October 20, 2002August 2, 2026

Declaration of C. Linn Gould in support of the Port Of Seattle’s response opposing ACC’s motion for stay

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C. Linn Gould, a risk assessor and soil scientist working for the Port of Seattle, declares under penalty of perjury in support of the Port’s opposition to the Airport Communities Coalition’s motion for stay. The declaration outlines Gould’s qualifications and professional role in developing fill criteria for the Third Runway embankment. Gould asserts that fill meeting the 401 Certification’s criteria will not adversely affect aquatic life or violate water quality standards near the Third Runway embankment.

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As the source for federal transportation grants, the Puget Sound Regional Council was charged with developing a system to meet the growing need for commercial aviation. When the search for a second airport failed, they authorized the Port of Seattle to build the Third Runway, with a mandate to develop a noise abatement and mitigation program. In their effort to stop the Third Runway, the ACC argued over every detail of the Port's efforts--including property buyouts and sound insulation. The dispute was meant to be settled by a three member Expert Arbitration Panel. This is their final report. It finds 2-1, that the Port's program was insufficient in several respects. Despite that, funding for the Third Runway was approved by the PSRC, and the 'Port Package' program, proceeded largely unchanged. Expert Arbitration Panel's final decision finding that the Port of Seattle had not shown sufficient reduction in real on-the-ground noise impacts to satisfy noise reduction conditions required for approval of a third runway at Sea-Tac International Airport. The majority decision concluded the Port's noise abatement programs were insufficient despite being impressive in scope.

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