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HomeMy WebLinkAbout07012019 City Council Work Session Laydown - Airport Altermate Plans Motion: PACAB recommends Council direct Administration send a letter to the Alaska Department of Transportation and Public Facilities Commissioner and Cc Federal, State and Borough Representatives insisting Alternative 1.1 be reconsidered for the Seward Airport. Motion: Administration will forward comments to Council if they chose to send a letter based on our recommendation. ALTERNATIVE 1.1:Reconstruct Existing Main Runway 13-31 (4,533 feet x 75 feet). • Reconstruct and raise Runway 13-31 above the 100-year flood level. • Install riprap(bulkhead)to protect the embankment from flooding. • Eliminate Float Pond-cost saving measure • Eliminate Runway 16-34-cost saving measure • Value engineering, for example additional tests and engineering reports re: soil stability • Future use reexamined and fully defined population data gathering- numbers are low for summer • Discuss importance of habit of the area with community's use- reason to keep long runway and not expand short • Include reasoning with C130s(full load deliveries only possible with this runway) and Dash 8 (only able to land on runway with this length)-key for emergency in Seward for community and individual access to save lives with life flights • This is the only runway with ability to provide for future instrument landing equipment • Topography favors existing main runway • Include shareholder's list of interested parties that havealready spoke in favor of 1.1 • Pattern letter as a rebuttal to Selection of the Design Alternative 10/3/2017 • Include points from Carol Griswold letter • Explore dredging channel-point to Metco's current permits • Cite that FEMA LOMR's and CLOMR's faster to obtain then DOT asserts • Decreases impact to private property owners • Explore alternate funding sources • Invite DOT to come and discuss with community in a larger forum as a presentation Q and A March 19, 2019 To Whom It Should Concern Re: Seward Airport Improvement Plan I have great concerns about the DDT's selection of Alternative 2.2 which would shift the existing, 2,289' x 75' Crosswind Runway (16-34)to the east and extend it by 1, 011 feet to 3,300'x75'. This plan would abandon the existing 4,533' x 100' Main Runway (13-31) that also serves as a levee that protects the airport, infrastructure, and salt marsh west of the Resurrection River. (Note FAA lists RW 16-34 at 4,533'.The Plan variously lists it at 4,249' and 4,500'.) I, along with many others, support Alternative 1.1 which would retain and maintain the existing 4,533' RW 13-31. At all the public meetings,the public and pilots spoke overwhelmingly in favor of this option but it was taken off the table by ADOT. Any alternative will require a continual funding source and staff with no guarantees of success. The long runway must be raised, fortified, and maintained as a levee with the runway on top to protect the rest of the airport and infrastructure to the west. It is risky and shortsighted to abandon it. The Crosswind Runway points directly at an extremely important habitat for resident and migrating birds, and the location of a large Arctic Tern nesting colony. Extending the runway will bring all the fixed wing aircraft, including small jets, much closer and lower to the wetlands and ponds upon approach and departure. This will unnecessarily increase the risk of bird-aircraft collisions, and jeopardize the aircraft and wildlife. Mitigation of all developmental impacts are critical to protect the integrity of this wetlands ecosystem that also protects the Seward Airport and adjacent Alaska Railroad property from erosion, flooding, siltation, and the threats of continuing sea level rise. Extending the Crosswind Runway will negatively impact this delicate ecosystem Extending the Crosswind Runway also places it in an area that experiences flooding, extreme high tides, surf and ice impacts, overflow from the adjacent slough and ponds. Impacts and maintenance throughout the year including dramatically different winter conditions must be evaluated. The only viable alternative, if dredging the main channel is not an option, is Alternative 1.1, Reconstruct the Existing Main Runway 13-31 above the 100-year flood level, install riprap to protect the embankment from flooding AND bring it up to its previous weight-bearing standards. Thank you, Carol Griswold Seward, Alaska March 14, 2019 http://www.dot.state.ak.us/creg/sewardairport/documents/Draft-Environmental- Assessment.pdf Hi Bruce, Thank you for your invitation to provide comments on retaining the current long runway RW 13-31. I have a huge concern that if all the emphasis is placed on the importance of a 4000'+ runway, it will give even greater support to Alt 2.2 with a