Comments of the Regional Commission on Airport Affairs (RCAA) on the Draft Supplemental EIS (dSEIS) to the Seattle-Tacoma International Airport Master Plan Update

http://www.rcaanews.org/rcaaseis.htm
Comments of the Regional Commission on Airport Affairs 
(RCAA) on the Draft Supplemental EIS (dSEIS) to the 
Seattle-Tacoma International Airport Master Plan Update
[Editor's Note:  Comments on the Port/FAA Draft SEIS
must be received by the FAA no later than March 31, 
1997.  Mail comments to:
Mr. Dennis Ossenkop
Federal Aviation Administration
Northwest Mountain Region
1601 Lind Avenue Southwest
Renton, WA 98033-4056
Also, please mail a copy of your comments to RCAA at 19900 4th Avenue SW 
Normandy Park, WA 98166
Your questions and comments must be specific.  Otherwise the Port/FAA may 
disregard them and claim they are too broad.  Ask that the agency comply with the 
requirements of Section 1503.4(5)  of the National Environmental Policy Act 
(NEPA) which requires that the responding agency.
"Explain why the comments do not warrant further agency response, citing the sources, 
authorities, or reasons which support the agency's position and, if appropriate, indicate 
those circumstances which would trigger agency reappraisal of further response."
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PREFACE TO COMMENTS
The Regional Commission on Airport Affairs (RCAA), a Washington corporation, 
is a non-governmental, citizen's organization, whose mission is to achieve a long-term 
integrated plan for air and surface transportation to meet the competitive needs of 
Washington state, and to achieve immediate and permanent reduction in noise and other 
adverse environmental impacts from commercial aircraft in the Puget Sound Region.
RCAA is governed by its Board of Directors, with input from numerous volunteers 
and from endorsing and supporting organizations in Pierce and King Counties. Its work is 
primarily performed by its volunteers. RCAA was created to be, and is, a coordinating and 
'umbrella' organization for citizen groups, institutions, organizations public and private, and 
individuals who support its mission statement.
Since its founding, RCAA has closely followed and actively participated, to the 
extent permitted, in such processes as the Port-PSRC Flight Plan study, the work of the 
State Air Transportation Commission, the work of the State High-Speed Rail Commission, 
the Expert Arbitration Panel review ordered by PSRC, and the present environmental 
review for the site specific third-runway proposal. Representatives of the organization have 
spoken and testified at numerous public hearings, have submitted their own studies and 
critiques, have encouraged others in similar activities. RCAA has commissioned expert 
studies of particular issues and has submitted those studies to appropriate official bodies 
involved in airport and transportation issues.
RCAA submitted extensive scoping comments at the start of the present 
environmental review and participated in the one occasion afforded for public input during 
the scoping process. RCAA's preparation and submission of the following comments on 
the Draft Supplemental Environmental Impact Statement for the Sea-Tac International 
Airport Master Plan Update is part of its ongoing concern with transportation issues and 
the adverse impacts of commercial aviation activities.
Introduction to comments of RCAA on the 
draft Supplemental EIS for Master Plan Update
A note on method: With stated exceptions, the abbreviations used in these comments 
are the same as those used in the draft Supplemental Environmental Impact Statement. 
Exceptions: 'POS' is sometimes used to mean 'Port of Seattle'; 'dSEIS" is used to refer to 
the draft Supplemental Environmental Impact Statement (the subject of these comments); 
'fSEIS' is used to refer to the final Supplemental Environmental Impact Statement to be 
issued in due course.
Our comments are numbered sequentially within each of the following categories, each 
of which includes discussion of related mitigation issues:
1.	Construction Impacts (see dSEIS sec. 5-4)
2.	Air Quality (see dSEIS sec. 5-2)
3.	Noise	(see dSEIS sec. 5-3)
4.	Wetland and Water Quality Impacts (see dSEIS sec. 5-5)
5.	Social and Socio-economic Impacts (see dSEIS sec. 5-7)
6.	Alternatives (see dSEIS sec. 1-3, Chap. 3)
7.	Other Comments
(A)	Planning Horizons
(B)	Surface Traffic
(C)	Cost
(D)	Methodological Concerns
(E)	Miscellaneous
8.	Request for Extension of Time to Provide Additional Comments
General Comments: We noted in our General Comments to the original draft EIS 
that the environmental consequences of the project are grossly understated, & that 
mitigation measures are utterly inadequate. Passage of time, and independent studies by 
disinterested experts (the Burien Impact Study team, for example), have only strengthened 
those conclusions.
Like its predecessors the DEIS and the FEIS, on almost every topic examined in which 
serious impacts on the surrounding communities are involved, the dSEIS does not meet 
minimum standards for accuracy, fairness, completeness, or technical competence. Major 
conclusions are stated as bald matters of fact, without citation to authorities. Important past 
& pending studies are omitted, and not even referenced. Permit applications submitted by 
the Port, and relevant reports and plans prepared by, or for, the Port are not mentioned. 
Documents are incorporated by reference under circumstances such that almost no 
readers could possibly become familiar with those documents (which, by the way, is a 
practice that we believe to be unlawful).
Concerns raised by us in our original scoping comments, and again in our comments 
to the DEIS, continue to be ignored. A clear example is our repeated request that 
projections not be expressed in terms of one absolute figure, but that ranges be presented, 
with analysis of probabilities. Yet throughout the dSEIS the reader finds projections 
expressed as single numbers when it is patently obvious that no reasonable person would 
stand behind such rigid projections. Issuing projections in the dSEIS without explaining 
their level of uncertainty is both unprofessional and misleading.
	Finally, we believe it is vitally important that the Final SEIS detail the commitments 
which the Port/FAA has provided to local cities, communities and residents to mitigate the 
impacts of the options proposed in the dSEIS. The mitigation promised by the Port of 
Seattle associated with its 2nd Sea-Tac runway expansion was not provided as promised. 
The impacts of this unmitigated damage have not been forgotten in these communities. 
We therefore believe that, prior to proceeding with discussions of any of the alternatives 
described in the Draft SEIS, the Port of Seattle/FAA should enter into binding agreements 
with local municipalities which dictate specific terms of how the impacts of the proposed 
actions will be compensated, and the mechanisms and means through which these 
programs will be accomplished in the affected communities and cities. 
RCAA COMMENTS ON DRAFT SUPPLEMENTAL IMPACT STATEMENT
PART 1: CONSTRUCTION IMPACTS
1-1. Truck Trips -- How Many? The discussion of truck trips for hauling fill 
material, found at p. 1-10 of the Summary, is unclear. Will the number of hauls and 
length of day during which loads are hauled be reduced? or not? The summary in 
the fSEIS should be clearer.
1-2. Truck Trips -- How Many? P. 5-4-4, first unnumbered paragraph, second 
sentence, refers to '109 hourly truck trips on all roads'. Compare to footnote 1, p. 5-
4-1, which seems to refer to 109 trips per day. Is it contemplated that there might be 
as many as 109 truck trips per day or 109 truck trips per hour? (The per-hour 
interpretation of-these ambiguities is strengthened by the reference to 1109 one-way 
peak hour truck trips' in the last full paragraph at p. 5-4-7.)
1-3. Truck Trips -- How Many? A table or graph might usefully be inserted in 
section 5-6 (A), showing anticipated numbers of trips per day for representative 
dates during the 5-year fill-haul period.
1-4. Truck Trips -- How Many? A table or graph might usefully be inserted in 
section 5-6 (A), showing anticipated numbers of trips per hour at the same dates 
used in constructing the table for trips per day suggested in the immediately 
preceding comment.
1-5. Truck Trips -- How Many? At p. 5-4-1, do the numbers in footnote 1 refer 
to daily trips? If so, the note needs to state that clearly.
1-6. Truck Trips -- Is It Trucks Only? The discussion of fill-hauling in the 
Summary, at p. 1-10, is couched in terms of truck trips. Is it not intended to use 
truck-trailer combinations for fill-hauling, & is not the discussion of numbers of trips, 
hours of operations, number of years needed for fill-hauling, all predicated on using 
truck trailer combinations?
1-7. Noise from Fill-Hauling. The Summary (p. 1-10) is silent as to any noise 
impacts from the fill-hauling operations. Surely some noise impacts are expected? 
The fSEIS should discuss this matter in the Summary.
1-8. Truck Trip Scheduling. Why will the fill-haul work peak at any particular 
year, and why the year 2000? (See sec. 5-4 (A), p. 5-4-2, second numbered item 
under first bullet point.)
1-9. Tables Need Work. The table numbering in section 5-4 needs to be 
changed in the fSEIS, to include numbering of the unnumbered table now appearing 
on p. 5-4-3, which should be Table 5-4-1, & then renumbering all further tables in the 
order in which they appear. It is confusing, & inappropriate, to have Tables 5-4-6 & 
5-4-7 appear before Table 5-4-1, especially when no page numbers are provided 
when the tables are discussed in the text.
1-10. Construction Noise Impacts -- Need for Mapping. The noise 
subsection, 5-4 (D), of the Construction Impacts section, does not present a 
comprehensible picture of the noise impacts to be received by properties adjacent 
and near to truck routes, nor does it present a comprehensible picture of the 
present and projected land uses along the haul routes. The fSEIS should present 
clear, detailed, and understandable maps, with 60 and 65 LDN noise contours -- 
existing and projected -- for each haul route. The present discussion does not permit 
policy-makers or citizens to reach any intelligent decisions on possible measures to 
mitigate noise by route selection or alteration, by restraints on hours of use, or 
otherwise, for one cannot tell what noise will be received by whom, when or where.
1-11. Other Construction Impacts -- Need for Mapping. Other construction 
impacts, such as general traffic congestion, dust (see subsection (E)), ground 
vibration, and restricted access to and from private property, should also be 
displayed in map format in the fSEIS. It would be best if the same base maps were 
used for all presentations of impacts, to facilitate comparability and assessment of 
cumulative impacts.
1-12. Combined Construction Impacts -- Better Identification of Impacted 
Areas. The mapping suggested in the two immediately preceding comments would 
perhaps serve as a useful way in which to identify more clearly those locations that 
might experience excessive detrimental impacts. The present text discussion at 
subsection (F) would be much more useful with accurate mapping, and with text 
discussion that could develop from study of such maps.
1-13. Construction Noise Impact -- Truck Noise Combined with Aircraft 
Noise. Is it accurate to assume, as does the first bullet point, p. 5-4-14, that there is 
no impact from truck noise if there is pre-existent aircraft noise? Isn't noise 
cumulative?
1-14. Construction Noise Impact -- Night-time noise & traffic. 
(a)	Apparently it is planned to run the fill-hauling vehicles well into the evening 
hours, and again early in the morning. We suggest that this will not do; further 
thought needs to be given to restricting the hours for major hauling work that 
would impact residential & health-care properties.
(b)	The fSEIS should present clear schedules, including proposed daily hours 
of operation, for the fill-hauling activity on the various routes under consideration, 
to permit all concerned to understand the full impacts of this massive activity.
1-15. Construction Noise Impact -- Air Quality. The proposed, soon-to-be-
adopted US EPA standard for airborne particulate matter between 2 and 10 microns 
in diameter should be addressed in subsection 5-4 (7).
1-16. Construction Impacts -- Lack of Quantification in Discussion of 
Social Impacts. All of the discussion in subsection 5-4 (F) should quantified.
1-17. Construction Impacts -- Mitigation measures inadequate. As to 
subsection (J), p. 5-4-19, we suggest that acquisition of some properties will not 
mitigate impacts on other properties, and a complete mitigation program needs to 
be developed in cooperation with the relevant municipalities, neighborhood & local-
business groups, schools, and residents and other occupants.
