Truth in Aviation: Summer 1995

Expert Panel: “Sea-Tac Not Congested, Look at Rail”

An Expert Arbitration Panel sharply questioned the Port of Seattle’s stated justification for building a third runway at Sea-Tac Airport in a recent ruling. After three rounds of hearings, in which the Port of Seattle argued that future delays require more landing capacity, the Panel ruled, “We have not found in the evidence presented to us a succinct, well-documented statement of the delay and capacity problems that have led the POS to seek approval of the third runway.”

No. 1 On-Time Airport Hopelessly Congested?

Is the delay really as bad as the Port says? Total hours of delay at Sea-Tac have fallen from 48,000 hours in 1988 to 26,000. In fact, the most recent numbers show Sea-Tac as first in the U.S.A. for on-time departures and sixth for on-time arrivals. The Port claims that the delay is supposed to begin in the year 2001, but the Expert Panel could find forecasted future delays only “when poor visibility coincides with peak demand.” The Panel was charged to consider whether demand management options are “feasible” alternatives for the third runway. If peak demand can be reduced, the “need” for the runway shrinks. So, the Panel has considered such demand- reduction measures as higher fees for use of the airport during peak hours, changes in the ‘gates’ rules (to induce airlines to consolidate flights or fly more passengers per plane), and diversion of so-called ‘commuter’ air travel to rail.

Could They, Would They, Go by Rail?

The Expert Panel’s latest report considered rail travel as a form of demand management: give travellers an alternate way to go, to cut down traffic at the airport. The experts observed that high-speed rail, such as the ‘Bullet Train’ in Japan, would lead to a ‘very substantial diversion’ of people travelling by air to and from Seattle, Vancouver, and Portland.

However, the Panel concluded that the short-term prospects of such a system are so uncertain that high-speed rail does not rule out the “need” for a third runway by the year 2001. But, the Panel asked, what about short-term improvements in the existing rail system, especially between Portland, Seattle, & Vancouver? To quote the Panel’s report, “air demand at Sea-Tac includes a large number of flights to and from Portland and Vancouver, especially during peak periods”, adding “significantly to air congestion”. Many of these flights have “low load factors” (not many passengers in the plane). If even a relatively small number of airline passengers switched to rail, would the commuter airlines then eliminate some of their peak-period flights, and thus significantly reduce the delays that these flights cause, or will cause? The Panel could not find that improvements in rail service were or were not a feasible system of demand management. As a result of their findings, the Panel will proceed to a second phase of work, seeking more evidence on the rail issues. RCAA presented a major report on rail alternatives prepared by expert Hal Cooper at the earlier hearings and will make a followup presentations to the panel.

Sweetheart Contracts Rule Out Peak Period Pricing

As to non-rail demand management, the Panel gave a mixed verdict. They found a surprising reason to rule out “congestion pricing” as a feasible alternative to third-runway construction. This would be a system of higher charges by the Port to airlines for use of the facilities during period of peak demand. In theory, low-volume commuter airlines would find the higher prices prohibitive and they would therefore re-arrange their schedules, resulting in less congestion, less delay, leaving no reason to build a third runway. According to the Expert Panel, however, the Port has entered into contracts with the airlines that prevent the Port from charging reasonable peak-period fees. These contracts apparently run into the next decade, and the airlines show no inclination to let the Port set new rates. The Panel strongly urged that the Port negotiate different contracts in future, “to allow for the introduction of properly structured peak hour pricing”, but found that because of difficulties with the governing contracts, it could not “confidently say that the POS has the ability to introduce peak hour pricing before the year 2001”.

Port’s Numbers Foggy
Bogan: 3rd Runway not needed with LDA…

The official justification by the Port of Seattle for its third-runway project Seattle-Tacoma International Airport is that the two existing runways are so close together that only one can be used during the frequent bad weather (44% of the time), and intolerable delay will occur in a few years if commercial flights are limited to only one runway during that bad weather. Fog & low clouds are the main components of the bad weather.

How Much Fog at Airport?

