EXH0513023086

PCHBPollution Control Hearings Board of the State of Washington

Re: Port of Seattle July 23, 2001 Low Streamflow Analysis As you know, Northwest Hydraulic Consultants has been retained on behalf of the Airport Communities - Coalition (ACC) to provide a technical review of stormwater facilities and related streamflow impacts fi'om the proposed 3rd runway development at SeaTac airport. The purpose of this letter is to comment on the July 23, 2001 Port of Seattle two-volume document titled "Low Flow Analysis Flow Offset Facility Proposal." The comments here are in addition to the outstanding Stormwater Management Plan issues and uncertainties described in our letter of lune 25, 2001, and summarized at our meeting on July 10, 2001. The Low Flow Analysisis an incomplete draft document. The document's opening page gates that "IT]he evaluation and low streamflow impact offset proposal is final..." However, the documentation of the evaluation is so poor as to make an informed review virtually impossible, and the impact offset proposal is inconsistent with other project documents. There is an absence of critical design and project operation information necessary to demonstrate how the system will function in practice. Because of these deficiencies, the present "final" proposal does not provide any assurance that impacts to low streamflows will be adequately mitigated. Our specific comments follow. 1. The substantive narrative portion &the document, the 37-page "Draft Low Flow Analysis/Flow Effect Offset Facility Report," is clearlyincomplete. Several of the sections identified in the report table of contents, and which are vital to understanding the analysis and flow offset proposal, are not…
V V