RCAA Comments on Sea-Tac Master Plan (SMP)
Draft Environmental Impact
Statement (DEIS)
Chap. IV, Section 7: Human Health
Comments on Chapter 4-Section 7: Human Health
Our comments on this section are in two groups. In the
first group, Comments IV-7-A throurgh IV-7-C, we include studies of
certain issues included within the scope of the Chapter; these studies
present materials, data, findings, and analyses not included in the DEIS,
which should be addressed in the FEIS. The balance of the comment
are our comments on particular points raised in the Human Health
section of the DEIS or suggested by it.
Items included as Comments IV-7-A through IV-7-C.
Comment IV-7-A: Submission to PSRC Expert Arbitration Panel on
Noise impacts: "Report on the Proposed Reduction in Noise Levels
at the Seattle-Tacoma Airport", Alice H. Suter, Ph.D. (October
26, 1996)
"
Comment IV-7-B: "Sleep, Noise, and Immunosuppression", published
in M.Vallet (Ed.) Noise as a Public Health Problem. Proceedings
of the 6th Internatonal Congress. Nice, 5-9 July. Vol. 2, pp
575-578. Arcueil Cedux, France:INRETS.
Comment IV-7-C: Submission to PSRC Expert Arbritration Panel on
British Sleep studies including:
1)In the High Court of Justice, Queen's Bench Divisions,
Crown Office List, In the Matter of an application for
Judicial Review, The Queen -v- The Secretary of State for
Transport, Ex Parte: The Council of the London Borough of
Richmond Upon Thames and others. Crown Office Re. No.
CO/2110/93 Affidavit of Walter Holland and Affidavit of
Birgetta Berglund;
2)Abridged cirriculum vitae for Holland & Berglund,
3)Scientific Review of "Report of a Field Study of Aircraft
Noise and Sleep Disturbance" issued Dec. 1992 vy the
Department of Transport, United Kingdon, Birgitta Berglund,
Ph.D. (May, 1993); and
4)"The U.K. Sleep Disturbance Study--A Critique", Jeffery
Gazzard. (A Presentation to the N.O.I.S.E. Annual Meeting,
Irving, Texas July 15th 1993)
Comment-7-1 : A volunteer, a professional librarian, has
undertaken a search of several computer data-bases to find
citations to published literature on the scientific, medical
& technical literature on health effects of aircraft noise.
The raw results of this search have been printed out, &
constitute Exhibit IV 7-1 to our comments. It will be
noted that this Exhibit runs to more than 200 pages,
encompassing an estimated 450 separate citations of
publications of potential interest to investigators studying
the issue of the effects of noise on human populations.
This includes only publications dated Jan 1991 or later.
These publications are found in learned journals,
published or sponsored by accredited universities or
recognized learned societies. It can be assumed that many
were also subjected to peer review before being accepted for
publication.
(a) The computer-data-base research shows that
impact of aircraft noise on human activity has been the
subject of ever-increasing investigation by researchers
from numerous disciplines. This investigation does not
occur in a vacuum --the intense research activity
itself is an indication that the investigators, & the
editors & reviewers of the journals in which they
publish, are aware that there is something significant
to investigate. Yet the DEIS dismisses this huge body
of research & its conclusions as having serious
methodological problems, on the basis of an unpublished
& unlocatable paper supposedly emanating from an
unknown Federal agency. The DEIS errs in dismissing
this matter without proper study.
(b)The DEIS seriously errs when it regards the
unreviewed, unpublished declarations of Federal
bureaucrats as having greater weight in matters of
science than the work of serious investigtors, having
genuine credentials, working & publishing under the
established rules for scientific investigation. This
error should be corrected in the FEIS. The following
corrective measures are suggested:
(1) Any papers relied on by the FEIS that
are internal Federal publications (i.e., not
published in independent, recognized learned
journals) should be properly cited in the
recognized (& unique) method for such citation,
which includes the Government document number.
Failure to provide proper citations disables
readers. For example, we are unable to locate in
the repository of Federal documents at the
University of Washington the paper referred to at
DEIS IV.pg. 7-2 Footnote 4, for no document
number is provided & the publishing body (Inter-
Agency Committee) is not a known Federal agency.
