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RCAA Comments on Sea-Tac Master Plan (SMP)
Draft Environmental Impact Statement
Chap. IV, Section 2: Land Use

Chapter IV, Section 2:  Land Use
     Comment IV-2-1 -- Land use -- noise -- correct &
incorrect premises.  The preparers of the DEIS state that
aircraft noise is generally regarded as the primary impact
of an airport on surrounding land use.  DEIS IV.2-1, col. 1.
 (a) This premise of the land-use section (2) of the impacts
chapter (IV) of the DEIS is correct.
     (b) We disagree with the incorrect premise that
society, the DEIS, the lead agencies, & governments
generally should ignore all noise impacts outside the 65 Ldn
contour.  See our comments on the noise section, supra.  As
the discussion below of land-use regulations by near-airport
cities will show, some levels of government are of opinion
that noise below the 65 Ldn level is of concern.
     (c) And, as our comments on the noise section explain,
we are not persuaded that the 65 Ldn contours presented in
this DEIS are accurate.
     (d) Nor do we agree that the the Ldn metric is the only
useful metric for measuring adverse noise impacts.
     (e) Finally, it is particularly important to remind the
reader that we strongly dissent from the view that Sea-Tac
generated noise will decline sharply in the future.  It is
as yet unclear whether all Stage 3 aircraft will be quieter
than every Stage 2 aircraft.  Citizen observers feel that
the larger Boeing 747s generate a great deal of noise close
to ground level.  The PSRC Expert Arbitration Panel that the
Ports current  noise budget & nighttime flight restrictions
program would reduce noise, but not enough so that citizen
on the ground can hear it.  (See our comments on noise,
Section 1.)  The schedule for phasing out Stage 2 aircraft
is potentially subject to stretching out & delays.  For any
minor gain from substitution of an aircraft with Stage 3
engines for one with Stage 2, there will be an offsetting
loss arising from increased air traffic at Sea-Tac (& at
Boeing Field International), there will be more noise
resulting from the Port's ardent wooing of East Asian
interests to send more heavy cargo aircraft to the Port --
aircraft that are immune from the Port's noise regulations.
Further, as we indicate in a comment on socio-economic
impacts, we are by no means persuaded that if built, the
third runway will be operated as posited in the DEIS, which
would be a most inefficient use of public money & of a
public facility.  Rather, we are persuaded that the Port may
well actually operate the runway to achieve a major capacity
increase for heavy (& noisy) aircraft, not as a subsidy to
inefficient commuter operators. as the DEIS  implies.
     Comment IV-2-2 -- Methodology.  As is obvious from our
comment IV-2-1, supra, we find the methodology of using 65
Ldn as the only method of measuring noise impact to be
unsatisfactory. We refer the reader to our noise comments
for further detail.  The preparers are to be commended,
however, for at least providing mapping of 60 Ldn contours
(though we believe the contours to be more extensive than
shown).  As we suggest in a later comment on this section,
mapping & study should extend to the 55 Ldn contour & to
other metrics.  Until the FEIS adopts more reasonable
metrics & uses more accurate devices (including legitimate
on-ground, state-of-the-art sampling) to construct noise-
contour maps, the descriptions of noise impact will not be
credible.
     Comment IV-2-3 -- Mitigation (pp. IV.2-4 - 2-6).  The
existing, snail's-pace mitigation programs are not adequate to
mitigate observable harmful impacts.  Insulation of
residential structures is fine, but no-one knows how to
insulate a yard, garden, deck, or patio.  Insulation is simply
not good enough.  It follows that insufficient mitigation
cannot be used as an excuse for ignoring impacts, though that
is the thrust of the DEIS.  The FEIS should face up to the
physical realities & recognize that insulation is not enough.
     Comment IV-2-4 -- Mitigation (p. IV.2-4).  The DEIS errs
in attributing the Port's noise-mitigation program to the mis-
named Noise Mediation Agreement.  What little the Port does
was mandated many years ago by other, more potent authorities.
The failed mediation process should not bear the blame.