Is the weather really that bad? Not according to one independent investigator, Gerald Bogan. Bogan, a well-known aviation consultant, studied the last two full years of hourly weather observations (obtained from the National Weather Service) and found that under FAA rules, both existing runways can be used 66% of the time. So, Bogan says, bad weather incidence is, not 44%, but only 34% with the technology now used by the Port. But according to Bogan, during half that bad weather, FAA rules would permit ‘dual-flow’ operation if the airport used the Localizer Directional Aid System (LDA). The bad-weather factor would then be only 17%. The writers of the DEIS for the third runway assumed that bad weather is spread evenly throughout the day. Bogan comments, “Logic would say that some of that poor weather had to occur during off-peak hours and, therefore, did not cause delays due to a single flow arrival stream.” Study of the actual hour-by-hour weather data confirmed this, and Bogan found that most of Sea-Tac’s ‘bad weather’ occurs late at night when it does not affect airport capacity.

How Much Delay?

Bogan analyzed prospective delay for the year 2020, in light of real weather data. Starting with the Port’s projection for Sea-Tac traffic for that year (441,600 combined landings & take-offs), he factored in peak-demand times, peak bad-weather times, the projected 2020 fleet ‘mix’, & the use of the LDA system, but no third runway. He found that in the two worst months (December, February), the percentages of flights that could encounter some delay due to a single-stream arrival flow were 1.5% & 1.8%, respectively. He observed that, considering all the uncertainties in long-range forecasting “this delay of less than 2% is negligible”. Mr Bogan’s conclusion? ” … a third runway is unnecessary, the DEIS conclusions are based on faulty assumptions. The Port has not exhausted all alternatives including LDA approach procedures …. [I]mplementing LDA procedures can be accomplished quicker and cheaper than building an additional runway.”

LDA systems cost less than $5 million.

City of Sea-Tac, Port Seek Court Order on Conflicting Powers

The City of SeaTac, whose boundaries include all of Sea-Tac Airport, has sued the Port of Seattle to establish the City’s legal right to regulate development activities, especially those at the Airport, occuring within the City’s corporate boundaries. The Port contends that it has the exclusive right to zone property that it owns within the City used, or usable, for airport or airport-related purposes. The two bodies are also asking the court to rule which has legal authority over fire protection, criminal activities, and storm-water control.

In its complaint, the City of SeaTac points to a specific statute, Revised Code of Washington sec. 14.12.030, which confers airport- zoning power on “political subdivisions” having an airport hazard area within its borders. The Port relies on a statute, RCW 14.08.330, which provides that a municipality owning or operating an airport shall have exclusive jurisdiction and control of that airport. The City responds that it has additional powers under RCW ch. 35A.63, which requires the City to prepare a comprehensive plan, including transportation and public-use elements. The City also says that other statutes permit & require it to protect environmentally sensitive areas, and to provide for drainage, storm water, & surface water. The Port now operates its own storm-water collection system, which discharges water into the City’s storm-water lines. Under Washington’s constitution and statutes, a port district is considered to be a limited-purpose municipality, while a city is a general- purpose municipality. Ports are granted power to employ their police departments & fire departments.

Of particular interest to RCAA supporters is the question of zoning for Sea-Tac Airport. Before incorporation, the airport area was zoned by King County as Airport Open Space and Light Manufacturing-P (Airport Facilities Uses Only). The Port’s proposed third runway would lie outside those zones, and under the City’s view of the law could not be built if the City did not change its zoning ordinance. The Port apparently believes that it can build wherever it wants, without regard to zoning laws. The case will probably be heard in Superior Court on opposing motions for summary judgement, without a trial. Since the entire controversy is about the meaning of various statutes and provisions of the Constitution, no testimony would be needed. Legal arguments are tentatively planned for the fall of this year. SeaTac is represented by City Attorney Daniel B. Heid.. The Port is represented by Craig Watson, one of the Port’s in-house attorneys.

What Runways Cost*

*Source: FAA

Airport  Length  Cost(in millions)
Baltimore  7800  $48 
Charlotte  8000  $43
Fort Myers   9-10,000  $87
Louisville (17L)  10,000  $50
Louisville (17R)  10,000  $42
Phoenix  7800  $88
Salt Lake  12,000  $120
Sea-Tac  8500’  $413.2

Sea Tac Expansion Costs Skyrocket

When the third runway was first considered as a Flightplan alternative, no additional costs beyond a 7000’ 3rd runway itself were included for Sea-Tac — although they were included for other alternatives. Now that that the Airport Master Plan is out, the true costs are beginning to show. Below is a table from the Sea-Tac Master Plan Update Draft Summary of Preliminary Cost Estimates. The Sea-Tac expansion first discussed at around $160 million has grown to an eye-popping $1.4 Billion, not including mitigation or the South Aviation Support Area (SASA).

