THE NORTHWEST SEAPORT ALLIANCE MANAGING MEMBERS Item No. Date of Meeting December 5, 2017 · 2017. 11. 30. · THE NORTHWEST SEAPORT ALLIANCE MEMORANDUM The Northwest Seaport Alliance

THE NORTHWEST SEAPORT ALLIANCE

MEMORANDUM

The Northwest Seaport Alliance

MANAGING MEMBERS Item No. 4A

ACTION ITEM Date of Meeting December 5, 2017

DATE: November 16, 2017

TO: Managing Members

FROM: John Wolfe, CEO Sponsors: Jason Jordan, Director Environmental Programs and Planning

Stephanie Jones Stebbins, Managing Director, Maritime, Port of Seattle

Project Managers: Deanna Seaman, Senior Manager Water Quality, and

Jane Dewell, Maritime Stormwater Program Manager, Port of Seattle

SUBJECT: Briefing on NWSA, Port of Seattle and Port of Tacoma’s Stormwater Programs

A. BRIEFING REQUESTED

The Northwest Seaport Alliance (NWSA) and Port of Seattle staff will provide an overview of the ongoing stormwater program, recent successes, and our priorities for next year.

B. BACKGROUND

The Port of Tacoma and Port of Seattle (ports) consolidated marine cargo business operations in 2015. In 2014, Port of Seattle (POS) embarked on formation of a Stormwater Utility for all POS property, activated the Marine Stormwater Utility in 2015, and completed an Inter-local Agreement (ILA) with the City of Seattle in 2016. POS has an Industrial Stormwater General Permit and a Phase I Municipal Separate Storm Sewer permit. Properties within the POS hold other, general and individual stormwater permits.

In 2013, The Port of Tacoma (POT) entered into an ILA with the City of Tacoma concerning stormwater fees and other related considerations. POT holds its own Phase I municipal separate storm sewer system (MS4) permit. POT has industrial and other (boatyard, individual) stormwater permits held by POT and by tenants.

As NWSA has continued to form and refine the Master Policy, the two ports’ stormwater programs have been discovering areas of overlap and coordination as well as areas where actions are unique and separate. All of these program elements are coordinated between the three organizations, two ports and NWSA, to support their common strategic, economic and environmental priorities.

Stormwater Programs Briefing December 5, 2017 Page 2 of 12


C. STORMWATER PERMIT DESCRIPTION

The goal of the Clean Water Act is to protect waters of the state to ensure fishable, swimmable, and drinkable water. The work our customers and we do on the land potentially impacts water quality, and stormwater conveyance is a potential pollutant pathway.

Compliance with stormwater permits, also referred to as National Pollutant Discharge Elimination System (NPDES) permits, is a challenge for tenants of NWSA, Port of Tacoma, and Port of Seattle. The permit encompasses many and complex obligations, the deadlines are tight, and regulatory challenges can arise quickly.

The Washington State Department of Ecology’s (Ecology) mandate under the Clean Water Act includes industry sector NPDES general permits. There are many sector permits. The Ports and NWSA deal with three main types: Phase I Municipal Stormwater Permit, Industrial Stormwater General Permit, and Construction Stormwater General Permit.

NPDES general permits have a 5-year cycle. The MS4 permit extends through mid-2019, and the ISGP permit through late 2019. In addition, Ecology is revising the 2012 Stormwater Management Manual for Western Washington (amended 2014), and there is now opportunity for both Ports and the NWSA to submit comments on these regulatory documents.

Phase I Municipal Stormwater Permit

Urban areas that collect stormwater runoff in municipal separate storm sewer systems (MS4s) and discharge to surface waters are required to have a permit under the federal Clean Water Act. Typically, cities, counties and special purpose districts are subject to this permitting program. Ecology considers the Ports of Tacoma and Seattle as large discharge contributors to state waters and decided to specifically include the ports in the MS4 permit program. The ports do not have the same responsibilities as the cities and counties nor do ports have enforcement or code writing obligations. This is a port-wide permit; every parcel owned by the ports is subject to the terms of this permit. Those parcels with tenants who perform activities that trigger the industrial stormwater general permit are additionally subject to ISGP terms.

The MS4 permit requires the ports to develop a Stormwater Management Plan and Program (SWMP) that includes the following elements:

Education program for port staff and tenants.

Public involvement and participation: Solicit public review of its SWMP. Make the latest updated version of the SWMP available to the public.