(2) Only in extraordinary circumstances
should unpublished work be cited, most especially
unpublished work by non-scientists.
(3) If it is felt absolutely necessary to
cite unpublished Federal studies, the FEIS should
at least disclose the relevant credentials, if
any, of the investigators.
This issue of citation of literature is one that we raised
in our scoping comments, hoping to persuade the DEIS/FEIS
preparers to avoid this very situation, & this issue recurs
throughout the DEIS.
(c) If there are problems with methodology in
relevant studies, the FEIS would do better to state
what those problems are & how they can be corrected.
(d) The possible existence of serious
methodological problems in this or that study does not
necessarily invalidate the general conclusion to which
studies lead--in this instance, the conclusion that
aircraft noise is indeed a problem.
(e) It should be noted that airport/aircraft noise
is an issue everywhere there is a major, in-city or
near-city airport. In the United States, many thousands
of citizens in hundreds of cities & towns are reporting
increased aggravation from increased noise. This noise
is generated by Federally-regulated aircraft, aided in
their operations by Federal subsidies, & travelling to
& from airports built in part with Federal funds. The
Federal government (particularly the F.A.A.) is
sponsoring this noise. Thus, the F.A.A., like its
counterpart civil-aviation agencies abroad, has serious
responsibilities in this regard, & cannot escape them
by asserting, EIS by EIS, that the state of the
research (by others) is unsatisfactory. The F.A.A.,
like its counterpart agencies abroad, has a duty to
investigate this matter thoroughly, preferably ferably
through outside, independent investigators, & not, as
here, to avoid & evade by unsupported blanket criticism
of methods of the studies that reach conclusions
inconvenient to the agency & its clients.
(f) The exhibit, 7-1, shows that there is a huge
body of work in this general field. Seemingly, the
F.A.A. is generally unaware of this work. What does
the F.A.A. propose to do to come to speed on this
problem?
Comment 7-2: Although the DEIS concludes that the impacts
will mostly be measure in "annoyance," it fails to present
any annoyance surveys done in communities experiencing at
least >55 Ldn for Sea-Tac both now & projected with the
alternatives..
Comment 7-3: The DEIS states: "the U.S. Environmental
Protection Agency (EPA)'s Levels Document, indicates that
exposure to sound levels of 70 Leq(24-hr) (approximately 75
DNL or 74.6 dBA for 8 hours) or higher on a continuous
basis, over a very long period, at the human ear's most
damage-sensitive frequency may result in a very small but
permanent loss of hearing." (Pg. IV4-7-1) While this is
obviously correct, the DEIS fails to state how many people
live & work in the vicinity of Sea-Tac experiencing > 70
Ldn, 75 DNL, and 74.6 dBA for 8 hours, respectively and the
demogprahic of this population , age, sex, and races.
Comment 7-4: Even more importantly, the DEIS fails to
mention that the EPA Levels document1 recommends noise
levels in residential areas of < 55 dB Ldn outdoors and <
45 dB Ldn indoors iin order "to protect public health and
welfare from the effects of environmental noise." [emphasis
added]. The DEIS fails to state how many people live in
areas exposed to noise levels > 55dB Ldn recommended in the
EPA levels document, or to descibe the demographics of that
population, or the potential health risks associated with
levels > 55 Ldn. It fails to examine the ability of the
"mitigation by insulation" programs to achieve < 45 dba
indoors.
Comment 7-5: The DEIS asserts that "aircraft noise levels
of 115 dBA, permitted bv OSHA for 15 minutes per day,,would
never be experienced by residents around Sea-Tac Airport as
shown in Appendix C. Appendix C shows that the peak sound
exposure level (SEL) currently impacting residents closest
to Sea-Tac is 111.7 dBA, at site 4299 (grid site F29).
Thus, hearing damage would not be expected for residents
near Sea-Tac."(Pg. IV 7-1)
a.) However, questions exist as to whether taxi-way &
runups have been included in the noise analysis, and in
the SEL data (see Comments on Chapter IV, Section 1.)
