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COMMENTS OF SEATTLE COMMUNITY COUNCIL FEDERATION
ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
FOR MASTER PLAN UPDATE, SEATTLE-TACOMA INTERNATIONAL AIRPORT
Introduction
I-1. Identity of commenter. Seattle Community Council
Federation is the city-wide coalition of Seattle community
clubs, community councils, and neighborhood associations.
We have participated throughout the Master Plan Update
process and predecessor public processes concerned with
Seattle-Tacoma International Airport, & with Central Puget
Sound transportation planning. Details are to be
found in the introductory portion of our comments on the
draft environmental impact statement for the Seattle-Tacoma
International Airport Master Plan Update, in our scoping
comments for the site-specific third runway environmental
review, & in earlier submissions.
I-2. Organization of comments. Our comments are organized
into the following sections:
I. Introduction
I-1. Identity of commenter
I-2. Organization of comments
I-3. Abbreviations
1. General Comments
2. Process Issues
3. Revised Passenger-traffic Forecasts
4. Purpose & Need
5. Terminal & Other 'Landside' Facilities
6. Impacts & Mitigation
I-3. Abbreviations. We frequently refer to the agencies
involved in this process by abbreviations:
FAA -- Federal Aviation Administration, U.S. Department
of Transportation
POS -- Port of Seattle
PSRC -- Puget Sound Regional Council
KCIA -- King County International Airport (popularly known
as Boeing Field)
Sea-Tac -- Seattle-Tacoma International Airport
We usually refer to the various documents in this
process by abbreviations, as follows:
DEIS -- the draft environmental impact statement for the
Sea-Tac Master Plan Update
FEIS -- the final environmental impact statement for the
Sea-Tac Master Plan Update
dSEIS -- the document now under review: the draft
supplemental environmental impact statement for the Sea-Tac
Master Plan Update
fSEIS -- the final supplemental environmental impact
statement, to be issued after comments on the dSEIS are
received and analyzed
Other abbreviations are consistent with those used in
the dSEIS.
1. General Comments
1-1. Of all measures proposed for
dealing with the purported air-capacity problem at Sea-Tac, the proposed
improvements as described & scheduled in the dSEIS
are the most expensive and least cost-effective.
1-2. The examination of alternative solutions for the
air-capacity problems of the four-county Central Puget
Sound area remains arbitrary, incomplete, and tainted by the
bias of the FAA and POS for a solution located exclusively at the Sea-Tac site
(expanded). In particular, the failure to examine rail
alternatives is inexcusable (especially in light of the
amazing change of heart on the utility of rail by the Washington Department of
Transportation, immediately after the Expert Arbitration
Panel of the Puget Sound Regional Council reluctantly ruled
out a rail alternative to Sea-Tac expansion in large measure
because of the reluctance of the Department of Transportation
to support significant rail improvements). Why was a rail
alternative not re-considered in the dSEIS?
1-3. The proposed third runway will be obsolete, by the
figures of the dSEIS, only a few years after its reż-
scheduled entry into service, as projected air-passenger
growth overwhelms the slight additional increase in capacity
gained by that improvement. Yet the dSEIS proposes no
remedy. Why?
1-4. The increase in projected passenger growth, the
significant proposed change in scheduling of construction of various
improvements, and the failure to provide any plan for local
and regional air traffic after the saturation point is
reached, all seem to require that this entire project be re-
submitted to the Puget Sound Regional Council for its re-
examination, for the projects & plans approved by that body
are not the projects & plans now proposed, & the professed
goals of the original proposal will not be met by the new
proposal, if the new traffic forecasts are accurate.
1-5. The environmental impacts of Sea-Tac expansion
remain under-estimated, especially in the city of Seattle,
especially in places where there are disproportionately
large numbers of persons of color and other specially-
protected classes, as defined by Executive Order 12898.³
2. Process Issues
The public-participation and public-information
process for the earlier stages of this long exercise were
ill-designed, inadequate, and inappropriate. The same is
true this time.
2-1. Inadequate distribution of copies of the dSEIS.
(a) The dSEIS was not adequately distributed;
several copies should of course have been lodged
in every branch library in Seattle, but were not.
(b) The dSEIS copies lodged with the libraries
should have been available for circulation, rather than
restricted to in-library use, given the length
and complexity of the document.
(c) The proponents were well aware of the
concern in the Columbia City neighborhood
arising from the 3-degree shift in north-departing flight
patterns, an affair that generated intense interest in
Sea-Tac matters in that neighborhood -- yet, the proponents
of the project saw fit NOT to lodge even one copy of the
dSEIS in the Columbia City branch library (or the Columbia
City Neighborhood Service Center, nor in the City's
community center in Columbia City).