Illicit Discharge Detection and Elimination (IDDE): a program to detect, remove and prevent illicit connections and discharges, including spills, into the municipal separate storm sewers owned or operated by the Port.

Mapping of all outfalls, land uses, tributary conveyance and associated drainage areas with 8” or larger diameter pipes and equivalent cross section of open channels.

Stormwater source control during construction.



Minimum technical requirements for development and redevelopment: if the size of a development project exceeds specific parameters, long-term stormwater treatment must be implemented.

Operations and Maintenance Program for all stormwater treatment and flow control devices, and catch basins to ensure that Best Management Practices (BMPs) continue to function properly.

Source Control in existing developed areas: Stormwater Pollution Prevention Plans (SWPPPs) are required to be implemented for all port-owned lands (POS and POT).

Annual monitoring program implementation and reporting.

Annual Reports which include the Stormwater Management Program update must be submitted to Ecology and posted on the Port’s website.

Monitoring: permittees have the option of not conducting stormwater monitoring at port sites for the MS4 permit but rather pay into a Stormwater Action Monitoring program that is coordinated by Ecology. These funds are used to study regional water quality, stormwater treatment, and source control issues. Both ports contribute to the Ecology monitoring program.

Construction Stormwater General Permit

Construction site operators are required to be covered by a Construction Stormwater General Permit (CSGP) if they are engaged in clearing, grading, and excavating activities that disturb one or more acres and discharge stormwater to surface waters of the state.

The CSGP requires weekly monitoring for turbidity, weekly inspections, and monthly reporting to Ecology. The contractor or owner is also required to develop and implement a SWPPP to ensure erosion and sediments are controlled during construction. On average the ports manage approximately six of these per year; typically the ports apply for the permit, transfer it to the contractor at the start of work, and monitor contractor activities for compliance.

Industrial Stormwater General Permit

Facilities that engage in industrial activities and discharge stormwater to surface waters of the state are subject to the Industrial Stormwater General Permit (ISGP). The current permit started in 2015 and expires December 31, 2019. The permit is typically renewed every five years. The permit can be terminated when the operator either stops operating or stops performing the specific activities that trigger the permit.

The ISGP requires the operator to develop a SWPPP that includes implementation of the following BMPs and other conditions:

Operational Source Control BMPs such as good housekeeping, preventative maintenance, cleaning catch basins, jetting lines, sweeping, spill control and placing drip pans and spill kits in visible locations.

Structural Source Control BMPs such as secondary containment, closed lids on dumpsters, storing materials inside buildings, covered washing and maintenance areas.



Treatment BMPs such as oil water separators, filtration systems, and chemical treatment systems.

The ISGP permit, which affects the container terminals and many other tenants, requires quarterly stormwater monitoring. Washington monitoring requirements are stringent compared to Oregon and California, which are significantly more stringent than other states in the U.S. This can put the ports and NWSA at a competitive disadvantage with Ports elsewhere that have less stringent requirements.

There are two basic elements of ISGP monitoring: meeting ‘benchmarks,’ and if exceeded, addressing corrective actions. Benchmarks are not water quality criteria, but serve as an indicator that water quality may be impacted if the discharges contain pollutants above the established benchmarks.

Zinc and copper are two important pollutants for Pacific coast states due to the detrimental effect both copper and zinc have on our endangered salmon, including increased mortality, erratic behavior, and developmental abnormalities. Washington’s zinc and copper limits are lower than both Oregon and California (Table 1). Sources of copper include vehicle brake pads, electrical wires, plumbing materials, fertilizers, wood preservatives, and anti-fouling paints on boats to name a few. Sources of zinc include tires, roofs, fences, light poles, other galvanized steel, and anti-corrosion paints.

Table 1. ISGP Monitoring Benchmarks

Pollutant WA Benchmark OR Benchmark CA Action Limit

Zinc 117 µg/L 120 µg/L 260 µg/L

Copper 14 µg/L 20 µg/L 33.2 µg/L

Turbidity 25 NTU 50 NTU 100 NTU

If benchmarks are not met, specific Corrective Actions are required until benchmarks are achieved:

Level 1 Corrective Action – additional operational source control BMPs, such as sweeping, implemented within 14 days of lab results. Implemented with every occurrence above benchmarks, these are actions an operator does to prevent pollution.

Level 2 Corrective Action – additional structural source control BMPs, such as covering storage areas, implemented no later than September the year following the exceedance. Implemented when two consecutive quarters above benchmarks. These are projects the operator completes to physically separate pollution from stormwater.