Runups can and frequently do produce sound exceeding
115 dBA and many last for 30 minutes in a 24-hour
period. Without the data, the DEIS fails to show that
runups do not exceed the high noise short term
standards.
b) Furthermore, this standard is, again, a workplace
standard where those exposed are exposed voluntarily &
paid to do their job, not unwilling members of the
general public in their own homes & yards..
c) These standards were not established considering
pregnant women, infants, children, the ill or the
elderly , and may not necessarily apply to them.
Comment 7-6: The EIS states that "The Bureau of Labor
workplace related noise standards permit unprotected workers
to be exposed to average noise levels of 90 dBA for eight
hours per day. There has been pressure from medical
researchers to lower the eight-hour standard to 85 dBA. As
is shown in Chapter IV, Section I "Noise", coverage aircraft
noise levels do not reach or exceed 85 to 90 dBA (as
measured in DNL)." Pg. IV 7-1) It is inappropriate to use
occupational standards for environmental noise pollution
where those exposed are unwilling and not paid for their
exposure. It is well-established in the literature that
"control" or "lack of it" over the noise source
significantly affects a person's response to the noise (See
Comment # IV-7-A) and subsequently also affects the
likelihood that they will experience the psychological
and/or physiological affects from the noise. In addition,
occupational standards do not contemplate potentially
sensitive populations, such as babies, children, the
elderly, the ill and pregnant women.
Comment 7-7: Although the DEIS correctly states that "The single-
event noise levels from many aircraft which operate from runways
at the Airport commonly exceed 85 dBA on neighboring residential
land uses." it fails to point out the well known NASA sleep
studies (See "The Health Effects of Noise on Man", Karl Kryter,
NASA Ref. Publication 1115,84 and Academic Press. Mento Park,
1985) showing that 80 SEL creates sufficient noise to wake a
person up inside with the windows closed (assuming 20 dBa from
going inside and closing the windows).counting 20 decibels SEL
for cold climtate construction.
a) The draftors of the DEIS are apparently from Chicago and
unaware that Seattle, despite its northerly location, does
not have a cold climate but a temperate, marine climate.
Plam trees can be grown north as far as Bellingham. Most
older homes were built with very little or no insulation.
The City has had a major on-going program to encourage
people to install insulation for energy conservation. The
local is just beginning to install double paned glass,
routinely with new construction-- again for energy
conservation. Air conditioning is very rare. It does not
get dark in summer until after 9 p,.m. On hot days, it is
traditional eat out on the deck or in the back garden and
just leave the windows open to cool the house down at night.
It is very doubtful that most homes in this area could
achieve a 20 dba reduction by moving inside and closing the
windows.
b) The EIS fails to examine the impacts on sleep disruption
that the alternatives will have on the airport communities.
Large numbers of people will be brought in under new flight
routes with jets directly over head. This airport sits in
the middle of the most densely populated corridor in 4
states with flightlines running out, not just over the
middle of the State's largest city and six largest Seattle
and Federal Way, in addition to the smaller cities in the
Highline communities. How many more people will be waked up
by a passing plane creating 80SEL? What are the
demographics of the population likely to be affected.
c) The SEL maps should be done for the north side of
the airport over the densely populated Seattle area.
Telling readers to turn the maps for the south side of
the airport upside down is ludicrous. The flight
tracks on the south don't resemble the north in any
way.
d) The SEL's for the more commonly used Four-Post
flight route should be shown in addition to the
Duwamish/Elliot Bay noise abatement route. Logs
showing the actual percentage of time each is used
should also be given.
e) The numbers of people likely to be affected by each
SEL of a Stage 2 and Stage 2 light and heavy jets
should be calculated.
