EXH AR023711: Internal Email — Tom Luster on Sea-Tac Third Runway 401 Certification and Reasonable Assurance

In this October 1999 internal memo, Washington State Department of Ecology staffer Tom Luster describes a meeting with his supervisor Paula regarding the agency's water quality review of Sea-Tac Airport expansion. Luster explains that he cannot yet provide 'reasonable assurance' that the Port of Seattle's proposal will meet water quality standards for Des Moines Creek, citing inadequate stormwater treatment plans and the Port's removal of flow augmentation measures from its mitigation plan. He expresses concern that management pressure to approve the project quickly could compromise the integrity of the regulatory review process.

Notes

Internal email dated October 20, 1999, from Tom Luster (Washington State Department of Ecology) to himself, cc’d to his home address, documenting a meeting with Paula regarding the Sea-Tac Airport third runway 401 water quality certification and reasonable assurance. Luster explains he cannot provide reasonable assurance under Section 401 (Clean Water Act) because Des Moines Creek is impaired due to high storm flows and low summer base flows, and the Port Of Seattle has dropped flow augmentation mitigation from its plan. Issues discussed include Level 2 stormwater detention, the proposed RDF (retention/detention facility), Highline Water District water rights, Miller Creek flow impacts (7–13% diminished flows), inadequate BMPs for stormwater treatment, FAA easement language for wetland mitigation, and NWRO (Northwest Regional Office) transfer threat. Management named: Gordon, Megan, John Glynn. Exhibit AR023711, filed in PCHB third-runway-eis administrative record.

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