EXH 235: Follow-up Comments Low Streamflow Analyses — ACC Letter to Ecology

In a July 2001 letter to the Washington State Department of Ecology, Northwest Hydraulic Consultants raised concerns on behalf of the Airport Community Coalition that the Port of Seattle's ongoing low streamflow analyses for Des Moines, Walker, and Miller Creeks near Sea-Tac Airport were likely underestimating the airport's impact on local waterways. The consultants argued that the models were poorly calibrated for upper-basin conditions and failed to account for post-1994 improvements to the Industrial Wastewater System or the future loss of forested areas due to planned airport development. They requested that a final report on the streamflow analysis and any proposed mitigation measures be made available for public comment before Ecology used it to make its 401 Certification decision.

Notes

Exhibit 235 (AR 018954). Letter dated July 23, 2001 from William A. Rozeboom, P.E., Northwest Hydraulic Consultants Inc., to Gordon White, Program Director, Shorelands and Environmental Assistance Program, Washington State Department of Ecology, on behalf of the Airport Communities Coalition (ACC). Raises concerns about low streamflow analyses conducted by Parametrix (Port of Seattle consultant) for Des Moines Creek, Walker Creek, and Miller Creek in connection with Sea-Tac Airport 401 Certification. Identifies three specific deficiencies: (1) model calibration focused on lower basin gages rather than upper basin gages more relevant to airport impacts; (2) failure to account for post-1994 expansion of the Industrial Wastewater System including lagoon linings and leak reduction; (3) failure to address low-flow impacts of future airport business park development at proposed borrow pit sites in the upper Des Moines Creek Basin. Requests that a final report documenting low streamflow analysis and mitigation proposals be issued and subject to public comment before Ecology relies upon it for its 401 decision. References email documents transmitted July 6, 12, and 13, 2001 by Parametrix to Ecology.

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