Comment 7-8: The DEIS claims incorrectly that "In spite of
years of study attempting to isolate the effects of airport
noise on humans, the impacts appear are so low that they
cannot be related to the general satisfaction of the
research community, particularly below DNL 70 dB."
a.) This mistates the findings of "Federal Agency Review
of Selected Airport Noise Analysis Issues by FICON
August, 1992 cited as support. This report does not
state that the effects are too so low that they cannot be
related to the satisfaction of the research community,
but only that more research needs to be done, an entirely
different conclusion.
b.) The scientific validity of this summary is
questionable as it has not been published in the
scientific literature nor given peer review and its
author's qualifcations are unknown. The document is not
generally available to the public and has no federal
document number. The obsure FICON Committee is listed as
author. FICON is not even listed in the catalog of the
Government Documents Library at the University of
Washington--a designated federal repository.
c.) What orginal research (that is not reviews of other
work) has been done by FICON and where has it been
published for peer review. Only those doing research &
being published in the professional and academics
journals and there for subject to peer comment and
review can represent the views of the scientific research
community.
d.) The DEIS has a duty to discuss the potential impacts
and the burden is on them to show that there are no
significant health impacts. The burden is not upon those
who suffer from those impacts to scientifically prove
isolated physiologic effects of noise.
Comment 7-9: The FICON report2 asserts that "Because the
Schultz curve (ed note. discussed in Suter below) provides
the only widely accepted dose-response relationship between
environmental noise (in terms of DNL) and a health and
welfare parameters, annoyance, DNL has been accepted as the
most useful and informative metrics for describing the noise
exposure of a community caused by an airport..." However,
subsequent studies have shown that "annoyance levels" for
aircraft noise occur at significantly lower levels of DNL
than other types of transportation noise. Exhibit 2 of our
comments on health impacts contains a review of these
studies by Dr. Alice Suter3. (This review was presented to
the PSRC Expert Panel in Dec. 1994 and was known to the
authors of the DEIS.prior to publication. We included it
here in toto as a portion of our comments on the DEIS and
ask that each of its major points be considered.)
Comment 7-10: The DEIS claims that "According to a recent
summary of aviation noise research some international
researchers have published data indicating that a
significant physiological risk exists. However, the summary
of such studies indicates that virtually, all of the studies
have had serious methodological problems and therefore
questionable results.4" (pg. IV-7-2)
a.) he summary cited is a summary of U.S. Federal
Government studies, not all research on noise impacts.
U.S. Federal Studies government studies were severely
curtailed in 1982 when funding was cut for the EPA
noise office.5 Consequently, most of the scholarly
research has been done in universities & hospitals in
Europe.
b.) the citation here is to another pamphlet again
produced by the mysterious FICON. This pamphlet is
apparently is not in print. We were unable to obtain a
copy at the public library or the government documents
repository at the University of Washington. How do
members of the public contact FICON?
c.) To say vaguely that there are supposed
methodoligical problems with all research ever done on
the basis of unpublished pamphlet prepared by one
committee of federal bureaucrats whose office is
unlisted in government directories is a transparent
attempt to sprinkle disappearing powder over existing
field research. This is not acceptable, misinforms
public policy makers, and does not extinguish the FAA's
duty under NEPA and the Port of Seattle's duty under
SEPA and NEPA to discuss all potential health impacts
from noise and the populations exposed to them.
Comment 7-11 DEIS should state the physiologic risks
identified by the European and American researchers and cite
the studies involved.
Comment 7-12: We would agree with the draftors of the
DEIS that the research is difficult & in some cases
inconclusive. However, health research is always
difficult., public health research particularly so. Health
research cannot be conducted in ways that would harm the
people being studied, further complicating matters. Very
few public health studies escape some difficulties.
However, "methodogical problems" do not necessarily mean
that the results are questionable, only that there are some
limitations in what they mean. If the writers of the DEIS
reject a particular study identifying a physiologic risk,
DEIS should explain the findings and the specific the
particular methodological limitations of the study. Without
this information, it is impossible to give specific
comments.
Comment-7-13: The authors don't distinguish between
epidemiologic, physiologic, clinical studies, survey and
dose-response studies and they should, specifically when
discussing methology.
