Declaration of Mary L. Vigilante in Opposition to Plaintiffs’ Amended Motion for Class Certification

Bearse v. Port Of Seattle

Notes

Declaration by Mary L. Vigilante, President of Synergy Consultants, Inc., filed in King County Superior Court (Case No. 09-2-22569-9 KNT) in opposition to Plaintiffs’ Amended Motion for Class Certification in Bearse v. Port of Seattle. Vigilante, a 32-year environmental consultant specializing in airport noise and air quality studies, argues that aircraft emissions from Sea-Tac Airport’s Third Runway cannot be segregated from other pollution sources (automobiles, trucks, light manufacturing) on a class-wide basis, that noise contours (DNL) do not correlate with aircraft exhaust emission patterns, and that property-by-property analysis would be required to assess any emissions impact. The declaration addresses criteria pollutants, greenhouse gases, hazardous air pollutants, NEPA, EIS/SEIS for Sea-Tac Airport Master Plan, and disputes plaintiffs’ allegations of ‘toxic discharge and fumes’ at class members’ properties.

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