future extension of 700' of RW 16-34 to reach 4000'. Issues with the wildlife, birds,jurisdictional wetlands, private land, etc that would complicate and negate the 700' extension must be emphasized, so that Seward will never have a long runway if RW 13-31 is abandoned. (I will certainly comment on this!) Allowing the river to breach RW 13-31 as proposed may very well help to restore the original floodplain, but will also threaten the new RW 16-34 and millions of dollars of infrastructure at the airport and Alaska Railroad property. RW 13-31 needs to serve as a levee and runway. I've noticed comments at City Council and PACAB meetings in support of a long runway may be misinterpreted to mean support of the new RW 16-34 with extension. Comments must express support for improving and maintaining the existing long runway RW 13-31. The following are points gleaned from the Seward Airport Improvement Project EA that will need to be strongly opposed: Main runway: RW 13-31 4,249' x 100' Currently restricted to small aircraft with a weight of 12,500 or less due to weakening of embankment caused by flooding. Length exceeds need of current and forecast aircraft, although the longer RW would make the airport available for infrequent use by larger aircraft. Alternative 2.2 EA proposes closing and discontinuing maintenance of this long runway Resurrection River expected to be overtopped and breached by future flood events, allowing floodwaters to reach RW 16-34,thereby restoring part of the original floodplain (bad idea) Secondary runway: RW 16-34 2,289'x 75' • • Mein Office(907)224.4050 {as ea • Ponce(907)224-3338 CITY OF SEWARD • Harbor(907)224.3138 PO. BOX I61 "'1 • Fire(907)224-3445 SEWARD,AI.4SKA 99664 Olh7 r,r<► • City Engineering(907) 0(9)2 4-4046 • 049 • Utilities(907)224-4050 • Fax(907)224-4038 February 22,2017 DOT&PF Design&.Engineering Services Preliminary Design& Environmental P.O. Box 1 r1(90(I Ancllorige,Alaska 99519-6900 Dear Brian Elliott Thank you for the opportunity to comment on the proposed Seward Airport Improvement project. The City of Seward desires to see the same result as DOT&PF: a reliable working airport meeting ADG- II and Alaska Commilnity Class airport design standards, and that will accommodate flume demand and growth. We offer the following,based on your agency scoping letter cfJanuary 24,2017. As you've noted, recent changes in stroll') morphology have resulted in more frequent overtopping of RAN 13/31. 11 has also shifted the main watercourse of Resurrection River to the west, at first obliquely against and then aligned with the runway. it is lair to SIR that, rather titan "...the main runway is located adjacent to the river..."that the river has relocated itself adjacent to the runway. We have discussed this in the DOT sponsored community meetings held over the last couple of years to address this issue, and were informed that in-river worst, or channelization, is prohibited. Doing such work in the river is not impossible, or even impractical. Routine in-river work mining gravel,protecting riverbanks and adjacent properties, and performing flood mitigation and prevention tasks are routinely permitted and completed, both by government agencies and private parties in and adjacent to the Resurrection River. Redirecting the river as an element of protecting the runway should not be taken olT the table. As is common with rapid transfer high-deposition streams in the area watershed. watercourses migrate within the floodplain boundaries, and at sonic point this river will be somewhere other than where it is now. Formulating a protection strategy (Alt 1.1 or 2.2) on an assumption that the floodway watercourse will remain in one place like a well-defined Kenai River or similar will likely impede the river from migrating further west, but will be of no use if the river migrates to the east. From a floodplain manager's perspective rerouting the river or placing obstructions that shape and limit the river's own natural relocation are channdiiatirm activities that require engineering and permitting. Neither is impossible, nor is one prohibited and the other allowed outright. The current flow path continues to deposit material at the head of Resurrection Bay, causing siltation at the Alaska Railroad dock that requires ongoing maintenance and expense. it may be that the Railroad prefers a one-time larger investment (with others)towards relocating the river flow to the channel Further cast, where the predominant flow was located until fairly recently. This would allow natural siltation to continue,but without repeatedly impacting shipping operations. The possible need to acquire private properties in order to implement either alternative was mentioned. Without specific parcels being identified in the seeping letter,we can't he sure which properties