EXH AR023005: ACC Analysis Proposed Mitigation Ratios STIA Third Runway Wetland Impacts

A September 2000 report by Azous Environmental Sciences, commissioned by the Airport Communities Coalition, critically analyzes the Port of Seattle's wetland mitigation plan for the SeaTac Third Runway construction project. The report identifies numerous errors in wetland acreage accounting, inadequate mitigation ratios, and flaws in the proposed compensatory measures, including out-of-basin mitigation that fails to replace lost wetland functions in the affected Miller, Walker, and Des Moines Creek watersheds. The author concludes that the Port's plan falls short of Washington State Department of Ecology standards and the regulatory goal of no net loss of wetland functions.

Notes

Letter dated September 1, 2000 from Azous Environmental Sciences to Washington State Department of Ecology (Tom Luster, Erik Stockdale), U.S. Army Corps of Engineers (Gail Terzi, Jonathan Freedman), U.S. Fish and Wildlife Service (Nancy Brennan-Dubbs), National Marine Fisheries Service (Lynn Childers, Steve Landino), and EPA (Lee Daneker), prepared at the request of the Airport Communities Coalition (ACC). The letter analyzes proposed wetland mitigation ratios submitted by Port Of Seattle for impacts to wetlands from SeaTac third runway construction. Key findings: mathematical errors in Parametrix wetland acreage accounting; unsubstantiated temporary vs. permanent impact distinctions; buffer enhancement along Miller Creek and Walker Creek deemed inadequate one-for-one functional replacement; Auburn out-of-basin wetland mitigation lacks functional linkage to WRIA9 watersheds (Miller Creek, Walker Creek, Des Moines Creek); proposed ratios fail DOE recommended standards of 3:1 (Class 2/3 forested), 2:1 (scrub-shrub/emergent), 1.25:1 (Class 4). Reviews documents including Parametrix Wetland Functional Assessment (July/August 1999), Natural Resources Mitigation Plan, Biological Assessment, and SeaTac Runway Fill Hydrologic Studies Report. Exhibit AR023005.

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