Level 3 Corrective Action – additional treatment BMPs implemented no later than September of the following year. Implemented when three consecutive quarters above benchmarks. Adding stormwater treatment, such as Chitosan or modular wetlands, may require significant capital expenditures to retrofit existing facilities with treatment.

Washington is more stringent than both Oregon and California in escalating through Corrective Action Levels. Under the Washington permit, facilities have the potential to go from being in compliance to a Level 3 corrective action in less than one year.



In California exceedances are based on the average of all sample results for the reporting year, which allows more time for adaptive management and confirming effectiveness of efforts. In Oregon, while Corrective Action Level 1 would be initiated following the first quarter of exceeding a baseline, the permittee is allowed three years before a Corrective Action Level 2 must be implemented.

This lack of uniformity between states is a huge challenge for businesses, and affects Washington Ports’ competitiveness. Our gateway competes with ports in states with far less protective standards. We have the challenge of meeting these standards and helping our customers meet these standards; all while creating and maintaining family wage jobs.

D. PORT OF SEATTLE PROGRAM

Century Agenda

The Port of Seattle established a Century Agenda for the 21st century with a focus on stewardship of the Port’s natural resources. The strategies to achieve this include positioning Puget Sound as an international logistics hub, advancing tourism, promoting small business and work force development, and to ‘be the greenest and most energy efficient Port in North America.’ A specific objective includes to ‘…meet or exceed agency requirements for stormwater leaving facilities owned or operated by the Port.’

Stormwater Program

The Port of Seattle holds a Phase I MS4 permit, with about 34% or Port properties falling under the MS4, with 65% under ISGP permits, and 1% under other stormwater permits (i.e., boatyard, individual). The SWMP is updated annually, and operation and maintenance guidance, BMP fact sheets, IDDE brochures, and other documents and training for Port staff and tenants help to provide guidance and support meeting the MS4 permit obligations. With environmental and marine maintenance staff working together to meet or exceed permit requirements. Requirements include City of Seattle stormwater codes and are outlined in numerous manuals. Information from state and city requirements is incorporated into SWPPP documents for all Port properties under the MS4 permit.

Marine Stormwater Utility

The Port of Seattle’s Marine Stormwater Utility (Utility) was formed in 2014 to enable the Port to provide services, facilities, systems, and programs for surface water and stormwater management and pollution control. A benefit of Utility work is water quality protection in the Puget Sound. The Utility collects stormwater fees from the Port, NWSA, and tenants, and reinvests the income into maintaining and upgrading the stormwater conveyance infrastructure. The upgrades are not associated with treatment for industrial activities, which would typically be a tenant’s responsibility. Prior to creating the utility, most of the stormwater fees paid by the Port and its tenants were diverted from the Port’s properties to address City of Seattle priorities. Progress goals for assessing and rehabilitating the Port’s stormwater infrastructure are shown in Table 2.



Table 2: Port of Seattle Marine Stormwater Utility Goals

Year Assess

(%) Rehabilitate

(%) Miles of Pipe Rehabilitated

2016 15 6 5

2017 30 12 9

2018 75 18 14

2019 100 24 19

2020 30 23

2025 45 35

2030 60 47

Century Agenda Goal – 2035

75 59

The Utility Charter included rates for 2015 through 2017. Rates for 2018 were approved by the Port Commission on November 14, 2017. The rates apply to all Port-owned maritime property, which includes land managed by the NWSA. Tenants pay stormwater fees based on the area of their leaseholds. The stormwater fees for the remaining unleased land are paid by the operating business. The operating business is either the NWSA or the specific Port business unit that oversees the unleased property.

Rates for the Marine Stormwater Utility have been lower than those for the City of Seattle. As a comparison, rates in the City of Tacoma are significantly lower than both Seattle and the Port’s Utility. A comparison of the 2018 stormwater utility rates is shown in Table 3.

Table 3: 2018 Stormwater Utility Rates for Seattle and Tacoma, WA

Stormwater Rate Category City of Seattle Port of Seattle City of Tacoma*

Undeveloped (0 - 15% Impervious) $37.60 $32.69 $0.28 (+ $7.65)

Light (16 - 35% Impervious) $57.44 $50.55 $0.87 (+ $7.65)

Medium (36 – 65% Impervious) $82.86 $73.42 $1.21 (+ $7.65)

Heavy (66 – 85% Impervious) $109.16 $98.51 $1.74 (+ $7.65)

Very Heavy (86 – 100% Impervious) $130.77 $116.52 $2.33 (+ $7.65)

*Notes: Rates are shown as $/1,000 square feet of area. Tacoma has waterfront and non-waterfront rates, and calculates per 500 square feet of area. The rates in this table are waterfront, which are lower than non-waterfront x 2 to correspond with the City and Port of Seattle. Tacoma also has a monthly fixed fee, shown in parentheses.

