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RCAA Comments on Sea-Tac Master Plan (SMP)
Draft Environmental Impact
Statement (DEIS)
Chapter II: Purpose & need; Alternatives to satisfying the
needs
Introduction to Comments on Chapter II. Our comments on this
Chapter are in two groups. In the first group, Comments II-A
through II-E, we include five studies of certain issues included
within the scope of the Chapter; these studies present
materials, data, findings, & analyses not included in the DEIS,
which should be addressed in the FEIS. In the second group,
Comments II-1 through II-64, are our comments on particular
points raised in the DEIS or suggested by it.
Listing of items included as Comments II-A - II-E:
Comment II-A: An Evaluation of a third runway at Sea-Tac
International Airport: Delays, airport capacities, airport life
times, & passenger volumes, RCAA White Paper Book No. 2, John
Sandelius (1992).
Comment II-B: Seattle-Tacoma International Airport third runway
project: air capacity, RCAA White Paper Book No. 1 Gerry H.
Bogan (1993)
Comment II-C: Prepared testimony on the passenger ridership
diversion potential for the railroad passenger service
alternative to the Sea-Tac Airport runway capacity expansion,
Hal B.H. Cooper (1995)
Comment II-D: Implementation of an LDA/DME Approach to Runway
16R in lieu of a third runway at Sea-Tac, Gerry H. Bogan (1995)
Comment II-E: Final Phase I Order on Demand/System Management
Issues, Puget Sound Regional Council Expert Arbitration Panel
(July 27, 1995)
Comment II-1: -- Purpose & Need --Objective
(a) The FEIS should clearly state the authority for the
statement of overall objective found at DEIS II-1. It is not
compatible, on its face, with the statements of objective found
in Chapter I.
(b) From all that appears in Chapter II of the DEIS, this
objective emanates, not from any responsible public body or
official, but from a technical report, Technical Report No. 3,
Port of Seattle, May 1994. (DEIS, II.1, n. 1.) This is a
strange way to define the work to be done in the latter stages of
environmental studies for a project estimated to cost $1500
million.
(c) The actual documents authorizing this present EIS
process and the involvement of the two co-lead agencies should be
specifically cited, & set out in full in the FEIS, so that the
authority given & objectives defined may conveniently be compared
to the work reported in the DEIS & FEIS, & so that readers can
judge how well the objectives have been met.
(d) Readers generally will not understand from either
Chapter 1 or Chapter 2 of the DEIS what the relationships are
between the Port Commissioners' resolution of 3 November 1992,
the various resolutions of the PSCOG & PSRC, any Federal
authorizations, other actions (if any) of other public bodies or
officials, & this process. Those relationships should be fully
explained in the FEIS. This is especially important given that
the careful reader of the DEIS will observe that it does NOT
comport with the directions given by the General Assembly of the
PSRC & thus does not comport with the amended Regional Airport
System Plan (RASP) of the PSRC approved by the PSRC. Or, the
FEIS must to explain how the Executive Board of the PSRC
overruled the General Assembly & arbitrarily amended the RASP to
exclude one of the necessary conditions of the prior inclusion of
the third runway in the RASP, as well as consideration of Paine
(e) If the process was actually begun in whole or part by
some ruling or order within the U.S. Department of
Transportation, that ruling or order should be set forth in full,
& the legal authority for its issuance should be provided. As
things now stand, this DEIS appears to have been prepared &
issued on the bare authority of a minor F.A.A. functionary, one
Dennis Ossenkop, & a couple of minor Port employees. This exact
issue of authority to initiate the process was raised in our
scoping comments, Part III, nos. 4, 5, 6, 7 & 8.
f.) The FEIS should explain with crystal clarity how the
F.A.A. has become involved as a co-lead agency in a project that
until now has been that of its other co-lead agency (Port of
Seattle) and the PSRC.
Comment II-2: -- Purpose & Need--Objectives. Mr Ossenkop & his
Port colleagues inform us (through quotation of the Technical
Report cited supra., that the process has the following
objectives:
Prepare a comprehensive Airport Master Plan (Update) for
the airside, terminal & landside needed at Sea-Tac to meet air
travel demand to the year 2020 & beyond.
It is further stated at DEIS II.1 that an undated resolution
of the Port of Seattle, no. 3125, (which we know, but not from
the DEIS, to have been passed on 3 November 1992) requires that
the master plan update study fulfill these additional objectives
(which we refer to hereafter as the Resolution 3125
objectives):
Design a mechanism and process to promote (land use and
community) compatibility through improved coordination,
communication & involvement [the purpose of the parentheses in
the foregoing material is not understood]
...third runway studies ...
reconsideration of a fast rail system together with
diversion of all cargo carriers [emphasis supplied]
Full exploration of the impacts of peak period pricing
Full exploration of other demand management techniques
Exploration of land acquisition and redevelopment to
compatible uses
Attenuation of airport noise through the use of barriers
Promotion of aggressive on-airport emissions reductions
[presumably referring to air pollution]
Promotion of regional transit & reduction in use of
automobiles
Improvement of the aesthetic appearance of the airport
boundary
Development of a comprehensive stormwater management plan
It would be better to quote fully, or even better, to set out in
full in facsimile in the main text (or an Appendix), the source
documents for the objectives as stated at DEIS II.1.
Comment II-3:-- Objectives; planning horizon. At various
places in the DEIS (& appendices: e.g., Appx B, p. 19), it is
asserted that the planning horizon for the Master Plan Update &
the EIS is the year 2020. _
(a) The first objective quoted in Comment II-2 shows that
the planning horizon is NOT cut off at 2020 but extends into the
indefinite future. Wherever the DEIS considers alternatives,
adverse impacts, or mitigation however, the planning horizon is
cut off as of 2020. The FEIS should determine that a truly
appropriate planning horizon extends beyond the year 2020 &
should provide the necessary detail to extend the relevant
discussion out beyond 2020 to at least the year 2050. This
especially applies to the discussion of the high-speed (TGV) rail
alternative. See Comment II-C supra. In general, we would
suggest a planning horizon in the range of 2050 to 2070._
(b) he study reproduced as our Comment II-A, the Sandelius
paper, shows that in the year 2020 Sea-Tac with the third,
dependent runway proposed in the DEIS, will no longer be able to
meet the projected travel demand posited by the planners of the
Port & PSRC. The 1993 Bogan report, our Comment II-B, reports
the same thing. Unless the co-lead agencies are now changing
radically downward their projections of travel demands in the
period 2020-2030, it is important that the FEIS reveal (i) how
the third runway & other construction advocated in the DEIS will
meet air travel demand ... beyond [2020].
(c) If, as now seems evident, demand will once again exceed
demand at or about the year 2020, on the current projections, the
FEIS should tell the reader what the plan is for meeting that
demand.
Comment II-4: Objectives; air travel study. We assume
that there is no question whether the first of the objectives
stated at DEIS II.1 permits consideration of the possibility that
travel demands to the year 2020 & beyond may be met by
modalities other than air travel. A more restrictive
interpretation would forbid fair consideration of alternatives to
the existing air-travel system. The FEIS should discuss this
question. We urge that the FEIS will be fatally flawed unless it
fully considers non-air alternatives to meeting anticipated
future air travel demand.
Comment II-5: Objectives; high-speed rail & air-cargo
diversion. One of the Resolution 3125 objectives is stated as
reconsideration of a fast rail system together with diversion of
all cargo carriers, a curious limitation. The DEIS, perhaps for
good reason, discusses fast rail without the limitation seemingly
imposed by the Resolution.
(a) The FEIS should explain why the study of a rail
alternative should be limited to consideration only in the
context of diversion of all carriers of air cargo, for cargo
diversion seems to be an alternative that merits independent
study, just as the TGV (high speed) rail alternative (which
is primarily a passenger alternative) merits independent
study.
