Exhibit 220: Email from Raymond Hellwig to Tom Luster re Des Moines Creek Fish and POS Third Runway Stormwater Review

A January 2000 internal email from EPA's Raymond Hellwig to Tom Luster addresses concerns about premature deaths of Coho salmon in Des Moines Creek near Sea-Tac Airport, in the context of the proposed third runway project. The email clarifies that stormwater discharge regulation will be handled through NPDES permits rather than Section 401 Water Quality Certifications, as the NPDES permit provides the only mechanism for ongoing regulatory oversight under the Clean Water Act. Hellwig directs Luster to defer to the Water Quality Program on stormwater issues and to stop raising the 401 Certification as an alternative avenue for addressing water quality standards.

Notes

Exhibit AR018841. Email dated January 3, 2000 from Raymond Hellwig (WQ Program) to Tom Luster (SEA Program), cc’d to Ron Langley, Dave Garland, Erik Stockdale, Gordon White, Jeannie Summerhays, John Glynn, Kevin Fitzpatrick, Paula Ehlers, Megan White, and Dan Silver. Responds to Luster’s December 23, 1999 message regarding premature death of Coho salmon in Des Moines Creek and stormwater discharge concerns related to the Port Of Seattle third runway proposal. Clarifies that regulation of stormwater discharges from facilities covered under both 401 Certifications and NPDES permits will be handled under the NPDES permit, not the 401 Certification. References City of Normandy Park and City of Burien concerns, WDFW coordination, Clean Water Act, adaptive management BMPs, and internal agency policy decisions on respective roles of SEA and WQ Programs. Document filed in PCHB third-runway-eis administrative record.

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