Comment 7-14: The DEIS quotes one researcher in a
magazine interview saying that, "Several problems that
occur in trying to associate exposure to airport noise with
adverse health effects are 1) oriented measurements of noise
yield a poor indication of personal noise exposure, and 2)
long latency periods between exposure and disease greatly
complicate interpretation of research findings." (pg. IV-7-
2)
a) So what? The DEIS seems assumes that this is
sufficient to extinguish the need to discuss the health
impacts of noise pollution and to apparently to reject
all studies published in the peer reviewed literature
as suffering methodological problems. It is not. By
this standard, health studies on almost every subject
would be rejected. All epidemiological & pollution
exposure studies (except perhaps radiation which can be
measured by wearable badges) lack methods of defining
individual dose response. The individual dose response
for the A.I.D.S. virus is unknown. That doesn't mean
that exposure of tens of thousands of innocent
individuals to the AIDS virus won't have serious health
impacts.
b). Most things which have a potential to cause
cancer, heart disease, hypertension, & hearing loss
have a long latency period. The latency period for
AIDS is unknown and extremely variable. That doesn't
mean that there is no health impact.
c)This is a absurdist & willful misunderstanding of the
scientific process, not an honest discussion of what
are the known and likely impacts of long term exposure
to noise pollution.
Comment 7-15 We can find no physicians, epidemiologists, or
other qualified health researchers on your list of document
preparers. Please indicate who prepared each section (noise
pollution, air pollution, water pollution, air safety and real
estate losses) of the health impacts section and their medical &
scientific qualifications.
Comment 7-16 (DEIS pg. IV-7-4)Losses in property values are
not generally considered "health impact, much less a psycological
impact." The reasoning that this may cause stress absurd. The
discussion of real estate values should have been in the the
socio-economic impacts sections where people would be more likely
to find it. Because it is found there in the DEIS those who
don't read the entire impact statement are likely to note its
absence only, file that comment, only to be told to look under
health impacts in reponse. This would prevent them from being
able to make substantive comments on the loss of real estate
values absent reading the entire document to find the discussion
buried in the "health impacts section". Given that very, very
few copies of the 2200 page impact statement are available to the
public, it is highly likely people would comment on one section.
The remedy to this error would be to give those who note the
absense of a discussion of real estate losses as their comments
to the socio-economic section (because they did not find it in
health impacts) should be told where is is buried in the health
impacts section and given a 60 day extension for filing
additional comments.
Comment 7-17: Please note: /we put our comments on the
discussion of real estate values contained in the DEIS Health
Impacts section under "Socio-Economic" impacts.
Comment 7-18: (Pg 7-2, & etc.) When discussing "annoyance" ,
the impact statement should note that the term "annoyance" is
used in scientific circles to rank people's reaction to noise
ranging from mild instrusions to physical torture and should not
be taken to mean minor or insignificant. It should also note
whether the studies only included "highly annoyed" or if they
included other measures of annoyance. Furthermore, they should
indicate if the study was done on aircraft noise specifially or
just transportation noise generally.
Comment 7-19: (DEIS pg. IV-7-2) (quote) The FAA document to
which the impact statement directs cites as proof that there is
little "reliable evidence" of a relationship between aircraft
noise and mental health is a ten year oldpamplet written by a
couple of FAA bureaucrats reviewing even older studies. It is
also out print. A great deal of evidence has been gathered
subsequent to 1985.
a.) We refer you not only our exhibit 1 the data base
search since 1991, but also to the literature review Oct
1992 done by Dennis Hansen, M.D. and Lee Sanders, M.D. Ph.D.
Page 7, who say "Studies have shown a marked increas in the
use of tranquilizer and sedatives around jet airports (3,4)
and an increase in the rate of alcolholism and its
associated medical problems (5 )Experts have said that noise
heightens aggressive behaviours and dampens helful impulses
which may in part explain an increased incidence of crim &
domestic violence in airport communities (). Man studies
have shown an increased number of psychiatric admissions
from noise-impacted neighborhoods around jet airports.