(d) Copies should have
been lodged in the libraries serving other affected Seattle
neighborhoods, such as Georgetown, Broadview, Queen Anne,
Ravenna-Bryant, Laurelhurst, and Capitol Hill.
(e) We note that the fact sheet included in the
dSEIS reveals a failure to lodge copies of the dSEIS in
public libraries in several places outside our city where Airport
activities have caused concern. These localities, all of which have
branch King County libraries, include: Issaquah, Maple Valley,
Mercer Island, and Tukwila. We also note that no copies
were lodged at Gig Harbor, a city that filed a brief amicus
curiae in our lawsuit against FAA over the four-post plan.
2-2. Scoping. Should there not have been scoping
hearings before the dSEIS was prepared?
2-3. Usual inadequate hearings. As we have come to
expect in this process, the proponents once again provided:
(i) too few public hearings (only one this time),
(ii) an inconvenient location (an obscure POS space inside the
Airport passenger terminal) for the one hearing that was
provided,
(iii) the usual inconvenient (rush-hour and dinner-
hour) time for the hearing.
(iv) Of course, when the proponents refuse to
recognize that their project will have adverse impacts in
the City of Seattle, it is no surprise that they refuse to
hold hearings on their project in our city. What will it
take for FAA and POS to recognize that residents of the City
of Seattle have a legitimate concern about the activities of
the Airport and about the expansion that FAA and POS are
touting?
(v) What will it take for FAA and POS to recognize that
they have a duty and a responsibility to schedule a complete
suite of public hearings, with actual decision-makers in
attendance, at reasonable times and at
reasonable places, taking into account the work and family
responsibilities of ordinary citizens?
2-4. Critical documents withheld from public. In the
last go-round (the preparation of the FEIS), the proponents
first issued the FEIS, and then released, seriatim & slowly
& to an extraordinarily restricted audience,
the Technical Reports on which the FEIS was actually based,
containing the actual studies, analyses, computations, &c;,
relied on by those who wrote the FEIS. This
time, the gimmick was to withhold the actual revised
traffic forecasts on which the dSEIS is said to be based.
These reports should have been included in the dSEIS. Why
were they withheld?
Also withheld were the financial planning documents
that led to the conclusions averted to so obliquely at p.
2-21 & 2-24, dSEIS (Part 3 A, first bullet point). Why were
these financial planning documents not included in the
dSEIS? Why were they not at least cited in standard
citation form so that interested parties could locate &
peruse them?
2-5. Lack of index. One way to make it difficult for
the public to participate in the environmental review
process is to make the documents hard to use. Particularly
troublesome is a failure to provide either a comprehensive analytical
table of contents or, much better, a topical index. The dSEIS fails to
provide either. This has now become an established pattern
with the POS and FAA, to the point where one has to assume
that these failures are deliberate. Are they?
We called for a proper index in our scoping comments
before the site-specific environmental review for the third
runway began, noted the absence of an index in our comments
on the DEIS, note that no topical index was provided for the
FEIS (a one-page alphabetized version of a one-page table of
contents listing chapter and appendix titles is no
substitute for an index) --- and here we are again! Another
FAA and POS environmental document with no index! Why?
Does the FAA or the Port not have access to index-
preparation software?
Later comments call attention to a few specific examples
of readers' difficulties arising from lack of a proper
index. See, e.g., Comment 3-17.
3. Revised Passenger-traffic Forecasts
3-1. Where are the actual revised forecasts?
(a) Readers attempting to understand the discussion in the dSEIS about
various revised traffic forecasts are handicapped by having
to rely on the disjunct summaries of those forecasts
(evidently prepared by persons other than those who prepared
the actual forecasts) without having the actual documents before them.
(b) Why not reprint the FAA & POS forecasts as
appendices, since they appear
not to have been lodged with any libraries, or, so far as one can
tell, published?
(c) If these documents were published,
what are the citations and where have
these documents been lodged where the public
can have useful access to them?
(d) Important to an intelligent, independent
understanding of the issues raised by the new forecasts is
an understanding of the methodologies & assumptions on which
they are based. If the methodologies &c; are to be found
in the actual forecast documents, it would be important (i)
for the public to be so advised, & (ii) for the documents to
be included in the EIS. If the forecast documents do not
completely spell out the methodologies, &c;, then documents
setting out the methodologies should be included in the
fSEIS or, at the very least, accurately summarized in the
fSEIS and accurately cited, so that independent reviewers
can consult them?
(e) Why were these critical documents not furnished
to previous commenters on the DEIS and FEIS?
3-2. Ranges or hard numbers in forecasts? Do the POS
and FAA forecasts referred to in the dSEIS give one hard
number or a range? If a range, what is the range? If not a
range, why not? See RCAA Comment I-9, FEIS, with which we
completely concur.
