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RCAA Comments on Sea-Tac Master Plan (SMP)
Draft Environmental Impact Statement (DEIS)
Chapter IV, Section 8: Socio-Economic Impacts

Chapter IV, Section 8:  Induced Socio-Economic Effects
Introduction to Comments on Chapter IV, 8.  Our comments on
this section of Chapter IV are in two groups.  In the first
group, Comments IV.8-A through IV.8-C we include studies of
certain issues included within the scope of the section;  these
studies present materials, data, findings, & analyses not
included in the DEIS, which should be addressed in the FEIS.
In the second group, Comments IV.8-1 through IV.8- n are our
comments on particular points raised in the DEIS or suggested
by it.
Listing of items included as Comments IV-8-A - IV-8:
     Comment IV-8-A:  Letter of Dr. Lynn Michaelis responding
to Flightplan DEIS.
     Comment IV-8-B: Summary of M. Frankel Survey of Property
Values,  Richard Zerbe, Ph.D. and Andrea Hambly, M.S.
     Comment IV-8-1:  The DEIS, p. IV.8-1, reports that
construction of the project will result in creation of a huge
number of construction jobs' (45,500).
     (a)  The FEIS might advise the reader that the 'jobs'
     involved, except for those of POS & FAA bureaucrats, are
     only temporary, not full-time, long-term employment in the
     usual sense of the word job.  The FEIS might reasonably
     address the question whether these temporary positions
     will be filled by local people or by the usual crews of
     boomers from Texas.
     (b)  We find no estimate of the dollar amount of the wages
     to be paid to those holding such 'jobs';  if there is such
     an estimate, may we suggest that in the FEIS the number of
     'jobs' & the wages from those 'jobs' be discussed in the
     same place?
     c)   The FEIS might reasonably state with clarity that any
     (i) direct, (ii) indirect, or (iii) induced economic
     benefits to the local economy from the overall expenditure
     for the project would be approximately the same for any
     other project of the same magnitude.  If there is a local
     benefit, it is not because the project is an airport
     project but because it is a big project.  The FEIS might
     also reasonably state that the same general principle is
     true for wages paid construction crews for this project
     and for any other project (or collection of smaller
     projects) of the same magnitude, (plus or minus a
     percentage point here or there, depending on the wage
     levels of the various trades & crafts involved).  In fact,
     the FEIS might candidly reveal that the benefits would be
     the same if the sponsoring agency simply distributed to
     the inhabitants of the Central Puget Sound region checks
     totalling the amount projected as the cost of the third
     runway -- an economic boost that would have no adverse
     environmental consequences.
     Comment IV-8-2.  -- Economic Impact-- Sales Tax.  The FEIS
should clarify the expression 'sales tax revenue generated by
people directly employed at the airport', p. IV.8-1, col. 2.
The reader wonders, Sales taxes on what transactions?
     Comment IV-8-3 --- Economic impacts of airport activity --
generally.  The DEIS presents conclusions as to the number of
jobs, earnings, &c.;, directly attributable to Sea-Tac Airport.
See unlabelled box, p. IV.8-1, col. 1, & Table IV.8-1, p. IV.8-
3.
     (a)  The totals seem grotesquely large.  It is hard to
     visualize, for example, 78,000 people working at the
     airport (see cited Table).  One wonders where they all
     park.  But the reader may learn, not from the text but by
     perusal of Table IV.8-2, p. IV.8-10A, that the DEIS is
     actually claiming only 13,806 jobs at the Airport at
     present. The rest of the claimed jobs, some 65,000, are
     somewhere else, who knows where.
     (b)  Is it the DEIS' assumption that every visitor to the
     area arrives by air, & that anything a visitor purchases,
     any money spent by a visitor, is attributable to the
     airport?  If so, then measuring economic impacts must be a
     chancy art, for some other investigat might say that a
     purchase made by a visitor at a hotel shop was
     attributable to the hotel industory, or to the publishing
     industry (if the purchase were a book) or to agriculture
     (or to candy manufacturing) if the purchase were a box of
     Aplets or Cotlets -- or to law-enforcement, if the visitor
     were an attendee at a police conference.  And so on.  How
     good are these numbers cited in the DEIS?
     (c)  And what happens to these curious numbers if the
     visitor were to travel in the future not by air but by
     rail?  Are the dollars spent by vistors diverted to other
     transportation modes less worthy than those spent by air
     travellers?  One would assume that the money all spends
     the same, & that it is a bit presumptuous to attribute
     visitor expenitures to the Airport.  The FEIS should give
     cleaned-up, more realistic, numbers.