PART 2: AIR QUALITY
2-1. Air Quality -- Health Consequences. The dSEIS is silent as to air and water 
pollution by particulate matter emitted from aircraft operations related to Sea-Tac.
(a)	How much, and what types of, particulate matter is expected to be emitted 
as the result of aircraft operations related to Sea-Tac, at each measuring date 
(including year 2020)?
(b)	What literature has been reviewed in this regard? Cite it.
(c)	What are the anticipated health consequences from such pollution?
(d)	The dSEIS is silent as to the proposed change by the US EPA of its 
standards for particulate matter, which, as the preparers of the dSEIS surely 
know, will bring particulate matter in the size range of 2.5 microns within EPA's 
standards. What will the consequences be for Sea-Tac airport and its environs 
when the new PM standard comes into effect?
(e)	The dSEIS is silent as to the proposed change by the USEPA of its 
standards for ozone, which, as the preparers of the dSEIS surely know, will 
tighten the ozone standards considerably. What will the consequences be for 
Sea-Tac and its environs when the new ozone standard comes into effect?
2-2. Air Quality -- Health Consequences. We note that there is not a word in the Air 
Quality section of the dSEIS about the health consequences of the air pollution to be 
anticipated from Sea-Tac operations in the future.
(a)	What are the anticipated health consequences from Sea-Tac pollution 
(including exhaust from aircraft using the facility)?
b)	What literature has been reviewed in this regard? Cite it.
(c)	What are the (alternative) mitigation measures proposed?
(d)	What is the level of increased Cancer Risk to the population associated 
with the Alternatives discussed in the SEIS. Provide the study which was done to 
assess the increased level of cancer risks due to chemical and air pollution 
impacts from Sea-Tac airport.
2-3. Air Quality -- Health consequences. We note that there is no discussion in the 
Air Quality section of the SEIS of the health consequences of aerial fuel dumping 
associated with Sea-Tac operations. It is well known that such dumping is a common 
phenomenon, especially over Beacon Hill and Rainier Valley in Seattle. The SEIS admits 
fuel dumping events occur from aircraft operating at Sea-Tac. The March 1, 1997 edition 
of the Highline News reports that the FAA recorded an incident of fuel dumping which 
occurred on July 8, 1996. 
(a)	Do the preparers disagree with the foregoing statements, & if so, in what 
particulars & on what factual basis (citing available documentation)?
(b)	What is the projected amount of future fuel dumping associated with Sea-
Tac operations?
(c)	What are the anticipated health consequences from future fuel dumping 
associated with Sea-Tac operations?
(d)	What literature has been reviewed in this regard?
(e)	What (alternative) mitigation measures are proposed?
2-4. Air Quality -- Will Aircraft Emissions Increase throughout the Planning 
Period? It appears from the last sentence of sec. 5-2 1 (p.5-2-2), and from Exhibit 5-2-3, 
p. 5-2-4, that the preparers of the dSEIS expect aircraft emissions of carbon monoxide, 
ozone, and hydrocarbons to increase every year to the year 2010, even though emissions 
of these substances from all sources in the so-called Region will decrease. Is this a correct 
understanding? If not, what is being forecast in this regard?
2-5. Air Quality -- Chief Executive’s certificate. See sec. 5-2 7, p. 5-2-12.
(a)	Does the statute (49 USC 47106(c)(1)(B) provide, as this section implies, 
that the chief executive officer of a State may delegate his or her authority to 
make the statutory certificate? If so, cite and quote the exact language.
(b)	Did the letter of 20 December 1996 referred to p. 5-2-12 state that the 
director of the Department of Ecology was acting for the Governor 
(Washington's chief executive officer), under the provisions of the above-cited 
Federal statute. Quote the exact language.
(c)	What state-law authority permits the Governor to delegate authority under 
the cited Federal statute? Cite and quote.
2-6. Air Quality -- Projections. Other commenters have advised us that the figures 
for NOx emissions in the DEIS, FEIS, and dSEIS seem to bear no clear relationship to the 
numbers of operations projected, the known emission characteristics of the fleet mix, or 
other relevant factors. It seems that despite ever-increasing levels of operations in fact and 
projected in the future, NOx emissions do not rise proportionately. Comment and explain. 
Kindly set out the various NOx predictions put forward at various stages of this 
environmental-review process (preferably in tabular or graphic form), and explain the 
assumptions underlying the various projects.
2-7. Air Quality -- Particulate Emissions. Are particulate emissions from Sea-Tac 
aircraft operations considered in the discussion of air-quality issues associated with third-
runway construction, or, have those emissions been removed from the relevant models?
2-8. Air Quality - Conformity provisions. We do not believe that the project 
will be in compliance with the general conformity provisions of the Clean Air Act for 
the following four reasons:
1. The project de minimus levels would be violated if proper input had been used in 
the modeling of impacts.
2. The SEIS indicates several locations where pollutant concentrations will exceed 
the National Ambient Air Quality Standards for NO2, CO and PM10.
3. The intent of the SIP is to reduce emissions and achieve attainment and 
maintenance of the standards.  This project increases emissions of CO and ozone 
precursors without any control measures to reduce airport related emissions which 
could jeopardize the maintenance status of the area. The potential for a new 
violation of the PM10 standard from construction activities and exceedances of the 
new ozone and PM2.5 standard would also violate the Clean Air Act and general 
conformity regulations.
4. All predicted exceedances of the federal standards are within areas of public 
access and represent ambient locations and therefore, must be mitigated.
The fSEIS should discuss compliance with conformity regulations and mitigation.
PART 3: NOISE
3-1. Is the Port Serious About Noise and Noise Mitigation?
(a) On page 5-3-2 the dSEIS states: "On the basis of scientific surveys and 
analysis, the FAA has established 65 DNL as the critical level for the 
determination of noise impacts." Authorities cited in support of this claim are 
"Federal Aviation Administration Part 150 and the Federal Interagency 
Committee on Noise" (FICON). The FICON document referred to fails to 
establish or cite authorities establishing 65 DNL as the threshold for health 
effects caused due to noise.(p.2-4). 14 CFR part 150 contains no provisions 
establishing noise levels of 65 DNL as a threshold for determining health effects 
caused due to noise. The Noise Expert Panel's Final Decision similarly 
challenges the dSEIS's bald assertion that 65 dB DNL is the threshold for 
determining impacts on populations exposed to noise. In their Final Decision on 
Noise Issues" issued March 27, 1996 the Panel wrote: "The Port cites the 1992 
FICON Report . . . since that FICON Report was issued, a considerable body of 
medical literature has been developed, documenting the adverse effects of 
exposure to noise levels in the 65 to 75 dB range, including psychological 
distress, loss of concentration and reading comprehension, and other 
physiological effects." (p.20)  The fSEIS should cite the "scientific surveys and 
analysis" which the dSEIS purports establish 65 dB DNL as the critical level for 
determination of populations affected by noise?
(b) In our DEIS comments (COMMENT IV-1-7) we asked for a comprehensive 
search of the scientific literature which cited all references, documentation, and 
the scientific basis explaining the DNL 65 establishes the threshold of impacts. 
No response was provided. We repeat our earlier comment and request a 
response in the fSEIS.  As we noted in our earlier comments, in a recent 
rulemaking,    the FAA apparently endorsed the EPA's position that it should 
"modify the definition of (the noise study area) so as to eliminate the perception 
that the area within the DNL 65 dB contour is the sole area to be considered for 
noise impacts, while retaining the flexibility of extending beyond the DNL 65 dB 
contour." 
(c) Additionally, we provided in our earlier comments on the Draft EIS a copy of 
the results of a search of scientific, medical and technical literature on the health 
effects of airport noise. The results of this literature search turned up over 400 
separate citations of publications of potential interest to investigators studying 
this issue. Since our search additional information has come to light. We request 
that the fSEIS review our previous DEIS comments as well as recent literature 
concerning aircraft noise and request that it cite all references, documentation, 
and the scientific basis explaining its assertion that DNL 65 establishes the 
threshold of aircraft noise impacts. 
(d)	How much of its own money does the Port of Seattle (POS) plan to spend 
for noise mitigation? It seems from p.1-14 that the insulation programs are 
restricted to activates financed by FAA per Part 150 studies. Please do not 
include funds received from other governmental bodies in the response.
(e)	For what noise-mitigation activities will the Port of Seattle's (POS) own 
money be spent (if any of the Port's money will be so spent)?
(f)	What is the timetable for implementation of the noise insulation program. 
Include a table showing the amounts in dollars which will be allocated year by 
year for noise remedy programs through the year 2020.
(g)	Include a copy of the interlocal agreements signed by local cities, including 
Burien, Des Moines, Federal Way, Tukwila, Normandy Park, and SeaTac and 
local school districts, including the Highline School District, which contain funding 
commitments for noise programs, which will be executed prior to authorization of 
the 3rd runway.
3-2. More Maps Needed. SEL contour maps should be prepared & included in 
the fSEIS, comparable to the 65 DNL maps (Exhibits 5-3-1 & seq.) depicting the 
100 dB, 90 dB, and 80 dB SEL noise contours for existing conditions as well as all 
proposed options 
3-3. Estimated Population Impacted by Noise.
(a)	The assertion in 5-6 1 (B), and in the associated tables (Tables 5-6-1 
through 5-6-3), that with increased airside activity under the preferred alternative 
(100,000 operations per annum, is it not?) there will only be another 1280 
people adversely affected (i.e., within 65 LDN contours). This assertion is not 
supported by factual studies or comprehensible explanations. Please provide 
both.
(b)	If activity increases of 20 or 25 percent don't budge the 65 LDN contour by 
more than a minor fluctuation (probably within the margin of observational error), 
the logical conclusion is that the LDN metric is structured and computed in such 
a way as to suppress recognition of actual noise impacts. If that is a wrong 
explanation, provide the correct one, if there is one.
3-4. Latest INM Noise-Modeling Program Should Have Been Used. The DNL 
noise contours were developed on the basis of the FAA's INM Version 4.11 noise 
modeling program. This version of the INM does not represent the best available 
methodology for modeling noise impacts. Version 5.0 of the INM program has been 
available for years. Version 5.1 of the INM was released prior to the announcement 
that a dSEIS would be issued. We find it appalling that the noise analysis for a 
proposed project whose cost and impacts amount to over $7 billion dollars, is being 
assessed by a consultant paid nearly $5 million dollars, apparenlty too cheap to 
purchase the latest revision of the INM noise modeling program, costing some $250 
dollars. Because  the following comments reveal that the noise analysis in the dSEIS 
is fatally contaminated with faulty assumptions and will need to be redone, the 
revised analysis in the fSEIS should utilize the current version of the INM. We note 
that the latest version of the INM (5.1) is capable of directly using INM version 4.11 
files, and files from earlier INM versions can be used with minor changes.
3-5. Modeling Assumptions Should Have Been Stated. 
(a)	The dSEIS failed to include the modeling assumptions used in producing 
the noise contour maps in the noise analysis. The Port/FAA have been 
previously criticized for failing to produce the data assumptions used to produce 
noise exposure maps. In their "Final Decision on Noise Issues" issued March 27, 
1996 the PSRC Expert Panel wrote: "despite the Panel's specific request, the 
Port failed to supply detailed information on the assumptions and adjustments it 
used when it applied the INM to compute changes in (i) DNL contours and (ii) 
the population adversely affected by noise . . . ". [p.15] The following data 
assumptions used in generating the INM noise contours and analysis are 
examples of what should have been included in the dSEIS and should be 
provided in the fSEIS:
1.		The definition of the approach and departure flight tracks.
2.		Verification of the selected flight tracks with actual operation conditions, 
		correlation with radar data, etc.