3-3. When were forecasts available? (a) Why does dSEIS, p.
1-1, say that the fiscal year 1996 Terminal Area Forecast
was available to regional FAA in May 1996, whereas p. 2-2 says that
the FY 1997 forecast came out in December 1996?
(b) Why wasn't FY 1996 Forecast available in
December 1995, if the FY 1997 Forecast was available in
December 1996?
(c) What is the fiscal year?
(d) When & how was the FAA 1996 forecast referred
to at p. 1-1
communicated to (i) the staff of PSRC? (ii) the Executive
Board of PSRC? (iii) the
membership of the General Assembly of PSRC? (iv) the
representative of POS in the General Assembly of PSRC?³
3-4. Does use of different years affect analysis? Does
it make a difference to the projections & conclusions in the dSEIS
that the new FAA traffic forecasts are based on the (undefined) fiscal year,
whereas the new POS forecasts are based on the calendar year? If so, what
is the difference?
3-5. What additional forecasts were considered? Ch. 2,
I A, p. 2-2, of the dSEIS, refers to the 'fiscal year 1997 Terminal Area
Forecast (TAF) for [Sea-Tac]', commenting that the FY 1997 TAF showed
that 'forecast demand could grow significantly faster than was
predicted by the Master Plan Update'. The paragraph then continues,
'In response to these forecasts ... .'. What other forecast or
forecasts, other than the FY 1997 TAF, are here referred to?
3-6. Inconsistent air-carrier load figures. At p. 2-3
of the dSEIS, describing the methodology used for FAA Terminal Area
Forecasts, one reads that the TAF assumed, inter alia, that "the
domestic air carrier load factor (actual percentage of passengers
occuping available seats) was assumed to remain constant at 65.3%".
Yet in preparing the DEIS the promoters of the Sea-Tac expansion plan
and nominal authors of the DEIS represented to the public and local
decision-makers that the load factors were 57 per cent. for the larger
(more than 60 seats) planes and 44.5 per cent. for the smaller (less
than 60 seats) planes. See RCAA comment II-36.
(a) Please explain the discrepancy.
(b) The fSEIS should provide figures based on actual Sea-Tac
load factors, low and inefficient as they are.
(c) We note that among the factors described at 2-3 is a possible (not a
predicted) increase of 0.039 per cent. in the number of air-carrier
seats per departure, referring, as we understand the term 'air
carrier' only to aircraft seating more than 60 passengers.
(d)(i) Is the explanation for the discrepancy a belief
by the promoters of the project that there has been, or will
be, a sudden increase in efficiency? (ii) If
so, (a) how did that, or will that, happen? (b) will there be more
increases in efficiency, (c) will increases in efficiency, diminish,
or even obviate, the asserted need for the third runway?
3-7. Obscure statement about commuter operations needs
clarification. Referring again to p. 2-3, dSEIS, it is also
said that commuter operations (aircraft seating 60 or less)
'could' (not 'will' or 'are likely to') rise from a 1995
load factor of 30 passengers per flight to 47.1 passengers
per flight in the year 2010.
(a) Does this statement refer to the situation at
Sea-Tac or all commercial airports in the U.S.?
(b) How was this possible increase in load
efficiency dealt with in the FY 1997 TAF projection?
(c) What causes are suggested for such a dramatic
increase in load factor (57 per cent.)?
(d) What are the conditions under which the
preparers believe that this rise will take place, and what
are the conditions that would prevent it from taking place?
'Could' is too vague, so tell us what the likelihood is of
this event occuring.
(e) As the foregoing group of questions suggests,
the practice of giving the readers disjunct, partial,
summaries of critical documents, instead of the documents
themselves, is almost a guaranty of confusion, ambiguity, &
incompleteness.
3-8. Further vagueness in methodology discussion.
Referring to the discussion, beginning at dSEIS, p. 2-4, of
the methodology used in preparation of the Port of Seattle
updated forecasts:
(a) How was 'demand for air travel' 'identified'?
(b) What does 'demand' mean in this context?
(c)(i) Does 'identified' in this context mean that
a numerical value was derived? (ii) If so, how was that
numerical value derived? (Or was it just guessed at?)
(iii) If a numerical value was not derived, what does
'identified' mean in this context?
(d)(i) How was the 'extent of the constraints
associated with the existing airfield, terminal facilities
[&c.;]' 'identified? (ii) Does 'identified' in this context
mean that numerical values were assigned to the various
factors mentioned? (iii) If not, what does 'identified'
mean in this context?
(e) Could the last sentence on p. 2-4 be recast,
please, to more conventional and understandable language?
The expression "versus after completion of the Master Plan
Update improvements" is particularly baffling.
