[EDITOR’S NOTE: The following is a Letter to the Editor, written by a Reader. It does not necessarily reflect the opinion of The B-Town Blog nor its staff:]
The attached Scoping comments (download PDF here) are not meant to replace my comments submitted at the Highline College Port of Seattle/FAA outreach but are meant as supplemental. I am copying below a list of additional questions from an email exchange with Cayla Morgan, FAA Environmental Specialist which she refused to answer unless submitted through the Scoping process.
I fail to understand why the SAMP Scoping boards for air quality and climate are empty and why the public health board has risk of explosion and little else that has anything to do with public health concerns.
These boards could be populated to provide at least some framework for the public to know or understand how much or little the Port of Seattle and FAA plan to cover.
I was involved in the four-year process for the third runway from Scoping to Final Supplemental EIS, MOA air quality study, Record of Decision and Governor Locke’s certification of the project. This entire process was an attempt to cover up the true impacts, provide false data, downplay impacts and as a result, further a dangerous, unmitigated airport pollution problem. The subsequent legal cases pushed this process out another 8 years while the community fought impacts with meager resources that pushed cities near bankruptcy. In the end what we received was a somewhat smaller environmental destruction.
This current process should include a greater level of transparency and honesty. Agencies, officials and those responsible for oversight should assure the project not only complies with existing laws, but rises to an environmental standard that they themselves would want for their own families. This principle is reflected in state law at WAC 173 which guarantees each person in the State of Washington the right to a healthful environment.
I also realize that the proper analysis may disclose the need for removing billions of dollars worth of residential land uses that are far too close to the airport. This proximity problem is a result of the 1989 “Mediation” agreement which kept incompatible land uses intact in exchange for a noise mitigation program. This was the cheap way out of a problem for the Port of Seattle. An Expert Noise Panel appointed by the State of Washington in 1996 determined the noise mitigation program wasn’t successful. Subsequently, many of the insulated homes have had insulation and windows mold, fail and rot. There is currently no plan to repair, or expand the program. This is unacceptable. Other cities are getting updated products and upgrades.
In summary, it would be easier to site another airport in the state with a proper buffer of 33,000 acres than to try and make this situation acceptable, livable and compatible.
QUESTIONS SUBMITTED TO CAYLA MORGAN OF THE FAA:
Hello Cayla: Thank you for spending time discussing some of our questions at the SAMP Scoping meeting last night. I have a few questions that I hope you can answer.
The “air quality” team said the CO2 figure of 363,306 metric tons per year (2016)Â produced by Landrum & Brown in a preliminary air quality draft I received six months ago uses only a takeoff cycle of approximately 2 minutes. The figure I received from Elizabeth Leavitt, Port of Seattle senior environmental staff member at the Energy and Sustainability Committee in 2016 was 5.4 million metric tons per year which includes all fuel pumped for CO2 in 2015 but not methane, black carbon or nitrogen oxides which are major contributors to climate impact and in my opinion, should be calculated for their respective contribution.
The AQ staff said that FAA regulations requires them to use only the truncated figure, part of the LTO.
Question: Please provide the regulation/guidance/AC or whatever governs this calculation?
Question:Â I am also seeking a copy of any EA, FONSI, CATEX document you referenced from 2006/2007?
I am also concerned about the conditional approval FAA received from EPA in 1997 which required an air quality analysis prior to any future build post 2010 due to predicted violations of the NAAQS. Monitoring around the airport drives in 1998 found CO levels at roughly 80% of the federal standard during a slow period of operations along with particulate and NO2 levels higher than any historical regional monitoring. The congestion around the airport along with the massive increase in operations over the years and lack of monitoring in the area combined with close-in communities is cause for concern for compliance meant to protect public health and welfare.
Question:Â Will any monitoring of the air quality be required before approvals are issued? If so, will air toxics be included along with criteria pollutants?
In 1993, McCulley, Frick and Gilman monitored hydrocarbons in the neighborhoods around Sea-Tac and found several of concern above the Washington State Acceptable Source Impact level including benzene, formaldehyde, acrolein, etc. Due to these and other studies showing increased cancer risk, the Port of Seattle and FAA were asked to conduct a risk analysis for the third runway EIS which did not happen due to the consultant citing “lack of information.” It now appears the community is experiencing higher than average respiratory illnesses and cancer and the State Department of Health map of health disparities along with EPA EJ Screen confirms the area surrounding Sea-Tac is in the above 80th percentile of negative health outcomes. These communities have already been identified by FAA in their PEA for the Automated Turn dated September 2017 as predominately minority and low income for Environmental Justice. There are requirements for notifications, HIA, SIA, and numerous other investigatory measures included in the Federal Interagency Working Group “Promising Practices” report from March 2016 and other regulatory framework.
Question: Will FAA require a thorough evaluation of the EJ conditions and health disparities in the community surrounding Sea-Tac Airport including a risk analysis that uses monitoring to validate modeling?
Lastly, I am still confused as to the role of FAA in planning aviation capacity in Washington. The DOT Air Transportation representative believes FAA has to provide direction for the state to move forward on siting and building or expanding facilities. Yet, it seems FAA has referred to the state as the lead on this process. I am concerned because the state does not necessarily understand airspace constraints or the potential for harm of the human environment from concentrated high noise and emissions in the congested corridors. Due to constraints on the Sea-Tac facility which drives up the expansion cost tremendously that FAA must help fund, does it seem wise, prudent or usual to not more aggressively pursue alternatives to Sea-Tac expansion that are less harmful?
Question: What is FAA’s role in regional or state decision-making to either stop expanding Sea-Tac or to build another airport/expand existing facilities?
NOTE:Â If you would like your comments to be included as part of the Port of Seattle’s SAMP scoping, they must be received or postmarked by Sept. 28, 2018 through at least one of the following methods:
Mr. Steve Rybolt
Port of Seattle
Aviation Environment and Sustainability
P.O. Box 68727
Seattle, WAÂ 98168
- Submitted in writing at any of the four public meetings
- Recorded by the Court Reporter at any of the four public meetings
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