Minutes Exhibit B
Port Commission Regular Meeting
of March 27. 2018





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UNITED STATES ENVIRONMENTAL
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Reply To                                                                                  AP 31?
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7996
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Mr. Dennis Ossenkop
Federal Aviation Administration -
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Northwest Mountain Region
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l60 I Lind Ave, S.W.                      3""  I] 6 I995
Renton, Washington 98055-4056

Dear Mr. Osscnkop:

1996 comments on the Final Environmental Impact
This letter supplements our March 18,
at Seattle-Tacoma
Plan Update Development Actions
Statement for Proposed Master                                               projects
it details our concerns with this and adjacent
International Airport (nal EIS) and                                    under Section 309 of
is in accordance with our responsibilities .
regarding air quality. Our review
National Environmental Policy Act (NEPA).
the Clean Air Act (CAA) and the
as well as the air
lture air quality around the airport
We continue to have concerns about                                    with the State
on conformity
BIS.  Our comments are based primarily
quality analysis in the nal                                                       from other
the Clean Air Act (CAA) and cumulative impacts
\   Implementation Plan as required by
projects around the airport.
While we have
EIS is a dratt conformity analysis.
The conformity analysis in the nal
recent weeks, the dra EIS did
and other agency representatives in
been discussing this with FAA                                           EPA has had to
and therefore this is the rst formal opportunity
not contain such an analysis                                       information needed for a
ofour comments is to provide the
comment on this issue. The intent
will meet the requirements of the CAA.
final conformity analysis that
a
CAA mandate that any federal agency proposing
The conformity provisions of the                                       that the
for air pollutants must demonstrate
or maintenance area
project in a nonattainment                                    of concern. Because with the
State Implementation Plan for pollutants
project conforms to the                                                 National Ambient
the severity of exceedances ofthe
an increase in
project, the nal IEIS shows                                           the Sentnc Airport. we
monoxide (CO) at two intersections near
Air Quality Standard for carbon                                    that the project conforms
does not support your conclusion
believe the drntl conformity unnlyuin
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to the State lIuplemeutntion

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18

from sources such as
emissions prior to 2000', the years 2010 and 2020; (b) emissions
and (c) mobile emissions
constnrction and haul vehicles, associated increased congestion;
associated with the use of regular gasoline.

and "with project" air quality
2. An air qualityanalysis that compares the "no project"
above.
impacts for the years stated in item one
scenario results in an increase in
3. Appropriate mitigation measures-~if the "with project"
levels in the "no project"
either the 'equency or seventy of cxceedances above the
these impacts.
scenario. measures should be developed to mitigate

entities to conduct adequate, specic
4. Commitments from appropriate governmental
increase in the severity or
and enforceable mitigation measures that will prevent any
Ambient Air Quality Standards
frequency of predicted exceedances ofthe National
outside of
(NAAQS). Since the increased modeled exceedances occur at intersections
commitments to conduct these mitigation
airport property, it may be necessary to obtain
local authorities.
measures 'om other agencies or
\'i'
H
ofEcology (WDOE)
We have discussed our comments with the Washington Department                     H
All three agencies believe that     I
and the Puget Sound Air Pollution Control Agency (PSAPCA).
determine the         Q
near the airport and to
monitoring is needed to assess the actual air quality
adverse air quality impacts from the project. Accordingly. we
measures needed to mitigate any
and PSAPCA's letters. In panicular. we support the
support the comments set out in WDOE's                                       which could
comment letter for establishing a monitoring program,
steps identified in PSAPCA's
be used for subsequent modeling and air quality analysis.

for the area around the airport,
EPA understands that several major projects are proposed
We are
to the airport at the south end.
including the extension of SR 509 which will connect
this
are not understood. For
concerned that cumulative air quality impacts from these projects
OfDecision (ROD) should contain a more comprehensive
reason. we believe the Record
with other agencies to
cumulative impacts analysis. including a commitment to working
that will accurately reect
implement a shortterm and long-term air quality monitoring program
several proposed projects in and
baseline conditions and reect the changes in air quality as
around the Seatac Airport are developed.

address these issues as well as
We expect that the FAA and the Port of Seattle will
and local authorities to ensure that air quality
provide commitments to work with regional
with WDOE and l'SAl'CA, is
standards are not violated around Seatac Airport. EPA. along
appropriate monitoring,
committed to continue to work with FAA and the Port on developing
modeling and air quality analytics

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contact me
Detailed comments are enclosed, and ifyou have any further questions please
Director of the Ofce of Air Quality at (206) SS3-02l8.
at (206) 553-1234 or Anita Frankel,
v
Thank you for the opportunity to review this document.