All money collected by the Utility must be spent on stormwater expenses. To date, $1.8 million has been committed and spent on capital for equipment to get the Utility up and running. Additionally, approximately $5.7 million has been spent on expense activities, primarily



performing the assessments to obtain baseline data, urgent repairs, and administrative costs in operating the Utility. Other efforts include billing and policy creation, and working with the City of Seattle on the ILA. There is an additional $6 million committed for capital works through 2021, and about $7.5 million projected to complete the assessments by 2019, as well as additional administrative costs.

Port of Seattle Successes

Marine Stormwater Utility Progress: Overall, 30%, or over 23 miles, of stormwater system assessment has been completed as of October 30, 2017. An additional 9.5%, or over 7 miles, has been rehabilitated, including a dozen urgent repairs of fully collapsed pipe. The majority of the assessment work has occurred on T5 (about 76% or 62,000 ft) and T18 (about 60% or over 50,000 ft). The remaining assessments have occurred where needed, such as T46 and T91, due to other Port and NWSA priorities. The plan for 2018 is to complete the assessments on NWSA-managed properties and continue progress on Port properties according to business needs.

AAPA 2017: The Port of Seattle applied for and was awarded the American Association of Port Authorities’ (AAPA) environmental recognition for formation and operation of the Marine Stormwater Utility. The Utility is a practical yet creative solution to the issue of rising costs for stormwater management and is the first of its kind in the port industry. Prior to establishing the Utility, the Port paid the City stormwater drainage fees that reached nearly $4 million in 2014, were rising annually at 10%, and the Port received no return on investment. The Utility now collects and uses these fees from Port tenants and business units, resulting in a zero net cost to the customers.

E. PORT OF TACOMA PROGRAM

Strategic Plan

The Port of Tacoma developed performance goals and expectations of its CEO for 2017. Environmental Stewardship included site clean ups and return to economic performance, habitat mitigation plan implementation, and a Maritime Industrial focused Environmental Stewardship Sustainability Program. In the stormwater arena, the goals included tenant outreach and assistance, permit compliance, and infrastructure mapping.

Inter-Agency Agreement with City of Tacoma

In 2013, the Port of Tacoma entered into an inter-agency agreement (IAA) with the City of Tacoma regarding the municipal separated storm sewer system. The purpose of the IAA was to provide a cooperative framework for coordination by the Port of Tacoma and the City of Tacoma to eliminate barriers to compliance with the terms of their respective Phase 1 stormwater permits.

The benefits of the IAA from a Port of Tacoma / NWSA perspective include a permit review agreement, spill response coordination, access to City of Tacoma’s Certified Wastewater Laboratory, and coordination with City of Tacoma on the MS4 infrastructure in the Tideflats. Further, the IAA sets a fee reduction for properties that directly discharge to the water without running through City infrastructure.



The Port of Tacoma manages six ISGPs and the MS4 Program. Staff retain a “hands on” approach with customers helping find solutions to compliance issues. As customers request assistance, staff provide source control evaluations, pilot projects, and downspout treatment boxes. Staff highlight BMPs, permit strategies, and upcoming changes to permits. The Port of Tacoma, via NWSA currently manages 6 Industrial Stormwater Permits for the following sites:

Table 4: List of Permits managed by POT / NWSA

Permitted Facility 2017 Permit Status

East Blair One Terminal This site meets benchmarks

Maintenance This site is currently in consistent attainment. It has a media filtration unit installed.

OCT The site has installed treatment and we continue to improve the system. We are not yet at consistent attainment.

SIM This site has a membrane filtration system for solids and is now in consistent attainment.

NIM/T7 We have treatment installed and like OCT, continue to improve the system to achieve consistent attainment. The North end of NIM is meeting benchmarks.

West Sitcum Terminal (formerly APMT)

We are installing treatment on a voluntary basis to ensure the successful operation of our new tenant. Construction will be complete in 2019.

