http://www.rcaanews.org/rcaa

COMMENTS OF SEATTLE COMMUNITY COUNCIL FEDERATION TO THE DRAFT ENVIRONMENTAL IMPACT STATEMENT ON THE SEATTLE-TACOMA AIRPORT MASTER PLAN UPDATE August 4, 1995

Comments on Draft EIS for  Airport Master Plan Update Page 1
                      Identity of commenter
Seattle Community Council Federation is a not-for-profit
Washington corporation, made up of community clubs, councils
and associations in the City of Seattle.  It is the only
city-wide organization of its type.  The Federation
submitted scoping comments at the start of this particular
exercise, and has been continuously active in Airport
affairs since the days of the Joint Overflight Committee.
Noise from aircraft operation, including noise due to Sea-
Tac, has long been a concern of many of our member groups.
It had a special task force on aircraft noise, the Aircraft
Noise Group, since 1989.
              General impact of Sea-Tac on Seattle.
     Our principal interest is in matters directly affecting
the people and the neighborhoods of Seattle.  Noise and
other impacts from Sea-Tac (particularly air pollution) have
become problems in every corner of our city, from Broadview,
on the extreme northern border, to Seward Park in the south
east, from West Seatttle, Queen Anne and Magnolia across to
Beacon Hill and the Rainier Valley, in the lower-income
areas, in mixed neighborhoods, in the most prosperous
residential areas, in the health-care district on First
Hilll -- everywhere.
              Meaningless Noise Impact numbers
     We are quite aware, even without the current DEIS, that
the F.A.A. likes to aver that there is no noise outside its
oddly-drawn 65 Ldn contours.  This comment says that the
F.A.A. is wrong.  The agency's activities and the activities
that it sponsors, that it is supposed to control but does
not, produce plenty of annoying, bothersome, anger-producing
noise, day and night, in areas far removed from any that the
agency recognizes as being impacted.  The noise discussion
in the present DEIS is utterly unrealistic.  The noise
metric of 65 Ldn is essentially useless in determining where
in Seattle there is unwanted, undesirable noise from Sea-Tac
operations.  If noise wasn't a problem, we wouldn't be
complaining.  We're complaining.  It's a problem.  The
F.A.A. starting with the FEIS, needs to come up with more
realistic, more honest, ways of measuring noise and its
adverse impacts.  Hiding behind its own archaic,
unscientific, and self-serving regulations may be a legal
justification for bureaucratic indifference, but it is not a
proper excuse.
               Socio Economic Impacts of Noise
     Noise harms our neighborhoods.  We know it, even if the
F.A.A. and the Port are locked into states of denial.  It
causes direct stress, it causes anger, it causes distrust of
government, cold, callous, indifferent, and even hostile
government, agencies that seem to be in the pocket of large
corporate interests.  Noise diminishes property values.
Noisy neighbors harm property values;  noisy streets and
freeways the same.  Seaplanes, helicopters, and most of all,
Sea-Tac jet aircraft, make properties and neighborhoods less
desirable.
     Big-city neighborhoods are under a lot of stress at
this time.  New zoning regulations from every level of
government seem indifferent to preservation of family-
oriented neighborhoods, indifferent to private home
ownership.  Problems in the education system (once the most
admired in the State) make city living look less attractive
to many.  Sudden and large shifts in neighborhood and all-
city demographics are disturbing.  Ground traffic volumes
are up, street conditions are worse.  Taxes seem to head to
ever-new heights.  We are endeavoring, sometimes against
what seem great odds, to hold together an important social
unit, the neighborhood.   Massive doses of unnecessary
overflight noise is another and serious strain on the
neighborhoods and on the social fabric generally.
     We lived through, and worked against 'white flight' we
worked against considerable opposition to keep some
neighborhood connection and parental involvement in the
common schools, we've worked for and achieved neighborhood-
based, pro-active policing.  But the city still suffers from
the devastation of the urban-renewal days, with seemingly
desirable, large, tracts of land lying empty in the heart of
the city.  How easy will it be to secure desirable
development on ground just under the ever-noisy flight paths
that go down the mid-line of our city?  The FEIS needs to
address overflight noise and air pollution as disincentives
to reasonable and orderly property development in Seattle.
