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Chapter 4 Section 9 Air Quality
Comment: 9-I: Introductory comment. The reader wishing to
understand Chapter IV, Section 9, Air Quality in the DEIS must
also read and consult Appendix D Our comments address both the
discussion in the main text and relevant parts of the Appendix.
***
Comment 9-1: The discussion of the impacts on air
pollution are based on two theoretical models: 1) the EDMS
inventory model , and 2)a dispersion model. apparently unique to
this E.I.S.
Comment 9 2: It is not possible to fully evaluate the
results of the EDMS inventory modelling and provide correct
comment because the assumptions and inputs used for the inventory
model are not given in the DEIS.
Comment 9-3: I It is not possible to fully evaluate the
results of the dispersion model and provide correct comment
because the assumptions and inputs used for the dispersion model
are not given in the DEIS.
Comment 9-4: While computer models are a useful
supplement, they cannot subsitute for actual measurement and
monitoring of pollutants in the community.
Comment 9-5: The inventory model as presented does
not inventory all the pollutants emitted, particularly from
aircraft (e.g., formaldehyde and 1.3 butadiene, benzene. The
inventory model does not separate particulate matter from piston
engines from that for turboprop/turboject engines. ) Their
absence is especially egregious because they are indicators for
carcinogens from aircraft noise. These pollutants were included
in the Midway Study which was referenced in Section 7 of the
DEIS. and used to calculate health risks.
Comment 9-6: Without validation, no computer model
rises above the level of refined speculation, and we can find no
evidence in the DEIS or elsewhere that either one these models
have been validated with appropriate measurement & testing
against model predictions, nor has there been any review of the
quality of the model in the professional literature. Indeed, the
Department of Ecology disclaimed the EDMS inventory model as
being a rough estimate only. (See, "Airport's Air: How bad?
Seattle Times, 1/3/92.)
Comment 9-8: In addition, the findings reported here
are proportionally out of line with previous uses of this same
model at Sea-Tac by the DOE & PSAPCA (p. IV-9-10B) and with
actual measurements taken in the Sea-Tac area in studies done for
the Port of Seattle (Appendix p. D-92-D128.)
Comment 9-9: The DEIS incorrectly assumes in the air
quality section that, unless the pollution from pushes the region
outside of legal compliance, it has no impact. Impacts well
below this level have a substantial impact & should be covered.
Comment 9-10: This FEIS should point out that
measurements shown in Appendix D do indeed violate the standards.
For example, the 8 hour standard for carbon monoxide (CO) is 9
ppm, but measurements at the Upper Level Deltas [sic] departure
gate shown on p. D99 is 10.0 ppm, well over the standard. The
FEIS should identify measurements over the standards, along with
modelling, and not make the faultly assumption that only illegal
levels of pollution have an impact.
omment 9-11: Although the DEIS mentions measurements
taken in the Sea-Tac area in the Appendix D, pg. D92 to it fails
to incorporate them into the analysis and relies solely on the
unvalidated modelling.
Comment 9-12: The EDMS Model uses departures* to
calculate peak-periods at the airport , and the DEIS presents a
table of assumptions used for departures at p. D3. This table
explains why comment & evaluation requires that readers know the
assumptions & inputs to the models. (*Departures are used
because arrivals take longer than departures. If an airport can
achieve 60 departures during a peak hour, it will always have <60
arrivals.)
(a) Those running the model used only 43.9 as the assumed
peak-hour departure level for 1994 ("Existing"), even though
normal peak departures at Sea-Tac are greater than 60 per
hour. The State's 1991 EDMS survey uses a more realistic 72
peak-hour departure level. However, peak hour departure
levels of 90 are possible at Sea-Tac, as was demonstrated
during the Goodwill Games. Use of the 43.9 figure does not
reflect the potential peak period capacity of the existing
airport and is highly questionable. The DEIS EDMS inventory
greatly underestimates the levels of air pollution --
especially those from aircraft -- because of this low
assumption.
(b) The model makers apparently used the same peak hour
departure levels for "do-nothing" and "with project,"
showing peak departure levels of 46.58 for both "do-nothing"
and "with project" in 2010, and 50.67 peak departure levels
both "do-nothing" and "With project" for 2020. "Do Nothing"
and "With Project" have precisely the same result? Then why
are we wasting money on this EIS? The FEIS needs to clarify
this and reconcile these numbers with those used in Chap. 2,
Purpose and Need, to justify the project.