     (d)  Unfortunately, the reader cannot follow up on the
     issues raised here, for the one cited source, The Local
     and Regional  Impacts of the Port of Seattle  (1994) is
     not a published work, & the publisher or author(s), Martin
     O'Connell Associates, is/are unknown to libraries or book
     stores.  This is yet another of the numerous instances in
     which this DEIS relies on semi-secret documents as
     authority for dubious sweeping generalities.
     Comment IV-8-4 -- Economic impacts -- methodology (p. IV.8-
1).  The methodology is based, we are told on published (but
uncited) reports (reports by whom?), and on consultation with
the Port of Seattle, State agencies (naming two), & employees
of local jurisdictions (only King County actually named).  This
is yet another, & particularly egregious, example of the
stealth method of citation of authorities in which this DEIS so
often engages.
     (a) The FEIS should list  each consultation, tell us who
     was consulted (including official position), & what each
     consultee contributed to the total methodology.
     (b) If the preparers used any standard texts on
     econometrics, or consulted any professional economists
     (none are listed in the chart of preparers in DEIS ch.
     VI), the texts should be properly cited (with page
     references) & the economist(s), if any, fully identified.
     Comment IV-8-5 -- Economic impacts -- This comment
addresses subsection (2) Existing conditions, at p. IV, 8-3.
In the absence of any real information as to how the preparers
guessed at the numbers presented in this Section, commenters
can say very little about them.  Some may agree, others may
think (as we do) that they seem inflated.
     Comment IV-8-6 -- Economic impacts -- general.  See FEIS
IV.8-4, paragraph (3)(A) 1. Do-nothing alternative.  It is
interesting that the preparers believe that the employment
levels at (or directly attributable to) the Airport at future
benchmark dates will be the same under all Alternatives,
including do-nothing (no third runway).  This appears to be a
retreat from the assertions in prior justifications for the
project that failure to construct the third runway would have
severe adverse impacts on the local economy.  The adverse
economic impacts predicted by the DEIS are only the projected
costs of delay to be felt by certain airlines.  See paragraph
(3)(A) 2, & parallel discussion in DEIS ch. II.
     Comment IV-*8-7  -- Economic impacts -- costs allocation
to beneficiaries.  It would be revealing ifn the FEIS were to
report the economic impacts, were the cost of this project to
be borne by the parties benefiting.  It is the consistent
position of the DEIS that the sole purpose of the project is to
enable more intense use of the Airport doing poor-weather
conditions.  As is established elsewhere in our comments, the
need for that more intense use is directly attributable to the
very substantial overuse of landing & take-off capacity by
commuter airlines.  If the Airport were run in an rational
manner (in economic terms), the commuter opoerators would
either be diverted to a more appropriate airfield or would be
charged fees commensurate with the true value of the resource
that they are using inefficiently.  So, it is fair to day that
the beneficiaries of this project, as the need is presented in
the DEIS, are those commuter airlines who are not bearing the
true cost of their wasteful operations.  Do these entities have
the resources to pay for this project?  If not, why should
anyone else pay for something that is for the benefit of these
benefits?
     Comment IV-8-8 -- Economic impacts -- passenger benefits.
From another point of view, the true beneficiaries of the
proposed expansion are those individual persons who fly the
commuter airlines.  The FEIS would do well to reveal how many
enplanements of commuters are involved per annum, & also how
many discrete individuals are involved.  This might best be
done with a distribution curve, reporting annual enplanements
by frequency.  The public has been led to believe that some
people are making very large numbers of trips per time period.
What would ticket prices look like if these people were
required to pay for the third runway, being proposed in truth
for their benefit?  What would true-cost pricing do the
comparative attractiveness of various transportation modes?

     Comment IV-8-9 -- Economic impacts -- diminution of
property values.  Section 8 of Chapter IV contains no
discussion of the issue of diminution of real-property values
as a result of noise & other adverse impacts from airport
operations & aircraft overflight.  This is a matter of very
serious concern to numerous property owners in areas throughout
the western portions of Pierce, King, & Snohomish Counties, but
it is entirely ignored as a socio-economic consequence of
aircraft activity.
     Comment IV-8-10 -- Economic impacts -- diminution of
property values.  There is some scant discussion of this issue
buried in obscurity at p.IV.7-4, as a mental-health issue, as
if diminution in property values is of no concern unless it can
be shown to have caused mental stress.  The discussion of
depression of real-property values belongs in Section 8.
     Comment IV-8-11 -- Economic impacts -- diminution of
property values.  The misplaced discussion at p. IV.7-4 once
again relies on bald assertions, unsupported by authorities,
except for a quotation from one improperly cited (unpublished?)
F.A.A. report from 1985, which appears to be a report on the
authors' examination of other people's work, done in 1960 and
in the period 1967-1970.  It is entirely unclear who did that
work 25 to 35 years ago, where, with what methodology.  It is
abundantly clear that they did not, unless they had working
time machines, study the impacts of the commercial aircraft of
today.  The cited report gives no reason why the work done so
long ago should be relied on as a useful indicator of
conditions to be expected today or when the third runway comes
into operation.