     Comment IV-2-5 -- General land-use concerns.  The
discussion in section 2, Chapter IV, is necessarily bound up
with the discussion in Chapter III, the mandatory
description of affected environment.  For convenience's
sake, our comments on the landuse aspects of Chapter III
will be included here.
     Comment IV-2-6 -- Present uses -- study area (DEIS III-
1; DEIS IV.2-2).  The DEIS study area is far too small;
this is an consequence of the mistaken adoption of the 65
Ldn parameter as the sole test of impacts, & is compounded
by the acceptance of the Port's mis-calculated, self-serving
contour map.  The study area should expand to 55 Ldn, &
should also include areas under significant SEL impacts.  A
proper study area should include all areas under the North-
South approach/departure routes & all areas subject to out-
the-pipe acceleration noise, such as the portions of
Seattle, Mercer Island, the East of Lake Washington
communities like Medina, all under the "East Turn", & those
under the "West Turn" & those under the comparable turns
South of the Airport, and those under the 4-post routing.
     Comment IV-2-7 -- Compatability.  See p. III-2, col. 2.
The DEIS seems to think that is the function of local land-
use planning to "ensure the compatability of their land uses
with airport operations".  Has the airport operator no duty
to ensure that its operations are consistent with the
expressed needs of the people on the ground?  Or is it
"Airport Uber Alles"?  If everything has to be changed to
accomodate the airport, then the Port of Seattle has
abruptly become the chief land-use planning agency for the
three-county area -- all without seemingly needful
amendments to the Constitution or changes in the Revised
Code. We think that the DEIS is wrong in this particular.
     The FEIS should recognize that, since the early 1970s,
the King County & the Sea-Tac communities have endeavored to
plan land-use in a manner compatible with the Airport's
operations, while the Airport was to endeavor to be as good
a neighbor as it could.  The Plan's projections of increases
in passenger enplanements into the 1990s closely follow
actual growth.  The plan's projections of increases in
passenger enplanements into the 1990's closely follow actual
growth.  A third runway was not even hinted at.
     The County & the cities planned accordingly.   This
planning was consisten with the Airport's Master Plan & with
the 1985 Master Plan Update in which "it was determined at
the outset that now new runways at Sea-Tac would be
considered, primarily because (1) the existing runway
configurations had previously been determined to provide
adequate capacity for the planning period, (2) there already
has been an enormous investment in the existing runways, and
(3) construction of a new runway would have a large
environmental impact. Similarly, it was reconfirmed that Sea-
Tac should continue to accomodate general aviation activity
only to the extent that such activity supports its function
as the principal air carrier airport in the region.'  (1985
Master Plan Update, p. 1)
     It is the Port that now wants a radical change in long
existing understandings.  It is utterly unreasonable for the
Port & FAA to expect generations worth of compatible
planning all based on three long-term plans in which the
Port actively participated, to be overturned at the flourish
of an E.I.S. or Master Plan Update.
     Comment IV-2-8 -- Land use -- compatability.  The DEIS
reports, p. III-2, that the extent to which the City of
SeaTac's land-use regulations will apply to the Airport is
"currently the subject of an interlocal negotiations
process".  It would be more accurate to say that
negotiations, if any, have broken down, & that the City of
SeaTac is suing the Port to achieve recognition of its
governmental authority.  The FEIS should make the correc
tion, though it would be wise not to hazard a guess on the
outcome of the ligitation.
     Comment IV-2-9 -- Land use -- transit.  Much of the
DEIS discussion of existing & future land use in Chapter III
& in
Chapter IV, Section 2, turns on assumptions about the future
of rapid (rail) transit & of the Vision 2020 transportation
plan of the Puget Sound Regional Council.  See e.g., p. III-
3, III-7, IV.2-15.  The FEIS needs to take into
consideration that the voters have once again defeated the
regional leadership on the rapid-transit issue, that as
things now stand, there will NOT be rapid-rail stations in
SeaTac, & all the other elements of the plan are also not on
the cards at this time.