(b). The limitation appears unreasonable. It seems more
reasonable that the FEIS should look at diversion of some air
cargo, and also at diversion of all air cargo, away from Sea-
Tac to other sites, as alternatives meriting consideration
independent of, as well as in conjunction with, the high-
speed rail alternative.
(c) The FEIS should examine all rail alterntiave, not
just high-speed.
Comments II- 6 - 15: Objectives; other objectives not
addressed. The other nine Resolution 3125 objectives each should
be separately addressed in the FEIS.
Comment II-16: Purpose & need; definition of 'region'. The
FEIS needs to adopt, & to plainly state, one & only one
definition of the term 'region'. At some places, the FEIS refers
to region as if it mean King County, or King, Pierce & Snohomish
Counties, or those three & Kitsap County. At other places, the
context suggests that the region of interest is the States of
Idaho & Washington, or other areas much larger than the three or
four counties of the Central Puget Sound sub-region. We note
that in our Scoping Comments, p. 3, fourth unnumbered bullet
point we specifically asked for a definition of 'region' in the
DEIS & for consistency in its use. We urge that the term be used
exclusively to cover the States of Washington & Oregon, plus
those parts of the State of Idaho that rely on air service at
Sea-Tac as an important transportation link (DEIS, II-1), plus
these parts of British Columbia: Vancouver Island, the Lower
Mainland, & the Okanogan. An airport designed to meet only the
needs of King County, or King & its bordering counties West of
the Cascades, is no airport for the region in the next century.
Comment II-17: Purpose & need; definition of 'Master Plan
Update'. At some places (as in the Technical Report quoted on p.
II-1, first paragraph), the Master Plan Update is referred to as
a document, & at other places as, second paragraph of Section 1,
p. II-1; p. II-19; p. III-3, second unnumbered paragraph), as a
process. It can scarcely be both. Let the FEIS settle on one
stated definition, preferably the Update as a single document;
the associated studies are best referred to individually, as
studies.
Comment II-18: Purpose & need; expectation of ever-
increasing 'airport activity'. At p. II-2, it is assumed &
stated that 'airport activity' will increase with or without
airport development.
(a) Does 'airport activity' basically mean 'operations' as
that term is used through the FEIS (landings/takeoffs)? If not,
what?
(b.) Also explain how 'airport activity' will increase
without airport development.
Comment II-19: Purpose & need; expectation of ever-
increasing 'airport activity' (p. II-2). This 'expectation,
stated at p. II-2, assumes the thing to be studied in the later
parts of the document, which is the need for the proposed
project. It must surely be evident that if the preparers of the
FEIS assume that operations will mount in number no matter what,
& if the decision-makers accept this artfully insinuated
assumption, then all the study of alternatives to runway
construction are negated before the study begins.
Comment II-20: Purpose & need; expectation of ever-
increasing 'airport activity' (p.II-2). It is assumed here,
also, that the posited increase in operations will necessarily
result in inefficiencies of operation, an assumption that
predetermines the study of various alternatives, including
alternatives of improvement in groundside management techniques.
We agree that most qualified investigators believe, & experience
shows, that large delays occur before the arithmetical capacity
of the airport is reached. See our Comment II-A (the Sandelius
paper) at p.2, for example. However, one must also take into
account the high likelihood of additional technological progress,
improvements in management of the traffic system airside, &
various groundside measures that may increase efficiency. The
FEIS must examine whether greater levels of operations provide
greater revenues that will then be available to finance useful
improvements other than more runways. Again, if the FEIS
insinuates an unproven assumption that only runway expansion can
prevent inefficiency, the FEIS is not examining alternatives
objectively, & decision-makers are being misled.
Comment II-21: Purpose & need; expectation of ever-
increasing 'airport activity' (p. II-2). The first full
paragraph at DEIS II-2 assumes that it would be wrong for the
Region (meaning the Port of Seattle) to have to compete with
other ports in Washington, as well as throughout [the U.S.A.]
and Canada for the position of a principal gateway to the
Pacific Rim. It is surprising to read that the F.A.A. is in the
business of deciding that one port should be preferred over
others. Surely, agencies of the Federal government should
refrain from such invidious exercises. Indeed, there is a
specific Constitutional prohibition against such actions: No
preference shall be given by any regulation of commerce or
revenue to the ports of one State over those of another, U.S.
Const., Art. I, 9 (in part). The FEIS should be re-cast, to
eliminate every trace of Federal preference for the co-lead
agency over any other port. This would be best accomplished by
the F.A.A. withdrawing as the co-lead agency for the FEIS.
Comment II-22: Purpose & need (p. II-2). The needs
statement is not supported by any reference to any official
document or action of any official body. Needs defined by
governing bodies & officials before the Update study began should
be stated separately from needs identified by bureaucrats, such
as Mr. Ossenkop, or unnamed consultants. As the DEIS is written,
the needs statement does not state the policy decisions of any
known person or agency, let alone anyone with authority.
Therefore, the individual needs that are discussed in the balance
of 1, Chapter 1, are essentially irrelevant, & the discussion
should not appear in the DEIS, & need no comment.
Comment II-23: Purpose & need (p. II-2). Assuming,
however, that the FEIS will (a) cite some authority for these
anonymous needs statements, & (b) that such authority will appear
in the FEIS, we comment on them individually below, Comments II-
24 through II-37.
Comment II-24: Purpose & need: Improve poor-weather
capability (p. II-2). Sea-Tac's two existing runways lie very
nearly North & South. The constraints of the site, & of
topography on site & near-by, force all conceivable Sea-Tac
runways into a North-South orientation. The result is that large
commercial (jet) aircraft must arrive & depart the airport on
flight paths that take them over many of the most populous cities
of the State: (Seattle, the state's largest city, population
516,239--every neighborhood is affected by Sea-Tac traffic):
Tacoma (3rd most populous, Tacoma: many neighborhoods are
affected); Bellevue, (4th most populous; some neighborhoods are
affected ) & many other incorporated cities & towns, including
Mercer Island, Clyde Hill, Beaux Arts, Hunts Point, Yarrow Point,
Medina, Kirkland, Renton, Federal Way (6th most populous city of
the State), Auburn, Kent, Tukwila, SeaTac, Des Moines, Burien,
Normandy Park, Ruston, Gig Harbor, & others, as well as densely
settled unincorporated areas, such as Maple Valley, Mirrormount,
& Skyway. Many of these areas did not receive Sea-Tac associated
overflights until the heavy increase in Sea-Tac operations in the
1980s led the F.A.A. to relocate flight paths in such a manner as
to blanket western King County & adjacent parts of Pierce County.
Many of these areas also receive aircraft noise, air
pollution, & fuel dumping from flights associated with other
airfields: Boeing Field International (King County Air Port),
Renton Municipal Airport, Paine Field, McChord Air Force Base,
the aviation facilities at Fort Lewis, the float plane base on
Lake Union in Seattle, float plane activities on Lake Washington,
& the airfield in Kitsap County, as well as private strips
scattered around the Central Puget Sound, together with noise &
pollution from operation of rotary-wing aircraft from all sorts
of sites.
The FEIS should more candidly recognize (1) the heavy impact
of Sea-Tac arising from the inevitable North - South orientation
of its flight tracks & (2) the central location of the facility
within the metropolitan area, concurrently recognizing that this
airport has the greatest environmental impact on activities on
the ground of any airport in the Central Puget Sound area, the
State, or the Region and the whole vast territory north of San
Francisco or West of Minneapolis.
Comment II-25: Purpose & need: Poor weather (pp. II-
2/3). Is it not an error to lump together as one category the
four different poor-weather, low-visibility conditions designated
IFR1, IFR2, IFR3, & IFR4, together with the not-good, but not-
quite poor condition designated as VFR2? See table II.1-1, p.