     The FEIS needs to consider the impacts on neighborhoods
of this unwanted, undeserved, intrusive noise.  For some,
the unabated, uncontrollable noise will be the last straw.
How many people will be driven out by this nuisance?  What
are the demographic implications of noise displacement?
Will the city continue to attract and to hold at least some
of the best and brightest, despite this newest  device to
make urban living unattractive?   Where will people go, if
they can afford to go, to escape?  Not to some other
neighborhood in the city, for none is immune from the
overflights.  Out to the county?  But it seems that all the
densely populated centers receive overflight noise, and
every time there is a juggling of flight paths, another area
gets hit.  Into the country?   Growth management essentially
cuts off this possibility.  The implication is that people
will be driven completely out of the Central Puget Sound
region.
     People working out of their homes, people whose work
requires extreme mental concentration, they will suffer
disproportionately.  Retirees who are home all day, many of
whom have looked forward for years and decades to gardening,
golfing, and other outdoor recreation after retirement, find
their enjoyment of life sadly diminished by noise from
overflights in their back yards.  People will start to think
long and hard about remaining in such an environment.  The
prosperous may start to leave.  The FEIS needs to look at
this consequence of business-as-usual down at the airport.
Consider the economic harm to the city as prosperous and
highly productive people are essentially driven out.
     In referring all these ills to our own city, we do not
wish to seem to minimize the impacts on the social fabric of
other parts of the vast affected area.  Certainly  many
communities closer to the airport will suffer similar
adverse impacts, and some will in time be sadly wrenched,
with many of those who long provided leadership and
stability finally leaving, some at considerable financial
sacrifice, when it becomes clear at last that the Port and
the F.A.A. are determined to induce all significant
commercial-aviation activity to occur at Sea-Tac.
                    Mitigation Impossible
     It is simply impossible to mitigate the harm here
proposed.  Our gardens and yards cannot be insulated.  The
home-insulation program is so narrowly circumscribed that
tens of thousands of impacted homes are artificially denied
assistance.  The Port cannot afford to buy up the properties
that it should acquire to have a decent separation between
itself and those upon whom it is inflicting itself.   It
would have to buy out half Seattle.   What would be the
point?  Destroy the urban centers that the Airport
supposedly serves?
                     No Need Established
      We cannot see any need for this project.  It is
patently obvious to anyone who has followed the Port's
expansion activities for very long that the bad-weather
delay argument is a fabrication.  No-one in their right mind
would spend this kind of money for the measly increase in
flights that would follow.  If that were the real concern, a
modest amount of demand management would clear up the
Airport for decades to come.  Just get those space-consuming
little commuter planes out of the way.
     Diversion of even a small number of people from
commuter aircraft to rail would also provide an indefinite
relief  to the facility.  Many other ameliorative measures
have been suggested, all to be rejected.  Why?  Because the
bad-weather delay is not the real reason for the project.
The Port wants a MAJOR expansion.
     We have attached as our Appendix A our report at least
some of the available alternative, and ask you respond to
its points.
                Alternatives Given the Brush
      The EIS should have looked seriously at the two viable
remote locations proposed for a true regional airport of
realistic capacity, the proposed site down in Lewis County,
presented to AIRTRAC, and the existing, operational site at
Moses Lake.  The purported difficulties of ground
transportation, as we all know,  can be solved with
available technology -- except that the Port ardently blocks
all realistic consideration of such alternatives.
     Sea-Tac cannot possibly meet the projected air-travel
needs of the future for this region.  Maybe, maybe, if risky
innovative techniques of flying in total fog, wingtip-to-
wingtip, were instituted, but only then if the commuter
craft are sent elsewhere, and certainly Sea-Tac will not
support the bigger, faster planes of the future.  Even if
there were no noise impacts, just  plain constraints of
geography, the place will not work for the future.