(f) In the DEIS and FEIS, the project proponents
took the position that the same number of 'operations' will
occur at Sea-Tac in the foreseeable futures, whether or not
the third runway is built. See Response 4-3-7, at p. R-32,
for a recapitulation of the position. (i) Are the Port and
FAA now abandoning that notion? (ii) If so, why? (iii) Are
the Port and FAA taking the position that the same number of
passengers will use the Airport in the foreseeable future,
whether or not the third runway is built? Please explain.³
3-9. Unexplained, dramatic decrease in Air Taxi/Commuter
operations. At
p. 2-6, Table 2-3 projects a decline in "Air Taxi/Commuter"
operations from an observed 138,000 in year 1995 down to 110,000
by year 2010. No explanation for this remarkable decrease is
provided. What is the explanation?
3-10. Unexplained, dramatic increase in commuter
efficiency. At p. 2-17, FAA is said to have projected that
commuter seats would jump from 30 seats per departure, at
present, to 47.1 in the year 2010.
(a) What is the basis for this projection,
especially in light of the somewhat justified but lesser
increase in the POS forecast discussed at the same place?
(b) We may note
that a co-operating person downloaded from the Internet for the
purposes of these comments the materials
cited in footnote 3, p. 2-3, supposedly delineating the FAA's
methodology in making its TAFs, & that the file -- though it
contains much of interest -- does not contain any
explanation of the assumptions used in constructing the computer
program that constitutes the file. Where are those assumptions
published?
3-11. Unexplained inconsistency in departure-usage
estimates. We note that at p. 2-17, the dSEIS reports that
the POS assumes a one-seat
per year increase in departure usage, and FAA, O.35 seats per
departure. This difference yields rather large divergences even in
the short-term planning horizon used in the present exercise. The
differences in the two assumptions, and the reasons therefor, need
further discussion.
3-12. KCIA & other nearby operations not considered. Conspicuously
absent from the discussion in the dSEIS is the
interrelationship between operations at Sea-Tac & operations
elsewhere, especially
at KCIA (also projected to experience great growth, as at least the FAA must
know). At some point, the FAA, at least, must face up to
the operational problems that arise & will continue to arise
from having crowded so many airfields into the heart of the
Central Puget Sound area: Paine Field (South Everett), the floatplane
'field' at Lake Union (Central Seattle), Renton Municipal,
Sea-Tac, the Kitsap County facility, McChord AFB, and Ft
Lewis. With the exception of Ft Lewis, all these facilities
put ever-increasing numbers of operations over the residents
of the City of Seattle. A complete environmental review of
the Port's grandiose expansion plans at the Sea-Tac site
should surely encompass the airside issues arising from
growth in traffic at the airfields named above. When will
that review be conducted, & by whom? Keep us involved, so
that we can participate in the scoping & then in the rest of
the environmental review of this aspect of Sea-Tac expansion.³
3-13. Discrepancy between new forecasts & reported
Sea-Tac experience. We note also that both forecasts, as
described at p. 2-17, use air-carrier
load factors for forecasting that differ radically (upwards) from
experienced rates at the airport. The fSEIS should explain the
reason(s) for making these forecasting assumptions.
3-14. Delays occasioned by stress on the near-by
roadway system. How did the dSEIS preparers arrive at
the values referred to in at pp. 2-12 and 2-14 for mean arrival and departure
times for passengers? The text suggests that they are simply guesses
(assumptions).
3-15. Costs of delay to air passengers. The dSEIS says,
at p. 2-21, that poor weather delay costs travellers
time and that that delay is described in the FEIS. Where? In
the DEIS/FEIS process, we were given to understand that delay to
passengers was not a factor in the Port's justification for the pro½-
ject, that the justification was delay to airline operators, that the
very acceptable passenger-delay figures for Sea-Tac were irrelevant to
the delay-to-operator justification. Were we wrong in that understan½-
ding? If so, how? Or, have the POS and FAA changed the ground for
their justification of the project by now adding alleged passenger
delays to the asserted operators delay?
3-16. Poor-weather delay vs. groundside delay.
How is "poor weather" delay related, if it is, to the
groundside delay that is advanced as justification for the groundside
projects? See last unnumbered paragraph on p. 2-21.
3-17. Description of delay factors inadequate.
The dSEIS discussion blandly refers to descriptions
of poor-weather delay factors as they affect travellers and
airport users (meaning airlines?) as having been "described in the
February, 1996 Final EIS". Where?
