EXH AR023598: ACC Comment Letter Opposing STIA Third Runway 401 Certification and 404 Permit

A February 2001 letter from law firm Helsell Fetterman, representing the Airport Communities Coalition (cities of Burien, Des Moines, Federal Way, Normandy Park, Tukwila, and the Highline School District), urges the U.S. Army Corps of Engineers and Washington State Department of Ecology to deny the Port of Seattle's permits for the proposed Sea-Tac third runway. The letter argues that the Port had already spent nearly $300 million on construction before receiving required Clean Water Act approvals, and that its application lacked adequate stormwater management plans and failed to meet water quality standards. Independent experts retained by the coalition found the Port's environmental mitigation proposals to be technically flawed, incomplete, and legally insufficient.

Notes

Letter dated February 16, 2001, from Helsell Fetterman attorneys Peter J. Eglick and Kevin L. Stock, representing Airport Communities Coalition (ACC) — comprised of Burien, Des Moines, Federal Way, Normandy Park, Tukwila, and Highline School District — to Jonathan Freedman (U.S. Army Corps of Engineers, Seattle District) and Ann Kenny (Department of Ecology, Northwest Regional Office), Corps Reference No. 1996-4-02325. ACC urges denial of Port Of Seattle’s Clean Water Act Section 401 certification and Section 404 permit for the third runway and MPU improvements at Sea-Tac Airport. Letter details Phase 4 embankment construction ($31–$48 million, 50 acres clearing, 2,300,000 cubic yards fill, two sedimentation ponds), alleges Port has spent ~$300 million pre-permit, and argues Ecology lacks ‘reasonable assurance’ under state water quality standards. Cites PCHB case Okanogan Highlands Alliance v. Department of Ecology and Battle Mountain Gold Company (PCHB Nos. 97-146, 97-182, 97-183, 97-186, 99-019). Raises deficiencies in stormwater management plan (SMP), Miller Creek relocation, 18 acres wetland fill, inadequate Best Management Practices, and comments by Northwest Hydraulic Consultants, Sheldon & Associates, and Water Resources Consulting (Dr. Peter Willing). Exhibit AR023598–AR023600.

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