Expansion Project   Costs (in millions)*
3rd Runway (8500’dependent)	   $  413.2
Extending existing 16L another 600’  $   67.2
Existing terminal expansions  $  547.6
STS (Satellite Transit
  System) improvements   $  130.1
Roadway & parking  $  176.3
Other landside  $   82.9
TOTAL  $1,417.3
*Source: P& D Aviation 1995

Not included
Environmental mitigation
  including noise  $ 200-300
NPDES storm water 
system improvements  Not given
SASA  $  400
No light-rail terminal  Unknown
Demolition of airport
  tenant facilities & other 
  tenant  improvements 
  which must be relocated  Unknown
Terminal area relocations   $    9.1
Litigation costs & settlements    Unknown

Cities Scorn DEIS on the Third Runway

Serious problems in the Draft EIS for the third Sea-Tac runway were noted by the nearby cities of Burien, Des Moines, Normandy Park, & Tukwila, members of the Airport Communities Coalition. Federal Way and Mercer Island also joined in the ACC comment blistering the DEIS. Aided by the Washington, D.C., aviation law firm of Cutler and Stanfield, the cities focused on failure of the DEIS to detail specific actions needed to complete the projects, the failure to consider the cumulative impacts of the airport expansion together with numerous other public projects proposed for the immediate area. The comments also call attention to the faulty weather statistics, conflicts with local land use plans, and failure to discuss problems of surface transportation after construction.

The City of SeaTac, in a separate comment, called attention to the probably steep loss in property values as the noise footprint of the airport expands and criticizes faulty maps in the DEIS which erroneously show the noise-impacted area as shrinking. SeaTac also commented that serious issues of air and water quality and wetlands impacts were not properly addressed in the DEIS.

City of Burien gets $500,000 to study runway impacts

Thanks to efforts by State Senator Mike Heavey (D), the City of Burien has been awarded $500,000 by the State for use in studying potential impacts of a Sea-Tac third runway. The City is considering how best to use the money. Should it undertake more extensive and better air quality research? Examine noise impacts? Acquire parklands? Protect water resources? Work on mitigation of what one working paper calls “blighting impacts” of the air traffic shadow on residential neighborhoods and business districts? Find ways to over come surface-transportation problems that would come from increased ground traffic in and around the airport? Plan against noise & traffic congestion to be caused by construction? Monitor the particulate matter from jet engine exhaust for health planning? Study how expected increase in commercial activity could be focussed to offset “blighting impacts”? Work on affordable-housing concerns? None of these impacts was adequately addressed in the draft EIS, according to Burien city staff.

Issues identified in Burien are common to other airport communities, and tentatively Burien expects to engage in a cooperative planning program with the cities of Des Moines, Normandy Park, and Tukwila, as well as the Highline School District. They expect to co-ordinate with Federal Way, Mercer Island, and SeaTac. It is expected that Highline Hospital District and other special districts in the area will also be involved.

Port Sued in Federal Court for Long-Continuing Water Law Violations at Airport

Acting for the Waste Action Project, Seattle attorney Richard A. Smith has filed suit against the Port of Seattle in U.S. District Court at Seattle for court orders to stop numerous violations of Federal laws against water pollution, said to have occurred at Sea- Tac Airport. The suit also seeks damages of up to $25,000 per day per violation.

“Every time that we turn over another rock at the airport, another appalling environmental problem crawls out.” Greg Wingard, WAP

A Federal statute requires a special permit for the Port to discharge waste water from the airport to surface waters, in this instance, Des Moines and Miller Creeks, directly, & Puget Sound, eventually. The state Department of Ecology issues the permits. The Port as permit- holder is required to monitor for numerous substances & conditions – fat, oil, grease, ammonia, glycols, sludge, petroleum & by-products, & others. Strict limits are placed on the amounts of these substances that may enter surface waters, and special requirements for handling these waste waters are required.