3.		Assignment of flight track segments
4.		Identification of Aircraft types
5.		Maximum gross takeoff weight
6.		Maximum gross landing weight
7.		Static thrust, and operational thrust levels 
8.		Noise curve selected for specific aircraft types
9.		Flight profile of each aircraft modeled
10.	Identification FAA approval for non-standard (including NDAP) INM
		profiles use in model
11.	Annual number of operations of each particular type of aircraft.
12.	The type of engine associated with each type of aircraft modeled.
13.	Data assumptions used for modeling taxiway noise
14.	Data assumptions used for modeling run-up noise
15.	Source data used to estimate affected populations
16.	Source data for base map including topographical data
(b)	We note that the absence of the modeling assumptions makes it 
impossible for the reader to analyze the reliability of the resultant noise analysis. 
We noted this in our scoping comments, and repeated this requirement later in 
our comments on the draft EIS, that inclusion of the data assumptions 
associated with analyses contained in the EIS documents was a mandatory 
requirement to enable the public to make informed comments. This information 
was not provided in the final EIS and again has not been included in this 
document. Please provide it in the FSEIS.
(c)	Our ability to make informed comments on the noise analysis in the dSEIS 
has been further impaired by our inability to obtain the information from the 
author of the SEIS through request made under Washington State's Open 
Public Records Act. Attached as an Exhibit to these Comments is a copy of a 
letter dated 7 March 1997 from Port of Seattle Planning Program Manager 
Diane Summerhays, stating the information which provides the basis for the 
modeling assumptions in the dSEIS NEMs is not available from the Port of 
Seattle, a preposterous assumption since the SEIS is a joint Port of Seattle/FAA 
publication.
3-6. NEM for 1996 Should Be Included. A noise exposure map (NEM) for the 
year 1996 rather than 1994 should have been included in the fSEIS to allow a 
comparison between most recent noise exposure conditions as compared to the 
noise exposure predictions made for the years 2000, 2005, and 2010, &c.; The total 
number of aviation operations in 1996 (395,000) exceeded the year 1994 operations 
(345,052) by 44,957 operations. We note that the 1996 noise exposure map 
produced during the recent Part 150 Update assumed predicted rather than actual 
number of flight operations, &c;, for 1996 and therefore would not suit as a reliable 
reference. A noise contour map showing actual noise exposure conditions at Sea-
Tac for 1996 is required to made a reliable comparison. Please provide it in 
response to this comment.
3-7. NEM's Depicting Seasonal Variations of Air Traffic Should Have Been 
Provided in the dSEIS The INM User's Guide states "It may be useful or necessary 
to perform supplemental analysis for different times of the year or other time periods. For 
Example, a supplemental analysis may be necessary for the spring season as compared 
with fall and winter, if significant changes in fleet mix, flight operations, or flight tracks 
are anticipated." (INM Version 5.1 User's Guide, p.2-2) Sea-Tac airport experiences 
significant shifts in flight operations and flight tracks through the year. The 1991 Part 
150 Update reported that in 1990, Sea-Tac airport was in South flow conditions 69% 
of the year and in North flow conditions 31% of the year. (p.24) During the Months of 
January through June and October through December SeaTac airport was in South 
flow conditions 76% of the time. During the months of October and November Sea-
Tac was in South flow over 92% of the time. NEM's depicting seasonal noise 
exposure should have been developed in the dSEIS and should be included in the 
fSEIS. Please provide them in response to this comment.
3-8. 65 dB Noise Level Mischaracterized. On p. C-3-8, the dSEIS states that 
65 dB is a relatively low environmental noise level". In their "Final Decision on Noise 
Issues" issued March 27,1996 the Noise Expert Panel found "a considerable body of 
medical literature has been developed, documenting the adverse effects of 
exposure to noise levels in the 65 to 75 dB range, including psychological distress, 
loss of concentration and reading comprehension, and other physiological effects." 
Panel Order, p. 20. Cite the authority for the assertion in the dSEIS or remove it 
from the final SEIS.
3-9. Correlation of Noise Exposure Map Contours with Port Remote Noise 
Monitoring System Data. The Port of Seattle maintains 11 separate remote noise 
monitoring system (RMS) stations in areas surrounding Sea-Tac airport. These 
stations measure DNL (Day-Night average noise level) as well as time above (TA) 
noise metrics, single event level (SEL) as well as other metrics. Remote NMS data 
recorded for the year 1996 should have been presented in the dSEIS and correlated 
to the 1996 NEM for the base year study. The compared noise levels should include 
the DNL, and time above (TA) as well as the single event level (SEL) metrics 
recorded at each of the eleven (11) RMS stations. A table should be included 
comparing the respective DNL, TA and SEL metrics from the RMS system with the 
level predicted in the INM model.  
An error analysis showing the statistical correlation between the predicted INM 
contours and the noise measurements recorded through the Port's Remote RMS 
should also have been included in fSEIS noise analysis. Provide this comparison 
and analysis in the fSEIS.
3-10. The INM Predictions of SEL are Invalid. The INM was not designed for 
single-noise event prediction., but rather for estimating long-term average input 
data. The FAA's INM User's guide states that comparisons between measured data 
and INM calculations must be considered when modeling SEL noise levels with the 
INM. (Integrated Noise Model (INM) Version 5.1 User's Guide, p.2-3) The dSEIS 
contains no comparison between actual actually measured SEL noise levels and 
SEL noise levels predicted using the INM noise modeling program for the base year. 
The fSEIS should provide this and an alternate methodology for predicting single 
event noise impacts for future years and include contour maps depicting future year 
SEL noise conditions.
3-11. Questionable INM Input Assumptions Concerning Utilization of 
Runway
fSEIS
(a) The flight track for jet departures in Table C-3-16 indicates that the utilization 
of runway 16X for departures of heavy aircraft (exceeding 300,000 lbs.) under 
north flow conditions is estimated to be 1% for each of three (3) departure flights 
tracks (HT11, HT17, and HT33) and that the noise impacts of the third runway 
are based on the assumption that it would be utilized by operating departing 
flights along only one flight track which would constitute only 13% of the airports 
operations. Please reconcile the proposed utilization of these runways with the 
cost-benefit analysis which should also be provided in the fSEIS. Indicate in the 
comments the section number where the cost-benefit analysis assuming this 
runway utilization can be found.
(b) Under south flow conditions the dSEIS assumes use for runway 16X (third 
runway under north flow conditions) is 1% for each of three new flight tracks 
under both day-time and night-time operations. The utilization of the third runway 
under south flow conditions is 13% for one individual flight track under south flow 
conditions. Please reconcile the proposed utilization of these runways with the 
cost-benefit analysis which should also be provided in the fSEIS. Indicate in the 
comment the section number. where the cost-benefit analysis assuming this 
runway utilization can be found.
(c) The allocation of usage of the third runway under south flow conditions shows 
one flight track (TOl) accommodating 2% of the operations of the 3rd runway of 
heavy aircraft (exceeding 300,000 lbs.) along only one flight track whose 
operations would 3% of the airports operations. Table C-3-16 makes similar 
presumptions for other aircraft types. Evaluation of noise impacts for jet aircraft 
weights less than 300,000 lbs. are based upon the assumption that the third 
runway would be utilized by aircraft operating with use of three separate flight 
tracks (JTll, JT15, and JT 33), each of which would utilize only 1% of Sea-Tac 
Airport's flight operations. Under south flow conditions the dSEIS bases its noise 
prediction on the assumption the third runway would be utilized by jet aircraft 
(weighing less than 300,000 lbs.) operating with use of one flight track, whose 
operations would constitute only 2% of Sea-Tac Airport's operations. The noise 
analysis for the new runway for the year 2010 also estimates that the noise 
impacts based on the assumption that the third runway would be used by 
propeller aircraft less than 1% of the time along three flight tracks under north 
flow conditions (PT11, PT13, and PT 15), while the noise assessment is based 
on projections that aircraft operations of approximately 2% of Sea-Tac’s 
operations would occur under south flow conditions. Please reconcile the 
proposed utilization of these runways with the cost-benefit analysis provided in 
the fSEIS. Indicate in the FEIS comments the section where the cost-benefit 
analysis assuming this runway utilization can be found.
3-12  Prefatory note on sections 3-13 - 3-25. Specific concerns about the 
assumptions being made in the INM which have not yet been reported for public 
review and comment, and are requested to be provided in the fSEIS are as follows:
3-13. Estimates of Affected Population. During the Puget Sound Regional 
Council's Expert Panel Hearings last year Dr. Sanford Fidell noted that "adjustments 
on the order of 2 dB made by the Port to reconcile differences between measured 
and predicted SEL values "could easily lead to errors as great as thousands of 
people in estimates of populations exposed to similar noise levels in different time 
periods." (Testimony Presented by Dr. Sanford Fidell to the Expert Arbitration Panel 
on Noise and Demand/System Management on Phase II Noise Issues, p.2).
(a)	Provide documentation from U.S. Census Bureau records including the 
census tract information used to estimate the total population affected by noise 
levels of 55 dB, 60 dB, 65 dB, 70 dB, and 75 dB DNL.
(b)	Provide a description of the analysis used to predict the impacted 
population in various noise exposure zones (55-60 dB, 60-65 dB, 65-70 dB, 70-
75 dB, 75+ dB, &c.;) in the fSEIS. Include the analysis used to determine the 
margin of error of the estimation of the impacted populations with confidence 
intervals and sensitivity tests to support the statistical reliability of the dSEIS 
data. 
3-14. Ground Noise. Previous Sea-Tac noise exposure maps (NEMs) have not 
included the impacts of ground noise from Sea-Tac airport. Recent versions of the 
INM (Versions 3.9 and later) are capable of integrating runup noise and taxiway 
noise into the NEMs. Aircraft runup noise and taxiway noise parameters were not 
included in the input files used to generate the Year 1990 and 1996 noise exposure 
maps (NEMs) produced in Sea-Tac's last (1991) Part 150 Update. The 1991 study 
did find that DNL noise levels at remote monitoring stations RMS 5 (S.171st & 10th 
Avenue S.) and RMS 10 (S.192nd & 11th Avenue S.) located immediately West of 
Sea-Tac read higher than predicted by the 1990 NEM by 3.1 and 1.7 decibels, 
respectively. A professional engineer conducted an independent study which 
measured Sea-Tac's 65 dB DNL noise contour as far as 4,000 feet west of the 
location shown on the Port's 1990 NEM.(Sea-Tac Noise Study prepared for RCAA 
by Errol Nelson PE, January 1993 previous submitted by the RCAA). The SEIS 
should publish the data assumptions used to model runup noise and taxiway noise 
in the INM noise exposure maps published in the fSEIS.
3-15. Assumptions about Future Noise Levels Erroneous. Section 6 (p. 5-
3-7) makes two absurd assumptions. First, that "Future impacts will be less than 
the current noise exposure regardless of which Master Plan Update alternative is 
pursued", and second, "The 'With Project' alternatives would result in slightly 
greater noise exposure in comparison to the Do-nothing Alternative. Justify these 
assumptions or correct them.
