HomeMy WebLinkAboutResponse_to_Comments Apron A 0310161
March 1st 2015
Department of Community & Economic Development
City of Renton
1055 South Grady Way
Renton, WA 98057
Subject: Boeing Response to Muckleshoot letter regarding Apron A CI project Shoreline permit #
LUA16000028
To: Vanessa Dolbee Planning Supervisor
This letter provides responses to comments submitted in a letter (dated February 12, 2016) to
the City of Renton (the City) by Ms. Karen Walter, Watersheds and Land Use Team Leader, of
the Muckleshoot Tribe (the Tribe). The Boeing Company (Boeing) wishes to thank the
Muckleshoot Tribe for their comments and the City of Renton for the opportunity to respond to
those comments. Boeing has a record as a strong environmental steward and is committed to
incorporating conservation measures in all of its projects in order to minimize and avoid adverse
environmental impacts. That is true of the current Apron A project under review.
The comments from the Tribe can be categorized into the following three areas:
Concerns about the light impingement modeling results;
Concerns about increased predation on juvenile salmonids in the lower Cedar River
associated with light pollution. These concerns are based on extrapolations from the
results and recommendations reported in the Tabor et al. (2004) study to conditions
along the lower Cedar River adjacent to the Apron A project site; and
Mitigation measures to help reduce light pollution levels along the lower Cedar River to a
management goal of 0.1 lux.
Boeing will categorize its responses to the Tribe’s comments, accordingly.
Excerpts from the Tribe’s comment letter will be provided in italics and Boeing’s responses will
be provided below each comment in normal font.
Light Impingement Modeling.
2
However. the information provided in the modeling from the Casne Engineering Impingement
Study (December1, 2015) modeling and AMEC Stream Study (January 2016) both indicate that
the project lighting elements will increase the artificial light intensity along the affected lower
Cedar River areas by around I 00 to 400 percent depending on the location. Existing light
intensity in the lower Cedar River already exceeds the recommended goal from Tabor et al.
(2004) of 0.1I lux by a factor of 10 or more in the project area. For reference, 0.1 foot candle (fc)
is equal to 1.0764 lux (Ix). On that basis, we disagree with and do not understand how AMEC
can possibly conclude that:
"Even though the estimated light intensities from the modeling are higher than the
measured light intensities, the model clearly demonstrates that there should be no
significant change in light intensities on the LCR adjacent to the site under the proposed
plan."
The point that Boeing was trying to make when discussing the modeling results was that the
model demonstrated that there would be no statistically significant change in light intensities
along the west shore of the lower Cedar River after implementation of the proposed Apron A
lighting plan when compared to existing lighting conditions. The mathematical model used does
not measure or predict absolute light intensities but only measures differences in light intensities
between existing conditions and those conditions that may occur after the new lighting plan at
Apron A is built and activated. The model used by Boeing’s electrical engineering contractor is
calibrated in foot candles (fc), not in lux, and is not intended to predict absolute light intensities
along the lower Cedar River under all atmospheric conditions.
The modeling of existing conditions demonstrated a range of light levels between 0.1 to 0.5 fc
on the west bank of the lower Cedar River. Under the proposed lighting plan at Apron A
described in the Standard Stream Narrative and Habitat Data Report, the model demonstrated a
maximum light level of 0.6 fc along the west shoreline. A value of 0.1 fc greater than that
modeled under existing conditions, which is not a statistically significant increase under the
parameters used to run the model. A good lighting model can deviate anywhere from 5 to10%
from the actual install, with deviations on the higher side for low-level light samples, as is the
case for this project. Factors such as weather, time of day, and angle of the sample being
recorded (angle of incidence) can have an impact on the results, all within these tolerances.
Since the Standard Stream Narrative and Habitat Data Report for the 737 Max Flightline Utilities
– Apron A CI Project was submitted to the City, modifications have been made to the proposed
lighting plan. The original lighting impingement study submitted to the City on December 1, 2015
used a proposed lighting model based off of the original design review layout. Since then, the
lighting design has changed slightly, reducing the number of fixtures located east of the 05-440
(Super Cabana) building, helping further minimize artificial light intensity on the adjacent Cedar
River.
The light impingement model was rerun incorporating changes to the proposed Apron A lighting
plan. The revised lighting calculations, based on the updated design, show a reduction from a
maximum of 0.6 fc modeled under the original design, down to a maximum of .4 fc under the
revised design. This represents an overall reduction of 33% in light intensity from the original
design, as well as a decrease of 0.1 fc from the maximum light intensity modeled under existing
conditions. It should be noted that these results are not in addition to the existing light, rather
they are the calculated sum total of light in the area once the project has been completed. To
insure that these model calculations are accurate, follow up light samples will be collected at the
conclusion of the project.
3
The Standard Stream Narrative and Habitat Data Report will be revised to incorporate all project
design changes and the new light modeling results. The revised report will be re-submitted to
the City for review.
With its additional lights along the Cedar River as shown in the lighting study, will add another
0.6 fc of light intensity to an area that already exceeds the recommended goal from Tabor et al.