II.3, & associated discussion. The FEIS should indicate what
arrival capabilities are associated with each of the six
different defined weather conditions: it is well-known that an
additional runway will do nothing to increase operations capacity
under those weather conditions that lead to complete closure of
the airport. But the discussion does not seem to differentiate
between weather that restricts flights & weather that prohibits
them.
Comment II-26: Purpose & Need: Poor Weather (p. II-3). The
DEIS states ... during poor weather (IFR and VFR2), Sea-Tac is
limited to a single arrival stream. Based on the 10 year weather
analysis performed by the Master Plan Update, poor weather (with
the associated single arrival stream at Sea-Tac), occurs about 44
percent of the time. The DEIS however fails to substantiate the
basis for the results of its purported 10 year weather analysis
or provide any data or statistical analysis to substantiate this
claim. F.A.A. officials, recently questioned during the Expert
Panel hearings, were unable to provide any substantive basis for
the 10-year weather analysis. In fact, F.A.A. official Sarah
Dalton, disclosed during the recent Expert Panel hearings that
the delay calculations for the third runway in the DEIS are based
on a computer simulation model (SIMMOD) which had not correlated
the relationship between the airport's demand profile and weather
variations when calculating the delay figures published in the
DEIS. (See Transcript of Expert Arbitration Panel Hearing, May
4, p. 68, l. 14.) This observation was recently recapitulated in
a recent finding by members of the Expert Panel who wrote:
Neither the POS nor the WSDOT has offered a fully developed
analysis that shows, for example, how much of the delay at Sea-
Tac (either experienced in the past or forecast in the future) is
attributable to the coincidence of peak demand and poor
visibility, and how sensitive the resulting delays are to
relatively small changes in the level of peak operations.
(Comment II-E, p. 4, supra.)
Comment II-27: Purpose & Need: Poor Weather (p. II-3). A
recent study has also challenged the 44 per cent. bad weather
(VFR 1) figure cited in the DEIS. See Comment II-D, supra.
Implementation of an LDA/DME Approach to Runway 16R in Lieu of a
Third Runway at SeaTac Airport, G. Bogan & Associates Inc.
(1995). This study includes a detailed analysis of hour-by-hour
weather observations reported by the U.S. Weather Bureau for the
years 1993 and 1994. This study reviewed nearly 17,000 discrete
hourly weather observations taken at Sea-Tac and reported to the
U.S. Weather bureau.
Based on U.S. weather bureau records over a two-year period,
the Bogan study found the 44 per cent. bad weather figure in
the DEIS grossly overstated and The DEIS fails to provide any
substantiation justifying its 44 per cent. bad weather figure.
The DEIS 44 per cent. bad weather figure must be rejected. In
order to meet its burden of proof for that bad weather figure,
the FEIS must provide a statistically sound response, based on
certified U.S. Weather Bureau data.
Comment II-28: Purpose & need: Poor weather (p. II-3).
A reference is made to a '1991 Capacity Enhancement Study'. While
some readers may be familiar with this work, most will not be.
The study is not reproduced in any appendix to the DEIS; its
author(s) & publishers are not named. It is very bad practice to
rely on documents & studies that are not properly identified in
an EIS. See our Scoping Comment, second bullet point, p.3. This
error might have been corrected had the preparers provided an
Authorities section.
Comment II-29: Purpose & need: Delay (p. II-3). The DEIS
explanation of Exhibit II.1-1 should be made clearer. The Exhibit
bears the caption 'Hourly Arrival Distribution' but the text, p.
II-3, col. 1, seems to suggest that it shows 'operating delay'.
The Exhibit shows something, not delay, but what it shows is
unclear.
Comment II-30: Purpose & need: Delay; definitional problems
(p. II-3). In discussing the '1991 Capacity Enhancement Study',
the DEIS rather confusingly defines 'delay': delay ... is not
related to flight schedule delay. Yet we read later, p. II-5,
that a certain 'average delay level' was determined desirable to
minimize ... passenger inconveniences. Surely in that
discussion, delay refers to flight schedule delay, not 'aircraft
operating delay'; surely it is no inconvenience for the
passenger to have his or her aircraft operate for a longer period
of time than expected, so long as he or she arrives as expected.
The term is used so confusingly in Ch. 4, that readers cannot be
sure what sort of 'delay' is being referred to at any particular
point; the result is that no rational justification for the
project is provided.
Given that this whole project supposedly is advanced to
reduce 'delay', it would be desirable for the FEIS to provide a
comprehensible definition of 'delay' & stick with it throughout.
We warned in our scoping comments, Part IIA, first bullet point,
sub-item 7, that the DEIS & FEIS should provide complete
definition & consistency of all terms of art.
If 'delay' is used at any point in the DEIS or FEIS to refer
to expectations of travelers & cargo shippers, the FEIS should
clearly point out such usage. If any part of the rationale for a
third runway in the DEIS depends on conclusions as to delay, as
perceived by travelers & cargo shippers, that discussion needs to
be much more explicit in the FEIS, & the reasonableness of such
perceptions needs further discussion.
This concern about the definition of delay was recently re-
echoed in the July 27, 1995 ruling issued by the Puget sound
Regional Council Expert Panel, who also questioned the purported
delays described in the DEIS. In their procedural order the
Panel wrote: We have not found in the evidence presented to us
a succinct, well-documented statement of the delay and capacity
problems that have led the POS to seek approval of the third
runway. (See Comment II-E, supra , p. 4.)
Comment II-31: Purpose & need: Recent reductions in
delay (p. II-3). It is said, in numbered subparagraph 5, that
(since 1989), [t]he aircraft fleet is more homogenous, meaning
that there are fewer larger and smaller aircraft using the
Airport. The common understanding is that more & more larger
aircraft are using the aircraft. If larger aircraft indeed are
being phased out (which types?), what impact will that have on
the average numbers of passengers per flight? Should we look
forward to a Sea-Tac with few or no Boeing 747s? What are the
implications for landside services? The FEIS should reconcile
the above-quoted statement that fewer larger planes are using Sea-
Tac with the statement at DEIS I-9, col. 2, that there is an
increased use of larger aircraft at the facility.
Comment II-32: Purpose & need: Delay: costs of (p. II-
4). In col. 2, second unnumbered paragraph, the DEIS presents a
figure for present costs of delay at Sea-Tac to airlines & a
figure for a higher volume of traffic. What is the source of
these numbers? Sources should always be provided.
Comment II-33: Purpose & need: Delay; acceptable level
(p. II-5). What is the source for the statement as to the
maximum tolerable level of total all-weather delay? Sources
should always be provided for such assertions.
Comment II-34: Purpose & need: Delay; measurement (p.
II-5). We question the use of the 10-minute average all-weather
delay measurement (calculation) as the criterion for determining
an unacceptable amount of delay. It is the premise of this
exercise that poor-weather delays are the whole problem? If that
be so, then the analysis should focus on -- poor-weather delays.
Such delays should be measured or calculated directly, not
inferred from some other measurement. The FEIS should make the
necessary corrections.
Comment II-35: Purpose & need: Delay (pp. II-4 - II-6).
(a) The DEIS proceeds on the assumption that commercial
airlines will increase their number of flights into & out of Sea-
Tac ('operations') without regard to operating efficiency. The
FEIS should explain the reasoning behind this assumption, or,
more realistically, abandon it.
(b) If the commercial air carriers decide, as the DEIS
assumes, to continue to add flights -- unnecessary flights, as we
show in Comment II-36, infra -- & if major increases in delay do
occur, then the air carriers, travelers, & cargo shippers can
decide how bad the added delays truly are; if the operating
costs are too high for the air carriers, they can & will make
rational economic decisions in accommodation of their own self-
interest. They can & will cut back their schedules, just as they
already do from time to time in many major air travel markets.