F. NORTHWEST SEAPORT ALLIANCE PROGRAM

Budget Summary

Table 5: Budget Summary

Project Element Cost

Municipal NPDES Permit $375,000

NWSA Industrial NPDES Permit $541,000

POT Industrial Permit Management $14,000

Hylebos Water Way Source Testing $42,000

Policy, Strategy, and Future Focus Initiatives $138,000

Total $1,110,000

Strategic Plan & Dashboard

The purpose of the strategic plan is to focus resources and staff on priority activities that have

a direct positive impact on water quality. The primary focus has been on tracking number of

NWSA managed acres implementing source control and treatment each year. This year, the

goal was 50 and we have exceeded that goal with 96 acres under source control and treatment.

In 2018, we will place another 75 acres under source control.



Collaboration

The NWSA has a number of projects with the Ports of Seattle and Tacoma that demonstrate the significant collaboration between these partners.

North Harbor

T5 Pilot and Modernization Projects: Both Tacoma and Seattle have had great success with downspout treatment units on roof drains, which help to reduce contaminants flowing to industrial properties. Seattle’s downspout treatment system consists of oyster shells in a blue barrel, and Tacoma uses compost, gravelly sand and biochar in a cubic yard box. Both of these systems are installed at the Transit Shed at T-5 with a goal of evaluating performance, determining best media mix, and evaluating break through curves for the media (i.e., how long until the media needs to be replaced).

The Terminal 5 modernization project provides improvements necessary to serve newer, larger vessels, including crane rail strengthening, berth deepening, slope stabilization, electrical supply/distribution upgrades, new fender system and structural rehabilitation of the dock. This is in support of future terminal tenant at T5. Stormwater improvements at T5 will be developed once a tenant is secured for the facility, and will address any regulatory requirements associated with the type and extent of operations at the terminal.

T46 Treatment System Upgrade: Under the T46 lease amendment, the Port is obligated to construct a stormwater treatment system that meets current stormwater standards in conjunction with Lessee’s implementation of operational best management practices. Total Terminals International LLC was required to have stormwater treatment installed and operational at T46 no later than September 30, 2014, to meet ISGP Level 3 Corrective Action. Ecology approved a request to extend the completion date to June 30th 2015. The work includes removing existing manholes and connecting pipes, and installing stormwater treatment systems at three outfall locations. Three Upflo stormwater treatment systems were installed in 2015;. The systems are currently being fine-tuned with the support of NWSA staff to function better with operations at T46. In October 2017, the stormwater monitoring results for copper and zinc met benchmarks following system improvements, which was a significant milestone for the treatment system.

T18 Tenant Assistance and Upgrades: The T18 tenant, SSA, is under an agreed order with Ecology to provide stormwater treatment. The tenant completed Phase I of the treatment installation in the fall of 2016 and is currently designing Phase II of the stormwater treatment system. The construction of Phase II will commence in spring 2018 and will treat the stormwater from 47 acres. Once Phase II is complete, approximately 134 acres will have end-of-pipe be treatment. If required by Ecology, Phase III will be designed during 2019 and installed in 2020.

In coordination with the T18 stormwater treatment work, the Marine Stormwater Utility is replacing outfalls at T18. This project will rehabilitate 13 outfalls that discharge into the East Waterway, and will be conducted over the next 4 years. The repair of outfalls will be coordinated with both the tenants’ stormwater treatment project and their terminal operations.



South Harbor

West Sitcum: NWSA staff and POT Maintenance successfully installed enhanced catch basin inserts and downspout treatment boxes throughout the 135 acre terminal in advance of an engineered treatment system next fall. The early testing results show a pollutant load reduction of 50% in conjunction with the new tenant’s stringent application of best management practices and source control efforts.

East Sitcum terminal will include retrofitted proprietary vaults. The facility continues to struggle meeting benchmarks which required upgrades to the current treatment system. POT re-designed the vaults, installed bulk media and preliminary results show the site now meeting benchmarks. This will be migrated to all similar vaults on Terminal 7.

Kaiser (Parcel 77): This redevelopment site will have new stormwater infrastructure installed in support of its proposed use as auto processing facility. .It will reuse existing site features to minimize stormwater management costs.

NWSA Successes

The NWSA has enjoyed successes in 2017. California Stormwater Quality Association recognized our log yard treatment system as an innovative solution for chemical oxygen demand. We were the only non-California facility recognized. We successfully helped T-46 retrofit their treatment system such that the terminal now meets benchmarks. We have met with 35% of our tenants this year and provided direct assistance with either the ISGP or the MS4 requirements.

