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EXH AR023701: Email Chain Stormwater Compliance, 401 Certification, NPDES Permitting STIA Third Runway

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Sea-Tac Airport
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This 1999 email chain between Washington State Department of Ecology staff discusses the challenges of applying water quality standards to stormwater discharges related to the proposed Sea-Tac Airport third runway project. Officials from the Water Quality and Shorelines/Environmental Assistance programs agreed that strictly enforcing numeric water quality criteria on stormwater is scientifically and legally difficult, and recommended an 'adaptive management' approach requiring monitoring and ongoing improvements rather than immediate full compliance. The correspondence also highlights resource limitations, the relationship between Section 401 and 402 Clean Water Act permits, and the need for a consistent statewide policy on stormwater review.

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Notes

Email chain (AR023701) dated March 4–11, 1999, among Washington State Department of Ecology staff including Ann Kenny, Tom Luster, Raymond Hellwig, Kevin Fitzpatrick, and John Glynn discussing stormwater compliance, Section 401 certification, and NPDES permitting in the context of the Sea-Tac Airport Third Runway project. Key topics include difficulty applying WAC 173-201A numeric water quality standards to stormwater discharges, adaptive stormwater management as a legally defensible approach, compatibility of CWA Section 401 and Section 402, the Puget Sound Stormwater Manual, NWRO Water Quality Program resource constraints (approximately 1,100 stormwater permits annually), and a March 25 meeting with Port of Seattle’s Elizabeth Leavitt regarding 401 Certification stormwater requirements for the Third Runway. Participants include CASE (Citizens Against Sea-Tac Expansion), RCAA, and WAP (Greg Wingard) as citizen group stakeholders.

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