3-16. Noise Barriers. Strategies to reduce noise impacts on surrounding 
communities utilizing noise barriers should be considered in the fSEIS. We note the 
FAA recently approved plans for the construction of a noise berm on the western 
edge of airport property in Paine Field’s Part 150 Master Plan and Noise Study 
Update issued October 1996. The noise berm is being provided to "protect 
residences just west of Paine Field Boulevard from experiencing higher aircraft 
noise than they presently experience. Similarly, the construction of a noise berm on 
the West side of Sea-Tac Airport would shield residents in the West area of the City 
of SeaTac, and residents of Burien and Normandy Park from harmful and annoying 
noise caused by runups, takeoffs, and landings. Indicate what written financial 
commitments the Port of Seattle has made in conjunction with the construction of 
noise berms for attenuation of aircraft noise from Sea-Tac airport. Include 
documentation evidencing the Port's financial commitment in the final SEIS. Provide 
maps showing proposed berms. Provide drawings showing typical berm 
construction, as planned. 
3.17.	Levels of Annual Operations Used in Future-Year NEMS. Total number of 
operations projected for future-year periods are problematic in the dSEIS. Currently, 
there exist at least a dozen projections of air traffic activity at Sea-Tac for the year 
2000. Forecasts of the total number of Sea-Tac airport air carrier operations in the 
year 2000 have ranged from 260,810 operations per year to 452,800 operations per 
year, a variation of 191,990 operation per year. The latest Terminal Area Forecast 
for Sea-Tac airport developed by the Federal Aviation Administration should be 
utilized in developing the future-year noise exposure maps in the SEIS. 
3-18. Verify Aircraft Flight Profiles Used in the INM. A 1981 FAA study ("A 
Comparison of FAA Integrated Noise Model Flight Profiles with Profiles Observed at 
Seattle-Tacoma Airport", George W. Flathers, December 1981, Report No. FAA-
EE82-10) determined that aircraft flight profiles at Sea-Tac were not consistent with 
the profiles used in the current version of the INM noise modeling program. This 
study noted that the departure profiles used in the INM "were constructed under the 
assumption that, for all aircraft types, airlines employed the FAA noise abatement 
departure profile as outlined in AC 91-53. However, the observed data for the low-
bypass-ratio engined aircraft in the study (DC-9, B-737, B-727) suggested that for 
these three types of aircraft, this may not be the case." 
The 1991 Part 150 study assumed that Stage 2 aircraft followed the FAA's 
suggested Noise Abatement Departure Profile (AC 91-53) which calls for thrust 
reduction after takeoff upon reaching 1000 feet elevation. (Noise Exposure Map 
Update: 1991 prepared by the Port of Seattle April 1992, p.54) However, no 
substantiation that these procedures were being followed by the airlines serving 
Sea-Tac was provided in the update.
We further note that the FAA now requires approval of Noise Abatement 
Departure Profiles (NADP) in the INM model. The INM User's Guide specifically 
states: "INM 5.1 does not contain pre-approved NADP's . . .". (p.2-2) No 
documentation was provided in the dSEIS indicating the FAA has approved NADP 
flight profiles for use in the INM. 
Evidence including tower orders, adoption of standard or NADP operations for 
departures by the scheduled air carriers, radar data, etc. should be provided to 
corroborate that operational assumptions used to predict noise exposure in the 
NEMs are actually being followed by aircraft at Sea-Tac. The fSEIS should contain 
this documentation. Additionally, publish NEM's which show alternative noise 
contours assuming (1) the use of NADP in the INM model and (2) assuming 
standard departure procedures. Publish documentation provided by FAA approving 
the use of NADP flight profiles in the NEMs.
3-19. Verify Fleet Mix Assumptions. Careful consideration must also be given to 
the parameters used in the INM noise model used to estimate fleet mix. The 1996 
NEM produced in the recent Sea-Tac Airport Part 150 update assumed Stage 2 
aircraft operations constituted 14.73% of Sea-Tac's total flight operations. According 
to the Port of Seattle's Noise Abatement office the percentage of Stage 2 jet 
operations during 1996 exceeded this level. The fSEIS should provide the 
assumptions underlying its predictions of future aircraft fleet mixes.
3-20. Verify Aircraft / Engine Types Used in the INM. Careful verification of 
aircraft types and engine models selected for use in the model should be made by 
the consultant. The INM noise modeling program allows the user to select a noise 
curve for each type used in the INM to match a specific aircraft/engine configuration. 
Noise levels produced by the same type of aircraft vary considerably depending on 
engine type. For example, a model 737-300 equipped with JT8D-15QN engine is 
5.6 dB louder on takeoff than the same model aircraft equipped with JT8D-7QN 
engines (Estimated Airplane Noise Levels in A-Weighted Decibels, AC No. 36-3F 
published by FAA, August 10, 1990, p.23).
Noise levels on departure vary by as much as 10.2 dB comparing a Stage 2 
727 outfitted with JT8D-17RQN engines compared to a 727 equipped with model 
JT8D9FCD engines. Accumulation and propagation of error through the INM noise 
model should be limited by verification of aircraft type and engine parameters. The 
fSEIS should provide .documentation that verifies that the engine configuration 
assumed comports with the specific aircraft type designating in the INM used in 
generating noise exposure maps for Sea-Tac.
3.21.	Verify Statistical Reliability of INM Data. During their recent (1996) 
investigation into the Port of Seattle's Noise Exposure Maps (NEMS) the Expert 
Arbitration Panel requested that the Port (i) present information on confidence 
intervals to support the statistical reliability of its data, (ii) provide documentation of 
the assumptions and adjustments it made when developing the INM contours, (iii) 
show the assumptions used for estimating impacted populations, and (iv) produce 
sensitivity tests to evaluate the effects of these assumptions. The Port did not 
comply with these requests (p.14). The above information is similarly missing in the 
analysis in the dSEIS. Provide this analysis in the fSEIS.
3.22.	Include Noise Contributions from Other Area Airports in NEM's. The 
Noise Exposure Maps should integrate the noise level contribution from other area 
airports, particularly Boeing Field, located approximately six (6) miles north of Sea-
Tac. The DNL values of noise generated from Sea-Tac should be added to the DNL 
noise levels produced from Boeing Field to produce and accurate and realistic 
assessment of the combined noise impacts of these two airports upon the citizens in 
the south Seattle, south King County areas. (See p. 6-3 of INM User's Guide.)
3.23.	Base Map. Version 5.1 of the INM is capable of generating noise contours on 
U.S Coast and Geodetic Survey (U.S.G.S.) maps which model the topographical 
feature of land surrounding the airport facility being modeled. The fSEIS should 
present NEMs that incorporate the topographical features of U.S.G.S. maps into the 
noise model and calculate DNL, TA, and other metrics each of the locations 
modeled.
3-24. Noise Abatement Departure Profile. The Noise Expert Panel also 
recommended that the Port/FAA evaluate the utilization of noise abatement 
departure corridors to minimize aircraft noise impacts and "Evaluate, with FAA and 
community input, the potential net benefits of a noise abatement departure profile 
employing a steeper angle of climb, coupled with an expanded residential acquisition 
and insulation program if, as a result of a steeper departure profile, the 75 dB DNL 
contour expands in the immediate vicinity of the airport while areas farther out receive 
benefits."
Provide an analysis of the effects on noise exposure of the population in the 60 dB 
DNL and above noise affected population through adoption of noise abatement 
departure profile employing a steeper angle of climb. Include revised noise contour 
maps for the future year 2000, 2010, and 2020 showing the locations of the 60 dB, 
65 dB, 70 dB, and 75 dB DNL as well as the 70 dB, 80 dB, and 90 dB SEL noise 
contours surrounding Sea-Tac airport based upon the level of operations projected 
in the SEIS using the noise abatement departure profiles recommended by the 
Noise Expert Panel.
3-25. Preferential Runway for Noise Abatement. The Noise Expert Panel also 
recommended that the Port/FAA evaluate the utilization of a preferential runway 
during periods of low activity:
e.	Evaluate, with FAA and community input, the potential net benefits of 
preferential runway use during "low activity" periods (would more use of the east 
runway, for example, result in reduced overall population noise exposure?) --
coupled with an expanded residential insulation and acquisition program, as 
needed.
Include in the SEIS an analysis of the potential changes in noise impacts which 
would result through the preferential use of runways during low activity period to 
achieve a reduction in noise impacts.
3.26. Part 161. Recent policy shifts by the FAA have indicated increased 
flexibility by the FAA in implementing enhanced noise reduction programs at airports 
adopting enhanced noise restrictions under Part 161 regulations. Recently in 
connection with its approval of a Part 150 Noise Compatibility Program for Pease 
International Airport in New Hampshire, the FAA approved funding for a Part 161 
study as an element of the airport's Part 150 program (Airport Noise Report, April 
15, 1996). Citizens and local municipalities surrounding Sea-Tac airport have 
suggested that the Port of Seattle engage in a Part 161 study in conjunction with a 
Part 150 Update Study currently underway at Sea-Tac. (See also ACC testimony 
before Noise Expert Panel dated Feb. 16, 1996.) In November 1995 the King 
County Council adopted Resolution No. 9709 which funded a Part 161 program to 
establish current and future noise restrictions at Boeing Field. The final SEIS should 
comment on the impact future Part 150 and Part 161 programs will have upon 
future development at Sea-Tac Airport.
3-27. Social Surveys. In its Final Decision on Noise Issues issued March 26, 
1996 the Expert Panel recommended that social surveys be utilized to evaluate 
community attitudes concerning the impacts of airport noise upon citizens. The 
Panel recommended "That the Port and the organizations representing the affected 
communities jointly sponsor social surveys at regular intervals to assess the 
effectiveness of future noise abatement and mitigation measures in terms of perceived 
noise impacts. 
We concur with the view expressed by the Port's noise consultants in the 1993 
AIRTRAC Final Report (p. 3-33): 'The way to avoid incorrect predictions of community 
response to a ... [noise reduction] action is to ask the community directly how it feels 
about a particular airport action and the proposed mitigation program connected to it." 
Explain why the Port/FAA have not conducted the social surveys recommended by 
the Expert Panel as part of its review of environmental and social impacts.
3-28. School Sound Insulation. The Expert Panel recommended:
"That, with respect to the Noise Remedy Program, the Port take the following 
actions:
a.	Begin a rapid, full-scale program of school insulation as soon as the 
impasse with the Highline School District is resolved, with the maximum feasible 
commitment of re-sources and the earliest possible completion schedule."
Include a copy of the written financial commitment the Port of Seattle has made in 
conjunction with the insulation of schools in the Highline School District.
3-29. Public Buildings Sound Insulation. The Expert Panel recommended:
"That, with respect to the Noise Remedy Program, the Port take the following 
actions:
b.	Complete the "sensitive-use" public buildings insulation pilot studies and 
fund the full program envisioned in the Noise Mediation Agreement, as well as a 
program for insulation of multi-family dwellings, with an aggressive schedule to 
allow completion as soon as possible. The Port Commission is on record as 
committed to these programs."
Indicate what written financial commitments the Port of Seattle has made in 
conjunction with the insulation of public buildings. Include in the fSEIS documentation 
evidencing the Port's financial commitment.
3-30. Expand Residential Acquisition Program. It is significant to point out 
that the boundaries of the Port of Seattle's present noise remedy program still 
remain based upon the Port of Seattle's earlier 1982 estimate that only 260,810 
operation per year would occur at Sea-Tac in the year 2000. The annual operations 
at Sea-Tac currently outstrip the year 2000 operation prediction by approximately 
136,000 operations per year. The Expert Panel noted that the expected  reduction in 
total population exposed to noise levels of 65 dB DNL and above has not occurred  
as predicted.  The Panel recommended: 
"c.	Evaluate the possibility of an expanded residential acquisition program 
offering more of the most severely impacted people the buy-out option, even if 
no additional Federal money is made available for this purpose. While relocation 
is not desired by all (nor easy for anyone), the environs of a major airport are 
plainly not the best location for residential neighborhoods."