The suit charges that the Port repeatedly discharged excess pollutants, that it failed to submit the required monitoring reports, & often did no monitoring at all.

Part of the approved waste-water system consists of lagoons (large holding ponds) where polluted water is held, by the terms of the discharge permit, until it can be processed through a treatment plant. The Waste Action Project charges that polluted water from one or more of these lagoons has often been sent without treatment to surface waters, & frequent overflows have occurred in violation of the permit and federal law.

Violations of monitoring requirements have been discovered from July 1990 to the present, according to the Waste Action Project, and are part of the suit. The Department of Ecology has tracked improper operations and maintenance by the Port as far back as 1965, according to a letter sent to the Port on Feb. 27, 1995 by Ecology engineer John Drabek listing numerous violations. A Port of Seattle spokesperson, quoted in a Seattle newspaper, called the suit “groundless,” and a Port attorney was quoted as saying that the plaintiffs would have to show continuing violations in order to win. In response, Attorney Smith told our reporter, “we’ll stand by our allegations.”

For more information, write CASE Waste Action Project, 19900 4th S.W., Seattle 98166.

Port’s Plans conflict with previous Miller Creek Settlement

The Draft Environmental Impact Statement made a major omission in suggesting that fill dirt could be taken from several sites along the headwaters of Miller Creek. Any disturbance of that area is prevented by a settlement between King County, the Port of Seattle and Mrs. Helen Kludt and her neighbors prohibiting future channelization of Miller Creek or disturbances of flow rate.

Local Zoning of Airport OK Under Federal Law, Ohio Court Rules

Federal court cases permit a city to issue zoning rules that apply to airports owned by other municipalities, according to a July 1995 decision in a lawsuit brought by the City of Cleveland, Ohio, against a near-by suburb, the City of Brook Park. Cleveland owns Cleveland Hopkins International Airport, part of which is in the neighboring city. Like the Port of Seattle, Cleveland decided to build a third parallel runway, mostly in Brook Park. Existing zoning was inconsistent with new runway use.

Cleveland asserted that Brook Park’s zoning ordinances apply to activities over which the U.S Congress has asserted full control. The court found otherwise — no “express preemption of local land use ordinances” –in any of the Federal statutes relating to aviation or all statues combined. Cleveland also asserted that the local regulations unconstitutionally interfere with or burden interstate commerce. The trial judge found that there was no discrimination against interstate commerce and that there was no risk that interstate activities at the airport would be subject to inconsistent regulation by different states.

The case may be appealed to the U.S. Court of Appeals.

Citizens Trounce EIS on 3rd Runway

“The third runway is the most-damaging, most-costly, and least-effective of the various reasonable alternatives for reducing delay.” So began the formal comment of RCAA on the Draft Environmental Impact Statement (DEIS) for the third runway at Sea-Tac. Three full volumes of analysis, supporting technical papers, and appendices completed the submission, responding to the contention of the Port of Seattle and the Federal Aviation Administration (FAA) that the third runway is needed because it is the only alternative that will reduce delays during peak period bad weather and prevent economic damage and delay costs arising from restricted capacity.

The RCAA comments covered the failure of the Port and FAA to look realistically at numerous alternatives to construction: demand management (to reduce peak-period commuter flights); diversion of air passengers to rail; diversion of all-cargo flights to other facilities; ‘green grass’ sites away from the Central Puget Sound region; and LDA to reduce peak/period bad weather delays.

The comments attacked the unsatisfactory and unscientific analysis of noise problems, showing that the DEIS used an inaccurate method of analyzing noise, failed to conduct actual monitoring, and relied on a discredited computer model. Air pollution concerns were also addressed, again with attention to unscientific methodology, failure to do actual monitoring, false assumptions, and other errors. RCAA also disputed the contention that there is no proof that overflight noise causes medical problems for people on the ground ;and submitted a huge bibliography of studies of noise and medical problems showing a great deal of scientific work in this field, work that the DEIS ignored. An extensive discussion was included about the purpose and need for the project, showing that the need was grossly overstated. The DEIS ignored the option of a true regional airport for the next century.

