Notes
Letter dated December 28, 2001 from Azous Environmental Sciences (AES) to Gail Terzi and Michelle Walker, US Army Corps of Engineers Regulatory Section, Seattle District, on behalf of Airport Communities Coalition (ACC), reviewing the November 2001 Natural Resource Mitigation Plan (NRMP) by Parametrix, Inc. for the Port Of Seattle’s SeaTac Third Runway construction (permit reference 1996-4-02325). AES argues the NRMP mischaracterizes enhancement at Vacca Farm as wetland restoration (claiming 6.6 or 12.3 acres), that mitigation fails no-net-loss and no-degradation standards, that in-basin mitigation opportunities were not fully addressed, and that drainage channel design for maintaining Miller Creek seepage flow hydrology is vague. Cites USACE Regulatory Guidance Letter RGL 01-1 and Society of Wetland Scientists definitions of restoration vs. enhancement. Also references Des Moines Nursery and Wetland A17 restoration projects added to mitigation package.