The failure of the DEIS and FEIS to have real indexes
leaves users of those documents no way to find prior
discussion of such issues as delay (short of re-reading all
the volumes every time some such reference is made in a
later document like this dSESIS, or short of constructing
one's own index), unless the dSEIS provides accurate
references back to prior discussions. We suggest that an
actual index be provided for the FEIS and that proper cross-
references be provided from dSEIS / fSEIS to any prior
documents cited. ³
3-18. General & summarizing comments on forecasting
issues. (a) It is refreshing that someone on the 'official'
side of this long discussion at last admits that the
forecasting of future air traffic is an arcane art, rather
than an exact science. This admission would have been more
useful had the new forecasts been couched in terms of ranges
or statistical probability.
(b) The discussions in the dSEIS of the details of
the new forecasts, the methodologies & assumptions used in
the new forecasts, the degree of reliability of the new
forecasts, and the interrelationships between them are
incomplete, confusing. It would perhaps have been better to
provide one full, complete discussion, rather than having
piece-meal discussions at various places in the document.
The fSEIS should improve on the discussion, as well as
including the full texts of the forecast documents &
reprinting or citing the documents that set forth the
methodologies used in preparing the various forecasts.
(c) The conclusions reached by the authors of the
dSEIS from the revised forecasts do not seem to follow from
the forecasts. Rather, the informed reader glimpses through
the fog two powerful realities not openly dealt with in the
dSEIS: (1) The financial resources for constructing the
$3000 million worth of improvements in the Master Plan
Update do not exist, & no-one on the staffs of the two
proponent agencies knows where such funds are likely to be
found; (2) No serious engineering work on the third runway
itself has been done. Neither POS or FAA has seriously
addressed the difficulties of the immense proposed fill
operation -- difficulties that led to a negative
recommendation for a similar project in the recent
environmental review of the Albuquerque, New Mexico,
airport's master plan update. As a result, staffs need more
time to do (or to have done) the engineering, & to consider
the hitherto-unrecognized difficulties that such work will
doubtless reveal.
(d) This project, & its problems, were not
adequately understood at the time that it was jammed through
the PSRC. The revised traffic forecasts alone would appear
to require a (full) re-examination by PSRC, as well as by
the Port of Seattle Commissioners and higher, more
responsible, levels within the FAA & in the office of the
Secretary of the U.S. Department of Transportation. ³
4. Purpose & Need
4-1. Purpose & need. The dSEIS inadvertently casts
serious doubt on the purpose & need discussion in the DEIS &
FEIS, as well as the DEIS & FEIS prepared for the
"programmatic" environmental review, under the auspices of
POS & PSRC. There seems to be a retreat from the major conclusion
of thosee earlier documents. Those documents asserted that
there was rapidly approaching an air-capacity crisis at
Sea-Tac, occasioned by rapid growth in air-passenger traffic
coupled with poor-weather restrictions on use of the
facility (i.e., an inability to use both runways during
'poor weather' conditions). Do the FAA and POS still stand
by that earlier analysis?
4-2. Purpose & need. The earlier documents concluded
(to no-one's surprise) that the solution to the predicted
air-capacity crisis was construction of a third runway at
Sea-Tac, lying parallel to the two existing parallel
runways, but at a sufficient separation from them that the
new runway could be used together with the more easterly
existing runway during 'poor weather' conditions, thus
accomodating
an additional 100,000 operations per year. Do the
FAA and POS still maintain that the proposed third runway
would have the effect just described? If not, what is the
position of the project proponents in this respect?
4-3. Purpose & need. In contrast to the two earlier
site-specific
documents (DEIS, FEIS), & the 'programmatic' EISes referred
to in Comment 4-1,
the dSEIS now seems to suggest that growth of
passenger air traffic -- greater growth than predicted in
the earlier documents -- does not require an accelerated
construction schedule for the most important single measure
to relieve the air-capacity crisis. (i) Does this mean that the
DEIS and FEIS were wrong in arguing that a third runway was
needed to meet traffic growth? (ii) What is the explanation for
the seeming contradiction that more rapid growth requires
slower implementation of the principal proposal for dealing
with that growth?
4-4. Definition of 'delay' needed. The dSEIS seems to
say that the project is needed to obviate costs of delay.
Page 5-1 [second], second bullet point. (Why this
discussion is buried in the 'Environmental Consequences'
chapter is a separate question. Should it not appear in
Chapter 1, Part 2 (B) 'Purpose And Need', or in Chapter 2,
part 2, 'Project Purpose And Need'?) 'Delay' as used in
dSEIS should be defined clearly and in an obvious location.³
4-5. Support needed for assertions about costs of delay. The
assertions about costs of delay appearing at dSEIS, p. 5-1
[second], are just that -- mere assertions. Citations to
studies supporting the bald assertions about the costs of
delay (however defined) are needed.
4-6. Discussion needed as to effects of ASQP delay. The
dSEIS refers, p. 2-18, to delay as measured by the Airline
Service Quality Performance (ASQP) measure. (i) We do not recall
this measure being discussed in the FEIS (the absence of a
citation to discussion of it in the FEIS is suggestive).