Stormwater Working Group: NWSA has created Stormwater Working Groups in both the Seattle and Tacoma harbors with the intention of sharing lessons learned and best management practices that have worked at the Port and for customers. Staff have seen our customers share some great lessons learned at these meetings and, when surveyed, our customers placed a high value on these meetings and the FAQ we have built on the NWSA website. Staff held a “Do it yourself” Stormwater and Environmental Workshop in the parking lot of the Fabulich Center and had four terminal operators and five support business customers from both Seattle and Tacoma attend.

Ecology Workgroups: NWSA staff work with agency workgroups to coordinate responses to new permit language. Staff participate with the MS4 group, ROADMAP, Communities of Interest, Stormwater Workgroup, and others to stay informed of potential changes to permit language, guide language where we can to ensure language we can comply with, and learn from other permit holders their compliance strategies.

Tenant Outreach: The Port of Seattle each year meets with at least 20 % of MS4 tenants to review SWPPPs, provide input and information sheets on best management practices, and address question and training needs. This year, Port of Tacoma has met with 35% of its tenants and have met all of the Alliance Customers.



Best Management Practices Book Collaboration: NWSA is working with the Center for Urban Waters, University of Washington Tacoma team to collaborate and organize our data. We want to know best practices by terminal operation type – e.g. what works on a straddle carrier (grounded) type operation versus what works on a crane to chassis (wheeled) operation. This future goal includes development of a BMP “Play book” that has the designs and media recipes for the treatment systems on each of these terminal types that are meeting benchmarks.

Working with Real Estate: staff has been working to eliminate zinc where it can. We have been collaborating with POT/NWSA Real Estate to change lease language with the goal of managing galvanized surfaces to prevent zinc leaching, replacing old fencing with coated fence, and considering non-galvanized building materials when building new buildings. The Port of Seattle developed a flyer for tenants and business units to help reinforce this message in early planning when making construction materials decisions.

G. FUTURE FOCUS

New Acreage under Source Control

The NWSA’s CEO Scorecard has environmental metrics. One of these is counting the number of new acres with source control or treatment systems installed. The goal for 2016 of 50 acres was surpassed with 78 acres with new treatment or source control. In 2017 the goal was 53 acres and thus far we have placed 92 new acres under source control or treatment.

Pro-active Tenant Outreach

Once a tenant has triggered a level three corrective action requirement, the timelines are tight. NWSA staff have determined a good approach is to talk directly with tenants when they have their first exceedance to ensure the next six months are spent in steady improvement rather than ending with a level three corrective action requirement. If an operator does appear to need treatment to meet benchmarks, connecting with him early increases the response timeline and creates the time to engineer a good solution rather than a fast one.

Coordinated Regulatory Review

There will be opportunities in 2018 and 2019 to comment on Ecology’s proposed changes to stormwater permits and documents, especially the ISGP, MS4, and Stormwater Management Manual for Western Washington. The two ports and NWSA will conduct their own analyses of permit impacts to tenants and business units, and prepare comments, if appropriate, to share with the state regulators. During these public comment opportunities, we will share findings and coordinate responses to benefit both ports and NWSA.

Green Marine

Green Marine environmental program is a voluntary certification that provides a detailed framework for North American maritime companies and organizations to establish and reduce their environmental footprint. Participants range from ship owners, ports, seaway corporations, terminals and shipyards and are required to show year over year improvement.



The Green Marine program relies on an evolving list of performance indicators such as spill prevention, environmental leadership, and community impacts. Each indicator is ranked from 1-5. Level 1 constitutes the monitoring of regulations while level 5 indicates leadership and excellence. The program relies on annual self-evaluations with independent third party verification every two years. The process is highly transparent as results are made public each year.

The Port of Seattle completed its 5th self-evaluation in 2016 and has continued to show improvement. POS staff is currently working on advancing our performance for the 2017 cycle. POT/NWSA completed its first self-evaluation in 2016 and is working on advancing its performance in the 2017 cycle.

H. NEXT STEPS

The two ports respond to identical permits in unique ways. Both approaches are guided by the unique regulatory environments of City relationships, Ecology regions, and stakeholder communities. This means that the two ports will continue to successfully collaborate. The programs by which permits are managed will continue to be substantially different. As the regulatory environment and stakeholder relationships change, the two programs will continue to adapt to provide the best service for customers and stakeholders in each harbor.

I. ATTACHMENTS TO THIS REQUEST

Computer slide presentation.

Documents

THE NORTHWEST SEAPORT ALLIANCE MANAGING MEMBERS Item No. Date of Meeting December 5, 2017 · 2017. 11. 30. · THE NORTHWEST SEAPORT ALLIANCE MEMORANDUM The Northwest Seaport Alliance