Notes
Declaration by Dyanne Sheldon filed in PCHB Case No. 01-133 (Airport Communities Coalition v. State of Washington Department of Ecology and Port of Seattle) in support of ACC’s sur-reply on motion for stay of Section 401 Certification No. 1996-4-02325 and CZMA concurrency statement. Sheldon challenges the adequacy of NRMP Performance Standards and 401 Certification conditions for pre-construction groundwater monitoring, arguing the standards — including soil saturation benchmarks for organic and mineral soil wetlands in ‘normal rainfall’ years — are imprecise and unmeasurable. She critiques the use of Wetland Indicator Status (WIS) ratings of Pacific Northwest plants as a statistically valid performance measure, noting she participated in the original mid-1980s WIS rating exercise and that facultative plant ratings (33-67% probability) do not constitute rigorous quantitative science. References Stockdale and Kelley declarations, the 1987 Corps of Engineers Delineation Manual, and a 500+ acre Puget Sound lowlands wetland monitoring program.