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EXH AR021386: Rebuttal to Response to 401/404 Comments, Miller Creek Relocation & Master Plan Update, STIA

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A biologist with Columbia Biological Assessments submitted a formal rebuttal in June 2001 challenging the Port of Seattle's environmental responses related to proposed Master Plan Update Improvements at Seattle-Tacoma International Airport. The rebuttal argues that the Port failed to adequately assess impacts on Miller Creek, particularly regarding fish habitat, water temperature, and dissolved oxygen levels during summer months. The author contends that no proper baseline survey of fish and aquatic organisms was conducted, making regulatory approval and proposed mitigation measures scientifically insufficient.

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Letter dated June 20, 2001, from John A. Strand, Ph.D., Principal Biologist, Columbia Biological Assessments, to U.S. Army Corps of Engineers (Muffy Walker, Gail Terzi) and Washington State Department of Ecology (Ann Kenny), rebutting the Port Of Seattle’s April 30, 2001 response to 401/404 comments on Public Notice No. 1996-4-02325. Strand argues the Port’s analysis of impacts to Miller Creek from the Master Plan Update Improvements (MPU) at Seattle-Tacoma International Airport is scientifically inadequate: no quantitative baseline fish survey has been conducted, summer flow, temperature, and dissolved oxygen (D.O.) will not support cutthroat trout in the relocated reach, riparian shading will take several or more years to establish, and multiple cited documents (Natural Resource Mitigation Plan, Biological Assessment, Wetland Delineation Report, Wetland Functional Impact Analysis) address impacts only in general terms. Challenges Clean Water Act Section 404 permit and Section 401 certification. AR021386–AR021388.

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