Sincerely,

Chuck Clarke
Regional Administrator

Enclosure

cc:    Doug Brown. Ecology
Paul Carr. Ecology
Barbara Hinkle. Port of Seattle
Gene Peters. Landrurn and Brown
.
Mary Vigilante, Synergy Consultants
Dennis McLerran, PSAPCA
Brian O'Sullivan, PSAPCA

'.__/
General Conformity

Air Act mandate that any federal agency
The conformity provisions ofthe Clean                               determination that
area make a
in a non-attainment or maintenance
proposing to conduct a project
its project would not:
standard in any area;
new violation ofany
(I) curse or contribute to any                                     in any area; or
ofany existing violation ofany standard
Gi) increase the frequency or severity                                                     in
mterim emission reductions or other milestones
ofany standard or any required
(iii) delay timely attainrnent
any area.

a higher test
Clean Air Act, Congress established
Through Section l76(c) of the Federal                             non-federal public
offederal money than is the case for
for federal agencies and the expenditure                                armatively nd that its
a federal agency to
entities. The conformity provisions require
or private                                                             violated the National
conditions in areas that have previously
actions will not worsen air quality                                          used to determine    D-115
EPA recognizes that the modeling
Ambient Air Quality Standards (NAAQS).
worst-case
is for screening purposes to predict
carbon monoxide impacts at intersections
ensure that worst-
require that a federal agency
scenarios. However, the conformity provisions                                        without
worst-case pollutant impacts
with its project are no Worse than the
case pollutant impacts                                                    '
such a project.

certain public notication and comment procedures
The general conformity rules establish
determination ($8 Flt 63214,
when making a conformity
that a federal agency must follow                                            is the draft
determination contained in the Final His
November 30, 1993). The conformity                                      period. The
be modied after the public comment
conformity nding, and implies that it may                                         ofDecision
determination will be included in the Record
FAA has stated that the nal conformity                                     detennination, the
analysis does not support a conformity
for this ElS. While the draft conformity                                             to
emissions inventory and commitment
a corrected
nal determination could, based upon
appropriate mitigation measures.
.
H.   it
enforceable
rule sets forth the requirements for
Section 93.160 ofthe general conformity
or severity of
when an increase in the frequency
mitigation measures that must be taken
exceedances is modeled. This section states:
for
must be identified and the process
to mitigate air quality impacts
(a) Any measures that are intended                                                 sandals
an implementation
ofsuch measures must be desm'bed, including
implementation and enforcement
containing explicit timelinea for implementation.                                                         c
'u
' ' gthalaFederalsetionisinconformity,thcl-'ederal agencymaltingtheconfonnity "
(b) Priortodct
determinationmustobtainwritteoeommitmcntsfromtheappropriatepersonsorngenciatoimplemmtany '
making conformity determinations.
as conditions for
mitigation measures which are identied

'.

38

Given the 1318's projected increases in the severity ofexceedances ofthe CO NAAQS, mitigation
measures meeting the requirements of93. 160 are necessary in order to demonstrate conformity.

.H.. .           C-l ' ll

It should be noted that the general conformity rule also foresees situations where
mitigation measures may need to be modied in the tture due to changed circumstances. Section
93.160 (e) establishes the mechanism where mitigation measures may be modied so long as the
new mitigation measures continue to support the conformity determination. While the mitigation
measures need to be clearly specied, they may be changed, ifneeded.

