EXH AR006548: Second Declaration of James C. Kelley, Ph.D. — ACC v. Ecology and Port Of Seattle, PCHB No. 01-133 / 01-160

Notes

Second Declaration of James C. Kelley, Ph.D., professional ecologist with Parametrix, Inc., filed in Pollution Control Hearings Board (PCHB) cases No. 01-133 and No. 01-160, Airport Communities Coalition (ACC) v. Department of Ecology and Port Of Seattle. Kelley addresses §401 Certification Condition D1g requiring bi-monthly wetland monitoring downslope of the Third Runway embankment fill at Seattle-Tacoma International Airport. Declaration argues Ecology’s September 21, 2001 revision deleting the ‘before construction’ monitoring requirement is scientifically justified because pre-construction hydrologic, vegetation, and soil data from downslope wetlands has been collected since February 2001, and twice-monthly groundwater monitoring in 2-inch PVC shallow wells began August 2001. Responds to objections by ACC wetlands consultant Amanda Azous (Azous Decl. ¶32) regarding hydrologic performance standards and drainage basin alteration. Cites Natural Resources Mitigation Plan Section 5.2.3, Conditions D1h and D1j, adaptive management, redoximorphic features, hydric soils, and wetland indicator plant species.

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