(7,8,9,11.)"
b) See Also, Kryter, K.D. "Association of Heathrow Airport
Noise with Psychiatric Admissions." Psychol Med 20:1022,
1990. and Kryter, K.D. "Aircraft Noise and Social Factors
in Psychiatric Hospital Admission Rates: A Reexamination of
Some Data" Psychol. Med May:20(2): 395-411, 1990 finding a
statistically significant correlation between mental
hospital admissions and aircraft noise exposure.
Comment 7-20: The DEIS does mention the controversial British
sleep study which heavily criticized by the research community
and has not yet been subject to formal publication in scientific
journals or peer review--as have large numbers of other studies.
The other study , done by the Air Force is not yet published and
not of any use. It should be noted that that British Sleep study
was done by the British Transport Authority in response to
pressure from airport operators wishing to expand night flights,
and the Air Force has found its training flight & other
activities the recent source of considerable complaint, so both
sources have an interest in minimizing the impacts of noise from
airports. Sleep problems are among the most frequent complaints
from excessive airport noise pollution, and the existence of this
study does not address the exisitng sleep problems or potential
impacts of nightly disturbing the sleep of hundreds of thousands
of residents. Which residents in the Sea Tac will experience
noise levels sufficient to disturb sleep. and what are the
demographics of that population and age, race, sex. (Comment 7:
Laboratory studies show fairly consistently that noise disrupts
sleep beginning at about 45 SEL and waking large numbers of
people up at about 60 SEL. 80SEL is considered to be the level
at which people can be waked up inside with the windows closed..
The EIS could at least provide this data.)
Comment 7-21: The DEIS implies that those who find their sleep
disrupted, or other health impacts are reponsible for proving it
before the impact will be discussed. On the contrary, the
burden is on the draftors of the EIS to show through studies at
Sea-Tac, in these communities, given the specific topographical,
weather, noise, and other perhaps unknown factors what the
potiential impacts on sleep disruptions and other health issues
will be and how. it will be mitigated. It is not the
responsiblity of the victims of the airport's noise pollution; it
is the responsiblity of those who are creating the noise
pollution in the first place. One poorly done sleep study at
another airport does not relieve the Port or the FAA of this
obligation under SEPA, NEPA, or other statues.
Comment 7-22: "Some studies suggest that there are clear
indicators that noise, articlarly aircraft noise has a
detrimental effect of the cardiovascular system, mortality rates,
birth defects, achievement scores, psychiatric admissions, sleep
disturbance and overall psycological well being. However,none of
these studies have gained acceptance from researchers that would
asslow the studies to be used a s basis for impact assessment.
DEIS Pg. IV-7-5 "
a) Which researchers,? Which studies? What reasearch have
the reseracher done that is not reivews of other other
reasearch. We have reference to two pamphlets and one
outdated book prepared by FAA functionaries. What research
was done at Sea-Tac , how was it subjecteed to peer review
and where is it published/
b)Are the writers of the DEIS recommending that pregnant women
remain in the airport communities above 65 Ldn? Are they
willing to take responsiblity for the consequences?
c)The the writer s of the EIS recommending that African
Americans hypertension remain the the airport communities
above 55Ldn, even though they are at much higher risk for
renal failure? Are they willing to take responsibility for
the consequences of this?
d)This paragraph appears to conclude that not enough is known
about the impacts of noise pollution on human health to
support airport expansion in the middle of an urban area.
Comment 7-23--The E.I.S. must investigate and fully disclose
all impacts of noise on children -- both to their health and
to their education --. This DEIS utterly fails to address
the needs of children. We asked specifically for this in
our scoping comment referrd to Hansen & Sanders report
titled The Adverse Health Impacts of Airport Expansion with
Particular Reference to Sea-Tac International Airport. above
which showed some evidence of birth defects, for example.
The authors of the EIS made no effort to do any studies of
the special impact on the education of children.
Comment-7-24: The FEIS should use noise measures & maps that
have been properly validated by actual measurement. These maps
at the very least should go down to the 55Ldn EPA protective
standard and 80 SEL, the best measurement of noise levels that
can create sleep disturbances. (Please see also our comments on
the inadequacy of the INM noise model.