(c) Amazingly, the air pollution estimates assume that the
projects would only add 6.77* flights per hour by the year
2020--even with the third runway and other projects. It is
astonishing to think of spending a billion dollars or more
on just 6.77 flights per hour. The FEIS needs to clarify
this and reconcile these number with those used in Chap 2,
"Purpose & Need" to justify the project. (*To get the 6.77/
hr. figure we subtracted 4093 peak departures given for
"existing from 5067 peak departures given for "with project
in 2020" on page D-3, DEIS Appendix D.)
Comment 9.13: According to the State Department of
Ecology, Air Quality Program, Sea-Tac airport is one of the
largest source generators of air pollution in King County,
producing 8% of the carbon monoxide and 5% of the nitrous oxides
in the county. Please explain the apparently contradictory
assertion on pg. IV.9-1 of the DEIS that "Aircraft operating at
Sea-Tac contribute less that 1% of the carbon monoxide
emissions, nitrogen oxides, and volatile organic compound for all
mobile sources within the Puget Sound Region."
Comment 9.14: Air emissions from Sea-Tac come from
both aircraft emissions and ground transport emissions from cars
& buses, for both passenger and freight. According to the DOE
study referenced in question 9.2, aircraft emissions constitute
approximately 88.3% of the emissions and ground traffic the
remaining 11.7%. Please explain the apparently contradictory
assertion in the DEIS on pg. 9-1 that "The majority of the
pollutant emissions in the Puget Sound are generated by motor
vehicles (i.e., cars, trucks, buses, taxis, motorcycles.)" This
quote prompted several other questions:
(1) Which pollutant emissions are referred to in this
quotation?
(2) Doesn't the percentage depend upon which pollutants are
being measured?
(3) Does it include NOx, PM2.5, and benzene and aldehyde
whose contributions come more heavily from jet exhaust than
others.
(4) What is the majority pollutant in the affected
communities? The FEIS should give this figure.
(5) Isn't this simply a product of the assumptions fed into
to the models? Could we not state the the primary pollutant
was almost anything -- swiss cheeze molecules -- if we fed
that assumption into the model?
Comment 9.15: Emissions from fire tests emit
significan levels of pollution, although their percent of
contribution has never been measured. These are not included in
the "inventory" and their contribution to the existing
conditions. Although the DEIS appears to assume that this test
will stop, the DEIS should explain why the Port of Seattle got an
exemption from the air quality standards from the State
Legislature to continue and when and under what conditions it
will stop. It should also give the results if the the fire
testing is not stopped, so that its contribution can be
evaluated.
Comment 9.16: Because Sea-Tac sits on one small site,
unlike other comparable air pollution sources (i.e., freeways)
where the source is spread, pollutants reach very high
concentrations in the three mile area just around the airport.
How do the models presented in the EIS account for this?
Comment 9-17: The "brown cloud" sitting over Sea-Tac
is visible the I-5 freeway and from downtown Seattle on clear
days. The primary culprit in this kind of smog is ozone. Jet
aircraft have contribute heavily to the ozone factor because they
generate such large quantities of NOx, which contributes to ozone
formation. Newer jets create less CO but more NOx. However,
ozone was not measured
Comment 9.18: Full analysis of existing conditions is
explicitly required under the SEPA rules. (WAC 197-11-440(6)(a).
That should include all conditions for which there is a known
standard and all other conditions which might have and impact--
such as toxic chemicals in jet exhaust. It whould be verified by
acutal measurements. The DEIS analysis of existing conditions
fails to meet these tests.
Comment 9-19: The E.I.S. must contain a sufficiently
detailed analysis to permit a comparative evaluation of the air
quality impacts that the proposal would create for each
alternative, as required by the SEPA rules at Sec. 440 (5) (c)
(v). The DEIS does not contain any comparative anyalysis at
all. It assumes that the peak hour demand will be the same under
all alternatives, doesn't reconcile its projected operations with
those used elsewhere in the EIS and is grossly inadequate in the
depth of its analysis--most particularly with regard to ozone.
Comment 9-20: The E.I.S. must contain alternatives to
attain the proposal's objectives at a lower environmental cost as
required by SEPA, Section 440(5)(B). We can find no analysis of
this in the DEIS.