(2004) to reduce sockeye salmon predation. The proposed addition of0.6 fc from the project
significantly exceeds the 0.009 Ix recommendations.
This comment is incorrect. The results of original the light impingement modeling did not
demonstrate an additional 0.6 fc increase in light intensity from the proposed lighting plan, but
did demonstrate, as discussed above, that under the proposed lighting plan, the modeled range
of light intensities along the west shoreline of the lower Cedar River adjacent to the Apron A
project site was between 0.1 and 0.6 fc, 0.1 fc above the modeled existing maximum of 0.5 fc.
Again, discussed above, this does not represent a statistically significant increase above
existing conditions.
Under the revised lighting plan, the maximum modeled light intensity along the west shoreline of
the lower Cedar River will be 0.4 fc, a decrease of 0.1 fc from the modeled maximum of 0.5 fc
under existing conditions.
Light Pollution along the Lower Cedar River as a Cause of Increased Salmonid Predation
Existing light intensity in the lower Cedar River already exceeds the recommended goal from
Tabor et al. (2004) of O, I lux by a factor of 10 or more in the project area.
The Tribe cites the Tabor et al. (2004) study as justification for decreasing light intensities in the
lower Cedar River to reduce salmon predation. Although Tabor et al. (2004), under their
experimental field conditions, did demonstrate that direct lighting affected the behaviors of out-
migrant juvenile sockeye salmon (Oncorhynchus nerka) and resulted in increased predation by
cottids (Cottus spp.), their study did not demonstrate increased Salmonid predation throughout
the lower Cedar River, particularly in the lower Cedar River adjacent to the Apron A site. There
are no sources of direct lighting in the lower Cedar River adjacent to Apron A and Boeing is
aware of no studies that have been conducted in the lower Cedar River north of the Boeing
South Bridge that have examined increased Salmonid predation attributable to existing light
conditions along this reach of the river.
According to Tabor et al. (2004), direct lighting is intense lighting that occurs in a relatively small
area every night and usually all night. In contrast, reflected light and moonlight are not very
intense but they are spread over a much larger area and vary greatly with the weather and
moon phase. Direct lighting probably has strong localized effects on sockeye salmon fry,
whereas reflected lighting and moon light probably have weak effects over a large area. Which
of these has more overall effect on sockeye salmon fry is difficult to assess. However, it is much
easier to reduce direct lighting than to address reducing reflected light. Direct lighting can be
turned off, redirected, or shielded. Reducing reflected light would be a much larger and far more
difficult management objective. Tabor et al. (2004) also indicated that reducing light level
intensity can be beneficial for emigrating sockeye salmon and suggested keeping light intensity
below 0.1 lx (0.009 fc) would be a prudent management goal.
4
Tabor et al. (2004) discussed factors, other than light intensity alone that may affect Salmonid
predation:
The substrate type across the channel width may also have an important effect on
predation in a lighted area. Larger substrates will create a rougher river channel and
may have more abundant low-velocity locations for sockeye salmon fry. However, these
same sites will probably also have more large cottids. In riffles of the Cedar River, the
abundance of cottids larger than 50 millimeters (mm) total length (TL) was greatest in
areas with large substrates such as cobble (Tabor et al. 1998). At the 1-405 bridge site,
the substrate consisted primarily of cobble and large gravel; there we were able to
collect several cottids larger than 50 mm TL. At another lighted bridge site in the Cedar
River, however, the substrate was mostly small gravel, and few cottids larger than 50
mm TL were collected; thus, the overall predation at that site was probably minimal
(Tabor, unpublished data).
The lower Cedar River adjacent to Apron A ranges between 4- and 6-feet deep, depending on
the season and river discharge, and is a depositional zone with a substrate consisting of silty
sand. Vertical bulkheads occur along both banks of the Cedar River adjacent to Apron A. These
conditions are substantially different than those where Tabor et al. (2004) conducted their field
studies in 1999.
Tabor et al. (2004) described two of their study locations on the lower Cedar River as having
“high light intensity.” These were the Renton Public Library, which spans the lower Cedar River
(Figure 1) and I-405 Bridge (Figure 2). At the time of the field studies conducted by Tabor et al.
(2004) in 1999, both structures were equipped with lighting that resulted in direct light impinging
on the underlying Cedar River. The substrate of the Cedar River beneath the Renton Public
Library is composed of cobble (Figure 1), whereas that of the river beneath the I-405 Bridge is
coarse gravel and cobble (Figure 2).
5
Figure 1. Renton Public Library. Note lighting fixtures (circled), as well as the cobble substrate
of the underlying Cedar River
6
Figure 2. I-405 Bridge. Note lights beneath bridge (circles) and the cobble-gravel substrate of
the underlying Cedar River.
Nothing comparable to the lighting or habitat conditions at the Renton Public Library or the I-405
bridge exists in the lower Cedar River adjacent to Apron A. The nearest light fixture to the lower
Cedar River in the Apron A project area is located 48 feet west of the west shoreline of the
lower Cedar River that projects light to the west toward the Apron A project area and away from
the lower Cedar River.