The results our a monitoring program, such as the type identied in the EPA, WDOE,
and PSAPCA comment letters ofJune 6, 1996, may form the basis for modifying mitigation
measures. Air quality analysis based on such monitoring and related modeling could demonstrate
that mitigation measures conunitted to in order to demonstrate conformity were no longer
needed, or that different or additional measures were appropriate.
. .
El           ll'i       ."

One alternative approach to determining confonnity that would not necessarily include
mitigation meaSures might be a phased development ofthe project. With this option, FAA would
grant a full approval for certain projects that are proposed in the FEIS while conditionally
approving implementation of other projects contingent upon mher environmental analysis. This
assumes that the projects are truly separable, and therefore that the FAA would be able to show
conformity for each ofthe major subsets ofproposed projects. It should be noted that both the
general conformity mic and NEPA regulations identify criteria for determining when projects can
be assessed separately. Both sets of criteria would need to be met. Ifthis approach is used, then
the monitoring program supported by EPA, WDOE, and PSAPCA would he usetl to support the
modelling that would be required to demonstrate confomrity for the conditionally approved
projects. Elements of such an approach are set out in the PSAPCA letter to FAA, dated
June 6, l996.

Cumulative Impacts

The Council on Environmental Quality Regulations for Implementing the Provisions of
The National Environmental Policy Act state in 40 CFR Part 1502.16(a) 'and (b) that the
Environmental Consequences section ofan EIS will include discussions ofdirect effects and their
signicance and indirect effects and their signicance (section l508.8). According to 40 CFR
Part 1508.8. cumulative impacts are considered "e'ects" and should therefore be discussed in this
section ofthe 13. A Cumulative impact is the effect "on the environment which results 'om the
incremental impact of the action when added to other past, present, and reasonably foreseeable
tturc actions regardless ofwhat agency (Federal or non-Federal) or person undertakes such
other actions. Cumulative impacts can result om individually minor but collectively signicant
actions taking place over a period of time." (Section l508.7) We believe the ROD should reect
consideration or the cumulative impacts of the following projects since they may affect one
another:  Scntac expansion, the SR 509 proposal, the South Aviation Support Area, the

18

the City of
DesMoines Creek Business Park, the Federal Detention Center, the Seatac Hotel,
near Seatac Airport, the proposed
Seatac improvements to three miles ofInternational Boulevard
CTI campus and the 28l24th Arterial.

intersections in the
We noted several inconsistencies in projected air quality for the same
ElS's for the aforementioned projects. This variability underscores the need for additional
coordination between project leads. The inconsistences are as follows:

those orn
1)     The modeling results for air quality in the Seatac nal EIS conict with
two
the dratt BIS for the SR 509ISouth Access Road Corridor Project at
intersections (both ElS's used the same models). The two ElS's model conicting
188th and
results for existing conditions and More action alternatives at South
CO
International Blvd, and South 200th and International Blvd. for the average
with the
concentrations indicated on page 4-7 in the SR 509 ElS, as compared
[H in the Seatnc nal ElS. Both analyses model C0
same analyses on page lV.9-l
Seatac
violations for existing conditions. but for future action alternatives the
509 analysis does not.
analysis shows modeled CO violations where the SR
shown in
2)     Modeled air quality impacts at South 200th and International Blvd. are
and 112), the
the South Aviation Support Area Final EIS (pages 4-106 to 109
28l24th Street Arterial Final EIS (page 3.22) and the CTI Final EIS (page 4-7, 8).
million C0.
The results vary for each project ranging item 5.0 to 13.3 parts per

local projects into    S
The ROD should clearly indicate that the FAA has taken all of these
be available to other     I
consideration when modeling air impacts. The data from modeling should
Data sharing will contribute to a
agencies so that their analyses will be consistent with FAA's.
more comprehensive cumulative impacts
better overall air modeling analysis that will also assure a
presentation.

