Notes
Exhibit EXH0216 (AR 018789–018791). Email and attached draft memo dated October 17, 2000 from Tom Luster (Ecology) to Joan Marchioro, Raymond Hellwig, Paula Ehlers, and Kevin Fitzpatrick regarding the adequacy of Ecology’s Section 401 Clean Water Act certification review for the proposed Sea-Tac Airport third runway expansion. Luster identifies multiple unresolved issues including: interaction of CWA Section 401 and 402 NPDES permit requirements; inadequate water quality BMPs for new stormwater discharges; timing of 402 major modification; flow augmentation conditions lacking reasonable assurance; undisclosed impacts to Tyee Pond; wetland impacts from IWS Lagoon #3 expansion; impacts identified in Port of Seattle de-icing report; clean fill criteria; piecemealing of project review; and compliance with Governor’s certification letter (Agreed Order and Clean Air Act). Cites Ninth Circuit decision and Water Quality/SEA Program 401/402 policy. Filed in PCHB third-runway-eis administrative record.