would be impacted,but it is likely the numerous smaller parcels to the east of R/W 13131.These properties,though A-105 subdivided and platted, can never he practically developed. lhere .s no legal access, and gaining same would be a large multi-agency effort. There arc no utilities (required by City Code prior to issuing building permits), and no easements acn,ss the various private and public lands that would be crossed to connect utilities. These facts are reflected in the assessor's tax values;most oldie smaller lots are valued at less than $1,000. Several owners have deeded their properties to the City in order to avoid paying taxes on undevelopable property. This gives the City. and the Seward Bear Creek Hood Service Area, a conservation and flood mitigation set-aside that's very valuable in providing needed''sponge"areas, with vegetation as stabilisation. If acquisition of some or all of these parcels is accessary to implement the project work,the City will facilitate in any way we can, including acquisition and assisting with a LOMR. We view the restoration of the predominant flow of Resurrection River to its historic channel matrix to the east, which includes sufficient width for inevitable meandering.as critical to the lasting success of either alternative. We prefer Alternative 1.1 as the less intensive in terms of wetlands impacts(-5 acres v. 13.5 for Alternative 2.2), likelihood of' less ongoing maintenance, mitigation of continuing impacts to shipping at the Alaska Railroad dock, and most likely to meet the common goals of a working and reliable airport that meets applicable design criteria and plans for future demand and growth. The scoping letter mentions that Seward is served by rail, road, and the marine highway; the Alaska Marine I lighway System suspended operation in and from Seward in the every early 2000's. We appreciate the opportunity to comment on this important project. We look forward to participating in the continuing discussion. Sincerely. City of Seward,Alaska f Ron I gong, Assistant City Manager t)onnn glen?, City Planner(for Ron Long) Email:rhnn;^'rrcitlofNttcnil net Phone:907 224-21120 A-106 Ken Risse From: Robert.D.Hornick@uscg.mil on behalf of Hornick, Robert D LT <Robert.D.Hornick@uscg.mil> Sent: Thursday, August 14, 2014 12:18 PM To: Ken Risse Cc: Coulter, Nathan CDR Subject: RE: PDC Engineering Facility Requirement - Seward I do not know who does the pavement strength tests or who funds them.The LCN report I was stating came from an Air Force report.We just go by what is published in the AK aviation supplement. As far as the use of an airfield during a mass casualty or natural disaster, if the runway is still usable we would/can use the C130 as an air ambulance to get people to higher level of care quicker. As far as the chain of command,we normally get our direction through our district office in Juneau Alaska. The H60/H65 helicopters have used Seward before, and usually they only require gas.As stated earlier the C130's have not been there in a while. I will not say we will never use Seward for SAR, as we never know what situation will present itself. Having Seward available for use by C130's only allows for increased flexibility/capability to respond. If Seward were rated for C130 use we would use it training pilots to land on shorter/narrower runways. Currently the only other field we use that is close to Sewards dimensions is Dutch Harbor and that is a 2 hr flight. You would probably see weekly flights stopping by for touch and go's. C130's would need no other services. Let me know if you have any more questions. LT Robert Hornick C-130 Assistant Operations Officer Robert.D.Hornick@uscg.mil (W) 907-487-5586 (C) 858-752-3103 Original Message From: prvs=296a1c91b=KenRisse@pdceng.com [mailto:prvs=296a1c91b=KenRisse@pdceng.com] On Behalf Of Ken Risse Sent:Thursday,August 14, 2014 10:12 AM To: Hornick, Robert D LT Cc: Coulter, Nathan CDR Subject: RE: PDC Engineering Facility Requirement-Seward LT. Hornick, Thanks for the reply. Can you tell me more about the way the Coast Guard would handle mass casualties or medical evacuations? For instance, if there were an accident with a fishing boat, cruise ship or other vessel with a dozen injuries,would the Coast Guard C-130 act as a medical ambulance moving mass casualties to hospitals in Anchorage or A13 other cities? If there were a natural disaster, not at sea, such as an earthquake,fire or flood, would the Coast Guard respond under FEMA direction? For the pavement strength, you mentioned that it previously had an LCN of 14. Do you go by the published pavement strength in the 5010 records (currently not available), or does the military test pavement strength at airports it plans to use? If there were no pavement strength limitations/restrictions, how many annual C-130 