(ii) There should be a citation, in standard form, to whatever
study or studies support the assertions about ASQP data at
dSEIS p. 2-18. (iii) The significance of the stated ASQP
figures needs to be explained, particularly in fiscal terms,
for Sea-Tac, and also in comparison to other airports in the U.S.
(iv) The discussion at p. 5-1 [second], second unnumbered
bullet point, appears to suggest that the proposed third
runway would have 'saved' the airlines using Sea-Tac $24 million
in 1994. What does 'saved' mean in this context? What is
the relation to the ASQP data referred to at p. 2-18? (v)
The fSEIS needs to explain in detail how the 'savings' of
$24 million would grow to $146 million 'near the year 2013'.
4-7. How much capacity gain is predicted? (a) It may be
noted that Exhibit 2-7, p. 2-26, which displays both the
delay curve of Ex. 2-2 and the delay curve with the desired
third runway, shows a similar (though less aburpt) marked
increase in delay for the three-runway airport at about
380,000 operations per annum. The exhibit shows that the
writers of the dSEIS believe that the upper limit for
practical capacity of the present airport (per NPIAS) is
about 445,000 operations, and the proposed airport, about
527,000; thus, according to that Exhibit, the third runway
is projected to increase the practical capacity by about
82,000 operations per annum. Is this a correct
understanding of the Exhibit, and of the position of the
proponents, as to the increase in capacity to be gained
(defined in terms of total annual operations) from
construction of the third runway? If not, what should the
reader understand in this respect, and why?
(b) If 82,000 additional operations per year are to
be gained, as suggested in part (a) of this Comment, is
there any correlatin (& if so, what?) between that increase
in number of operations and the purported savings of $146
million in costs experienced by the airlines 'near the year
2013'? Or are two entirely different concepts being dealt
with here?
4-8. Questions of cost effectiveness ignored. (a) Nothing
is to be found in the dSEIS
about the cost effectiveness of investing in a
facility that will be over capacity & obsolete in a very few years --
even fewer years under the new timetable than under the old one.
A full discussion of this issue is needed in the fSEIS.
(b) Indeed, according to p. 2-7, the Airport is
already operating above capacity (annual service volume =
380,000 operations, 1995 operations = 'nearly 387,000'
operations, and 1996 operations = 392,500.) On that showing,
are we to conclude (i) that the Airport can actually operate
with reasonable efficiency at levels above the previously-
stated capacity? (ii) that further minor 'tweaks' could
extend the usefulness of the facility indefinitely without
the third runway?
(c) And where is the legally mandated cost-benefit analysis? ³
5. Terminal and Other 'Landside' Improvements
5-1. Terminal capability. See Part II.4.B (p. 2-27).
(a) This section needs to be re-written, so that
the reader has a clear understanding of what conditions are
being discussed, & the dates on which those various
conditions are anticipated to occur. As written, the
section is too unclear to allow full analysis & discussion.
(b) The suggestion
that traffic forecasts can be extended into the decade of the 2020s by
a linear extension is disturbing and confusing. In ordinary usage, a
'linear extension' unless further qualified is a straight-line exten½-
sion. If there is anything clear from the preceding discussion of
traffic forecasting in the dSEIS it is that straight-line extensions
are the least-probable occurence in this arcane art.
(c) And from when is the
linear extension to start? Where is the straight line that is to
be projected?
(d) And what is meant in the second unnumbered
paragraph by the
expression, "if demand were to continue to grow at the current
rate"? What IS the current rate? The demand graphs and tables
displayed in the dSEIS to this point (see, e.g., Table 2-5, Table 2-6,
Exhibit 2-45, Exhibit 2-5) show increasing rates of growth, not
straight-line projections (with the exception of the Master Plan
Update, which, as could have been predicted, has already been proven
wrong).
5-2. Requirement for additional gates not justified.
(a) Why would more gates be needed past the activity level of
317,000 passengers per NBEG or 19 million enplanements p.a.? The
discussion here needs to be fleshed out.
(b) The confusing discussion here leaves the reader
with an initial
impression that the activity level 317,000-passengers-per-NBEG is
equivalent in some way to the activity level of 19 million enplane-
ments p.a. Only if the reader has already perused, understood, and
remembered the discussion at the top of p. 2-11 will the reader
realize that the 19 million enplanement p.a. level is equivalent to
422,000 passengers per NBEG, not the lesser figure of
317,000.
