ozone
                    non attainment area (definition fits area
                    where Sea-Tac is situated) and
                    *which emits or has the potential to emit one
                    hundred tons per year or more of volatile
                    organic compounds or oxides of nitrogen (Sea-
                    Tac emits 1,950 metric tons/year according to
                    the State Implementation Plan.)
                    *is located in a "serious" carbon monoxide
                    non attainment area where stationary sources
                    contribute significantly to carbon monoxide
                    levels and which emits or has the potential
                    to emit fifty tons per year or more of carbon
                    monoxide or (Sea-Tac emits 3,050 metric
                    tons/y according to the State Implementation
                    Plan.)
                    *is located in a "serious" particulate matter
                    (PM10) non attainment area and which emits or
                    has the potential to emit seventy tons per
                    year or more of PM10 emissions.  (Sea-Tac
                    currently emits 68 metric tons/year according
                    to the State Implementation Plan, and if the
                    3rd runway is constructed will emit much more
                    than 70 tons of "serious" particulate
                    matter.)
                         The inventory of particulate matter done
                    for the DEIS, and reported at table IV.9-4 as
                    .023 Tons per year particulate matter must be
                    a typo, and should be corrected in the FEIS
                    and a supplementary will have to be issued to
                    give people a chance to comment on the
                    impacts of this much particulate matter.
     c)   Addition of a third runway and/or other expansions
     contemplated by the Airport Master Plan changes meet the
     definition of a "major modification" under the act and must
     be so treated in the E.I.S.  Specifially, ozone should be
     monitored and estimated.
          S.I.P, Pg. 6: (40) "Major modification" means any
                    physical change in or change in the method of
                    operation of a major stationary source that
                    would result in a significant new emissions
                    increase of any pollutant subject to
                    regulation under the act.  Any net emissions
                    increase that is considered significant for
                    volatile organic compounds shall be
                    considered significant for ozone.
     d)    Addition of a third runway and/or other expansions
     contemplated by the Airport Master Plan changes meet the
     definition of a "new source" under the act and must be so
     treated in the E.I.S.
          S.I.P., Pg. 8:  (48)  "New Source" means the
                    construction or modification of a stationary
                    source that increases the amount of any air
                    contaminant emitted by such source .
     This would include increases in operations; thus, analysis
     should be done assuming peak-capacity, not half of that.
     e)    Sea-Tac is defined as a Major Stationary Source, and
     must be treated in the E.I.S. as a complex source of air
     pollution with special attention to measuring and estimating
     the effect of concentrations of multiple pollutants and
     local hot spots of very high concentrations..  There is no
     hot spot analysis in the DEIS  modelling, and furthermore,
     the measurement programs have no measurements off the ends
     of the runways -- areas most likely to be hot spots for jet
     exhaust as opposed to auto exhaust.
     Comment 9-30:  The type of jet fuel used is quite
significant  in determining the  emissions.  The inputs to the
model should use the most polluting jet fuel for "worst case"
analysis.
     Comment 9-31:  The modelling points in the dispersion
analysis should be relabelled.  They are not "receptor points"
because there are no monitors there to receive, and it is
misleading to the reader who quickly loses track of the fantasy
model and the real receptors--especially since data from actual
measuring was not included in the model.
     Comment 9-32:  Recent reports issued by Dan Greenbaum of the
Health Effects Institute, Cambridge, MA confirm that there is a
correlation between high particulate matter and death rates.
Particulates are poorly covered in the DEIS.  We have already
pointed out the typo creating a major reporting error on p. IV.9-
10C.  In addition, the PM10 screen is inappropriate for a site
with mixed car and jet exhaust.  The EPA will be revising its
particulate matter rulings this year because it is under court
order to so so, most particularly to measure PM2.5.  This finer
screen is particularly important to examine in the DEIS because
jet exhaust has finer particulate matter than, for example, truck
exhaust and doesn't not show up as much in the PM10 studies.