The fSEIS should indicate what steps the Port  plans for expansion of its residential 
noise remedy program eligibility area to mitigate the impacts of residents. Indicate 
what written financial commitments the Port of Seattle has made in conjunction with 
the expansion of the Port of Seattle's noise insulation program. Include 
documentation evidencing the Port's financial commitment in the final SEIS.
3-31. The fSEIS appears to assume the majority of housing construction in this 
region is cold weather construction. It is not. Homes here, for example, do not have 
the insulation, storm and or thermal windows and other cold weather construction 
techniques found in other cold-weather areas of the country or the air conditioning 
found in warm climates. The SEIS should reflect the temperate climate construction 
used in this area. 
3-32 Cold-weather construction: only 10%? In some places in the dSEIS the 
drafters appear to assume that cold weather construction is either brick or masonry 
construction. At others, it states that 10% of the housing is masonry or brick.
	(1) If it is only 10%, not the majority of the housing, the figures should be 
reworked and it is not clear in the dSEIS if they were.
	(2) The fSEIS should distinguish masonry from brick, as the dSEIS fails to 
do-what percentage of each. There are very few stone masonry houses in this 
region of the country. Furthermore, the dSEIS does not distinguish brick construction 
from brick veneer, which is essentially wood construction and should be so treated. 
The SEIS should correct this error.
PART 4: WETLANDS & WATER QUALITY IMPACTS
4-1. Miller Creek Relocation.
(a)	How does the Port propose to effect a plan to relocate and re-channelize 
Miller Creek, as well as to increase the rate of flow in Miller Creek, given that it is 
under an existing court order (consented to by the Port, as well as King County), 
forbidding it to undertake such actions? We previously provided copies of these 
settlement agreements (Kludt et al. v. King County and the Port of Seattle, King 
County Superior Court, Case No. 762259) which prohibits the re-channelization 
of Miller Creek and the increase in flow in Miller Creek, to the authors of the 
dSEIS. Nevertheless, this action is now apparently contemplated in the dSEIS. 
A previous response to our DEIS concerns about proposed plans to alter Miller 
Creek from the Port/FAA cited a completely unrelated matter before the State's 
Pollution Control Hearings Board. We again invite the commenters to provide a 
fSEIS which acknowledges the existence of the settlement agreements with the 
Port and King County which exerts local pre-emption of planning activities in the 
Miller Creek Basin. We look forward to comments responding to this matter in 
the fSEIS. Does the Port/FAA acknowledge the previously mentioned settlement 
agreements as pre-empting Port/FAA control over planning in the Miller Creek 
Basin?
(b)	Has the Port advised the U.S. Army Corps of Engineers of the court 
ordered settlement agreement referred to in (a)?
4-2. JARPA & §404 Application.
(a)	The texts of the applications, as well as the Miller Creek Relocation Plan, 
Wetlands Relocation Plan, and accompanying drawings and other documents 
referred to in Section 5-5 1, p. 5-5-1, should have been part of the dSEIS and 
should be included in the fSEIS. Please provide them in response to this 
comment.
(b)	How as a practical matter do the proponents expect the general public to 
comment on this subsection when the most important documents (the 
applications) are available only in two remote locations? Non-availability of these 
documents prohibits the review of impacts or the proposals made in the 
application for the Corps of Engineers Wetlands permits and impairs the public’s 
ability to make informed comments on the SEIS.
4-3. Use of out-of-basin wetlands replacements. We are aware that other 
commenters have commented, and intend to further comment, on the 
inappropriateness of substituting wetlands in one basin for those damaged in 
another, which is proposed here. We join in such comments, and ask for a full 
explanation of the legality (if any) and practicality of the proposal. The fSEIS should 
specifically address, city by city, the local codes that require wetland mitigation to be 
within the same drainage basin, as well as any other relevant legislation or 
regulations.
4-4. Sea-Tac International Airport Storm Drainage Plan Ignored. While we 
have been unable as of this writing to secure a copy of the document, we are well 
aware that on behalf of the Port, the firm HDR Engineering, Inc., has issued a multi-
volume final draft report, dated February 1997, entitled "Sea-Tac International 
Airport Storm Drainage System Comprehensive Plan".
(a)	Do the preparers deny the existence of this report?
(b)	Why was this report not referred to in the dSEIS?
(c)	What is the relationship between the Plan set out in the referenced 
document and the December 1996 Miller Creek Relocation Plan, prepared by 
Parametrix, Inc., for Landrum & Brown, a consultant to the Port? Set out in 
detail and in format permitting easy comparison the actions proposed, the 
adverse impacts thereof, & the proposed mitigations of such actions, as 
proposed in the two different documents & in the dSEIS.
4-5. Underlying Aquifers. Why is the dSEIS silent on the subject of impacts on 
aquifers known to underlie Airport property? This subject should be covered in the 
fSEIS.
4-6. Des Moines Creek.
(a)	We do not find -- the lack of an index is a real handicap here -- any mention 
of impacts on Des Moines Creek in Section 5-5 or elsewhere in the dSEIS. If 
Des Moines Creek was mentioned, the response, we are confident, will point out 
the location of such mention.
(b)	On the conclusion that the dSEIS ignores Des Moines Creek, we ask that 
the fSEIS explain why, in light of the fact that the Port has told the U.S. Army 
Corps of Engineers in Attachment B to its Section 404 application dated 18 
December 1996 that "[i]mpacts to Des Moines Creek will occur in later phases 
of construction activity", these impacts were not discussed in subsection 5-5 1, 
or anywhere else in section 5-5.
(c)	What are the projected impacts to Des Moines Creek, when will they 
happen, what are the consequences of the impacts, and what are the proposed 
mitigation measures (including the costs thereof)?
(d) As mentioned above any mitigation plans should be sequenced such that the 
mitigation is in place prior to the action for which the mitigation is required. 
4-7. Impact on Fish Populations.
(a)	While two goals are stated (p. 5-3-20, Goals 2, 5) in regard to enhancing 
fish populations in one of the creeks to be impacted by the project, nothing is 
said as to whether, or to what degree, either goal will be met. The fSEIS should 
show how each of the goals, including fish-enhancement goals, will be met for 
Miller Creek if relocation were to occur.
(b)	The dSEIS is silent as to impact on fish populations in streams in the 
affected area. The fSEIS should cover this topic.
4-8. Useful Life. The dSEIS says that the useful life of the runway will be 
approximately 5 years. (The revised completion date for the 3rd runway is the yeas 
2005. According to EXHIBIT 2-7 on page 2-25 of the dSEIS, Sea-Tac airport with a 
3rd runway will reach its "[p]ractical capacity per NPIAS" in the year 2000.  The 
same chart in the SEIS shows that according to FAA terminal area forecasts 
(TAF'S) Sea-Tac airport equipped with a 3rd runway would be classified as 
"Severely Congested per NPIAS" by the year 2010.  Please explain what the total 
amount of costs of this project will be, including capital costs, mitigation costs, as 
well as accrued financing and amortization costs. What is the cost per year of the 
new runway's useful life?  Provide an analysis which derives the rate of return on 
investment for this project? 
4.9 Lost Opportunity Costs. The fSEIS should discuss the lost opportunity costs 
to the region of spending public money on the 3rd runway project as opposed to 
spending it on alternatives.
PART 5: SOCIAL, SOCIO-ECONOMIC, & LAND-USE IMPACTS
5-1. Noise and Land Use. We comment again, in connection with Subsection 
5-6 1, that the 65 LDN metric is no fair measure of adverse airport noise impacts on 
land use. The Expert Arbitration Panel, the US EPA, the Natural Resources Defense 
Council, and many commenters in this long process all have pointed out various 
weaknesses of the LDN metric. We call, once again, for the use of more reasonable 
metrics. 
Single-event levels are studiously ignored in the discussion here commented on, 
yet everyone knows -even government environmental specialists -- that, more than 
anything else, it is the single noise event (be it from aircraft, motor vehicles, gunfire, 
human voices) that disturbs people in their everyday lives. We challenge the SEIS 
preparers to find anyone disturbed by a year-long average of aircraft noise. It may 
be that the FAA is cheerfully content to remain the prisoner of its own 
misconceptions on this matter, but the Port of Seattle, which is NOT bound to limit 
its good deeds to the cramped style of FAA, should now rise to the occasion and 
use more appropriate noise metrics. If there are any good reasons (a) to disregard 
the criticisms of the 65 LDN metric or (b) to stick with that metric criticisms 
notwithstanding, what are those reasons?
5-2. Noise and Land Use.
(a)	The fSEIS should present noise contour maps on the basis of 55 LDN 
contours as suggested by US EPA.
(b)	Single-event levels should also be presented in a comparable mapping 
format showing 100 dB, 90 dB, and 80 dB SEL noise contours.
(c)	Tables showing 55 LDN & SEL measurements should be presented, 
comparable to Tables 5-6-1 through 5-6-3.
(d)	The numbers of single-family homes, duplex/triplex homes, apartment 
houses, places of religious activity, schools, nursing homes, hospitals, &c.;, 
should be reported in terms of the other metrics suggested in this and the 
immediately prior comment. (c) 
5-3. Social Impact Discussion Grossly Deficient. Subsection 5-7 2, Social 
Impacts, is grossly deficient, to the point that some observers would think that it is a 
deliberate insult to the adversely affected communities.
(a)	The subsection correctly recognizes that social impacts include residential 
and business displacement, disruption of existing communities, disruption of 
planned development. P. 5-7-1. After setting out the number of single-family 
properties, apartments, and businesses to be acquired, there is not a single 
word about the consequences. Why not
(b)	Is it the intention of the dSEIS preparers to refuse to discuss the subject of 
residential displacement?
(c)	Is it the intention of the dSEIS preparers to refuse to discuss the subject of 
business displacement ?
(d)	Is it the intention of the dSEIS preparers to refuse to discuss the subject of 
disruption of existing communities?
(e)	Is it the intention of the dSEIS preparers to refuse to discuss the subject of 
disruption of planned development?
(f)	Each of the matters referred to in comments 5-3 (a) - (e) should be 
discussed in detail in the fSEIS.
5-4. Social Impacts: Pending Study Ignored; Depression of Property Values 
Ignored.
(a)	In addition to failure to discuss the very impacts that it recognizes, the 
dSEIS subsection 5-7 2, Social Impacts, fails to take into account the State-
funded impact study now being conducted by the HOK study team, a draft of 
which was released last Fall. Why was this study ignored? Why were no 
responses to the issues raised reported in the dSEIS? 
(b)	Will the fSEIS take into account the final, published version of the HOK 
study? If not, why not?
(c)	The HOK study describes in detail a major adverse socioeconomic impact 
that is not discussed in the subsection being discussed: depression of property 
values. Did the preparers fail to discuss this subject because they believe that 
there is no depression of property values resulting from airport-related noise? If 
not, why was this subject not discussed in dSEIS?
(d)	If the preparers agree that property-value depression is a real impact, do 
the preparers have an estimate of the dollar amount of the property-value 
depression resulting from Sea-Tac-related noise? What is that dollar amount 
and how was it computed?
5-5. Induced Socio-economic Impacts: Pending Study Ignored; Loss of Tax 
Revenues from Real-property Taxes.
(a)	We regard the notion of separating "Social Impacts" from "Induced Socio-
Economic Impacts" as nonsensical, and request that in the fSEIS the discussion 
of the two identical topics be combined.
(b)	The dSEIS fails to take into account the above-mentioned draft HOK study, 
which sets out, even in its preliminary, draft form, enormous losses of revenues 
to municipalities in the vicinity of the Airport as the result of airport-related noise. 