     Comment IV-8-12 -- Economic impacts -- diminution of
property values.
          (a) The psychology section of Section 7, Chapter 4,
     states that "[r]ecent comparisons" of appreciation rates
     of "residential property bear Sea-Tac" with rates
     elsewhere in King County found "no impact attributable to
     proximity to Sea-Tac".  No study is cited for these
     comparisons, so presumably they are unpublished.  Lack of
     citation leads this commenter to suggest that the
     comparisons were likely done by, or at the behest of, the
     co-lead agencies, as a part of this present effort to
     promote the third runway.  We suggest that no independent
     reader should give any credence to alleged comparisons of
     such uncertain origin.
          (b) Further questions arises:
                    (1) Can it be that aircraft impacts are
               depressing property values widely over King
               County?
                    (2) May it be that in the most noise-
               impacted areas there very few significant sales
               of existing homes?
                    3) Perhaps such sales as are made are sales
               to those hoping for re-zoning from residential
               use, being made less & less suitable by
               overflight noise, to more intense use, which
               would support the costs of insulation.  But who
               knows, when the alleged studies are cloaked in
               secrecy.
     Comment IV-8-13 -- Economic impacts -- diminution of
property values --  There is, we fear, another group of socio-
economic effects of noise on real-property values other than
simple depression of price.  We suggest that the FEIS should
look at this carefully.  Noise from aircraft using Sea-Tac has
very noticeably increased in volume & areas of impact over the
last decade, as one can detect by study of the records of calls
to the POS noise hotline, & as organizations concerned with
airport impacts can tell by the ever-increasing levels of
concern brought to them by ordinary citizens, farther & farther
removed from Sea-Tac.  There are more aircraft, they are very
noisy, they no longer seem to fly with any concern for the
noise endured by people below.  One of the lead agencies, at
the behest of the other, has altered flight paths for Sea-Tac
traffic so as to bring planes over many parts of the three-
county area that previously were nearly immune from overflight
noise & air pollution. These great changes have certainly
disappointed the reasonable expectations of thousands of
occupants they had wisely chosen places to live away from Sea-
Tac impacts.  Many of these occupants do not particularly want
to move;  many had thought that they had purchased their last
homes when they moved into their present residences;  people
such as this have put vast work & millions upon millions of
dollars into improvement of their properties.  Even if in their
maturity they wished to pull up their roots to escape aircraft
noise, can they recapture their investments?  What will be the
impact of their moving expenses if thousands of these citizens,
many of them on fixed incomes, were to decide to move to noise-
free areas?  Will the proceeds of their sales (reduced by the
costs of sale) be sufficient to permit them to acquire
comparable housing elsewhere (with the costs increased by the
costs of moving & purchase), using the funds received from
their former, noise-impacted homes?  And where will they be
able to go?  The co-lead agencies, in part through their paid
spokesperson, AirWashington, argue that these people foolishly
moved "down by the airport" & so are getting the noise that
they deserve.  We & such householders disagree, as do the
people far North in Seattle, & in Gig Harbor, & Maple Valley, &
Issaquah, & Medina, & numerous other places that are receiving
Sea-Tac noise thanks to the four-post plan.
     But let the FEIS directly answer the question:  Where are
such people to move in order to escape the present & the future
noise?  To answer that question, the FEIS must consider &
discuss what the future flight paths will be, when the fourth
runway will be built, what the noise impacts will be of the
unregulated aircraft from East Asia that the Port is so
assiduously seeking to bring here in ever-larger numbers, what
sorts of noise are to be expected from the aircraft of the
foreseeable future.      Let us suggest one answer, which the
FEIS should address:  persons displaced by Sea-Tac noise will
no longer rely on Port & F.A.A. assurances that there will be
no greater noise impacts; they will not move a few
neighborhoods farther away.  They will not be able to find
comparable housing in King County, especially now that growth-
management legislation has essentially restricted further
residential development to the Sea-Tac noise zone, the low-
lying Western part of the county.  The displaced persons will
be looking farther afield -- Bellingham, Olympia, Vancouver
Island, the Oregon Coast.  This commenter believes that the
process is already underway, & is likely to become very
pronounced as people begin to lose hope on the subject of Sea-
Tac.  Profound socio-economic consequences may take place, as
this stable, mature, salt-of-the-earth type of population
leaves.  Who comes in, if anyone?  What is the impact on a
community when it loses this group of residents?
     Comment IV-8-14:    -- Economic impacts -- Diminution
of Property Values -- A viable method of examining the
effects of airport noise on housing values at the national
level, called "the neighborhood,, pair model," was
recently studied in a report prepared by Booz, Allen &
Hamilton Inc. for the Federal Aviation Administration.