Comment 9-21: The E.I.S. must investigate & fully
disclose nitrogen oxide emissions at takeoff. The NOx standard
is an annual standard, but given that NO is an important by-
product of jet exhaust, there was certainly time to monitor these
emissions for a year in the airport communities. A monitor in
Beacon Hill, far from the brown cloud sitting atop Sea-Tac ,is
not adequate monitoring.
Comment 9-22: The E.I.S. must investigate and disclose
air, water, and health impacts from emergency fuel dumps within
15 miles of the airport. Many citizens complain about seeing
and smelling fuel dumps, but the air quality analysis neglects
the subject entirely and should not.
Comment 9-23: Sea-Tac should be treated as a "major
stationary source" under the Washington State Clean Air
Conformity Act defines "major stationary sources." It clearly
qualifies under the definition. Aircraft emit many different
chemicals, some of the highly toxic, which would be monitored &,
if necessary for the public health, regulated if Sea-Tac is a
"major stationary source". The DEIS fails to discuss these
chemicals and the standards for them even though few sources
create greater amounts of these types of pollutants that modern
jet airports. The DEIS must discuss all chemicals which have a
sufficient impact to be regulated under the "major stationary
sources" provisions of the clean air act. Port-owned facilities
are not exempt from the law.
Comment 9-24: The E.I.S. must consider no-build
alternatives or mitigations that would reduce aircraft
emissions.. For example, if the landside operations at Sea-Tac
were administered from the standpoint of reducing idling time,
this factor should be the same for all alternatives. If delays
are predicted as a result of the airport reaching capacity, there
is no reason why aircraft must spend this delay time idling in
taxiways. Both land based and airborne air carrier traffic is
highly managed. Under such a system there is no reason why
aircraft must spend excessive amounts of time simply idling their
engines waiting for clearance to take off. If the magnitude of
aircraft emissions is a result of idling time, that impact should
be addressed through alternatives and mitigations specifically
responsive to that impact.
Comment 9-25: The E.I.S. must
analyze the indirect impacts caused by the proposal as required by Sec. 060(4)(d) of the
SEPA rules. For example, the Flight Plan projects an expansion of office space of up to
2.3 million square feet and an additional 7,000 to 10,000 hotel rooms. All this airport-
related activity is projected to occur in areas immediately surrounding the airport. This
sort of secondary development would obviously produce very substantial increases in motor
vehicle trips. The E.I.S. should quantify and discuss these induced transportation
impacts. Assuming that the infrastructure exists to accommodate these additional trip
ends, substantial air quality emissions would result.
Comment 9-26: Because of the significant danger to the
biota inherent in air pollution, Sea-Tac's contribution carbon
monoxide in King County of the nitrogen oxides in King County
must be addressed because of the severity of pollution in such a
small area of land --less than 1/5 of 1% of King County. (May
1991 DOE Study -- Seattle Tacoma International Airport: Air
Pollution Contribution).
Comment 9-27: The F.A.A. is responsible for
implementing standards for commercial passenger jets and it does
so through engine certification data provided by the
manufacturers. The DEIS relies exclusive on this potentially
biased data to do its modelling and it should not. The E.P.A. is
currently in the process of requiring aircraft engines to conform
to the standards of the Federal Clean Air Act in parts of
California which severely restricts the F.A.A.'s ability to
accept the manufacturer's word as the emissions certification.
Actual emissions should be used to study air quality impacts.
Comment 9-28: The E.I.S. models are based on new
engines, pertectly maintained. In real life, older planes fly
and engines are not in perfect tune at all times. There is no
air quality inspection and maintenance (I/M) program for aircraft
This will tend to underestimate pollutants. The FEIS should
explain how this was addressed and how it will affect the
results.
Comment 9-29: It is not clear from reading the DEIS
whether or not international carriers are exempt from air quality
standards and thus not included in the air quality studies. We
can find, for example, no Aeroflot jet equivalents in the Table ,
pg. D-3 calculating the peak departure levels, however. The FEIS
should clarify this, as it will tend to understate jet emissions
in the models compare to real emissions. There is am impact from
foreign exempt carriers on air pollution and noise pollution and
they need to be included in impact studies of international
airports.
Comment 9-30: The E.I.S. must set forth how the
proposed action would carry out the various commitments contained
within the SIP for improving air quality in the region. The DEIS
fails to set out the requirements clearly and utterly fails to
show how they would be met.