(c) It is also unfortunate that the expression
'level of service' (which, one learns on careful perusal,
does NOT mean level of service) is used in this discussion, leading
the casual reader to think that 'service' means 'service'. This
discussion would be usefully improved if some other term could be
substituted for 'level of service' here. Perhaps 'groundside
passenger delay' could be used, with a cross-reference to the
discussion now appearing in the first full paragraph at p. 2-11.³
5-3. Landside capability. Part II.4.C (p. 2-27).
(a) Surely this Part is mislabelled, for surely
terminal capacity or capability is part of landside
capability? It would be useful to designate this as the
Airport-vicinity Roadway part.
(b) Here again 'level of service' conveys
a misleading impression. Anyone unfamiliar with Sea-Tac would
think that this paragraph says that there is not much ground traffic
in the vicinity of the airport. It would be better to say that the
roadways in the immediate vicinity are very busy and will become more
so, to the extent that under applicable ICAO standards congestion will
be so severe that the roadways
will be deemed inadequate at some or another date, stating
the date.
(c) The text statement that the RTA plan (which?) will relieve
congestion seems at odds with statements in the accompanying
appendix. See Table C-1-3, which plainly states that NO
passengers will use the RTA system as their means of access
to Sea-Tac.
(d) Note that the RTA plan included in the
Metropolitan Transportation
Plan, such as it is, adopted by PSRC (or 'Region', as the dSEIS puts
it) is NOT the operative plan, is NOT the plan approved by
the voters.
5-4. No need for groundside enhancements. The
discussion of terminal/landside contraints, p. 2-10 & seq.,
seems to show that in the worst-case scenario for groundside
passenger delays (19 million annual enplanements), the gate-
usage measure would rise to 422,200 passengers per narrow-
body gate equivalent, somewhat less than the comparable
measure for Pittsburgh and O'Hare in the recent past. On
this measure, there is no showing of significant groundside
delay for passengers at any conceivable level of
enplanements. Is this is a correct reading, & if not, why
not?
5-5. Groundside constraints could be met by enlargement
of lobby space. Assuming that we have read the text
correctly, it follows that the showing of significant passenger delay groundside under
extreme growth conditions boils down to an evaluation of the average
amount of floor space in the terminal lobby. The result is an assertion
that at 6.6 square feet per passenger (the 17.9 million enplanements
per year level) there would be unacceptable 'levels of service'
(quality of service) and
severe congestion (compared to an adequate 13 square feet per person
in 1995) (p. 2-11). Assuming that this conclusion is valid, what
should follow? Presumably, an examination of various alternative
means of reducing severe congestion and degradation of passenger
service on the ground. In fact, our reading is that only two
alternatives are referred to in the dSEIS. One is the package of
groundside projects discussed in the FEIS, which is recommended by the
dSEIS for early implementation. The other alternative is described in
a half sentence: "... the use of other existing check-in locations
would increase the passenger per square footage of lobby space ..."
(p. 2-11). In the latter half of that sentence, this alternative is
discussed, and dismissed, in perhaps the shortest & least satisfactory
discussion of alternatives yet seen around here: "the conditions
would still likely produce a LOS [level of service] F
[unsatisfactory]." Period. How did the author(s) reach that
conclusion? Surely the fSEIS needs to give a fuller discussion. At
first blush, it would seem that relatively inexpensive improvements
could be made to prevent the degradation of service that is posited by
the dSEIS when passenger levels reach 17.9 million per year. What
less-expensive improvements have been analyzed, by whom, and with what
results? ³
6. Impacts and Mitigation.
6-1. Impacts & mitigation discussion still inadequate.
The dSEIS is
utterly inadequate in its discussion of impacts & mitigation
thereof.
(a) The obsolete 65 LDN standard is still used. It was
never an appropriate standard, was not adopted in any
acceptable or scientifically defensible manner, and has been
recommended for replacement by the US EPA and the Natural
Resources Defense Counsel.
(b) Single-event impacts should be studied.
(c) We note the utter absence of analysis of impact
of jet-aircraft
exhuast fumes, including airborne particulate matter in the
size range 2 to 10 microns. This omission should be cured
in the fSEIS.
(d) We note the utter absence of analysis of
impacts from the practice of fuel dumpiing, especially
prevalent over Beacon Hill in Seattle. This omission should
be cured in the fSEIS.
6-2. Impact on Seattle schools. (a) The fSEIS should
examine the impacts on schools (public & private) in Seattle
on the basis of 55 LDN and an appropriate SEL level.
(b) Appropriate mitigation measures should be
presented after the study called for in part (a) of this
comment.
6-3. Impact on property values. We note that the FEIS
and the dSEIS are both silent on the issue of diminution of
property values caused by jet-aircraft operations. This
phenomonon is well-documented, having been most recently
addressed (as the proponent agencies well know) in detail
& depth by the international consulting firm HOK, conducting
a mitigation & impact study in areas generally South of
Sea-Tac under a State grant. Loss of property values should
be candidly addressed in the fSEIS.
