October 10, 2001August 2, 2026

Declaration of Andrea Grad in support of ACC’s opposition to Ecology’s motion to strike attorney-client privileged documents

Notes

Andrea Grad, a paralegal with Helsell Fetterman LLP representing the Airport Communities Coalition, declares that she submitted public disclosure requests to the Washington Department of Ecology regarding the Port of Seattle’s third runway applications. She describes how, after Ecology issued its Section 401 certification decision on August 10, 2001, she requested previously withheld deliberative documents and received them, including the Ray Hellwig notes that are the subject of Ecology’s Motion to Strike. She asserts that Ray Hellwig’s declaration supporting the Motion to Strike is incomplete because it omits this voluntary disclosure.

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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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