Inside EPA '3
Clean Air Report
and U.S. air policy
An exclusive biweekly report on the Clean AirAct
Vol. VII, No. 19  September 19, 1996

'7
WEIGHS RESTRUCTURING EFFORT
GRAND CANYON VISIBILITY COMMISSION
for western emission control strategies are given proper
In an effort to ensure that their recommendations
Commission (GCVTC) are exploring ways to
consideration by EPA, ofcials with the Grand Canyon Visibility Transport
in the
is considering expanding the number of states participating
restructure the organization. The GCVTC reportedly
them an equal vote.
commission and opening the doors to federal agencies, allowing                                                 that the
the legal authority to revamp the group, especially considering
But the commission must establish that it has
also promises to be
the Clean Air Act. thding the restructuring effort
GCVTC was created under the federal auspices of
a signicant hurdle (p3).

Suppressed report on FERC air impacts
"entrainment
JOINT N0x            spurs IJC resignation
UTILITIES DECLINE EPA INVITATION ON                            The top Canadian ofcial on the
STRATEGY                                         International Joint Commission resigned
to embrace an invitation
Electric utility ofcials say they are not ready                             last week, reportedly over efforts by
reduction
a nitrogen oxide (NOx)                                                    within the
by EPA to cooperatively develop                                            supporters of President Clinton
with deregulation and open
framework because they are being overwhelmed                             commission to shelve a controversial
Act
ofthe Senate's harshest critics ofthe Clean Air        report on the effects of the Federal Energy
access issues (p5). Some
rule
behind EPA release of a ne particulate matter        Regulatory Commission's open access
are questioning the logic
and ambient air data (p6).        on air quality (p5).
standard amid lingering questions about health
standard
warns that an ozone
And a recent American Lung Association report
EPA spurns pleas for redesignation.
57 million Americans om
under consideration by EPA will fail to protect                                 NOx waiver moratorium
unhealihy air (p7).                                                                    EPA has rejected a request by
environmentalists that the agency discontinue
Mebileoum                                   redesignation ofnonattainment areas and
ENGINE STANDARD                          tmtil
EPA POISED TO GIVE CLUES ON OFF-ROAD                   granting ofwaivers forNOx excwdances
with California
EPA is slated to issue by Sept 20 a document forged                     it addresses several outstanding questions
further
a federal rulemaking to           regarding pollution transport (p8).
regulators and engine manufacturers outlining
Sources tracking the
slash NOx emissions from off-road engines (p4).
vehicle program         White House hones in on post-2000
contentious development ofthe national low emission
carbon abatement strategy
vehicle mandates
predici the matter of states' rights to impose zero emission                            The Clinton administration is tightening
Federal Aviation
will be shelved until after the November elections (p11).                        its grip on a highly anticipated strategy to
an expansion project at
Administration ofcials are delaying the progress of                            nther slash carbon emissions aer this deeade.
the proposal does not meet                                        before a
the Seattle-Tacoma Airport out of concern that                                 Amongthe tenets likely to be proposed
conformity requirements (pl 1).                                                 committee ofthe international Climate Change
emissions
treaty this December is a call for
reductions from developed countries, as well as
Enforcement                                                                  enforcement
KEY 'CAM' PROVISION    a dramatically strengthened
INDUSTRY TARGETS INFLEXIBILITY IN
backbone (p19).
to make a clear distinction
Industry representatives insist EPA fails
and egregious Title V
between slips in emissions monitoring practices
assurance monitoring
violations in a key element ofthe proposed compliance                          Sen. Craig Thomas pushes for
meanwhile, say they are on track to release the     heightened cost-benet analyses
program (p14). EPA ofcials,
the end ofthe year (p15). House               Adding his voice to a growing
hotly debated credible evidence rule by
to determine why the         chants ofEPA critics, U.S. Senator Craig
Republicans are pushing for congressional hearings                                                                not
in regards to enforcement of    Thomas (R-WY) is urging the agency
Clinton administration is "doing less with more"                                                                 of
to lose sight of the regulatory cost
environmental regulations (p16).                                                                              ozone
tightening particulate matter and
standards in the agency's high-prole
revisions (p26).

NONA77AINMENT

ozone standard.
A district survey also uncovered that one in ve companies already uses low- and zero-level VOC water-
based solvents that are currently on the market.
SCAQMD face sti'opposition from the trucking community, because industry ofcials insist water-based
solvents will be useless in maintaining heavy-duty trucks. This concern prompted district officials to agree to a one-
year study to address the concerns ofthe trucking industry.