6-4. Loss of tax revenues. A companion issue to
diminution of property values is loss of municipal & school-
district revenues based on the real-property tax. This,
too, is a well-documented phenomenon, & needs to be
addressed forthrightly in the fSEIS.
6-5. Benefits versus harm. (a) While the dSEIS presents
some useful information about origins & destinations of air
passengers using Sea-Tac, it does not go far enough. The
information in Table C-1-2 and Exhibit 2, and similar tables
and maps, is not cross-correlated, the areas are ill-defined
(ZIP codes would be beter, & such data are available). A
fuller analysis would show that the users of the Airport in
large measure do not live in high-impac zones. A similar
analysis of residences of persons holding jobs directly
related to the Airport, especially if constrained by income
level, would doubtless show that the higher the income, the
less likely that the employee lives in a high-impact zone.
(b) In short, lower-income areas (like Georgetown, Rainier
Valley, White Center) bear a great deal of the direct adverse
impacts from present & projected Sea-Tac activities but
enjoy few if any direct benefits.
(c) Unfortunately, most of these same neighborhoods also
bear the brunt of KCIA's activity, & some also receive noise
impacts from operations based at Renton Municipal. A proper
EIS would analyze ALL these impacts, instead of following
the typical FAA & POS prectice of dealing with such impacts
piece-meal, airfield by airfield. There obviously are
cumulative impacts, which should be studied & reported on.
(d) Useful work on this subject was shown in the preliminary
draft of the hOK study (which, we know, was shared with
POS); the fSEIS should seize the opportunity to deal with
the unequal distribution of supposed benefits and known
detrimental impacts.
6-6. 'Environmental Justice' Executive Order. The FAA
at least is bound by Executive Order 12898. It is not even
mentioned, so far as we can tell, in the dSEIS. Why not?
6-7. Water quality. (a) It seems likely that the greatest
impacts on water quality from the project will fall in areas
literally adjacent to the Airport, including the underlying
aquifer (not even discussed in the dSEIS as far as we could
tell). We leave it to others to comment in detail on the
inadequacies of the discussion of these issues. But we
observe that the discussion seems superficial.
(b) Insofar as water-quality issues concern the
City of Seattle directly, we note that there is NO
discussion of this possibility -- yet the City is now
overflown by exhaust-producing, fuel-dumping, Sea-Tac traffic day & night,
with more to come, sooner than predicted. No impacts? Impossible.³
7. Miscellaneous Comments
7-1. Capacity limits arising from travelling public's
preferred usage times. Where
in Appendix R (the response-to-comments Appendix of
the FEIS) are readers to
find the discussion of limits on the airport's capacity caused by the
travelling public's desire to travel at certain times? (See dSEIS
2-10.)
7-2. Helpful exhibits. Exhibits 2-4 and 2-5, p. 2-16,
are particularly useful and easy to understand. They should
be retained in the fSEIS. We found especially helpful the
two-scale presentation in Ex. 2-4.
7-3. Lists of Tables, Exhibits. It would be helpful in
the fSEIS to havea tables listing the tables and exhibits.
7-4. Better Table of Contents. There are independent
documents contained in the Appendices that are not
separately identified in the present Table of Contents. All
documents should be separately identified.
7-5. Working papers. One finds at dSEIS, p. 2-7, n. 5,
a reference to a working paper prepared for this exercise.
(b) We deprecate the practice of doing the 'grunt work'
of environmental reviews in working papers that are not
included as part of the dSEIS released for public comment &
we ask that the proponents of the project put an absolute
end to this practice.
(b) All such papers should be included in the
dSEIS, & in the fSEIS.
(c) A full listing of such papers should be
included in all draft and final EISes.
(d) If not included in draft EISes, they should be
distributed with such drafts.
7-6. Secrecy. We deprecate the practice of hiding the
identity of those who act for public agencies in writing
EISes. What is to be lost by putting the blame (or, credit)
where it belongs? We ask that the fSEIS state the
authorship of its various parts clearly & unmistakeably.
This is particularly important in the case of the FAA, with
its incomprehensible multi-level structure of authority. We
know who the principal actors are for the Port -- though not
necessarily the identity of consultants -- and can evaluate
their work accordingly. But it would seem from the dSEIS
that insofar as the FAA is concerned, the leval of approval
and participation may be anything from a direct & personal
approval by the Secretary of the U.S. Department of
Transportation or only the approval of Dennis Ossenkop, and
anything in between. This is most unsatisfactory.
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COMMENTS OF SEATTLE COMMUNITY COUNCIL FEDERATION
ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
FOR MASTER PLAN UPDATE, SEATTLE-TACOMA INTERNATIONAL AIRPORT