EXH0516023128

PCHBPollution Control Hearings Board of the State of Washington

- Subj: The Port of Seattle's (Port) Low Flow Analysis/Flow Impact Offset Facility Proposal, prepared by Parametrix, Inc., July 2001. Dear Ms. Walker, Ms. Terzi, and Ms. Kenny: At the request of the Airport Communities Coalition (ACC), I have evaluated the Port's plan to use detained stormwater to augment summer low flows in Miller, Walker, and Des Moines Creeks. I offered some initial comments on the use of detained stormwater for this purpose in my Rebuttal to the Port's Response to 401/404 Comments, dated June 20, 2001, based on a general response (GLR7, page II-7) to comments to the Port's Sect 404 Permit Application. I earlier (September 2000) commented on the Port's plans to use either Seattle Public Utilities water or well water for this purpose. In undertaking this effort, I have relied on my education, specialized training, and professional skills acquired over a 26-year career (post Ph.D.) as an environmental scientist (see attached Curriculum Vitae). Conclusions In my opinion, for the following reasons, the Port has not provided sufficient information to enable the Washington Department of Ecology (Ecology) or the Army Corps of Engineers to conclude with reasonable assurance that detained stormwater, proposed for Draft 2 1 August 6, 2001 AR 023128 use in offsetting impacts of low summer flows in project creeks, will not harm the valued aquatic resources of the Miller Creek and Des Moines Creek Watersheds. • Violations of toxic substances (water quality) criteria in Miller Creek, Walker Creek, and Des Moines Creek, particularly for copper…
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