EXH 372: Letter Columbia Biological Assessments to USACOE & Ecology — CWA §404 Permit Adequacy Third Runway

A fisheries biologist hired by the Airport Communities Coalition argues that the Port of Seattle has not provided sufficient scientific evidence to justify a Clean Water Act Section 404 permit for its proposed third runway project at Seattle-Tacoma International Airport. The report concludes that the Port's plans would harm wetlands, streams, and fish populations—including federally threatened Chinook salmon—in the Miller Creek, Walker Creek, and Des Moines Creek watersheds through contaminated fill, toxic stormwater runoff, and the rerouting of Miller Creek. The biologist urges the U.S. Army Corps of Engineers to require additional environmental studies and water quality modeling before any permit decision is made.

Notes

Exhibit 372 (AR 021364). Letter dated February 16, 2001 from J. Strand of Columbia Biological Assessments, Richland WA, submitted to USACOE Project Manager Jonathan Freedman and Washington State Department of Ecology specialist Ann Kenny on behalf of the Airport Communities Coalition (ACC). Evaluates whether the Port Of Seattle has provided a scientifically defensible basis for issuance of a Clean Water Act Section 404 permit for the STIA third runway project (Public Notice No. 1996-4-02325). Addresses impacts to Miller Creek, Walker Creek, and Des Moines Creek, including chinook salmon (federally threatened), coho salmon, chum salmon, and cutthroat trout. Identifies deficiencies in Port’s environmental analysis including: elevated water temperatures and low dissolved oxygen in relocated Miller Creek; fish stranding and mortality risks from summer low flows and spawning gravel additions; chemically contaminated fill (PCBs, DDT) from Hamm Creek Restoration Project stockpiled at Seattle-Tacoma International Airport; violations of water quality criteria for copper and zinc in stormwater discharges; inadequate assessment of de-icer effects; and flawed use of Model Toxics Control Act (MTCA) Soil Cleanup Levels and NPDES permit modifications. Recommends transport, fate, and effects modeling of metals and other stormwater chemicals before permit decision.

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