TagPollution Control Hearings Board(1532)

A water resources consultant, writing on behalf of the Airport Communities Coalition, argues that the Port of Seattle's July 2001 Low Flow Analysis for Sea-Tac Airport expansion fails to provide reasonable assurance that the project will meet water quality standards in Miller, Walker, and Des Moines Creeks. The letter criticizes the submission as incomplete and rushed, noting missing figures, unfinished sections, and an unresolved plan to store the required 46 acre-feet of stormwater across the three watersheds. The consultant contends that the Port's proposed water quality protections—including filtration, aeration, and biofiltration swales—are unproven, inadequately designed, and fall short of the regulatory standard required for Section 401/404 permit approval.

A biological scientist hired by the Airport Communities Coalition reviewed the Port of Seattle's plan to store airport stormwater in detention vaults and release it into Miller, Walker, and Des Moines Creeks during summer low-flow periods. The review found that the plan could worsen water quality in those creeks, because stored sediments may release toxic levels of copper and zinc, and potentially harbor human pathogens from airplane wastewater. The scientist concluded that regulators lacked sufficient information to approve the proposal without further testing, modeling, and independent scientific review.

A August 6, 2001 letter from Water Resources Consulting L.L.C. on behalf of the Airport Communities Coalition critiques the Port of Seattle's 'Low Flow Analysis - Flow Impact Offset Facility Proposal' submitted in support of its Section 404/401 permit application for SeaTac Airport expansion. The letter argues that the Port's plan fails to provide reasonable assurance that the airport's stormwater management will meet water quality standards in Miller Creek, Walker Creek, and Des Moines Creek. Key concerns include an incomplete and unfinished proposal, insufficient stormwater storage capacity, unproven water quality treatment methods, and reliance on vague future 'adaptive management' rather than concrete, enforceable designs.

Email from Ann Kenny (Washington State Department of Ecology) dated August 5, 2001, distributing a revised Draft 401 Water Quality Certification for the construction of a Third Runway and related projects at Seattle-Tacoma International Airport (STIA) in the Miller, Walker, and Des Moines Creek watersheds and wetlands in SeaTac and Auburn, King County, Washington. The

Email from Ann Kenny (Washington State Department of Ecology) dated August 5, 2001, circulating a revised Draft 401 Water Quality Certification for the Port Of Seattle’s Third Runway construction at Seattle-Tacoma International Airport (STIA). Recipients include Gordon White, Raymond Hellwig, Erik Stockdale, Kevin Fitzpatrick, John Drabek, Dave Garland, Ching-Pi Wang, Katie Walter, Kelly Whiting, Joan

Deliberative memorandum dated August 3, 2001 from Katie Walter (Shannon & Wilson, Inc.) to Ann Kenny (Washington State Department of Ecology), transmitting revised draft 401 conditions for the Port Of Seattle Natural Resources Mitigation Plan (NRMP) Auburn Mitigation Site. Document 21-1-12020-001-M1 REVISED.doc covers Auburn Mitigation Site revisions including culvert placement issues on June 28, 2001

Email dated August 3, 2001 from Katie Walter (KLW@shanwil.com) to Ann Kenny, cc Erik Stockdale, regarding fish and stream monitoring recommendations for Port Of Seattle mitigation area. Discusses IBI (Index of Biotic Integrity) methodology limitations and augmentation with monitoring of temperature, turbidity, channel morphology, substrate quality, large woody debris, riparian canopy cover, and fish use.

Email chain between John Drabek and Ann Kenny (Washington State Department of Ecology) dated August 3, 2001, regarding a preliminary deliberative draft Section 401 Water Quality Certification (WQC) for the Sea-Tac Airport Third Runway. Drabek raises question about RCW 90.48 required AKART implementation in NPDES permit reissuances and integration with the 401. Kenny’s original email

In August 2001, King County's Department of Natural Resources submitted a technical review letter to the Washington Department of Ecology evaluating the Port of Seattle's Low Flow Impact Analysis and proposed offset facilities for stormwater management near Sea-Tac Airport. The review found the proposal goes well beyond the basic requirements of the King County Surface Water Design Manual and represents substantial mitigation for low flow impacts in affected drainage basins, including Miller and Walker Creeks. Reviewers noted several inconsistencies and data gaps in the documentation and recommended that a final consolidated document be prepared incorporating all corrections and technical memoranda.

Email dated August 3, 2001 from Katie Walter (Shannon & Wilson, KLW@shanwil.com) to Ann Kenny, cc Erik Stockdale, subject fish/stream monitoring. References Richard Brocksmith (fish biologist) and IBI (Index of Biotic Integrity) methodology for stream health monitoring. Proposes monitoring condition language for Port Of Seattle requiring monitoring plan covering temperature, turbidity, channel morphology, substrate quality,