Notes
Letter dated July 6, 2001 from Azous Environmental Sciences (AES) to US Army Corps of Engineers (Muffy Walker, Gail Terzi) and Washington State Shorelands and Environmental Assistance Program (Ann Kenny) regarding permit application 1996-4-02325, Port of Seattle Third Runway and STIA Master Plan Update Improvements. AES argues proposed fill activities in wetlands do not comply with Section 404(b)(1) Guidelines (Part 230), Clean Water Act, and the EPA-Corps Memorandum of Agreement requiring one-for-one functional replacement and no net loss. Document addresses deficiencies in the Natural Resources Mitigation Plan (NRMP) including unaccounted loss of wetland functions, reduced organic carbon production, loss of wetland landscape functions, underestimated permanent impacts, out-of-watershed mitigation exchanges for Miller Creek and Des Moines Creek, unmitigated cumulative effects, and underestimated hydrologic impacts. References Section 404, Section 401, Section 230.10(c)(3), Walker Creek, Miller Creek, Des Moines Creek watersheds, Parametrix Inc., and prior converted cropland mitigation. AR 023060.