They can & will re-adjust schedules so as to make better use of
non-peak hours. They may find themselves able to use other, near-
by airports for cargo operations. The FEIS should address the
question of whether market forces will lead to modification of
the behavior of airport users.
(NOTE: The DEIS refers to corporations using planes with a
capacity of 60 seats & more as air carriers, & those using planes
with capacity less than 60 seats as commuter operations. See,
e.g., p. I-9, col. 2. For ease of reference, we do not observe
that distinction, instead using the term 'air carrier' to include
all firms flying passenger or cargo aircraft into the Airport as
common carriers.)
Comment II-36: Purpose & need: Delay (pp. II-4 - II-6).
The DEIS errs in assuming that 90,000 more flights will come to
Sea-Tac by 2020 (DEIS I-9, col. 2) as a result of population
growth: the assumption is speculative at best. We comment
elsewhere (Comment I-7) about the problematic character of the
DEIS' population predictions. But even if the CPS area receives
the projected huge increases in people, comparable increases in
flights do not automatically follow. Master Plan projected
boarding increases by 2020 could be accommodated through a
combination of higher load factors, a modest increase in flights
using the existing two-runway configuration, high-speed rail
travel, technical advances, etc. as previously mentioned.
Currently, load factors for all domestic flight
operations at Sea-Tac are 57 per cent. for the larger (more than
60 seat) planes and 44.5 per cent. for the smaller (less than 60
seat) planes, according to the most-recent year-available 1993
figures in the Port of Seattle's Master Plan Update. The Master
Plan Update assumes that in the year 2020, the larger planes will
be only 60 per cent. full on average, & the smaller planes, 55
per cent. full. Thus, load factors on the larger class are
projected to increase 4 per cent. over 27 years, & for the
smaller, 10 per cent.
The Port's Year 2020 forecast of 19.1 million enplaning
passengers (Table I-3, p. I-10) could be met, without a third
runway, with a small increase of 20,000 more flights per annum,
each with the Port's official average seating capacity of 204
passengers per plane. None of the added flights need be the
smaller air taxi & commuter planes, because their 2020 load
factor is projected by the Update to be a still-weak 55 per
cent., so great increases in passengers on those flights could
easily occur with no schedule additions whatsoever.
These additional 4.08 million departing seats (from 20,000
additional flights with an average per flight seating capacity of
204), added to the existing 1993 departing seats of 15.9 million,
provides a total of 20.7 million departing seats, or nearly twice
as many as Sea-Tac recorded in 1994 (10.4 million). Any increase
in average load factor would result in higher totals of departing
seats or lesser numbers of required flights or some combination
of both. As our Comment II-35, supra, suggests, normal market
forces would, in the present two-runway solution along the lines
just suggested, rather than to the artificial 90,000-plus
additional flights projected by the DEIS.
Comment II-37: Purpose & need; improving poor-weather
capabilities; a larger perspective. As the DEIS partially
recognizes, p. II-1, p. II-4, Sea-Tac is part of a network or
system of airports, which extends not just throughout the U.S.A.
but world-wide. It is sometimes argued that poor-weather delays
at Sea-Tac have far-reaching adverse impacts on operations
elsewhere. See National Plan of Integrated Airport Systems
(NPIAS) 1990-1999, F.A.A. (March 1991), cited at n. 3, DEIS II-1,
inter alia. The system is supposed to be so stressed, so tightly
geared-up, so lacking in tolerance, slack, that any delay
anywhere has a cascading effect. It is asserted, and we have no
reason to disagree, that this situation will worsen as traffic
increases. DEIS II-1.
The DEIS gives us this warning, threatens us with enormous
costs to already troubled air carriers using Sea-Tac ($176
million per annum in the year 2020, DEIS, II-4), but fails to
carry the argument further. This problem of system slow-down or
gridlock is NOT a problem peculiar to Sea-Tac. It is an inherent
difficulty of the deregulated network in a time of increasing
numbers of flight operations.
(a) What the DEIS does not tell the reader, but what the
FEIS should, is the fiscal consequence of continuing with a
program of ever-increasing public expenditures that provide what
economists would call a 'free good' to the air operators
(especially the commuter airlines). At Sea-Tac, $1500 million,
this time. How much at the many other airports in the U.S.A.,
where similar expansion projects are pending, where DEIS's like
this one are being prepared? Is the Sea-Tac projected expense
typical? Should one assume that the 30 busiest airports in the
U.S.A. will each need another $1500 million in the next decade?
The FEIS must disclose the total fiscal consequences of
acceptance of the F.A.A.'s 'build it, so that they will come'
philosophy, listing the airports needing similar improvements,
current cost estimates for those improvements, likely completion
dates thereof, &c.; This EIS process is a part of the larger
process of re-vamping the entire system of major airports in the
U.S.A. The law requires, & good practice suggests, that the full
picture be disclosed each step of the way.
If this area accepts the idea that there is a duty to expand
Sea-Tac to reduce system delay, then the next area in line will
be told that they too have a duty to accept expansion of their
major airport (to match the improvements made at Sea-Tac), & so
on, for surely reduction of delay at this one airport cannot cure
the system-wide problems that the F.A.A. predicts.
(b) What happens when all these expansions are completed?
Will commercial air travel & air cargo operations level off? How
long till the Port of Seattle & its competitor/colleagues around
the world, together with the F.A.A. or equivalent civil aviation
authorities abroad, are back, drumming up support for a fourth
(or whatever number) runway, further site expansion, more
terminals, more ground connections?
The communities were assured that the second runway was all
that would be required, & grudgingly gave their assent to that
expansion on that basis.
RCAA has discovered, & reported, the Port's plans for a
fourth runway, plans that have been disavowed as a typographical
error in the 1993 Aviation System Capacity Plan. (F.A.A. Report
no. DOT/FAA/ASC-93-1, Appendix D, p. 58.) The FEIS needs to tell
the people when this process of expansion will end, how much the
public of the U.S.A. is expected to pay, & how, if at all, the
F.A.A. & the airport operators will CAP this runaway (runway)
program.
Comment II-38: Purpose & need: Is it capacity, is it
delay, or what? Flight Plan proposed the third runway in order
to reduce delays in the future due to a shortage of air capacity.
However, it turns out that because of its dependent operation the
third runway is a low-capacity runway with only 100,000
operations at best per annum and for practical purposes it is a
no-new-capacity runway when measures to prevent incursions of
aircraft using the third runway onto the existing two runways and
increased separations & staggering of so-called side-by-side
flight patterns are instituted for safety reasons. See our
Comment II-B, the 1993 Bogan report, pp. 4-5. Then the Port's
argument shifted to saying that the third runway was needed to
reduce delays during peak-period bad weather. DEIS, II-2 - 6,
DEIS, II-17. However, when other less-expensive, less-
environmentally destructive measures such as LDA are suggested to
deal with the weather problem, these are rejected for not solving
the delay problems, forgetting that the third runway itself does
not solve that problem.
Comment II-39: Purpose & need; measuring delay. It is
entirely unclear from Chapter II of the DEIS which techniques
were used to measure or to assess delay at Sea-Tac in the various
studies mentioned. We are aware of three different techniques,
known as ATOMS, ASQP, & SIMMOD, & that they yield very different
results as to delay. But the details of each are unclear to us,
& the average lay reader of the DEIS would not have a clue that
there are competing measurement or assessment methods, or that
different studies have produced different results. What is
measured? Who does the measuring? Are various causal factors
considered? reported? Who decides whether a delay is caused by
weather, by aircrew problems, by groundside problems? What
happens if one delay has multiple causes? What happens if no-one
is sure what the cause was? At a minimum, the FEIS should pull
up from the studies on which the lead agencies rely sufficient
detail to enable the intelligent lay reader to know what was
done, why, & how, to measure delay, & to understand what the
controversy is about the results reported in the DEIS, & why the
DEIS & FEIS accept a particular set of figures.