                  Disproportionate Impacts
     By obfuscating the noise impacts, the F.A.A. has so far
successfully hidden the disproportionality of  the impacts
of  Sea-Tac operations, impacts which we know from our
knowledge of our city's neighborhoods, acquired over many
years, to fall much more heavily -- though they are heavy on
all -- on people of color, recent immigrants, low-income
people, the halt, the infirm, the elderly.   Sometime or
other, honest noise measurements and honest noise maps will
have to be produced.  Let the FEIS be the place.  Then our
policy-makers can see the truth about the objectively racist
character of this proposal.
                    Diminishing Noise ??
     The DEIS makes a considerable splash about its
predictions that noise from Sea-Tac will diminish in the
future.  The Port's noise regulations, adopted half-a-year
after the Port terminated the noise mediation effort, are
said to be so effective that there will only be half as much
noise in a few years.  Any gains arising from the
regulations will, we believe, be negated by much-greater
volume, as the commuter planes are pushed out in favor of
heavy cargo aircraft, as the Stage 3 aircraft get older and
noisier, and the newer ones get bigger and noisier (and fly
from the extended easterly runway with greater loads), and
as the user fleet becomes more and more East Asian.   All
who are knowledgeable about noise know that  a reduction of
half in total energy will be barely perceptible, if it ever
occurred.   Indeed the PSRC's Expert Arbitration Panel.  The
way a jet is loaded and flown makes more difference than
Stage II or III for noise.
     Absurdly, Seattleites are told to turn the Federal Way
maps upside down to get an idea of the 80 SEL noise, which
disturbs sleep.  The FAA  & the Port can't be bothered to
produce complete maps.
                     Flying the Duwamish
     The DEIS talks about aircraft presently flying the old,
abandoned  Duwamish - Elliott Bay noise abatement route in
large numbers, especially during South flow.  We live under
the noise, and we're here to tell you that this talk is
bunk.  The F.A.A. directs traffic all over the place, but
mostly right down the I-5 corridor, so that the noise
exposure on human populations in Seattle is maximized.  This
should be fixed in the FEIS.   The DEIS also perpetuates the
myth that planes quiet  on arrival.  Some are but a heavy
jet makes more noise on landing than and old stage II on
take off--and they make a lot of noise turning and adjusting
as they line up for the runway.
                 Air pollution Not Measured
     The section on air pollution, main text and appendix,
artfully speaks of 'receptors' as having been used in the
studies of Sea-Tac air pollution.  Reading with care, we
discovered that in fact NO receptors were used.  The
"receptors" are merely geographical co-ordinates fed into
the computer model that was used to make educated guesses
about air pollution.  The FEIS should cure the deception,
innocent or otherwise, and not talk about imaginary
receptors as if they were real.  And, we find it hard to
believe that anyone will give any credibility to air
pollution conclusions that are not based on any real
measured data.  The FEIS should not come out till real field
work is done.   And let us add that  Sea-Tac's heavy
contribution to air pollution should not be concealed by
averaging it in with county-wide numbers, and by assuming
that there is no air-pollution problem unless the pollution
is so very bad that it violates statute law.  On those
bases, no-one's air pollution around here has any
significance, which is absurd.  The FEIS needs to get
serious about this subject.  Maybe the Port and  the F.A.A.
should hire some scientists to work on this subject, instead
of the same old crew of  professional airport apologists
hired to write yet another EIS justifying yet another lousy
airport expansion.
     We associate ourselves with the comments of our member
group, Ravenna-Bryant Community Association, and with the
comments of our colleagues in the North-East District
Council.  We also adopt the comments of the Regional
Commission on Airport Affairs.
                        Absurd Costs
     The price tag for the third runway goes up with each
passing year.  First , it was  $400 million (Flightplan) ;
then it was $900 million with so-called mitigation.  Now, we
understand it's $1.2 billion, not including mitigation.  Who
is minding the till?      Most other single (independent)
runway estimates in other cities run $40 million to a
maximum of $120 million.
                         Appendix A:
                The Need for the Third Runway
                  and Alternatives Thereto