Why?
(c)	The HOK study gives much higher numbers for these tax-losses than does 
the dSEIS. The dSEIS provides no explanation of its tax revenue-loss figures, 
whereas the draft HOK study sets outs its methodology & results in detail. How 
did the preparers of the dSEIS arrive at their numbers?
(d)	Explain & justify the differences between the dSEIS tax-loss numbers and 
the tax-loss numbers in the HOK study.
(e)	Provide comprehensive evaluations, based on valid, cited authorities, as to 
any offsetting revenue gains that the preparers expect the affected 
municipalities to receive as the result of expanded Airport activity.
(f)	What mitigation is proposed with regard to lost real-property tax revenues? 
Provide a copy of the real-property tax mitigation plan in the fSEIS.
(g)	The fSEIS should comment in detail on the conclusions of the HOK team 
that gains from Airport activity and losses therefrom do not fall proportionately 
on the populations, individuals, or municipalities involved. Chapter 1 of the draft 
study shows that the neighboring communities derive little of the benefits and 
most of the negatives. This is a major conclusion, new information in this 
environmental review process, and deserves the fullest examination in the 
fSEIS, including much more extensive mitigation measures than have been 
proposed to date.
5-6. Induced Socio-economic Impacts: Pending Study Ignored; 
Demographic Changes.
(a)	The dSEIS does not discuss impacts on community demographic profiles 
from Sea-Tac expansion. The above-mentioned HOK study indicates significant 
impacts from changes in demographic profiles. Why is the dSEIS silent on this 
matter? The fSEIS needs to examine this problem in detail, & to recommend 
relevant & sufficient mitigation measures.
(b)	Changes in demographic make-up of affected communities are shown in 
the draft HOK study to result in widespread changes in employment patterns. 
These changes seemingly are not recognized in the dSEIS nor does the dSEIS 
take into account in its optimistic view of the economic impact expansion on 
nearby communities the depression of average income, the increase in socially-
dependent individuals and households, the loss of existing businesses, and the 
consequent diminution of sales-tax & related revenues for the nearby 
communities. This subject (i) needs to be addressed in the fSEIS, & (ii) 
appropriate mitigation measures need to be suggested therein.
(c)	Impacts from demographic changes are shown in the draft study, albeit not 
in great detail, to have a damaging impact on the local public-school district. 
This subject (i) needs to be addressed in the fSEIS, & (ii) appropriate mitigation 
measures need to be suggested therein.
5-7. Inappropriate Shifting of Social Burdens. Massive Airport development 
is shown in the HOK study to result in billions of dollars of social burdens. Careful 
studies of such matters as origins of local residents using the Airport for travel 
purposes, and location of persons employed at the Airport or in direct association 
with Airport activities, such as those already done by the HOK team, strongly 
indicate that the benefits of the Airport are enjoyed by persons and communities, for 
the most part, well removed from the facility. The burdens, including loss of property 
values, diminution of real property tax revenues, loss of businesses, destruction of 
residential and business communities, increased social-welfare burdens, and the 
like, are directed upon the neighboring communities. The Airport & its employees & 
users gain; the local communities & their residents lose. Fundamental fairness 
would seem to dictate that the Airport itself should be the vehicle by which society at 
large accumulates, and redistributes, the funds & other assets needed to redress 
this balance (in much the same way that insurance serves the social purpose of 
evening out the unequal burden of risk-of-loss from societally approved 
transportation facilities such as highways). The fSEIS needs to address, in a global 
manner, how this unequal sharing of benefits and burdens is to be remedied.
5-8. Inappropriate Shifting of Social Burdens -- Executive Order 12898. 
One effort to prevent inappropriate shifting of social burdens is Executive Order 
12898, the Executive Order on Environmental Justice. The dSEIS is silent about how 
the dSEIS addresses impacts associated with this order, its requirements, and the 
disparate impacts of Sea-Tac activities that may fall within the reach of the order. 
The proponents/preparers are well aware of concerns expressed in many different 
ways about disparate impacts of Sea-Tac activities on populations specially 
protected by the Order, and it would be burdensome to include here the many 
letters, newspaper articles, and other documents reflecting those concerns & their 
expression. Many have been previously submitted to the Port of Seattle, by local 
residents, elected members of the King County Council, the city of Seattle, and local 
representatives of the State Legislature.
We call particular attention to the state environmental policy act (SEPA) 
administrative appeal of the FEIS approval filed by Ray Akers & the information 
found therein concerning the impacts upon his neighborhood in the Rainier Valley 
area which the dFEIS has chosen to ignore.  The fSEIS is obliged by law to deal with 
the E.O. 12898 issues in detail, with accuracy. We note with alarm that the residents 
of South Seattle have not been informed of the impacts which their community 
would be subjected to due to the Port/FAA's disregard of proper public notice and 
advertisement of the dSEIS. (We have elaborated on the Port/FAA failure to provide 
proper notice concerning this action in Part 8 of our comments.) 
PART 6: ALTERNATIVES
6-1. Use of Other Modes of Transportation As an Alternative to Project. 
See sec. III.1 (A) (p. 3-1). As was argued in RCAA Comment II-44 (h) to the DEIS, 
when 'edge' conditions are reached in airport capacity, any measure that diverts air 
traffic has a disproportionately beneficial, and cost-effective, impact. See also RCAA 
Comment II-46, II-55(b)(1).
(a)	The responses to the cited comments failed to address the 'edge' effect 
arguments, which leads to the conclusion that they are unanswerable, since no 
reason for ignoring them was offered.
(b)	The proponents should take the opportunity of this SEIS process to 
evaluate the beneficial impacts from the seemingly marginal improvements that 
could be experienced when Sea-Tac surpasses the 380,000 to 400,000 annual 
operations level, and begins to suffer markedly increased delay (cf. dSEIS 
Exhibit 2-7, p. 2-26).
(c)	The fSEIS should report more fully on the big change of heart as to future 
rail development in this State experienced by the Department of Transportation 
immediately after the Expert Arbitration Panel’s ruling on rail alternatives. It will 
be recalled that the DOT told the Panel that faster rail was utterly impractical. 
Then, after the Expert Panel's Dec. 8, 1996 Order was issued in reliance on the 
Department of Transportation's utterly negative evaluation, WSDOT turned out a 
big publicity blitz, seeking support for its program, seemingly developed 
overnight, for short-term implementation of faster rail and issued its study. 
Witness the Jan. 4, 1996 Seattle Times article reporting WSDOT's release of its 
Options for Passenger Rail in the Pacific Northwest Rail Corridor study. The rail 
alternative should be re-examined in light of the now-positive evaluations of the 
Department and its previous reliance that a 3rd Sea-Tac runway would be 
available to provide additional capacity by the year 2000. In its Final Order on 
Phase II Demand/System Management Issues issued December 8, 1995 the 
Expert Panel wrote: "We are confident that "high-speed" rail would produce a 
very substantial diversion of travelers from air to rail transportation in the 
Portland-Seattle-Vancouver corridor. (p.5) 
(d) The dSEIS assumes the relative attractiveness of air service from Sea-Tac 
will remain as it is today and has taken no account of the effect that a decision 
not to build a 3rd runway would have on other transportation options, including 
rail and the use of other airports. The fSEIS should discuss this in detail.
The fSEIS discussion should include comment on and resolve conflicts between 
the data presented in the fSEIS and  representations made by the Port of 
Seattle to the PSRC Expert Panel regarding the Panel’s Final Decision 
concerning Demand Management Issues. For example, i,  the Port told the 
expert panel  that the Port had "identified need to have the proposed new 
runway operational by soon after the year 2000." (Rebuttal of System 
Management Submittals, November 6,1995, pg. 2)
	The Port also verbally reassured the Panel that it would have the runway in 
operation shortly after the year 2000.  However, in a recent article published in 
the Tacoma News Tribune (February 8,1997 "3rd Runway Unlikely to Fly Before 
2005"), ," Mary Vigilante, "an FAA consultant who prepared the third runway 
project's supplemental environmental impact statement" was quoted stating, 
"There's not enough money to do it all at once". The fSEIS should explain in 
detail the impact the anticipated minimum five (5) year in availability of a 3rd 
Sea-Tac runway would have on  the other alternatives, including demand 
management, use of other airports, rail, & etc. The fSEIS should include a 
similar analysis for a using a ten and a fifteen year delay.
 Explain in the fSEIS how the introduction of the following alternatives to Sea-Tac 
expansion would affect the need for a third runway:
1. Implementation of rail service on the Vancouver, BC-Seattle-Portland, 
Oregon corridor.
2. Implementation of commercial air carrier service at Paine Field
3. Implementation of commercial air carrier service at other regional airports 
including Bellingham International, Vancouver, BC, Portland, Oregon, Moses 
Lake, Washington, Renton, WA, and other regional airports.
4. Development of Category E and F, and G traffic congestion conditions on the 
major arterials serving the Puget Sound area including Interstate 5, Interstate 
405, Interstate 167, Interstate 18, Interstate 520, and other major surface and 
intermodal transportation routes. 
(e). The fSEIS  should comment on the effects which legal challenges prohibiting 
Sea-Tac expansion will have upon proposed expansion of Sea-Tac airport 
including the options outlined in the dSEIS . What effects will the adoption of 
transportation alternatives, including alternate regional airports, rail 
transportation, and other external factors have on Sea-Tac airport's traffic levels 
given implementation of the Master Plan "Do-Nothing Option? 
	Project the effects of utilization of these alternatives on Sea-Tac air traffic 
levels and associated environmental impacts through the year 2020
(f)	As to the telecommunications alternative, the fSEIS should cite authorities 
for its bald assertions that telecommunications are still in the Dark Ages. 
Perhaps the authors of these materials have not yet heard of the Internet? A 9 
per cent. reduction in air travel in & out of Sea-Tac will be much more significant 
than the dSEIS material admits, when the airport begin to experience 'edge' 
conditions. Provide an analysis of the savings in dollars, including annual totals, 
of the 9% reduction in air travel associated with the use of new 
telecommunications technologies.
6-2. Other Airports. See sec. III.1 (B).
(a)	The non-appearance (in the eyes of the POS and FAA) of a 'sponsor' for a 
new airport does not rule out another airport as an alternative. The assertion at 
p. 3-4, Part III (B) 1. is a non sequitur. Otherwise, this whole exercise is a sham, 
for the proponent of any project need simply announce that it will not sponsor 
any alternative other than the preferred one, therefore there are no alternatives, 
end of discussion. Cite the legal authority for the proposition stated in the cited 
paragraph.
(b)	Surely it is not beyond the ability of the Government of the United States of 
America to encourage sponsorship of worthwhile alternatives, should they be 
identified. Or, the United States can become the sponsor -- not the first time that 
projects thought to be worthwhile were done under that sponsorship!
(c)	In fact, as we all know, there are known sponsors for serious airports 
capable of meeting the State's needs in the next century, & they should be 
named in the fSEIS & their proposals treated seriously. See RCAA DEIS 
Comment II-48, studiously ignored in the official responses. These sponsors 
have been ignored in the past, as all know, because the proponents of the Sea-
Tac expansion (the same people who are doing this environmental review) have 
the idea that the solution to future air-capacity problems has to lie in an 
unsuitable location, and cannot be sought elsewhere. See following comment.
(d)	The artificial limitation of the examination of alternatives to the Central 
Puget Sound sub region is pretextual, a mere ploy to avoid discussing real 
alternative sites. Why not frankly say that the study of alternative locations-has 
to be limited for political reasons to areas controlled by the principal advocate, 
the Port of Seattle, and admit that there is no interest in any solution that the 
Port does not control?