Comment II-40: Purpose & need; measuring delay. The
reader gathers from DEIS, II-5, that simulation analysis was
used to derive critical delay figures and that simulation
analysis means the employment of a mathematical model on some
data (what?) to predict, on the basis of assumptions (what?),
present & future delay. In the absence of any description of the
methods employed, a rational reader is left to take the results
on pure faith, which is not a satisfactory method of choosing
alternatives. The FEIS should much more fully disclose the
interplay between actual, observed delay (after disclosure of the
measurement techniques, see our Comment II-39, supra) &
mathematical models (describing them & their assumptions), so
that readers can follow the reasoning & calculations processes, &
in some instances no doubt, compare the reported results with
their own.
This problem of the use of undescribed mathematical models
that manipulate unreported data on the basis of unstated
assumptions is replete throughout this DEIS. An accompanying
problem is the technique of referring to unreproduced & obscure
reports (sometimes uncited) as the source of the results of these
mathematical processes. We suggest that this technique does not
comport with the requirements of the EIS process. The problem is
exacerbated when this obscurity involves the central rationale
for the entire $1500 million project. The reader, the decision
maker, is left with no independent basis for decision making, &
the interested outsider, no basis for intelligent comment. Why
bother with an EIS at all?
Comment II-41: Extension of easterly runway. Quite apart
from the original charge to study a third runway, the DEIS
proposes an extension of the more easterly of the two existing
runways (Runway 16L/34R), to accommodate larger aircraft flying
to East Asia. This extension consists of two elements. The
first is lengthening the actual runway by 600 feet, to 12,500
feet. DEIS II-6. The second element is the expansion of the
associated runway safety area (RSA). DEIS II-7. It appears to be
proposed to clear & grade an area 500 feet wide by 1600 feet long
at the South end of the easterly runway. DEIS II-26.
It would be helpful if the FEIS would give a much clearer
description of the preferred alternative for extension of the
easterly runway & associated RSA, including maps, to scale,
showing North, & showing the construction area(s) as is & as
proposed. Until there is a comprehensible description of the
proposed projects, it is difficult to comment on the possible
impacts. If the maps denominated Ex. II.3-3 and 3-4 are the ones
intended to show the proposal, then the text should make an
intelligible reference to them for the sake of the busy reader.
Comment II-42: Extension of easterly runway. This project
-- the actual extension of pavement & the other, lesser RSA
improvements -- will require, according to DEIS IV.19-7 & III
DEIS Appx J, p. 4, a total of 3,380,000 cubic yards of fill. We
mention these figures to give an idea of the scale of the
project: it will require almost a fifth of the fill required for
the entire brand-new third runway. The extension itself, then,
is a major undertaking. Yet, in terms of construction
difficulties & costs, it would certainly be a lot easier to meet
the projected need at a 'green grass' site on flat terrain. The
FEIS should consider that alternative, particularly in light of
the requirement to consider diversion of all-cargo carriers. Also
the FEIS should consider the noise & pollution impacts from
unregulated foreign aircraft operating all-cargo and nighttime
flights from places where noise & pollution controls are of no
consequence, like the Port's hoped-for big new freight markets:
China & Russia.
Comment II-43: Extension of easterly runway. Is the
proposed extension enough to meet needs to the year 2020 &
beyond? The DEIS only mentions one aircraft type as requiring
the extension to operate at maximum load. The FEIS should tell
the reader about other large aircraft, including those not yet
operational but in advanced planning stages. Perhaps an even
greater extension is really needed, making the need to look at
'green-grass' sites all the greater.
The next group of comments relates to the discussion of
alternatives in the DEIS:
Comment II-44: Reconsideration of a fast rail system --
rail generally.
(a) The present study was mandated by the Port of
Seattle to reconsider the alternative of a fast rail system. DEIS
II-1. This study does not reconsider fast rail. What it does is
report on discussions between someone (one or more anonymous
contributors to the DEIS, most likely) & unidentified personnel
in the Department of Transportation (WSDOT). DEIS II-10. The use
of undocumented conversations between unnamed persons as the
source for EIS conclusions is not satisfactory.
In an Appendix (B III), there is a perfunctory discussion of
WSDOT reports that predate the POS mandate here discussed &
discussion (without citations of authority) of two rail programs
now in operation in the State, neither of which is a fast rail
system, as we understand the term. In truth, the FEIS defies the
mandate of the Port on this matter. There is no reconsideration,
just a re-hash of what was not satisfactory the first time
around.
(b) A full reconsideration would at the very least discuss
existing fast rail systems. If one accepted the DEIS as a
complete source of information on this subject, one would have to
conclude that there are no such systems, except the Talgo 2000,
with a top speed of 125 m.p.h. As most informed people know, &
as our comment II-C (the Cooper report), ] supra details, there
is a high-speed passenger train running on conventional trackage
in Japan, the 'bullet train', and a more extensive system of high-
speed passenger service operating routinely in France, the 'Tres
Grande Vitesse' (very great speed, or TGV) trains. In addition,
there are high-speed lines in Germany of a conventional
character, & a German firm is successfully operating in western
Germany a very high speed magnetic-levitation demonstration
system (which runs on its own elevated, grade-separated,
trackage). These are four operational very-high-speed rail
systems, totally ignored by the DEIS. We also note the entire
absence of any information relating to the activities of the
States of Florida and Texas in this regard, which at least should
be mentioned & really should be explained in depth. We are aware
Floride is spending $50 million per year on high speed rail.
(See, Exhibit 2-3 , Railway Age. September 1994.)
(c) The abbreviated discussion in the DEIS (p. II-10) seems
to hint at grave technical difficulties in operating higher-speed
trains. (i) These difficulties cannot be severe, when one
considers that conventional coal-powered steam locomotives
achieved speeds in excess of 100 m.p.h. on then-conventional
trackage a century ago. (ii) Nor can they be severe when one
considers that the French, Japanese, & Germans are all operating
such systems routinely, as important contributors to their
regional transportation needs, & that Amtrak is operating
moderately fast trains in other transportation corridors in the
U.S. (see discussion in the Cooper report, our Comment II-C,
especially at p. 28, for U.S. experience) The FEIS should spell
out the supposed technical difficulties & indicate why they
cannot be dealt with satisfactorily in light of the actual
experience of operators of such system elsewhere.
(d) A full reconsideration would at the very least be based
on information from successful operators of high-speed rail
systems, not from an agency that is devoted to highway
construction & which has exactly no, zero, experienced in
designing, purchasing, or operating TGV rail (WSDOT). One
observer has suggested that the authors of this part of the DEIS
should have started with a telephone call to the commercial
attache in the French Embassy. It is not too late to make the
call. The FEIS needs to include relevant information from
successful operators elsewhere.
(e) The full reconsideration should not be limited by the
erroneous notion that the year 2020 is the 'planning horizon' for
this study. See our Comment II-3 (a) supra
(f) In a full reconsideration, attention should be directed
to a more expeditious timetable than is presently contemplated.
It seems absurd that a high-speed link from the CPS to Portland
cannot be built in less than 25 years. Our Comment II-C provides
summary information on planning & construction times for existing
high-speed systems, built much more expeditiously than 25 years
(pp. 34-5). Many, many examples of major engineering projects
could be cited, which though of comparable scope were constructed
far more swiftly, often with no prior experience, or in
unsurveyed territory, or under extreme conditions. One finds it
very hard to believe that a TGV system cannot be emplaced in a
time frame more like six to 10 years; the rights-of-way exist,
after all, as do several proven, commercially-available
technologies.
