Declaration of Dyanne Sheldon in support of ACC’s sur-reply on motion for stay

Notes

Declaration by Dyanne Sheldon submitted to the Pollution Control Hearings Board for Washington State in support of the Airport Communities Coalition’s sur-reply on a motion for stay regarding Section 401 Certification and CZMA concurrency statement issued to the Port of Seattle. Sheldon critiques the Performance Standards in the NRMP as lacking quantifiable standards for groundwater monitoring and challenges the use of Wetland Indicator Status (WIS) ratings as a statistically valid measure for determining wetland impacts. She argues that relying on such qualitative parameters to assess post-construction wetland success constitutes poor science.

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