(e)	The remarks in paragraph 4 of the cited section are, typically, mere bald 
assertions, unsupported by facts, reason, theory, or authority. The fSEIS needs 
to provide at least a semblance of support, particularly in view of the facts that (i) 
the dSEIS itself states that the 10-million-enplanement per annum threshold has 
been passed, and (ii) operators are already moving from Sea-Tac elsewhere 
(King County International Airport, Paine Field). What the dSEIS says cannot 
occur is underway. Explain that. What are the future implications?
(f)	We note in particular current moves by the scheduled commercial airlines 
to establish air carrier service at Paine Field. (See Seattle Times Feb. 11, 1997, 
p.B5) Paine Field's recently completed Part 150 Master Plan and Noise Study 
Update forecasts significant levels of National and Regional air carrier service. 
Forecasts for regional service with Paine Field served by regional air carriers 
only, range from 81,000 to 135,000 operations per year in 2004, prior to 
completion of the proposed 3rd runway. Forecasts for national service with 
Paine Field served by both national and regional air carriers range from 464,000 
to 776,000 annual operations in the year 2004. (See Attachment - Page B-9 
from Master Plan Study) For the dSEIS to ignore the impact of diversion of Sea-
Tac's commercial passengers to Paine Field of only a fraction of the above 
traffic levels constitutes an error and omission best characterized as gross 
negligence. The fSEIS should assess the impacts upon Sea-Tac's projected 
operations given the scenario of rapidly expanding commercial aviation growth 
at Paine Field
(g) We additionally note recent regional growth in commercial operations 
caused due to the addition of Vancouver, B.C.'s International Airport's 3rd 
runway as well as shifts to Vancouver airport due to the recent "Open Skies" 
treaty established between the United States and Canada. We also note the 
growth in commercial service at Bellingham international airport. (United Airlines 
"Shuttle") as well as the recent announcement that Horizon airlines is expending 
$20 million dollars to expand commuter operations from Portland International 
Airport in Portland, Oregon. The fSEIS should comment upon how development 
at each of these airports will influence commercial aviation growth at Sea-Tac. 
6-3. Demand Management. See dSEIS p. 3-5.
(a)	The discussion here misrepresents the findings of the Expert Panel. The 
fSEIS should not do so, but should report that the Panel found that demand 
management would not work because (1) the Port refused to put demand 
management into play and (2) the Panel and PSRC had no power to force the 
Port to adopt demand-management measures. (Another example of exclusion 
of alternatives by refusal to sponsor them.) In its Final Order on Phase II 
Demand/System Management Issues issued December 8, 1995 the Expert 
Panel wrote: "We nevertheless continue to have questions about the complex 
and dynamic delay and capacity problems that are seen by the POS as 
justifying the construction of the new runway.". The Panel noted "[t]he Panel 
does not believe that it has been charged with the generalized responsibility for 
determining whether there is a need to build the proposed third runway." (p.3)
(b)	We question whether applicable environmental-review statutes and 
regulations permit exclusion of alternatives just because there is a failure of will, 
or perhaps an excess of 'won't', on the part of the sponsor and/or 
environmental-reviewer. The fSEIS needs to discuss the question whether an 
otherwise-viable alternative can, legally, be excluded by the whim of the 
proponent of an action.
6-4. Localizer Directional Aide (LDA) Technology
(a) In its Final Order on Phase II Demand/System Management Issues issued 
December 8, 1995 the Expert Panel wrote: "Improvements in Technology, including 
LDA, can be expected to enhance the effective capacity of the airfield at Sea-Tac". 
Provide an analysis in the fSEIS of the cost savings in landing delays to the airlines 
associated with implementation of LDA technology at Sea-Tac airport as 
recommended by the Expert Panel in their Final Order on Phase II Demand/System 
Management Issues.
6-5. Global Positioning Satellite (GPS) Technology.
(a) In a previously submitted May 1995 report to the Committee on Transportation 
and Infrastructure of the House of Representatives titled Comprehensive FAA Plan 
for Global Positioning System is Needed the General Accounting Office stated that 
"FAA expects that the augmented GPS will be able to support runway approaches 
and landings in all weather conditions". (Report GAO/RCED-95-26, p.5, emphasis 
added) This 1995 report also noted FAA's change to the year 2000 as the milestone 
for the feasibility determination of GPS augmentation for supporting Category II/III 
precision approaches. (p.23) Explain why the dSEIS did not consider that 
implementation of GPS technology years prior to the completion date for a 3rd Sea-
Tac "bad weather" runway, which would very likely obviate the need for the runway. 
(b) In a recent (December 1996) report titled Proceedings of the NASA Workshop 
on Flight Deck Centered Parallel Runway Approaches in Instrument Meteorological 
Conditions progress concerning utilization of derivations of GPS technology is 
revealed. The report discloses that parallel approaches to runways separated closer 
than the 2,500 foot discussed in the DFEIS are now being considered for use in 
conjunction with this new navigational technology. (p.81) This report provides a 
graphic showing parallel landing approaches under IFR meteorological conditions 
are being studied with runway separations less than 2,500 feet. A United Airlines 
pilot discussed investigation into utilizing the technology for conducting paired IFR 
approaches to San Francisco airport's two runways which are spaced 750 feet 
apart. (p.104) Sea-Tac airport’s existing runways are spaced 50 feet further apart 
(800 feet) than San Francisco's. A copy of this report is attached. Explain in the 
FSEIS why the dSEIS did not contemplate options including new runways more 
closely separated than 2500 feet.
(c) Innovations in GPS technology have not been lost in the public media. The 
enclosed article published in the June 5, 1996 edition of Aviation Week and Space 
Technology reports a concept called "Traffic Conditional Approach" has been 
proposed "that could permit dual IFR approach streams leading to very closely 
spaced parallel runways." Explain in the fSEIS how implementation of this traffic 
conditional approach technology would or would not obviate the need for a third 
Sea-Tac runway.
(d) Finally, as reported in our Fall 1996 newsletter Alaska Airlines, one of Sea-Tac 
airport's major carriers is  now in the process of implementing GPS navigational 
technology in its 737-300 fleet aircraft. (The RCAA Fall Newsletter is available on our 
website. The URL is http://www.rcaanews.org/rcaa .) Explain in the fSEIS how 
implementation of GPS technology would or would not obviate the need for a third 
Sea-Tac runway.
(e) The fSEIS should indicate how implementation of GPS technology will affect 
each of the alternatives discussed in the fSEIS, during the years 2005, 2010, 2015, 
and 2020. The fSEIS should also provide a discussion of the impact of 
implementation of GPS technology allowing "poor weather" IFR approaches at Sea-
Tac upon the stated "purpose and need" for the 3rd Sea-Tac runway, the need for a 
"bad-weather" runway. 
6-6. Blended Alternative. See discussion at dSEIS p. 3-6.
(a)	The discussion here is fatally flawed by the mistaken notion that each 
alternative standing alone must be able to satisfy the need for the proposed 
project. The discussion should address the combination of non-project 
alternatives, including those referred to in earlier comments -- rail, medium-
speed rail, use of other nearby airports, teleconferencing & related technologies, 
LDA, GPS, increased efficiencies (especially with regard to the below-60-seat 
airlines, consuming 38 to 40 percent. of the operations capacity). Provide a 
matrix which describes the estimated effect on future Sea-Tac air traffic 
operations by year, through the year 2020, in five year increments. Analyze the 
effects on Sea-Tac traffic and delay costs assuming the following factors:
1. Assume medium and high-speed rail diverts existing Sea-Tac traffic 
levels in the following ranges: 5-10%, 10-15%, 15-20%, 20-25%.
2. Assume implementation of LDA technology which obviates the need for 
IFR approaches at Sea-Tac in the following ranges: 90-100%, 80-90%, 70-
80%, 60-70%
3. Assume FAA issues feasibility determination for implementation of GPS 
technology which obviates the need for all IFR approaches at Sea-Tac in 
the year 2000.
4. Assume new innovations in telecommunications technologies divert 
existing Sea-Tac traffic levels in the following ranges: 5-10%, 10-15%, 15-
20%, 20-25%.
5. Assume utilization of alternate regional commercial airports divert 
existing Sea-Tac traffic levels in the following ranges: 20-30%, 30-40%, 40-
50%, 50-60%, 60-70%
(b)	The delay discussion on p. 3-7 needs detailed cross-references to 
wherever it is in the FEIS that delay matters were discussed in depth (including 
comments and responses thereto).
PART 7: OTHER COMMENTS
The comments in this Part are organized as follows:
A.	Planning Horizon
B.	Surface Traffic
C. Cost
D.	Methodological Concerns
PART 7(A) -- Planning Horizon Issues
7(A)-l. Planning Horizon Should Be At Least Year 2020.
(a)	The planning horizon for environmental impacts should extend at least 
to the prior planning horizon originally established in the Master Plan Update for this 
entire exercise, the year 2020. See dSEIS p. 5-1. It seems absurd to plan to put a 
facility in operation in the year 2005 or 2006 and then refuse to look at impacts 
taking place beyond the year 2010. It defies human understanding to suppose that 
there would be no impacts five or six years after the third runway's expected coming 
into use.
(b)	Do the SEIS preparers assert that there will be no adverse impacts 
from the proposed actions after the year 2010?
(c)	Is it not the fact that the post-2010 years are ignored because 
preliminary studies show that the impacts will be progressively more severe, and the 
proponents of the project do not wish the public to know about those impacts? If not, 
give a valid explanation consistent with prior use of 2020 as the planning horizon in 
this environmental-review process.
(d)	State the planning horizons used in PSRC transportation planning 
processes, including aviation planning. If there are differences between the PSRC 
planning horizons (i.e. PSRC's Vision 2020) and those used by the SEIS preparers, 
explain them & provide justifications for deviating from the PSRC methods and time 
table.
7(A)-2. If Planning Cannot Be Done More Than 14 Years in the Future, Can Any 
Rational Planning Be Done in This Exercise? The putative reason for not doing the 
work beyond year 2010 --high volatility of travel demand -- is an excellent reason for 
not engaging in air-traffic forecasting as well, and therefore for not doing this project.
(a)	Can rational planning be done in light of the constraints suggested by 
the dSEIS (p. 5-1)?
(b)	Is the economy to be burdened with a 2 or 3 billion dollar project with 
over 4 billion dollars of adverse impacts on the basis of projections that do not 
include consideration of future events that are reasonably foreseeable, although 
perhaps not in exact arithmetical terms? Or does reasonable foreseability only apply 
to measuring the harm done by the project, not the alleged benefits?
PART 7 (B) -- Surface Transportation Issues
7(B)-l. Map Problems. 
(a)	Ex. 5-1-1 (simplified local highway map) should indicate whether it is 
current or includes proposed but as-yet-unbuilt roadways. Perhaps both are 
needed.
(b)	The hexagons with numbers, described as percent distribution of 
airport traffic, do not convey much meaning, and need at least a text explanation 
and a suitable cross-reference thereto in the table itself.
7(B)-2. Mitigation Issues.
(a)	Construction. (This matter relates to Part I of these Comments, 
Construction Impacts.) The HOK study, referred to in earlier comments, indicates 
that extraordinary wear and tear will occur to local roadways as the result of the 
colossal number of fill hauling trips. No mitigation is proposed in the dSEIS to the 
State, County, or affected cities for an exercise that apparently will be destructive. 
The fSEIS should examine the roadway mitigation problem & other mitigation 
issues and make realistic proposals.