Comment 7-25: The E.I.S. must investigate and disclose air,
water, and health impacts from emergency fuel dumps within
15 miles of the airport.
Comment 7-26: The E.I.S. should investigate and fully
disclose the health risks to adjacent communities from
benzene and determine if the ambient air quality
standard for nitrogen dioxide is being exceeded and
fails to do so.
45. The E.I.S. should investigate and fully disclose
the health risks to adjacent communities from
benzene and determine if the ambient air quality
standard for nitrogen dioxide is being exceeded.
46. The E.I.S. must utilize the mobile monitor van to
take samples at the airport and within a 10 mile radius
around Sea-Tac Airport expected to have the highest
impacts, especially for benzene (which may pose a large
risk to the nearby communities) and fully disclose the
results. This must be done prior to issuance of the
E.I.S. Promises by the Port of Seattle to do it in the
future have been given before and never adhered to and
won't be accepted by us this time around.
_______________________________
1Ibid.
2Ibid, pg 3-4.
3 Report on the Proposed Reduction in Noise Levels at the
Seattle-Tacoma Airport, Alice H. Suter, Ph.D., Oct. 1995.
(Attached as Exhibit IV: 7.2)
4Report on Aviation Noise Research Conducted by U.S. Federal
Agencies, FICON, June 1994 p B22.
5"The Dormant Noise Control Act and Options to Abate Noise
Pollution", Sidney Shapiro, Rounds Professor of Law,
University of Kansas, July 1991.
Comment IV-7-22 -- Health -- air safety. From the
DEIS, the reader would gather that air safety at Sea-Tac is
not an issue. Indeed, a reader of the DEIS would wonder how
anything could ever go wrong, here or at any other airport
under the control of the F.A.A. Yet, aviation accidents do
happen, even in the U.S.A., & when they happen, they are
sometimes catastrophic. The FEIS should candidly evaluate
the safety risks that arise from the present & projected
flight paths. We see no indication that flight paths will -
- or can -- be significantly altered to prevent large
commercial aircraft from flying at relatively low altitudes
over the two most populous cities of the western part of the
State. What is the statistical risk of large aircraft
striking such high, & heavily-peopled, structures as the
Columbia Center, Harbor View Medical Center, & the like?
Does the F.A.A. have disaster plans for such contingencies?
Comment IV-7-23 -- Health -- air safety -- additional
considerations. It appears to be a premise of the DEIS that
adding more traffic, larger aircraft, faster aircraft at Sea-
Tac, at Boeing Field, & so on has no safety implications.
We suggest that this premise is faulty, & at the least must
be articulated & justified in the FEIS. Larger aircraft
imply larger safety "boxes", as do faster ones. The FEIS
needs to discuss the consequences to the air-traffic-control
system of having aircraft -- more & more of them -- from
several different air facilities all avigating in & around
the major local airfields, three of which very nearly abut
one another. Can the BFI traffic be safely interwoven with
the Renton & Sea-Tac traffic, to say nothing of the McChord
traffic, under the more-crowded conditions of the
foreseeable future?
Comment IV-7-24 -- Health -- ground safety. (a) It
goes without saying that in terms of ground safety, we & the
lead agencies all are concerned about the possible
consequences to people on the ground -- innocent bystanders,
so to speak -- in the case of a crash. All take-off &
landing approaches are over heavily populated areas. The
DEIS leaves this question alone, but the FEIS should address
it.
(b) Another ground-safety concern is the handling of
the criss-cross ground traffic of aircraft landing &
departing. The FEIS should graphically present proposed
control methods to prevent on-ground collisions. The FEIS
needs to discuss in straightforward numerical terms what the
impacts will be on the efficiency of the third runway if
proper procedures are put in place to prevent what some have
called 'incursions'.
(c) It would be helpful for the FEIS to tell us all
how many other airports in the U.S.A. have both ends of all
their runways aimed at major cities, on hills, with lots of
tall buildings. We suspect that the Sea-Tac situation is
nearly unique -- another good reason, a safety reason, for
looking for a more suitable site for the airport that is to
meet the regional air travel needs into the
foreseeable.future.