EXH AR023092: ACC Letter to USACOE & Ecology — Scientific Adequacy Section 404 CWA Permit Third Runway

A fisheries biologist writing on behalf of 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 expansion at Seattle-Tacoma International Airport. The letter contends that the project would harm local streams (Miller Creek, Walker Creek, and Des Moines Creek) and their fish populations — including federally threatened Chinook salmon — through stream relocation, contaminated fill materials, and toxic stormwater runoff containing copper, zinc, and de-icing chemicals. The author concludes that the U.S. Army Corps of Engineers lacks an adequate scientific basis to approve the permit without additional environmental study and mitigation measures.

Notes

Letter dated February 16, 2001 from Columbia Biological Assessments (fisheries biologist J. Strand, Ph.D.) to USACOE Project Manager Jonathan Freedman and Washington State Department of Ecology Environmental Specialist Ann Kenny, filed on behalf of the Airport Communities Coalition (ACC). Argues the Port Of Seattle has not provided a scientifically defensible basis for issuance of a Clean Water Act Section 404 permit for the Seattle-Tacoma International Airport third runway project (Public Notice No. 1996-4-02325). Identifies deficiencies in the Port’s impact assessments covering: Miller Creek relocation, elevated water temperatures, dissolved oxygen, summer low flows, fish stranding and mortality, spawning gravel installation, peat dewatering on the former Vacca Farm; Soil Acceptance Criteria and contaminated fill (PCBs, DDT) from Hamm Creek Restoration Project; stormwater violations of water quality criteria for copper and zinc in Miller Creek and Des Moines Creek; de-icer toxicity; NPDES Waste Discharge Permit modifications; and cumulative impacts. Species discussed include federally threatened Puget Sound chinook salmon, coho salmon, chum salmon, cutthroat trout, yellow perch, black crappie, largemouth bass, pumpkinseed sunfish, prickly sculpin, three-spined stickleback, and crayfish. Exhibit AR023092 in the Third Runway EIS administrative record before the Pollution Control Hearings Board (PCHB).

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