EXH0238018964

PCHBPollution Control Hearings Board of the State of Washington

Subject: 401 Certification for Seattle-Tacoma International Airport. Dear Mr. Hellwig: Further to our meeting yesterday afternoon, we would like to briefly summarize the main findings to date of our review of the August 2000 "Preliminary Comprehensive Stormwater Management Plan Seattle-Tacoma International Airport Master Plan Update Improvements" (SMP). Please note that we only received our copy of the four-volume SMP on Friday August 31 and to date have only made a very preliminary and incomplete review of these documents. Further review comments will be forthcoming. We understand that Ecology will be making a preliminary determination today regarding the adequacy of the Port's submittals for making a decision on 401 Certification, and we are submitting these incomplete comments for your consideration in making that determination. Also, we would like to record our objections to both the delay in Ecology providing copies of the SMP to the Airport Communities Coalition and to the lack of adequate time for us and others to provide review comments. Our preliminary comments to date are as follows: 1. Anticipated impacts on base flows Volume 1: Section 6.2.1 - Predicted Baseflow Impacts Volume 4: Appendix F - Evaluation of Potential Base Flow Impacts There appear to be significant discrepancies or inconsistencies in the evaluation of the project's base flow impacts. It appears that the analysis presented in Appendix F does not rely on the same hydrologic model parameters as used elsewhere in the SMP. Most significantly, the base flow impact analysis appears to have relied on hydrologic model…
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