EXH AR006735: ACC’s Motion for Permission to File Overlength Reply Brief — PCHB Nos. 01-133 and 01-160

Notes

Motion filed October 8, 2001 by Airport Communities Coalition (ACC) via Helsell Fetterman LLP (Kevin L. Stock, WSBA #14541) before the Pollution Control Hearings Board (PCHB), State of Washington, in Case Nos. 01-133 and 01-160. ACC requests permission to file a 46-page overlength reply brief (exceeding the Board’s 30-page limit by 16 pages) in response to Respondents State of Washington Department of Ecology and Port of Seattle’s opposition to ACC’s Motion for Stay. Grounds cited include: Ecology filed a 26-page brief with 7 declarations (66 pages) and over 100 pages of exhibits; Port of Seattle filed a 30-page brief with 15 declarations (155 pages) and several thousand pages of exhibits. Also addresses issues relating to Section 401 Certification No. 1996-4-02325 and CZMA concurrency statement issued August 10, 2001, reissued September 21, 2001 as No. 1996-4-02325 (Amended-1). ACC consolidated its reply rather than filing separate responses that would have allowed 60 pages total.

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