Exhibit AR018931: NHC Follow-Up Comments on Stormwater Management Plan for Proposed Third Runway Development at Seattle-Tacoma International Airport

A technical review by Northwest Hydraulic Consultants, submitted to the U.S. Army Corps of Engineers and Washington State Department of Ecology in May 2000, raises serious concerns about the stormwater management plan for Seattle-Tacoma International Airport's proposed third runway. The report identifies major flaws in the hydrologic modeling used to assess drainage impacts, including inconsistent soil-type assumptions and unreliable flow predictions for Miller Creek. The consultants call for a complete overhaul of the modeling process, independent technical review, and clearer regulatory oversight of the Port of Seattle's stormwater design work.

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Northwest Hydraulic Consultants (nhc), retained by the Airport Communities Coalition (ACC), submits follow-up technical comments dated May 3, 2000, to U.S. Army Corps of Engineers (Jonathan Freedman) and Washington State Department of Ecology (Tom R. Luster) regarding the Stormwater Management Plan (SMP) for the Sea-Tac Airport third runway Master Plan Update Improvements. Letter identifies major discrepancies in HSPF hydrologic model input files for Miller Creek and Walker Creek basins, including inconsistent soil type assumptions (till vs. outwash soils) between pre-development flow targets and detention facility performance models, and four separate sets of runoff parameters for airport fill areas. NHC concludes the Miller Creek streamflow analysis is seriously flawed, flow targets for Level 1 and Level 2 (1994 existing development) are unsupported, and a complete overhaul of SMP hydrologic modeling is required including calibration to recorded streamflow data. Also raises concerns about King County Surface Water Design Manual (KCSWDM) 1990 vs. 1998 version applicability under the 09/04/97 Interlocal Agreement (ILA) between Port of Seattle and City of SeaTac, lack of local regulatory oversight, Master Drainage Plan (MDP) procedural compliance, and direct discharge impacts to Puget Sound. References Regional Detention Facility (RDF), Parametrix, Pacific Groundwater Group, and King County independent review.

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