EXH 238A: Northwest Hydraulic Consultants Letter to Ecology — 401 Certification STIA Master Plan Update Stormwater Management Plan Preliminary Review

A September 7, 2000 letter from Northwest Hydraulic Consultants to the Washington State Department of Ecology raises concerns about the adequacy of the Port of Seattle's Stormwater Management Plan for Sea-Tac Airport's Master Plan expansion. The letter identifies significant technical discrepancies in the plan's analysis of baseflow impacts on Miller Creek, questions the reliability of proposed water-rights acquisitions as mitigation, and flags inconsistencies between the stormwater plan and the Natural Resource Mitigation Plan. The consultants also object to the limited time provided for independent review of the four-volume plan and warn that cumulative water quantity impacts of future commercial development in the airport acquisition area have not been adequately assessed.

Notes

Exhibit 238A (AR 018968–018970): Letter dated September 7, 2000 from Northwest Hydraulic Consultants Inc. (Seattle office) to Ray Hellwig, Regional Director, Washington State Department of Ecology Northwest Regional Office, regarding 401 Certification for Seattle-Tacoma International Airport Master Plan Update (MPU). Reviews the August 2000 Preliminary Comprehensive Stormwater Management Plan (SMP) across four volumes. Identifies discrepancies in HSPF hydrologic model parameters for fill embankment baseflow analysis (Appendix F), finding groundwater plus interflow of ~44% versus 63.6% reported; predicts average groundwater reductions to Miller Creek from subbasins SDW1A and SDW1B of 0.10 cfs (July) and 0.09 cfs (August). Challenges SMP conclusions on water rights acquisition on Miller Creek (Appendix G), domestic withdrawal estimates of 0.01 cfs per user (6,460 gallons/day), irrigation return flows, septic system elimination. Raises concerns about cumulative impacts from future commercial development in acquisition area, inconsistencies between SMP and Natural Resource Mitigation Plan (100-year pre-development discharge at SR-509: 198 cfs vs. 71 cfs; detention volume 42 vs. 100 acre-ft for Miller Creek), preservation of existing basin boundaries, Walker Creek headwaters (Wetlands 44a and 44b, basin SDS7, Des Moines Creek diversion), and Industrial Wastewater System diversions. Filed on behalf of Airport Communities Coalition (ACC) at PCHB Third Runway proceedings.

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