Mobile Sources
'
F   i                      l

STATES RATIFY NLEV AGREEMENT, ZEV ISSUE APPEARS HEADED FOR SHELF
In the wake of the recent ratication by state air managers oftheir memorandum of understanding (MOU)
ofwhether states can implement man-
over EPA's 49-state national low emission vehicle (NLEV) rule, the issue
dates that require automakers to sell zero-emission vehicles (ZEVs) appears "headed for the shelf' until after this
November's elections, sources close to the issue say.
Though the states' unanimous ratication of their MOU represents a bold show of unity directed at both
automakers and EPA, states nonetheless appear content to let EPA address that issue outside the context of the
voluntary NLEV rule. EPA sources indicate this is the agency's preferred route.
On Sept. 5, members ofthe Ozone Transport Commission (OTC) - comprised of 12 northeastern states and
the District ofColumbia - voted 24 to 0 to endorse their MOU submitted to EPA in dra form in late August.
OTC's version ofthe MOU on a voluntary NLEV program was only a preliminary document initialed by members,
entire 24-member OTC for nal ratication.
an OTC source explains, and it required approval om the
Automakers had submitted their own MOU Aug. 23, with the two MOUs diverging on the matter ofthe rights of
individual states to move forward with their own programs for ZEVs. OTC supports such a provision, while automakers are
seeking a delay in the forced marketing ofelectric vehicles in any agreed-upon 49-state LEV program.
The MOUs seemingly marked an unsuccessful conclusion to a two-year effort by the groups to develop a
voluntary NLEV program that EPA could use to supplant a rule that the states agreed to in 1994. In September
1995, EPA had proposed to require indusn'y to begin introducing gasoline-powered model LEVs in the Northeast
a national
by 1997 and to phase in an increasingly stringent NLEV program throughout the country in order to meet
emission standard in 2001.

The unity displayed by OTC represents a "pretty powerful response to automakers and a strong state-
ment to EPA," one source close to the debate says. States' "tmequivocal support" of OTC's MOU "ows directly
'om automakers' behavior," the source explains, claiming "[automakers] pushed too far" and "got too cocky" with
their MOU. "It's rare to see that kind ofunity," the source continues, but "it is understandable" considering the
automakers' position and the looming deadline for state implementation plans that makes forward movement by the
administration on a voluntary NLEV rule especially critical.
OTC's MOU ratication "evens the playing eld" between states and automakers in the NLEV debate, another
the board." It nther puts on paper that "states
source says, by "showing in writing that their positions are unied across
on't challenge EPA on theNLEV rule," giving the ag-cy assurance to move forward with a rulemaking.
EPA sources indicate that the agency plans to build upon the principles in the two MOUs, and possibly issue a
nal rule by early next month.

' ri' I I
m
AIR-RELATED CONCERNS SLOW FAA DECISION ON SEATTLE AIRPORT EXPANSION
The Federal Aviation Administration (FAA), reportedly concerned that an expansion project at the Seattle-
Tacoma Airport (SeaTac) remains out of compliance with the Clean Air Ac '5 "conformity" provision, has post-
an approved
poned its Record ofDecision (ROD) that allows the project to move forward. Projects must receive
ROD pursuant to the National Environmental Protection Act
The delay comes following months ofnegotiations between local, state and federal air quality ofcials
no further
seeking an agreement with the FAA and SeaTac operator the Port of Seattle that would guarantee
deterioration ofthe region's air quality om the proposed SeaTac expansion.
The groups have been working on a memorandum ofrmderstanding (MOU) which sources say will establish an
standards for the area,
approach for a monitoring program and agreed-upon carbon dioxide (C02) and nitrogen oxide (NOX)
and potentially pave the way for a sooth ROD approval. Butrepmd concerns om EPA, state air agencies and civic

CLEAN AIR REPORT - September 19, 1996                                               1 1

MOB/LE SOURCES

slowed the project's momentum.
goups over the possible air impacts om an expansion now seem to have
The SeaTac Airport is located in King County, WA, within a designated nonattainment area for C02 and
with EPA to redesignate the area into attainment
ozone. The state Department ofEcology is curreny working
status based upon the recent history ofmonitoring, control strategies and maintenance plans.