operations would you expect at Seward in a typical year? Would Coast Guard search and rescue operations ever be based out of Seward? If so,what airport facilities are needed? Thanks for your help. Ken Risse, PE,Senior Associate Civil Engineer PDC Inc. Engineers Planning Design Construction 1028 Aurora Drive I Fairbanks, Alaska 99709 v 907.452.1414 I f 907.456.2707 I www.pdceng.com "Transforming Challenges into Solutions" Original Message From: Robert.D.Hornick@uscg.mil [mailto:Robert.D.Hornick@uscg.mil] Sent: Wednesday,August 13, 2014 3:33 PM To: Ken Risse Cc: Coulter, Nathan CDR Subject: RE: PDC Engineering Facility Requirement-Seward Ken, Understand you are inquiring about Coast Guard operations at the Seward airport with regards to C130 operations and impacts. Since I have been here (2012) we have not used Seward due to the fact that it is no longer tested for the C130 bearing capacity. From what I have been told we used to operate there when it was certified for our weight. The real impact for Coast Guard operations is for expedient planning in case of mass casualty or Medical Evacuation that would allow a quicker response via C130 than an H60. Additionally, if an H60 needed fuel and a fuel provider was not available at the airport the C130 could provide fuel. With the bearing capacity as it stands we would need a DOT waiver, which could take some time.The last report, before the 12,500 NOTAM restriction was established, is that the main Runway has an LCN of 14 equating to a max gross C130 weight of 100,000 lbs. With a runway length of 4500 we can normally operate at about 120,000 lbs, allowing enough fuel and gear to respond to the majority of situations. Let me know if you have any questions. 2 A14 LT Robert Hornick C-130 Assistant Operations Officer Robert.D.Hornick@uscg.mil (W) 907-487-5586 (C) 858-752-3103 Original Message From:Vojtech, Zachary R LT Sent: Wednesday,August 13, 2014 2:58 PM To: Hornick, Robert D LT Cc: DeAngelo, Daniel J LT; Coulter, Nathan CDR Subject: PDC Engineering Facility Requirement-Seward Bob, I received a phone call from Ken Risse who works for PDC Consulting Engineers, contract work with Dept of Transportation.They are putting together a Facility Requirement Chapter for the Seward airport and would like to know the importance of Seward in regards to the Coast Guard.Specifically,they are deciding whether or not the DOT should shorten the runway or change the weight capability, but would like to know impacts to our C-130 operations. Ken Risse's phone number is 907-452-1414 and email is kenrisse@pdceng.com. He will be completing this chapter by Friday, and would like to add our input to it before then. Thank you. Zach LT Zach Vojtech Air Station Kodiak w: (907)487-5887 3 A15 1 41 Note that the USACE method calls for a Class II +,Cal B&SP calls for Class IV-,and HEC-11 calls for Class II. Given the angle of attack of the flow to the runway embankment, Class III is recommended for embankment protection for the southern half of the Runway,including and extending upstream beyond the anticipated point of impinging flow. Above the point of impinging flow, Class II riprap is recommended. Additional analysis will be conducted following the selection of the preferred design alternative. Due to the length of Runway 16/34 in Alternative 2.2,the embankment will extend into the Resurrection Bay intertidal zone. Additional erosion protection will be required to protect the runway embankment from wave runup and storm surge events. Recommendations Though FAA Advisory Circulars,the Alaska Aviation Preconstruction Manual, and the Alaska Highway Preconstruction Manual (AHPCM)do not provide a design return interval specifically applicable for an airport adjacent a river,Table 1120-1 in the AHPCM recommends using a discharge with a 100-year return interval to design culverts and channel changes in designated flood hazard areas with no reference to the type of facility. ADOT&PF interprets this recommendation to be applicable for countermeasures pertaining to both flooding and scour at airport facilities in FEMA mapped floodways and floodplains(Janke, 2015). The braided channel of the Resurrection River adjacent to the Seward Airport has exhibited significant changes in location over time. Additionally,the frequency of runway overtopping events and the required maintenance has been increasing with time. Because of the dynamic nature of the Resurrection River at close proximity to the Seward Airport,the design guidelines should be conservative. Panels 4543,4544, 5006, and 5007 of the 2013 Flood Insurance Rate Map (FIRM)are found in Appendix H. Panel 4543 includes the Seward Airport and the Resurrection River Regulatory Floodway. FEMA regulations state communities shall prohibit encroachments,fill,new development, substantial improvements,and other development