Whether existing indirect light pollution along the lower Cedar River adjacent to the Apron A
project site is affecting juvenile Salmonid behavior or resulting in increased predation by cottids
or other fish predators is unknown.
Light Pollution Mitigation
Therefore, we strongly request that the City require that the project's lighting be further modified
in order to reduce the proposed artificial lighting impacts on the lower Cedar River. Importantly,
we note that unless done so, this project will undermine the success of the lighting reduction
plan associated with the City's proposed lower Cedar River dredging mitigation.
7
We believe that more can and must be done to meet both the project's needs for outdoor
lighting and to reduce impacts on salmon survival. We list some possible approaches below,
although lighting experts or firms with an interest in dark sky or wildlife-friendly lighting should
be consulted. You might contact Will Reed at Evluma in Renton for suggestions, although his
company specializes in outdoor programmable LED lights, I understand that he is
knowledgeable about wildlife friendly outdoor lighting. Examples to reduce lighting impacts
include:
Increase the shielding of fixtures to avoid stray light from reaching the shoreline and
night sky.
Reducing the height of poles.
Installing a dimming capability.
Limiting "on hours" to the minimum needed.
Further reduce wattage or light output.
While Boeing understands that the Tabor et al. (2004) study recommends a management goal
of keeping light intensities below 0.1 lux, a light intensity equal to that of a full moon, the goal of
the lighting design for the Apron A 737 MAC CI project is to not increase the intensity of light
impinging on the lower Cedar River. With the proposed revised lighting design for this project,
we are tracking to exceed this goal with a net reduction of artificial light on the adjacent lower
Cedar River
Additional efforts to help reduce light impingement on lower the Cedar River include the use of
directional, low-Kelvin temperature fixtures, which studies have demonstrated to not be visible
to animals that may be affected by light pollution, and the installation of lighting controls allowing
personnel to turn off general area lighting when not in use.
As reported in the Standard Stream Narrative and Habitat Data Report, Fong (2015) conducted
light impingement study, measuring light intensities along the lower Cedar River. As a result of
that study, Fong (2015) provided very specific mitigation recommendations as measures to help
reduce light pollution on the lower Cedar River adjacent to the Boeing Renton facility. These
recommendations were presented graphically in her report and included the following general
mitigation measures:
Reduce on hours for essential functions only;
Relocation of fixtures;
Re-aiming of fixtures;
Add shielding to existing fixtures;
Change fixture types to full cut-off equivalent;
Add dimming capability to fixtures;
Rotating fixtures away from Cedar River; and
Elimination of some fixtures.
Boeing will implement all of the mitigation measures as recommended by Fong (2015). These
mitigation measures will be implemented as a separate project that will occur in 2016 or 2017,
As stated and demonstrated in the Standard Stream Narrative and Habitat Data Report, light
pollution along the lower Cedar River is a regional issue, not just a local issue. Although Boeing
will implement all practicable mitigation measures that to help reduce light pollution along the
8
lower Cedar River, it will do so in the context of not endangering worker safety or interfering with
production goals.
As an aside, and unrelated to the Tribe’s comments, Larry Fisher of the Washington
Department of Fish and Wildlife (WDFW), in a letter addressed to the City of Renton ( dated
January 26, 2016), provided his comments regarding the measures taken by Boeing to insure
that the proposed Apron A project will not increase light pollution in the lower Cedar River. In
that letter, Mr. Fisher makes the following statement:
I am glad to see, based upon the information contained in the lighting impingement study
conducted for this project, that the City and the Boeing Company have already given this
issue serious consideration, and the project is designed in a manner to mitigate the
potential impacts of the lighting associated with the project on fish and wildlife resources
at the site.
While Boeing understands the Tribe’s concerns about potential light impingement from the
proposed Apron A project, the letter from WDFW demonstrates the agency’s satisfaction with
the measures already in place to insure that the project will not increase existing light pollution
in the lower Cedar River. A copy of the WDFW letter is provided as an attachment to this letter.
Again, thank you for the opportunity to respond to the Tribe’s comments. Should you have
additional questions or if you would like to discuss any of the above responses, please do not
hesitate to contact us.
Mark Clement
Renton & King County
Permit Specialist The Boeing Co.
206 617-2944
Mark Clement
Michael J. Sullivan
Boeing Facilities Engineer
MC 96-11
Desk: 425-965-2421
Cell: 206-617-5465
Fax: 425-965-2619
Michael J. Sullivan
9
References
Fong, D. 2015. Cedar River Electric Light Study. Prepared for the City of Renton, Washington
by Stantec, Lynnwood, Washington
Tabor, R.A., Brown, G.S., and Luiting, V.T. 2004. The effect of light intensity on sockeye salmon
fry migratory behavior and predation by cottids in the Cedar River, Washington. North
American Journal of Fisheries Management, v. 24, p. 128-145. http://rentonwa.gov
/uploadedFiles/ Living/CS/LIBRARY/Lower%20Cedar%20Light%20Tabor.pdf (accessed
November 24, 2015).