The FAA proposed last February to expand SeaTac by adding a third runway, and released an Envron-
mental Impact Statement (EIS) evaluating the potential environmental impacts of the third runway and other
determination tha: the
improvements at the airport. As required by the Clean Air Act, the FAA made a preliminary
the Seattle metropolitan area into
proposed expansion would not impede or delay Washington's efforts to bring
compliance with federal air quality standards for C02 and ozone.
In response to the EIS, EPA and the state Department ofEcology led formal comments stating that the air
clean air plan as
quality modeling analysis presented in the EIS did not demonstrate "conformity" to the state
the proposed expansion
required by the Clean Air Act. Federal law prohibits the FAA 'orn approving or funding
unless the agency determines that the air quality analysis demonstrates that the project would not prevent or impede
Seattle's effort to attain national air quality standards.
-n
Furthermore, EPA and the Department ofEcology each expressed concern that the project would result
and
additional violations ofC02 standards at key roadway intersections near the airport as a result of additional car
truck trafc. The air quality agencies were also concerned that the FAA had not committed in writing to "binding
Both
and enforceable measures" that would reduce pollution caused by congestion at the roadway intersections.
the airport.
agencies recommended a comprehensive program to monitor air quality around
noise
The project has already been delayed by local civic groups contending that it did not do enough to reduce
in surrounding neighborhoods. The Port of Seattle addressed those concerns by vowing to beefup noise reduction e'orts,
the Port,
thus reviving the plan. Since then, measures to redrrce air pollution have dominated the discussions, with the FAA,
craft an
loeal EPA ofcials and Department ofEcology representatives meeting over the past few months in an effort to
the outstanding environmental concerns.
agreement on how to move the project forward while satisfying
The postponement ofthe ROD "means the Port of Seattle can't move forward until they receive federal
the source
approval 'om F   ," one source close to the issue says. While FAA originally supported the project,
to ensure that the expansion meets all
points out, the federal agency is feeling pressure 'om EPA and other groups
necessary environmental requirements.
FAA ofcials could not be reached for comment.

Permits
" '
l' I r
h7

3M PULLS OUT OF PROJECT XL, PROGRAM COMES UNDER ECOS SCRUTINY
in the agency's
In the wake of a caustic debate between EPA and Minnesota over the state's involvement
the model for Minnesota's Project
Project XL regulatory reform program, the 3M Corporation's Hutchinson plant -
channels.
XL proposal  has opted to seek permits for its facility through more traditional regulatory
and has prompted state
The move by 3M signals the death knell for Minnesota's participation in Project XL
debates
environmental ofcials to create a task force to develop a dispute resolution mechanism for addressing
between state agencies and EPA on a host ofregulatory exibility-related issues.
launched
Minnesota was the rst state delegated by EPA to run Project XL -- the administration's initiative
rms with
late last year to reshape the relationship between companies and government regulators by allowing
and 3M's
stellar enviromnental records more 'eedom to develop their own pollution-prevention procedures 
was seeking a Title V operating permit that
proposal was the state's rst attempt to implement the program. 3M
would place a plant-wide emissions cap over all ofthe Hutchinson facility's air toxics sources.
must provide
But Minnesota could not forge an agreement with EPA on what level ofguarantees the facility
regarding environmental improvement, and the Minnesota Pollution Control Agency (MPCA) subsequently
between MPCA
informed EPA of its intention to suspend work on the Hutchinson project. A primary sticking point
environmental
and EPA in crafting an agreement was the issue of whether or not 3M had to guarantee superior
the company should be
performance "up front." State ofcials argued that because XL is an experimental project,
achieve environmental improvement.
granted some exibility to test approaches even ifthey did not ultimately
the way that the
EPA maintained that the state needed to implement a detailed test that ensured at every step along
environmental results than would have been required under otherwise applicabre
program was achieving better
rules. On this point, no compromise was possible, both sides contend (see Sept. 5 issue, p3).

12                                              CLEAN AIR REPORT - September 19. 1996