within the adopted regulatory floodway unless it has been demonstrated through hydrologic and hydraulic analyses that the proposed encroachment would not result in any increase in flood levels within the community of the base flood(100-year)discharge. In addition,the KPB Floodplain Development Ordinance (KPB, 1986) also prohibits any increase in flood levels during the base flood that result from fill, construction and other development within the regulatory floodway. Also note that minimum federal standards limit the maximum allowable rise of the 100-year Base Flood Elevation(BFE)to 1 foot. FEMA's regulations allow for State and local government regulations that are more stringent(allow something less than a one foot rise)to take precedence. Alternative 1.1 requires encroachment within the Regulatory Floodway due to construction of the raised runway. The hydraulic analysis shows a range of flood level increases within the regulatory floodway during the base flood.Additionally,BFE increases of more than 1 foot would occur in areas of the 1%chance floodplain other than the regulatory floodway. In addition to the large BFE increases,the impacts from the encroachment required by Alternative 1.1 B41 42 include backing up floodwaters onto private properties in the middle of the Resurrection River floodplain. The eastern limit would expand as well toward Nash Road,potentially impacting private properties. Additionally,floodwater velocities generally increase,which could lead to erosion and embankment toe scour. Finally,the large BFE increases would result in a substantial quantity of material being needed to raise the runway embankment to the design crest elevation. If selected as the engineering preferred alternative,this design would likely face substantial permitting obstacles and requires modification to the effective FIRM and Floodway Map. Such an action would require a Letter of Map Revision(LOMR),which is FEMA's modification to an effective FIRM, or Flood Boundary and Floodway Map,or both. LOMR reviews take up to 90 days to process, are subject to an appeal period,and usually become effective within six months after they are issued(FEMA,2015a). The preparation of a LOMR request includes extensive hydrologic computations,hydraulic analysis,and regulatory requirements. Alternatives 2.2 and 3.0 do not require encroachment within the Regulatory Floodway, and will result in BFE increases of less than 1 foot. Impacts to private properties from the BFE increases are much smaller than with Alternative 1.1. When including the effects from coastal flooding, there would be only small impacts (increased inundation)to the private properties in the middle of the Resurrection River floodplain. Similarly,there would be a very small expansion of the eastern limit of the 100-year floodplain toward private properties along Nash Road between the Seward Highway and Resurrection Bay. The expansions would still be contained within the Salmon Creek Effective FIRM floodplain. Average velocity increases would be less than 15 percent, though larger local increases may occur near new embankments. However, either of these alternatives may still require a Conditional Letter of Map Revision (CLOMR). A CLOMR is FEMA's comment on a proposed project that would,upon construction,result in the modification of the existing regulatory floodway,the effective BFEs, or the Special Flood Hazard Area(FEMA,2015b). A CLOMR is required when proposed changes will cause any increase the BFE where a regulatory floodway has been identified. Consultation with FEMA,the City of Seward,and the KPB Floodplain Administrator is suggested to determine if a CLOMR is required for either Alternative 2.2 or 3.0. The following recommendations are based on the hydraulic analysis described in this report, as well as applicable local and FEMA floodway and floodplain regulations: 1. The engineering preferred design should be either Alternative 2.2 or 3.0. 2. In the future, long-term stockpiling of overburden and gravel in the channel or floodplain of the Resurrection River downstream of the Seward Highway bridges should be discouraged. 3. The recommended design water surface elevation for the Seward Airport Improvements project is the water surface elevation during the discharge with a 100-year(1% chance) return interval plus a two-foot freeboard. 4. The recommended design condition for erosion protection for the Seward Airport Improvements project is the discharge with a 100-year(1%chance)return interval. B42 r 37 A `Ii �• - - kit i . s ..`:"Litp c: ...' f • �. • i • •• t 4 ` • ALTERNATIVE 1 1 i E�? 100 Yr Floodplain weh coastal floors ng Cross section ., Parcel Lines EG Boundanaa r 2013 Effectne FIRM 100 pr Fioodplam rTZ 2013 Effectne FIRM Floodea,,Area Figure 15. 