Exhibit 228: NHC Letter to U.S. Army Corps of Engineers Identifying Port Of Seattle Document Inconsistencies in SMP and NRMP for Sea-Tac Airport Master Plan Update

A December 2001 technical letter from Northwest Hydraulic Consultants, written on behalf of the Airport Communities Coalition, identifies inconsistencies in the Port of Seattle's stormwater management plans for Sea-Tac Airport expansion. The letter argues that the Port's hydrologic modeling failed to account for the planned commercial redevelopment of borrow pit areas by 2006, and that the Natural Resource Mitigation Plan reverted to an outdated stormwater approach relying on regional detention facilities to be built by others. These gaps, the consultants contend, prevent a full assessment of the airport Master Plan Update's environmental impacts.

Notes

Exhibit AR018905. December 18, 2001 letter from Northwest Hydraulic Consultants Inc. (NHC) to Colonel Ralph H. Graves, Ms. Muffy Walker, and Ms. Gail Terzi of the U.S. Army Corps of Engineers Seattle District (Corps Ref. No. 1996-4-02325), submitted on behalf of the Airport Communities Coalition (ACC). Identifies two inconsistencies in Port of Seattle’s Stormwater Management Plan (SMP) and Natural Resource Mitigation Plan (NRMP) for Sea-Tac Airport Master Plan Update Improvements. Comment 1 concerns borrow areas 3 and 4 (Aviation Commercial/Aviation Operations zoning, City of SeaTac; Borrow Area 1 in Des Moines zoned Business Park): Port’s April 30, 2001 response to 401/404 comments claimed borrow area modifications were ‘temporary and reversible,’ but Port Commission Agenda Item No. 8a (October 16, 2001 memorandum, Resolution No. 3469) anticipates commercial redevelopment within five years and a marketing plan within 6 months, contradicting the SMP’s exclusion of future developed conditions for ~155-acre combined borrow area footprint. Comment 2 concerns NRMP Page 1-10 footnote reverting to reliance on Regional Detention Facilities (RDFs) constructed by others, inconsistent with December 2000/July 2001 SMP which eliminated that dependency. Parametrix Inc. prepared the November 2001 NRMP. Miller Creek channel relocation and drainage channel performance concerns also noted.

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