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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.