Other groups & governmental bodies submitting critical comments on the third runway DEIS before the August 3 deadline included the S.W. King County Citizens, the Seattle Community Council Federation, the North-East District Council (Seattle), and Ravenna-Bryant Community Association (Seattle). Airport Communities Coalition and the City of SeaTac also commented extensively.

S.W. King County Citizens submitted 500 pages, including 60 pages detailing problems with the air quality section and a carefully research section on historical sites. Citizen groups based in Seattle were especially critical of the failure of the DEIS to weigh adequately the social & economic impacts of airport expansion, especially noise, both on the long-established residential communities near the airport, and the cities farther away, which receive very heavy concentrations of noise unrecognized in the EIS. One group (North-East District Council) included scores of extracts from statements of individuals suffering impact from overflight noise miles from the airport.

The Seattle Community Council Federation wrote of the “disproportionality of the impacts of Sea-Tac operations” on low income areas.

More DEIS Comments:

“The DEIS is like cotton candy. It looks big until you take a bite-then it’s mostly air.” — Seattle Community Council Federation.

“The construction of the Grand Coulee Dam – the largest public works project of its generation in the world – used an awesome 10,585,000 cubic yards of material. The Sea-Tac expansion will move two-and one sixth times Grand Coulee Dam [23 million cu. yards.] It is over sixteen times the gross cubic yardage of all three City Light Dams on the Skagit River. …The [DEIS] executive summary grossly understates the duration and impact of construction. It’s like describing a chop by a guillotine as a ‘neck wound.’ “–Ravenna Bryant Community Assoc. (in NE Seattle)

“If noise wasn’t a problem, we wouldn’t be complaining. We’re complaining. It’s a problem.”-Seattle Community Council Federation. FAA Report Outlines Aircraft

Noise Effects on Home Values

The effects of airport noise levels on housing values have been examined in a recent report written by Booz, Allen Hamilton for the FAA.

The study compared appraisals of comparable residential homes in both quiet and aircraft noise impacted neighborhoods around four major airports. The study’s results showed consistent trends: aircraft noise lowers home values and aircraft noise impacts are more pronounced in higher-priced areas. In one neighborhood, moderately priced homes were appraised over $60,000 more than in airport noise-impacted neighborhoods.





Flight Track Changes? Are they “beating the box?”

Citizens in Columbia City, Beacon Hill, Capitol Hill, Montlake, Mercer Island & Star Lake report recent substantial changes in normal flight patterns . As the outlying noise monitors are sited but not yet working, some were led to speculate that airlines & the tower were practicing “beating the box,” that is, flying around the monitors. Others pointed to August peak period traffic- a precursor of life with higher capacity. The tower apparently told some people that flights were being diverted for SeaFair, although citizens say the changes occurred before SeaFair started. Please keep a log of planes flying odd routes at odd times. If you can indicate your location, the exact time and/or the type of plane, that helps. Send them to the RCAA office by mid-October, and we will draw the expert panel’s attention to them. Call the Port’s Noise Hotline at 433-5393 to officially record complaints.

Mercer Island Hires Noise Consultant

The City of Mercer Island is conducting a study of SeaTac airport overflight noise levels on Mercer Island in response to residents’ complaints of aircraft noise. The focus of the complaints appears to be Sea-Tac airport traffic which turns east over Mercer Island under ‘north flow’ conditions. RCAA recently collected aircraft noise measurements on Mercer Island for use by the PSRC Expert Panel.

RCAA volunteers Do the Fairs

Dozens of RCAA volunteers have been “doing” the fairs with public information booths to tell people about the third runway issues, sign up new members, register voters, pass out buttons, bumper strips, and flyers. They registered nearly 500 voters, and eight hundred new RCAA members were signed up at fairs in Des Moines, Tukwila, Burien, Normandy Park, Federal Way, Magnolia, and Beacon Hill. RCAA sported a float at the Waterland Parade depicting local kids with ear muffs, studying under the din. The Magnolia Community Club Land Use Committee sponsored a booth at the Magnolia Fair on aircraft noise generally (they have Boeing Field and Sea- Tac and float plane noise). One hundred & fifty people signed their petition in just one weekend.