     Comment IV-2-10 -- Land use -- transportation plan of
PSRC. Reference is made, p. IV.2-15, to the so-called Vision
2020 Growth Strategy & Transportation Plan of the former
Puget Sound Council of Governments.  The FEIS might as well
realize that that plan, which was dead on arrival, has now
been taken off life sup+port, with the voters' defeat of the
proposed regional transit system.  The FEIS would also do
well to recognize that much of what was included in that plan
went well beyond the statutory  authority of  that agency or
its successor, the Puget Sound Regional Council (PSRC). The
FEIS might also address the question, if the Vision 2020 plan
was a comprehensive plan, not just a collection of wish
lists, then what does the defeat of its central element do to
the viability of the other elements?
     Comment IV-2-11 -- Land-use -- Vision 2020 Update.
Reference is made, DEIS IV.2-16, to a PSRC update of the
Vision 2020 plan. We are aware of no public process regarding
this update, & learned of it for the first time in this DEIS.
If there has been a DEIS on the Update, we know not of it.
We regard the update as a red herring, of no validity.  Is
this another PSCOG/PSRC docu+ment bought & paid for by the
Port?  We seriously question whether, as the DEIS hints, the
State growth management act has designated the PSRC to take
over the planning process from the counties & cities.  The
FEIS needs to clarify this matter.
     Comment IV-2-12 -- Statutes -- citation of.  In citing
statutes of the State of Washington, the FEIS should follow
the standard practice (NOT followed in the DEIS):  statutes
are cited by their codified section numbers, & the only
proper exception is those rare instances in which a very
recently passed act has not been assigned code section
numbers.  The code is cited as RCW (standing for Revised Code
of Washington) .  The section number is a three-part number,
the first group of digits representing the title number,
followed by a full stop.  The second group of numbers is the
chapter number, followed by a full stop.  The last group of
numbers is the section number (sometimes with subsection or
paragraph numbers).  It is customary to indicate in
parentheses after the RCW number the year date of the version
of the RCW to which reference is being made.  The statutes of
this State are to be found in public libraries in the
familiar green RCW binders, not in the form of individual
acts.  The average reader has no convenient access to acts as
such, only to code sections.
     Comment IV-2-13 -- Land use -- local planning
processes.  The DEIS, pp. IV.2-7 through 2.14, makes much of
the alleged failure of the planning processes in the Cities
of SeaTac, Des Moines, Normandy Park, Burien, & Tukwila to
make proper provision for the expansion of the Airport.
Most of this discussion is best characterized as self-
serving propaganda, & no doubt the indivi+dual
municipalities will deal with it all in their several com+
ments.  We believe that self-serving propaganda should be
eliminated from the text of the FEIS & from the mind-set of
the preparers & decision-makers.  The EIS process is
supposed to help to decide whether an alternative should or
should not be adopted, not to serve as a vehicle for thinly-
veiled attacks on those whose independent policies are
perceived as a threat to the project not yet through the
environmental-review process, not yet adopted by the lead
agencies (supposedly).  The FEIS should take a neutral tone,
& should evaluate the potential conflict in land use
policies in an even-handed way.
     Comment IV-2-14 -- Land use -- essential facility.  We
believe that the DEIS errs in supposing that, because the
City of
SeaTac has identified the Airport as an "essential public
facility" (p. IV.2-8, col. 1), the expansion of the airport
has thereby been determined to be essential, & subject to no
incidental or direct controls.  Nor can it be fairly said that
a unilateral determination that something is an "essential
public facility" thereby compels all other actors to
acceptance of all the much-extended possible consequences of
that designation, or of the designation itself.
     Comment IV-2-15 -- Land use --alternatives.  (a) The
discussion at DEIS IV.2-15 more properly belongs in, or
perhaps should be repeated in, the Alternatives portion of the
FEIS.  The isolated discussion here may serve to mislead
readers as to the true extent of the alternatives to Sea-Tac
expansion that should be considered.
     (b) Note also that this discussion is marred by the
assumption that the subregional rail-transit system is still a
viable proposition. The FEIS should make the appropriate
corrections.