100-year flood map for Alternative 1.1. Alt 1.1-This design alternative raises the elevation of Runway 13/31 above the 100-year flood with a 2-ft freeboard. Both runways remain above the base flood elevation. The Alt 1.1 water surface elevations across the floodplain east of the runway are substantially higher than those of the EG model. Water surface elevation increases of greater than 1 foot occur from Cross-section D to Cross-section J. The maximum water surface elevation increase is 4.04 feet, and occurs at Cross-section F. The private parcels in the middle of the Resurrection River floodplain are completely inundated. At some areas of the 100-year floodplain between the Seward Highway and Resurrection Bay,the eastern limit has expanded. At Cross-sections D and E, the Alt 1.1 floodplain boundary is 70 feet to the east of the Effective FIRM floodplain (red line). At Cross- sections F and G, the Alt 1.1 floodplain boundary is 300 to 500 feet east of the EG model boundary (dark blue line). Though it is within the Salmon Creek Effective FIRM floodplain Zone AH, the Alt 1.1 water surface elevations of Cross-sections F and G are slightly higher(1-2 feet)than the FIRM base flood elevations there. At Cross-section K,the Alt 1.1 floodplain boundary is approximately 400 feet northeast of the EG model boundary, but still within the Salmon Creek Effective FIRM base flood and floodway boundary. See FIRM Panel 4544. B37 38 Ni * , i / '''''Nei bioe -:. N,%.4.44.). /4. 4 .\ . 0 r" • 11.1414'•' -' '' ' ' .74. P.' 4 • ' AO /7:: :.k.',l\l'i I I*'lk..sa./l. l•Par-4 1:M11L" .:-.,, / � ' :,1 � ,ram r ;. ,., ` -. . i 1' sty'� °� ;;& i 4' cm.I ‘,r ,, • :. 1, 1 ,$.1 ,,‘. tit. 0 , lI. ,- � - - - - - . - . 1 i' - _ - ------- -- -- Figure 16. 100-year flood map for Alternative 2.2. Alt 2.2-This design alternative reconstructs Runway 16/34 and raises the elevation with a 2-ft freeboard above the 100-year flood. Though Runway 13/31 is abandoned for active aircraft use, it is armored to prevent embankment erosion and channel migration. Water surface elevation increases of less than 1 foot occur from Cross-section F to Cross-section M. The maximum water surface elevation increase is 0.78 feet, and occurs at Cross-section F. The private parcels in the middle of the Resurrection River floodplain are partially inundated. At some areas of the 100-year floodplain between the Seward Highway and Resurrection Bay, the eastern limit has slightly expanded. At Cross-section F,the Alt 2.2 floodplain boundary is 160 feet east of the EG model boundary (dark blue line); a low spot in Cross-section G 200 feet east of the EG boundary is inundated. These locations are within the Salmon Creek Effective FIRM floodplain Zone AH; however,the Alt 2.2 water surface elevations of Cross-sections F and G are lower than the FIRM base flood elevations there. At Cross-section K, the Alt 1.1 floodplain boundary is approximately 400 feet northeast of the EG model boundary, but still within the Salmon Creek Effective FIRM base flood and floodway boundary. 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Page 5,paragraph 2 Demand is not expected to increase significantly in the near future as the This number does not include the many residents of the immediate surrounding area population(currently 2,754)is growing at a rate of less than 2%a year. who utilize Seward's services.The populations of the surrounding areas including Seward,Bear Creek, Lowell Point, , Primrose,Crown Point,Moose Pass,and ???? is 99999 The growth rate in the area as a whole is 9999 (Not sure if the small Crown Point Lawing Airport covers some of these areas in their estimation) Page 5,paragraph 2 Recent departmental improvements to the Seward Highway make the The Alaska Railroad does not operate in winter. In a situation in which the only access highway safer and reduce travel time to about 2 hours....Seward can also be road to town is closed,there are no practical alternatives for medical transport or accessed by the Alaska Railroad and by ship. community evacuation. Examples include .. Page 6,paragraph 2 Alternative 2.2 had more advantages and less disadvantages than the other Looking at the list,this is not immediately obvious.They both lost nearly identical two alternatives numbers of advantages and disadvantages. Were the categories weighted?Is there a scoring sheet?Who made this determination? Page 7,paragraph 2 Alternative 1.1 requires fill,as well as placement of riprap into the Is this private land even habitable as it currently stands?Assessed property values are floodway... As a result, flood water boundaries increased significantly on all very low for the parcels directly to the east of the airport. I don't know enough to properties east of the airport... affecting about 160 acres more understand if they are talking about properties further east where the floodway extends beyond the FIRM map or not. Please reference the 100-year Flood Maps. Page 7,paragraph According to FEMA,any fill into a floodway is to be avoided as it will This should not be a deal breaker. We are willing to wait longer for the right solution. 