(Comment IV-8-C)  The procedure  consists  of three steps:
     1.   Identification by a local Realtor of two
     neighborhoods that have similar characteristics
     except for the noise level;
     2.   Selection of a sample of houses from each
     neighborhood with reasonably similar individual
     housing characteristics;
     3.   Use of a modified appraisal process by a local
     appraiser and statistical modeling to compare the
     housing values in the two neighborhoods.
Subjective inputs by local appraisers and Realtors are
explicitly incorporated in the neighborhood and home
selection process and are useful in interpreting the
modeling results, the report notes.     Conversely, asking
the appraiser to normalize the sales prices of the
selected homes to account for differences in house
characteristics make the appraisal procedure much more
quantitative compared to conventional appraisals, the
report states. "Hence, the analytical approach was
designed to minimize the effects of local conditions by
using local expertise and a combination of quantitative
and qualitative techniques that complement each other, and
seeks to overcome the shortcomings of previous studies
that exclusively used one technique or the other."
A series of studies was done around four major airports:
Baltimore-Washington International, Los Angles
International, and New York LaGuardia and Kennedy
International Airports to determine whether the procedure
was repeatable and verifiable, to see if any distinct
trends could be observed, and to determine if any
inferences could be made at the national level regarding
the impact of airport noise on housing value.
Booz Allen researchers concluded that the results of the
studies indicated that the neighborhood pair model is
viable and helps establish the boundaries of the effect
that airport noise has on housing values at a given
airport.  "The observed trends are consistent, showing
that the noise impact is more pronounced in higher-priced
areas and is hard to detect in relatively lowpriced
neighborhoods," the report concludes.
For instance, in the study around Los Angles International
Airport, they found that, in moderately priced areas, the
adjusted appraised value of homes suggested an average
$60,873 (18.6 percent) higher property value in the quiet
neighborhoods, or $4,348 (1.33 percent) per dB of
"additional quiet."   The FEIS should evaluate the effects
of noise under the alternatives on home values in existing
"quiet neighborhoods located in Normandy Park, Federal
Way, and Mercer Island, for example    On the other hand,
the results in the low-priced areas were much more modest
-  $1,268 (0.8 percent) higher property value in the quiet
neighborhood.
A later study in the New York area confirmed this finding.
As was observed in the LAX study, the results in the low-
priced areas indicate virtually no ($733, 0.5 percent)
difference in property values between the quiet and noisy
neighborhoods.  In the moderately-priced areas, the
adjusted appraised values suggested an average $10,700
(4.9 percent) higher property value in the quiet
neighborhood, or $1,070  (0.5   percent)  per dB of
additional  quiet.  In high-priced   areas, the adjusted
appraised value suggested an average $22,367 (5.7 percent)
higher property value in the quiet neighborhood, or $5,474
(1.4 percent) per dB of additional quiet.
The report concludes that the magnitude of the impact of
noise on property values cannot be estimated at the
national level at this time, since the results varied
across a wide range for the airports studied, and only a
small sample of airports was considered.  However, the
primary goal of the study was to assess the feasibility of
the neighborhood pair model to examine the effects of
airport noise on property values, and the findings
indicated that the methodology is viable and "reasonably
economical," the report concludes.
The results of a national study could help decision makers
in formulating national policy and would enable local
airport authorities to better deal with airport noise
impact, the report noted.      The FAA must perform
extensive cost-benefit analysis before implementing
proposed changes in the national noise related policies.
The report concludes that the aspect of noise impact which
needs to be better understood is its economic impact.  The
DEIS makes no reference to this and other current studies
evaluating the effects of airport noise on property
values.  The FEIS should include a detailed analysis of
all properties impacted by noise levels exceeding 65 DNL,
listing the current level of property value diminution
caused by existing noise levels, as well as the total
number, location and amount of loss of property value
caused by the noise levels associated with the
alternatives.
     Comment IV-8-15:    -- Economic impacts --Homeowner
damages -- The Port of Seattle is currently being sued by
approximately 120 homeowners residing in the cities of Burien,
Des Moines, and SeaTac who are allegedly impacted by the noise
of aircraft operations at SeaTac airport.  These property
owners are claiming the Port of Seattle's aircraft operations
of SeaTac have caused diminution of property values, loss of
quiet use and enjoyment,  and trespass of their property.  The 
FEIS should review these homeowners claims, the potential
liability of the airport operator due to all similarly impacted
homeowners, and the monetary amount of legal fees and costs
which have been paid thus far in this case and will likely be
incurred in the process of defending, settling, and paying
property and nuisance damage claims caused by SeaTac airports
present operations, as well as the amounts likely to be paid
under each of the proposed alternatives.