(b)	Long Term. Who is to bear the cost of fixing traffic messes that will 
occur long-term as the result of Sea-Tac expansion? Is this another burden to be 
thrown off on the local people and their local governments, all for the benefit of 
Airport users who pay little to no taxes to the local governments, and who mostly 
reside elsewhere?
(c)	The long-term mitigation problem is particularly poignant in the case of 
air cargo. The Port of Seattle operates at a yearly loss of over $35 million, which is 
made good by real-property taxes. While it is claimed that none of this loss comes 
from aviation activities, we have seen nothing to rebut the contention that this is at 
best a mere accounting convention. Air cargo, like marine cargo, passes through 
here on its way to & from remote destinations. Operating losses and unmitigated 
adverse impacts amount to subsidies given by the taxpayers and local residents to 
business activities in other States and in foreign countries, given as the dSEIS 
suggests (The FAA being co-author of the dSEIS) by our tax-exempt Port district. If 
this is being done at federal initiative, the federal government should pick up its fair 
share of the mitigation bill (in the billions, over-all); if this is only done for the 
convenience of the Port and its customers, then the Port should be the vehicle for 
redress of adverse impacts. The fSEIS needs to sort this all out, for surface traffic 
impacts, for all other impacts as well.
PART 7(C) -- Cost
7(C)-l. Are the Cost Estimates Reliable? Meaningful? It is conceded at p. 5-
4-1, referring especially to third-runway work, that detailed design & construction 
plans have not been prepared.
(a)	How reliable are the construction time lines suggested in either the 
FEIS or the dSEIS?
(b)	How reliable are the cost estimates suggested in either the FEIS or the 
dSEIS? We note that only several weeks ago the Port announced the estimated 
cost of just the 3rd runway alone jumped by $132 million dollars.
(c)	It appears that no engineers have been involved in this work (none are 
identified in the list of preparers of the dSEIS), and neither the FEIS nor the dSEIS 
examines the work that will need to be done to construct the third runway. (i) Is this 
huge earth-fill work practical? We are aware that the 1994 EIS for improvements at 
the Albuquerque Municipal Airport concluded that an runway extension with up to 
150 vertical feet of fill required -- closely comparable to the Preferred Alternative for 
Sea-Tac -- was impractical. (ii) Will the fill sustain the stresses to be placed on it by 
the aircraft that are expected to use it? Provide a copy of the geo-technical report 
prepared by a registered professional engineer which substantiates this.
(d)	Cite the relevant studies that support your response to this comment, 
and quote relevant portions that indicate that this work can be done. Identify the 
individual engineers and engineering firms who have done the work on the third 
runway to date.
7(C)-2. Cost-Benefit Ratio. Where are the cost-benefit studies required for this 
dSEIS? If they exist, including them with the fSEIS. Alternatively, indicate locations 
where they may be obtained or perused.
7(C)-3. Cost-Benefit Ratio. Perhaps the reason why it has been decided to 
shorten the planning horizon to the year 2010 is to avoid the problem discussed in 
this comment: the third runway will outlive its utility in a very few short years after it 
opens for business, and the number of those years shrinks as the new traffic 
forecasts are made. What sense does it make to spend all these billions of dollars 
for this short-term fix, when the forecasts indicate that the need for an alternative 
REGIONAL (not Seattle-Tacoma local) solution will be upon not more than six years 
after and more likely before the opening date for the proposed 3rd runway? The 
fSEIS should discuss this problem in fullest detail.
7(C)-4. What Will Happen When Capacity Limits Are Reached? Given the 
onrush of traffic and the likelihood that even if the third runway is built Sea-Tac will 
be far beyond capacity in a few years, what is proposed for the next action to 
alleviate the capacity crunch? Is the fourth runway now a 'gleam in anyones eye'? Or 
is it expected that technological improvements will permit another capacity increase 
at Sea-Tac?
7(C)-5. Future Aircraft. What actions are being considered to cope with the 
advanced aircraft of the future now under study, such as the so-called 'China 
Clipper', super-jumbo subsonic jets, and others?
7(C)-6. Rationale for Scheduling-Change. Why do Port staff now recommend 
that the third runway be operational by 2005 instead of the original target date of 
2000. See dSEIS, p. 2-21. What was reexamined, to what effect, and where are the 
results of the reexamination published?
7(C)-7. Financing Concerns. Careful reading and re-reading of Part 3 A, 
second unnumbered paragraph of first bullet point, p. 2-21, together with the first 
sentence on p. 2-24, leads us to conclude that the operative reason for the staff 
suggestion in this dSEIS to reverse the order of construction of the third runway and 
associated groundside projects --non-runway projects first -- is the unavailability of 
financing for the third runway during the time frame posited by the Master Plan 
Update and its FEIS. Is this a correct reading? If not, what is the correct reading, & 
why is the order of construction of the two major components proposed to be 
changed?
7(C)-8. Contingency Planning. There should be discussion in the fSEIS of 
contingencies that may arise from further delay in various phases of the over-all 
expansion project. In particular, the fSEIS should look carefully at the contingency 
that funding for the third runway will still not be available at the now-planned start 
date. Would it be rational to construct the landside facilities if third runway financing 
will not be available (whether at the time hoped for, or at all)?
PART 7(D) - Methodological Concerns
7(D)-l. Incorporation of Applications by Reference. 
(a)	 It is inappropriate to incorporate documents by reference (p. 5-5-2) without 
providing them for review.
(b)	Do the preparers of this SEIS expect that the Port Commissioners will 
troop down from Seattle to the Port's Engineering Office at the Airport, or the 
FAA's shop in Renton, to read these documents
(c)	Do the preparers think that it is practical for all the interested agencies, 
cities, special districts, community groups, individual citizens, and so on to 
review documents only available in the FAA's or Port's offices, with only one 
copy per office available for review?
7(D)-2. Incorporation of FEIS Appendix R by Reference. In the Air Quality 
section of the dSEIS, there is a general reference to air quality information 
appearing in Appendix R, the appendix to the FEIS setting out the official 
responses to comments on the DEIS. The dSEIS text then says that Appendix R is 
incorporated by reference.
(a)	The Appendix should not be included by a general reference. Rather, 
reference should be made to particular responses that deal with the particular 
issue under discussion in the dSEIS or fSEIS. The air-quality section of the 
dSEIS should be revised accordingly in the fSEIS.
(b)	This is a particularly aggravating practice in the instance of Appendix R for 
two reasons: (i) the rather scattered nature of the information in the Appendix; 
(ii) the Appendix was, unaccountably, not furnished to numerous commenters.
7(D)-3. Incorporation by Reference -- Another Instance. Exactly what parts of 
the FEIS are 'incorporated by reference' in the second full paragraph on p. 5-1? 
Give page numbers. Better yet, set out the material.
7(D)-4. Cumulative Impacts. See sec. 5-3 5 "Cumulative Impacts", p. 5-3-7.
(a)	The projects or developments referred to here should be specifically 
identified, one by one, and the present state of planning of each should be set 
forth.
(b)	Is it not true that ranges of possible impacts from these various projects 
can be forecast and considered?
7(D)-5. Cumulative Impacts. Subsection 5-6 1 (D) p. 5-6-5, suffers from the 
same defects as other discussions of cumulative impacts in the dSEIS.
(a)	Surely the other pending projects in the Airport area are well known to the 
preparers. Is this not so?
(b)	Surely the statutes and regulations require the preparers at least to make a 
colorable effort to gauge the impacts of other known projects. Is this not so?
(c)	The fSEIS should touch on known pending projects and at least give 
reasonable ranges of potential, cumulative impacts.
7(D)-6. Still No Index. Where is the index? Why do the Port and FAA refuse to 
provide indices to these environmental documents? Alphabetizing the table of 
contents (as was done for the FEIS) is not an index, for such a construct does not 
tell the reader where discussion of various topics can be found --the very purpose of 
an index. This is particularly disabling when trying to find discussion of such 
important matters as noise impacts, air quality, & water quality, where much 
important discussion occurs in the form of comments and responses, for which 
there is no index or other guide provided. We asked for an index in our scoping 
comments, we asked for an index in our DEIS comments, we ask again. By the 
way, there are perfectly adequate computer word-processing programs that will 
construct a fair-to-good first draft index at, so to speak, the push of a button. The 
results of that would be a lot better than the nothing that has been provided to date.
PART 8:  Request for Extension of Time to Provide Additional Comments
	8(A) Late Arrival of dSEIS Documents in Local Libraries - The dSEIS is 
almost 1,000 pages long, It is technically difficult and time consuming for the public 
to read and understand. Copies of the document have not been available to 
members of the public most affected by the proposed action. Most local libraries did 
not receive copies until the last week of February. The copy of the dSEIS at the 
Burien library is date stamped "Received Feb 25, 1997", one week prior to the 
public hearing. 
	The Des Moines library whose patrons include residents of one of the areas 
which would be most impacted by the project did not have a copy of the dSEIS 
available to the public as of noon on March 4, the day of the public hearing. Only 16 
copies of the dSEIS have been provided at public libraries, one per library. The 
dSEIS at each library is available for reference only. The FAA/Port presumes 16 
copies of the document are sufficient to notify over 200,000 citizens of the proposed 
action's environmental impacts.
	8(B) Cost of dSEIS Documents Copies of the dSEIS cost $60 dollars each, 
exorbitantly priced for even citizens of moderate means, not to mention low income 
residents who would be most impacted by the proposed action. 
	8(C) Lack of Availability of dSEIS Documents It took the Port and the FAA 
a year to write the draft supplemental EIS. The public should have many more 
copies available at reasonable cost, at least 90 days for review and comment, and 
at least two more local public meetings to review the proposal in order to provide 
meaningful public comment concerning the impacts on our communities.
	8(D) Unavailability of Documents Referenced in dSEIS Documents which 
concern elements of the proposed action which have the most significant impacts to 
the area were not even included in the SEIS. For example; the Wetlands Mitigation 
Plan and Miller Creek Relocation Plan.  A check with the reference librarian at the 
Burien Library on March 5 determined neither of these documents have been logged 
into King County's Library Catalog System and also that neither document is 
available at the Burien Library for public review and comment. A check with the Des 
Moines library on March 6 similarly determined that neither the Port's Wetland 
Relocation Plan or the Miller Creek Relocation Plan documents were available for 
public review at the Des Moines library. 
	8(E) Problems with March 4 Public Hearing A public hearing at SEA-TAC 
airport on a weekday (March 4) during rush hour was the worst possible 
location/time/etc. to solicit meaningful public comment for this SEIS. Many citizens 
were deterred by Sea-Tac airport's exorbitant parking fees. The public notice of the 
hearing did not indicate whether free parking would be provided for low income 
residents who wished to testify at the public hearing. 
	8(F) Request for Additional Public Hearings and Extension of Public 
Comment Period To remedy the improper conduct of this SEIS public comment 
process we strongly recommend at least two evening meetings in the local cities of 
Burien, Des Moines, Tukwila, Sea-Tac, Federal Way, Normandy Park, as well as 
communities in the Rainier Valley, Columbia City, Beacon Hill, Mercer Island, 
Magnolia, Capitol Hill and other affected areas, etc. should be scheduled and held to 
study the dSEIS. The present public comment period should be extended. After the 
public meetings are held a minimum 90 day public comment period should be 
allowed to permit members of the public to review the proposed action and make 
informed comments upon the proposal.
Comments of the Regional Commission on Airport Affairs 
(RCAA) on the Draft Supplemental EIS (dSEIS) to the 
Seattle-Tacoma International Airport Master Plan Update
http://www.rcaanews.org/rcaaseis.htm