(g) The DEIS discussion of TGV rail is marred by its
failure to consider the past, present & probable future mix of
operations at Sea-Tac in the absence of demand management. As
has been noted in prior comments, 40% (+2%) of operations are
devoted to but 7% of passengers, the commuters. Diversion of one-
seventh of these passengers to rail would free up nearly 6% of
operations capacity.
(h) It is important to recognize that in good weather or bad
the airport does not & cannot operate without delays at the
nominal top capacity. The DEIS reports, & all investigators
agree, that as the number of operations approaches the nominal
capacity, more & more delay is experienced, the delay time
increasing exponentially. See our Comment II-A, the Sandelius
study, for a summary explanation of causes of such delay. (This
is not a phenomenon restricted to this airport or to airports
generally; rather, it is a characteristic of systems involving
numerous movements of numerous things in constrained patterns.
It is true of motor-vehicle traffic on grid-pattern streets & on
freeways. It is true of movement of air under many circumstances
and of movement of liquids through tubes & orifices (where the
delay is called turbulence). It is true of many manufacturing
processes, such as printing, assembly-line operations, in-line
chemical processes.)
Therefore, any reduction in the number of operations confers
a disproportionate savings in delay when the airport is operating
at the edge, at the point where a slight increase in operations
results in much-increased delay. Moving several hundred people a
day by rail instead of by commuter aircraft may not do much to
reduce delay at traffic levels of 1990 or 1995 but it becomes an
enormous relief, far out of proportion to the numbers involved,
at projected future levels of operations, when delay begins to
rise very rapidly.
In fair weather, at this airport as now configured & with the
present mix of traffic, it appears that delay begins to rise very
sharply when operations approach 80 per cent. of nominal
capacity, & at about 50-60 per cent. during poor weather. The
FEIS needs to discuss this matter in full detail, & to keep the
idea in mind when considering various alternatives that seem to
reduce travel at the airport only slightly.
(i) The FEIS should investigate all rail options. In
addition to the high-speed and very high speed alternatives
mentioned above, the FEIS should investigate less costly rail
options that might come into operation sooner than other options.
The FEIS should take into account the conclusion of the Expert
Arbitration Panel, 27 July, 1995, with respect to the
possibilities of diversion of air passengers to rail, even rail
operating less than high speed velocities. At the very least,
the FEIS should consider issues which the Expert panel is also
studying.
At the request of the Expert Panel, WSDOT provided its views
as to the ability of improved rial service to alleviate the need
for Sea-Tac runway capacity expansion. That response closely
parallels the capacity given by the WSDOT to the E.I.S. preparers
on the same topic. The WSDOT reponses are deficient. WSDOT
greatly underestimates the market-penetration potential of
impvoved rail service to capture (divert) passenger trips
otherwise taken by rail. WSDOT failed , among other things, to
consider the effect of highway congestion on demand for rail.
The DEIS is far too pessimistic about the possibilities of
rail. The FEIS should take a more realistic view. Rail works to
direct passengers in Japan, Britain, France, Germany, the N.Y. to
Washington & Boston to NY corridors of the U.S. Why not here?
Comment II-45: Air cargo diversion. The third Resolution
3125 objective (DEIS II.1) is stated as reconsideration of a
fast rail system together with diversion of all cargo carriers
[emphasis supplied]. The DEIS treats fast rail as a separate
subject, as it should. Table II.2-1 (at pp. II.-9A & B) is
silent on the subject of cargo diversion. Chapter 2 devotes one
paragraph to the topic (p. II-17), & that considers only the
question of developing a cargo-only airport, rather than the
question of diversion of all-cargo operations away from Sea-Tac.
Nothing in Resolution 3125 speaks of an all-cargo airport, &
obviously cargo can be received at a mixed-use airport, so the
DEIS misses the point.
The single, unresponsive DEIS paragraph needs considerable
expansion in the FEIS. The DEIS reports that nearly half the
cargo now arriving at Sea-Tac comes in passenger craft, while all-
cargo flights constitute 6 per cent. of total operations. The
DEIS is silent on the anticipated future mix, though it projects
an increase of 131 per cent. in cargo tonnage as of 2020. It is
well known that the Port has a long-term program to encourage
much more cargo business, primarily from East Asia (& on aircraft
not subject to any Federal or local noise or pollution controls).
An increase in the percentage of cargo operations may be likely.
The FEIS needs to project the cargo mix at representative dates
from the present to & past 2020. The FEIS needs to present a
complete analysis of the consequences of diverting all-cargo
flights elsewhere, airport by airport. Here, as elsewhere in the
FEIS, the airports to be considered should include the two major
candidates for development as 'green grass' facilities, i.e., the
existing & operational Grant County International Airport & the
proposed site in the Toledo-Winlock area (Napavine Prairie), in
Lewis County. The FEIS should explain the reasoning behind the
DEIS statement that if air cargo does not all come to Sea-Tac,
some cargo would be required to arrive in the Region and be
transported to Sea-Tac (p. II-17, col. 2): one would have
thought that cargo once on the ground would then go by the usual
ground-transportation systems to its many local destinations.
The FEIS should abandon the idea that one of the purposes of this
planning is to give the Port of Seattle an advantage over its
competitors. See our Comment II-21, supra.
The gain to be realized from diversion of all-cargo operations
must be considered together with gains realizable from other
measures. The DEIS makes the methodological error of treating
each measure separately, finding that no one by itself does
enough to relieve the strain on the airport, & then dismisses all
the measures as inadequate without considering the potential
cumulative benefits.
Comment II-46: Improved telecommunications. This subject
is addressed at DEIS II-11 & -12. The DEIS dismisses any benefit
of the potential incremental reduction in Sea-Tac operations of 4
- 9 per cent. from increased use of telecommunications. Here we
have another example of the deep-seated resistance on the part of
the project sponsors to considering the incremental beneficial
effects on the Sea-Tac problem from a combination of possible
factors. The FEIS should overcome this bias & present as a full
alternative the results of reductions in operations that might
reasonably be expected to follow from high-speed rail, improved
telecommunications, peak-period pricing & other demand-management
techniques especially aimed at commuter operations, cargo
diversions, & other no-build remedies.
Comment II-47: Use of other airports. See DEIS II-12. The
discussion here essentially overrules the prior planning decision
to locate or develop a supplemental airport. Flight Plan Study;
PSRC General Assembly Resolution A-93-03. Apparently the Port &
the F.A.A. have concluded that the Port & PSRC were wrong in
their analysis of the Sea-Tac problem in Flight Plan: a
supplemental airport would not satisfy the needs addressed by
this Environmental Impact Statement (p. II-12, col. 2). What a
colossal waste of time & money Flight Plan was, then! Perhaps
the FEIS for Flight Plan is also wrong? Perhaps we need to go
back & re-do the RASP in light of these new conclusions, which
hold that the existing RASP is incorrect.
Comment II-48: Use of other airports. We note that the two
identified potential 'green grass' sites for additional airport
capacity, Moses Lake & Napavine Prairie, are once again
systematically excluded from serious study. The studies to date
of existing airports & potential airport sites in the Central
Puget Sound sub-region have amply demonstrated that each & every
one of them, including Sea-Tac, is unsuited for expansion: the
solution for the regional air-travel problem, as distinguished
from the desires of the Port of Seattle to dominate air travel,
plainly do not lie in the CPS sub-region. Other, more suitable
sites must be studied. The FEIS would be a good place to begin.
If the preparers of this present DEIS can
ignore the adopted Flight Plan with respect to a CPS supplemental
airport, then they can surely likewise ignore the restrictions
against looking at reasonable alternatives for new airport space.
Comment II-49: Peak period pricing. The present study was
mandated by the Port of Seattle, Resolution 3125, to examine the
alternative of peak period pricing. DEIS II-1. We find no
examination of this alternative & it is not referred to in Table
II.2-1, pp. II-9A & B, the summary of alternatives considered.