(a) With regard to mobile sources and particularly motor
vehicles, the SIP includes commitments to increase transit
use and for demand management (See Appendix D to SIP.)
Similar methods for aircraft use should be set out in the
DEIS.
(b) Sea-Tac meets the definition of "major stationary
source" and a complex source and must be so treated in this
E.I.S.
S.I.P, Pg. 7: (41) "Major stationary source means any
stationary source (or group of stationary sources
that are located on one or more contiguous or
adjacent properties and are under common control
of the same person or persons under common
control) which:
*emits or has the potential to emit one
hundred tons per year or more of any air
contaminant regulated by the state or Federal
Clean Air Act (Sea-Tac emits 5,125 tons per
year of pollutants into the air according to
the State Implementation Plan.)
*is located in a marginal or moderate ozone
non attainment area (definition fits area
where Sea-Tac is situated) and
*which emits or has the potential to emit one
hundred tons per year or more of volatile
organic compounds or oxides of nitrogen (Sea-
Tac emits 1,950 metric tons/year according to
the State Implementation Plan.)
*is located in a "serious" carbon monoxide
non attainment area where stationary sources
contribute significantly to carbon monoxide
levels and which emits or has the potential
to emit fifty tons per year or more of carbon
monoxide or (Sea-Tac emits 3,050 metric
tons/y according to the State Implementation
Plan.)
*is located in a "serious" particulate matter
(PM10) non attainment area and which emits or
has the potential to emit seventy tons per
year or more of PM10 emissions. (Sea-Tac
currently emits 68 metric tons/year according
to the State Implementation Plan, and if the
3rd runway is constructed will emit much more
than 70 tons of "serious" particulate
matter.)
The inventory of particulate matter done
for the DEIS, and reported at table IV.9-4 as
.023 Tons per year particulate matter must be
a typo, and should be corrected in the FEIS
and a supplementary will have to be issued to
give people a chance to comment on the
impacts of this much particulate matter.
c) Addition of a third runway and/or other expansions
contemplated by the Airport Master Plan changes meet the
definition of a "major modification" under the act and must
be so treated in the E.I.S. Specifially, ozone should be
monitored and estimated.
S.I.P, Pg. 6: (40) "Major modification" means any
physical change in or change in the method of
operation of a major stationary source that
would result in a significant new emissions
increase of any pollutant subject to
regulation under the act. Any net emissions
increase that is considered significant for
volatile organic compounds shall be
considered significant for ozone.
d) Addition of a third runway and/or other expansions
contemplated by the Airport Master Plan changes meet the
definition of a "new source" under the act and must be so
treated in the E.I.S.
S.I.P., Pg. 8: (48) "New Source" means the
construction or modification of a stationary
source that increases the amount of any air
contaminant emitted by such source .
This would include increases in operations; thus, analysis
should be done assuming peak-capacity, not half of that.
e) Sea-Tac is defined as a Major Stationary Source, and
must be treated in the E.I.S. as a complex source of air
pollution with special attention to measuring and estimating
the effect of concentrations of multiple pollutants and
local hot spots of very high concentrations.. There is no
hot spot analysis in the DEIS modelling, and furthermore,
the measurement programs have no measurements off the ends
of the runways -- areas most likely to be hot spots for jet
exhaust as opposed to auto exhaust.
Comment 9-30: The type of jet fuel used is quite
significant in determining the emissions. The inputs to the
model should use the most polluting jet fuel for "worst case"
analysis.
Comment 9-31: The modelling points in the dispersion
analysis should be relabelled. They are not "receptor points"
because there are no monitors there to receive, and it is
misleading to the reader who quickly loses track of the fantasy
model and the real receptors--especially since data from actual
measuring was not included in the model.
Comment 9-32: Recent reports issued by Dan Greenbaum of the
Health Effects Institute, Cambridge, MA confirm that there is a
correlation between high particulate matter and death rates.
Particulates are poorly covered in the DEIS. We have already
pointed out the typo creating a major reporting error on p. IV.9-
10C. In addition, the PM10 screen is inappropriate for a site
with mixed car and jet exhaust. The EPA will be revising its
particulate matter rulings this year because it is under court
order to so so, most particularly to measure PM2.5. This finer
screen is particularly important to examine in the DEIS because
jet exhaust has finer particulate matter than, for example, truck
exhaust and doesn't not show up as much in the PM10 studies.