2,3 result in an increase to the Base Flood Elevation,stipulated on the FIRM This process is not as lengthy as DOT implies. map....This impact would require a LOMR process to revise the Flood Base Elevation on the FIRM map... This process in lengthy and will impact forth there project schedule and budget. Page 7,paragraph 3 Public approval may be difficult to achieve as the final result may be an Who? Most land unused. Likely not difficult increase in flood protection rates for affected property owners. Page 8,paragraph 4 FAA 1050.1 F Desk Reference also references factors to consider when "Unacceptable" is subjective. Unacceptable to who?Current land use and potential assessing impacts on a floodplain's natural and beneficial values. Most future use should drive this consideration. Even as things currently stand,the "affected" notably, "would the proposed action or alternative cause flow alterations properties are unusable. that would result in unacceptable upstream or downstream flooding?" Page 8,paragraph 7 Proposed actions that have a potential to result in impacts at or above these We accept these delays as a necessary part of the process. defined Significance Thresholds require preparation of an Environmental Impact Statement(EIS)... Preparation of an EIS would result in a significant delay in the project schedule. Page 9,paragraph 2 During agency scoping,ADNR requested that construction activities not Who determined it would be difficult?Difficult or impossible'? impact river navigation.This may be difficult due to the river's location next to the runway and the river diversion that will needed to place fill. Page 9,paragraph 3 Construction activities associated with Alternative 1.1, including placement Are there ways to mitigate these impacts?Who was present at this meeting,and are of fill below OHW level in the river will disrupt existing fish habitat... minutes available?Can the Fish and Game representatives expand upon their Alaska Department of Fish and Game stated at the Agency Scoping recommendations? meeting(March 2017)that they prefer Alternative 2.2,as it has less impacts on the fish. Page 9,paragraph 4 While federal standards allow the base flood elevation to increase up to 1 In this case, based on the minimal impact to usable land,the City of Seward will easily foot in a regulatory floodway...,the Kenai Peninsula Borough(KPB) issue the necessary flood permits. ordinance(Title 21,Chapter 21.06)does not allow any increase.Although the City of Seward is the flood permitting agency for this project,their regulations mimic the KPB's regulations...It may not be possible to obtain a flood permit. Page 9,paragraph 5 The Corps of Engineers(COE)is required to authorize the least The City of Seward and its residents do not consider the impacts of Alternative 2.2 on environmentally damaging practicable alternative. While Alternative 2.2 the wetlands and sensitive bird habitat to be insignificant. We would like this fact and affects more wetlands,the COE will consider another alternative if it is the public use of this space to be weighted heavily in the assessment of alternatives. more practicable. Page 9,paragraph 6 Current staff experienced difficulty this past winter just maintaining snow Could DOT contract with the city for snow removal and other maintenance activities to -Page 10, removal at the airport... There is not a manned maintenance station in reduce costs? paragraph 2 Seward which makes maintaining the airport more cumbersome... Elimination of Runway 13/31 and Taxiway 1 would reduce regular maintenance costs at the airport by about 25%. Page 10,paragraph Some [pilots]noted that occasional winter winds prevent them from using Winter storms are a likely time roads are unsafe and the need for an airport would be 3 Runway 16/34. greater. Page I I,paragraph The Seward Highway,the airport access road and the Alaska Railroad all These conditions already exist.They will be improved with Alternative 1.1. What is 2 bisect the center of the Runway Protection Zone(RPZ) for Runway 13. Both specific FAA guidance about allowability of roads and railroads?(I don't know enough rail cars and passenger vehicles currently penetrate the Approach Surface about aviation to know how big a safety concern this is) for Runway 31,creating a safety hazard.New FAA guidance indicates that all improvements, including railroads and roads,should he removed from RPZ,s whenever feasible.Selection of Alternative 1.1 does not improve this situation much. Raising the runway will reduce the penetrations but likely will not eliminate them.