(If one considers pricing to be a form of demand management, as
indeed it is, then it has been dismissed together with all other
forms of demand management, in the cited table, by this
assertion: Not considered further, as these actions will not
eliminate the poor weather operating need. A short paragraph,
p. II-17, asserts, without reference to authorities, that airport
operators in the past have not been successful in changing the
operating behavior of major airlines through pricing policies,
seemingly because operating fees are, on average, only 3 to 6 per
cent. of operating costs. Even a single percentage point would
seem to this commenter to be, under some circumstances, the
difference between solvency & bankruptcy. The subject is worth
more intense examination in the FEIS.
Comment II-50: Peak period pricing. The DEIS worries that
effective peak-period pricing would be highly questionable (in
the legal sense. Our comments II-51(c) & (d) ]]]BU infra ]]] EU
addresses this concern in the over-all context of demand
management, & is equally applicable to this particular aspect of
demand management.
Comment II-51: Demand management, generally. The present
study was mandated by the Port of Seattle to examine the
alternative of demand management techniques beyond peak period
pricing. DEIS II-1.
(a) The discussion of this point is found at DEIS II-16/17.
It is entirely unsatisfactory & should be replaced in the FEIS
with a more thoughtful, & more thorough, analysis.
(b) The discussion of commuter operations may serve as an
example: The DEIS reports what is well known, that the commuter
traffic, 7% of passengers, takes up 40% (+2%) ]]] plus / minus
symbol needed here ]]] passenger operations. It is also well
known that commuter operations run with very great frequency to &
from the two major target cities (Spokane & Portland) & are under-
utilized, at a load factor of about 45% on average over-all. See
Comment II-36, supra, 2nd unnumbered paragraph. See also the
Cooper study, our Comment II-C, supra. A more careful
examination of demand management would report on the load factors
specifically for each of the two major target cities, & any other
important destinations that careful study would reveal. (We
assume that the flights to Portland & Spokane fly with load
factors considerably less than 45%.) Obviously, half-empty
flights every half hour to Portland & every hour to Spokane in
poor weather are a luxury when the airport is suffering from a
lack of capacity for larger aircraft carrying more passengers.
The FEIS should report how much money it will cost per commuter
passenger flight when the cost of money is taken into account.
It should not encourage a mis-use of what we are told is a scarce
resource.
(c) The DEIS seems to suggest, p. II-16, col. 2, that
administrative measures, perhaps including selective pricing, to
discourage over-use of 'slots' by commuter operations would
violate a principle that access be permitted to the Airport on
fair & reasonable terms, without unjust discrimination. Would
it truly be unfair, unreasonable, unjust to favor in some way or
another those operations that directly serve the greater number
of travelers? If so, then an obvious alternative that should
have been examined is a minor change in the applicable Federal
statute or regulation to permit a more rational allocation of the
resource among users.
(d) It is unsatisfactory for the principal Federal agency
regulating aviation to suggest that some types of demand
management (without identifying them) might violate the principle
just mentioned in part (c) of this Comment. Surely by now the
Federal co-lead agency has sufficient expertise in its own
regulatory area to know what will pass statutory & regulatory
muster? The FEIS should spell out what is acceptable, what is
not. If, as we do not believe, there still are 'grey' areas in
what is or is not permitted in the way of demand management, then
the FEIS should spell out those too.
Comment II-52: Demand management, generally. The do-
nothing alternative as to third-runway construction itself is a
form of demand management, as our Comments II-35 & 36 make clear,
& it should have been so considered in the DEIS. The FEIS should
take a harder look at 'do-nothing' as an effective way of letting
market forces do the managing that
the DEIS fears cannot be done directly (p. II-16, p. II-17).
Comment II-53: Demand management, generally. It appears to
be the premise of the DEIS that Sea-Tac is at present generally
adequate to meet air travel demand to the year 2020 & beyond,
except for the poor-weather constraints discussed at DEIS II-1 to
-6. See the comment in Table II.2-1, & see our Comment II-34,
supra. Is this a correct understanding of the position of the
preparers? If so, just how much of a diversion or limitation of
poor-weather operations would be required to prevent Sea-Tac from
being unable to meet the projected demands?
Comment II-54: Demand management, generally. The DEIS
dismisses demand management as not being a substitute for
increasing capacity, relying on the document, The Flight Plan
Project, Draft Final Report and Technical Appendices, PSRC & POS
(January 1992). DEIS II-17. Yet the Port of Seattle resolution
previously referred to (no. 3125, cited at DEIS II-1) mandated
that this present study fully explore demand management. It is
evident that the Port Commissioners were not satisfied with the
discussion in the January 1992 document, & the DEIS should not
have relied on it as the ground for dismissing this alternative.
The FEIS should examine the matter as mandated: fully.
Comment II-55: Demand management, generally. The DEIS sums
up its objections to all forms of demand management in Table II.2-
1, first page (DEIS, II-9A), as follows: Not considered
further, as these actions will not eliminate the poor weather
operating need. This conclusion rests on conclusions reached in
The Flight Plan Project, Draft Final Report and Technical
Appendices, PSRC & POS (January 1992), according to text &
footnote at p. II-17.
(a) This is another instance where the DEIS preparers
have blatantly ignored the Port's request, in a later action
(Resolution 3215), for re-examination of the prior third
+runway work. It is unsound, & unresponsive, to quote prior
materials as a substitute for a re-examination of the
subject dealt with in those prior materials. The public
still needs that re-examina+tion.
(b) We further suggest that the ultimate conclusion on
this point is wrong in two separate ways: (1) Any
diminution in the number of operations at SeaTac reduces the
possibility that the airport will reach what we have
referred to as edge conditions, that point when the large
number of operations results in suddenly-greater delays. See
our Comment II-A, supra , esp. p.2, & our Comment II-44(h),
supra. This applies both to good & bad weather, but the
projected need is for relief at lower levels of operations:
bad weather. ANY reduction in operations is particularly
important for relieving the very conditions that are said to
drive this FEIS. A combination of diverse measures that
reduce operations may put off into the far future that
feared time of very great delays: this DEIS certainly does
not show the contrary (in part because the DEIS scrupulously
avoids consideration of cumu+lative benefits of various
measures). It is worth noting in this regard that the Port
& the F.A.A. have been sedulous in taking many small-scale
measures to keep growth in numbers of operations from
causing 'unacceptable' delay: see listing, e.g., at DEIS II-
3, col. 2.
(2) It would appear from this DEIS that the bad-weather
delays will be right back with us at about the year 2020, if
the projections of levels of future operations hold true.
See Exhibits II.1-1 & -2, p. II-3A. Compare Fig. 3, p. 4,
our Comment II-A, which reaches a similar conclusion on the
basis of figures from the Draft Final Report, Puget Sound
Air Transportation Committee (1992).
Comment II-56: Demand management, generally; another
viewpoint. It is suggested that the FEIS consider demand
management as a form of conservation, as wiser use of scarce &
expensive resources. Our society has gradually come to
appreciate that in many instances it is less costly to conserve
than to build anew. This has long been apparent with respect to
domestic & industrial water (hence, in part, sewage-treatment
plants), & has recently become evident in the areas of electric
power generation, paper manufacture, metals extraction &
refining, & others. If one thinks of demand management as a way
of getting greater use, greater value, from the existing runways
& support facilities, demand management becomes a good thing,
standing by itself.
Comment II-57: Technology alternatives: LDA (p. II-
21). It is stated at DEIS II-21 that about 70 per cent of
arriving flights (South flow) align their approach over the
Duwamish corridor. The suggestion is that flights are so
directed, for noise avoidance purposes. The DEIS states, p. II-
21, col. 1, that were the Localizer Directional Aid (LDA)
technology employed at Sea-Tac, South-flow arrivals would fly
over more-populated areas, such as West Seattle & Beacon Hill,
with a substantial increase in noise.