Thanks to Pat Pompeo, Audrey Richter, Gwen Broznowski, and Jim Bartlemay for their hard work organizing and to all the volunteers. GREAT JOB!

Temporary Restraining Order

Chris Clifford of Renton has obtained a Temporary Restraining Order in U.S. District Court, extending the time to file comments on the third runway DEIS until August 30. A court hearing on that day will decided whether more time will be granted. The case is assigned to District Court Judge William Dwyer.

RCAA Needs You!

The Regional Commission on Airport Affairs was formed by citizens to help citizens. Before RCAA, the only place to get expert information on noise, air pollution, water pollution, Port waste, delays & capacity issues, new technologies, and regional (not parochial, Port) air transportation alternatives was the Port of Seattle. After RCAA, citizens from all over the region could find and develop their own information, analyze the issues, and make presentations of their facts to regional decision makers and the public.

We are making progress. Our noise experts showed that airport noise is more annoying than other noise at the same averages; our experts showed that the Port’s Noise Mediation Program produced a reduction but not enough to be heard – and the PSRC’s expert panel agreed. Our experts showed that, because the Port’s noise monitoring stations were only measuring 7% of the noise and low rumbles, insulation is ineffective. Our experts showed that there is more possibility for rail than the Port states – and again the expert panel agreed. Our experts are again showing that the Port’s weather data is inaccurate and that other technologies, such as LDA, would be more efficient than a third parallel runway for dealing with weather delays. And we aren’t done. Among other things, we are re-examining the costs – now according to the Port’s own estimates a whopping $1.4 billion, the price of a new airport.

You can help RCAA’s work through your contributions, your volunteer time, and your calls to public officials responsible for airport decisions. Please clip this form and send it in today with your contribution. You will receive our thanks, a No Third Runway bumper strip and our regular newsletter in return. Contributions are not tax deductible. RCAA, 19900 4th Ave. S.W. Normandy Park, WA 98166

RCAA Reader Card

Knowledge is power, and we want powered-up citizens. Get informed! Over the years, RCAA has had experts prepare papers on a variety of subjects related to airport noise and other airport expansion issues and has collected pertinent government documents. Many of our white papers & other materials are available at the Burien, Des Moines, and Valley View libraries or send your reader card & check to RCAA’s office at 19900 4th Ave. S.W. Normandy Park, WA 98166. Unless otherwise noted, all reader card reports cost $3.00 each (to cover copying & postage costs). Many are available in the RCAA Library.

Noise – PSRC Presentation by Alice Suter, Ph.D. (Airport noise more annoying that other noise & Noise Mediation & Nighttime Limitations within the error rate of + 2 dB(A.). – Alice Suter, Ph.D. Follow-up with expert panel. – Decision of PSRC Expert Arbitration Panel on Noise, Jan. 9, 1995 – INM Noise Model Flight Profiles: (Shows INM flight profiles used to draw noise maps inaccurate for Stage 2 &3 aircraft, especially heavy weight.)

Air Pollution – Williams, Beth-RCAA White Papers, Book 1 (Outlines possible air pollutants and summarizes DOE 1991 Study.)

Economics – Comment to Flightplan DEIS by Dr. Lynn Michaelis. (Basic economics of the third runway.) – FAA, Booz-Allen Consulting study on losses of property values due to airport noise. Sept. 1994. (Shows much higher losses in real property than claimed in Draft EIS, especially in higher priced areas.)

Health, Education & Safety – Dennis Hansen, M.D. & Lee Sanders, M.D., Ph.D. (Basic literature review of health effects of noise & air pollution in airport communities.)

Purpose & Need/Alternatives -Gerald Bogan, Weather & LDA. (Port needs for 3rd runway based on false weather assumptions.) – Dr. Hal Cooper Presentation to Expert Panel on Rail Alternatives. ($5.00) (Shows how diversion to rail could eliminate need for 3rd runway.) – Decision of PSRC Expert Arbitration Panel on Demand Management. July 27, 1995. (Casts doubt on need for 3rd runway.)

General – RCAA Scoping Comments to Draft Environmental Impacts Statement (DEIS) ($5.00). (A good mini-training course in issues, as well.) – RCAA Comments on DEIS ($10.00) (No appendices included)