(a) Would such noise exceed the 65-dBA Ldn level?
(b) Seattle residents & citizen groups that are in
communication with this commenter report that arrival
flights are all over the skies of Seattle, especially over
Beacon Hill & Rainier Valley, so that the statement as to
the location of South-flow arriving traffic is inaccurate.
(c) The FEIS should cite some published authority to
which readers can refer (best in an Appendix) for further
discussion of this landing-enhancement technique, to permit
independent evaluation of its potential benefits &
detriments.
Comment II-58: Technology alternatives: GPS (p. II-
21). The DEIS dismisses the usefulness of the Global Positioning
System (GPS). This system, which uses low-orbit earth satellites
to provide locational information of pin+point accuracy, would,
we are led to believe, permit safe operation of commercial
aircraft under the worst-visibility conditions, as if visual
flight rules were in effect. Is this a correct understanding?
The DEIS does not provide a satisfactory, quantified explanation
of the enhancements that GPS will permit, but the FEIS should.
Comment II-59: Technology alternatives: Wake vortex
avoidance (p. II-20/1). (a) The DEIS states, p. II-21/2, that
GPS will not enable dual approaches to the existing runways,
owing to wake-vortex issues described elsewhere in the DEIS (at
p. II-20/1). The wake-vortex discussion says that wake-vortex
avoidance/advisory systems are not expected to enable parallel
approaches on runways with a separation of less than 2,500 feet,
so it would not enable dual independent approaches during poor
weather conditions ibid.. But surely wake-vortex problems are
the same in good visibility and in poor? If the problems are the
same regardless of visibility, then it seems to follow that Sea-
Tac cannot operate parallel approaches on existing runways at the
present time. And if that be so, then the real issue here is not
a fog problem but a wake-vortex problem. It would be well if the
FEIS could clear up this point.
(b) DEIS II-20, col. 2, discussing the Precision Runway
Monitor system, seems to state that the required minimum
separation between parallel approaches to avoid wake vortex
problems is 3000 feet, not the 2500 feet stated in the Wake
Avoidance section. Why the discrepancy?
Comment II-60: The potential utilization of a third runway hinges
upon the ability of the Port of Seattle (POS) to install an
instrument landing system (ILS) on Runway 16L (the more easterly
existing runway). An ILS system is currently installed on Runway
16R, the shorter, more westerly existing runway. Before a third
runway can be approved, the F.A.A. must perform a full
feasibility and engineering study prior to issuance of a final
EIS to validate that an ILS can indeed be placed on Runway 16L.
If this cannot be done because of technical reasons, such as
topography, then a third runway would have to be placed much
further westward. The FEIS must respond and verify feasible
locations of additional ILS systems at Sea-Tac including the
proposed alternative runways discussed.
Comment II-61: Technology alternatives, generally.
(a) The DEIS spells out numerous technological
advances of the past, which are given credit for significant
improvement in operation of the airport, but seems to assume
that just at this point in time technology has ceased to
advance. We would suggest that before the FEIS comes out,
the person or people charged in this process with examining
technology should conduct a thorough up-dating review,
perhaps with a less pessimistic mindset. The DEIS does not
quite co-ordinate its conclusions about the various measures
discussed. The preparers seem to be fixated on independent
parallel operations as the only way to go.
(b) In particular, the DEIS seems remarkably
pessimistic about measures for dealing with wake vortices.
If wake vortices are as great a safety issue as the public
has been led to believe, then it would seem that the
avoidance measures described at p. II-20 should be used
routinely.
Comment II-62: The DEIS states because the new dependent
parallel runway is proposed to reduce poor weather delay, which
is predominantly arrival related, the runway would be expected to
be used primarily for arrivals. Recently however, F.A.A.
officials have disclosed that the delay calculations for the
third runway in the DEIS are based on a computer simulation model
(SIMMOD) which has not correlated the relationship between the
airport's demand profile and weather variations when calculating
the delay figures published in the DEIS. (Transcript, Expert
Arbitration Panel, p. 68, l. 14). Additionally, a recent study
has challenged the 44 per cent. bad weather figure cited in the
DEIS, 1995 Bogan report, our Comment II-D, supra. That study
proposes the addition of existing navigation technology in the
form of a Localizer Directional Aid (LDA) aircraft navigational
system to allow parallel dual stream arrivals under weather
conditions with ceilings as low as 2200 feet, a system which
obviates the need for a third runway. (For a detailed exposition
of LDA see Chapter II, Purpose and Need, p. II-21; for
discussion & rebuttal of the alleged noise difficulties that LDA
might cause, see our comments on the noise section of Chapter
IV.) The F.A.A.'s 1993 Aviation System Capacity Plan recommended
LDA as an improvement to Sea-Tac's existing airfield, including
provision of an LDA approach to Runway 16L/34R. 1993 Aviation
System Capacity Plan, Report DOT/FAA/ASC-93-1, Appendix C-53.
Other sources substantiate that weather conditions compelling
single-stream arrivals at Sea-Tac occur only 17 per cent. of the
time, as opposed to the 44 per cent. figure stated in the DEIS.
According to a 1988 study by P&D; Aviation (a consultant
to the Port for the current Master Plan Update!) [t]he yearly
frequency of occurrence of south flow conditions, with ceilings
below 2,000 feet is approximately 17 percent. Airspace Study
Working Paper 1, P&D; Technologies, pp.2-12 (March 1988).
The DEIS points out that under north flow conditions Sea-Tac
experiences predominantly VFR1 weather. A March 26, 1989
newspaper article also states that visibility conditions prohi+
biting dual stream arrivals exist only 17 per cent. of the time.
Seattle Times, 26 March 1989, p. E1.
The Localizer Directional Aid (LDA) aircraft navigational system
allowing parallel dual stream arrivals under weather conditions
with ceilings as low as 2200 feet, must be studied as an
alternative which may obviate the need for a third runway. The
Expert Panel wrote The Bogan report .. deserves scrutiny by, and
a response from, both the POS and the FAA. (PSRC Expert
Arbitration Panel, Final Phase I Order on Demand/Systems
Management Issues, July 27, 1995, p. 8.)
Comment II-63: Technology alternatives, generally. The
DEIS speaks of independent operation of the new, westerly runway
& the existing easterly. Does not the DEIS actually recommend a
dependent, rather than an independent, runway, seeing that all
four options recommended for further study (p. II-37, col. 2)
would have a 2500-foot separation from the easterly runway?
The minimum separation requirement for simultaneous takeoffs
from parallel runways (under radar control) is 2500'. The DEIS
states the purpose of the new runway as arrivals only. In
lieu of an interlocal agreement between the Port of Seattle and
the adjacent cities, the FEIS must consider use of the runway for
departures as well.
Comment II-64: The recent finding by the Expert Panel re-
echoes the main concern on the subject of Purpose and Need which
remains to be addressed in the FEIS: Sea-Tac is not currently a
highly congested airport. According to the most recent ASPQ data
available from the USDOT (for May 1995), Sea-Tac ranks #1 in on-
time departures (90.0%) and #6 in on+time arrivals. (84.6%) In
recent years, the total annual hours of delay (as defined in the
1995 FAA Capacity Enhancement Update) have dropped from 48,000
(in 1988) to only 26,000. Reported delays as compiled in the
FAA's ATOMS data series show a similar decline, from 30 delays
per thousand operations in 1990 to 6 delays per thousand
operations in 1994. (PSRC Expert Arbitration Panel, Final Phase
I Order on Demand / Systems Management Issues July 27, 1995, p.
6.
Recently, a television advertisement immortalized the line:
"Where's the beef?" The authors of the DEIS, must clearly,
articulately and persuasively convince the readers through their
FEIS, that they must spend $1.5 billion dollars to expand an
uncongested airport when far less costly alternatives are
alternives.