EXH0255019189

v. ) SUR-REPLY ON MOTION FOR STAY s ) STATE OF WASHINGTON, ) (Section 401 Certification No. DEPARTMENT OF ECOLOGY; and ) 1996-4-02325 and CZMA THE PORT OF SEATTLE, ) concurrency statement, issued August ) 10, 2001, Reissued September 21, Respondents. ) 2001, under No. 1996-4-02325 ) (Amended-I)) ) Dyanne Sheldon declares as follows: 1. I _m over the age of 18, am competent to testify, and have personal knowledge of the facts stated herein. 2. Per the responses in the second declarations of Ecology staff (Stockdale) and Port consultants (Kelley), it is claimed that the need for pre-construction groundwater monitoring is being met and will provide sufficient detail to assure protection of water quality. Their conclusions are based on the Performance Standards contained within the N]Uv[P and the conditions of the 401 Certification {Stockdale ¶ 3,4; Kelley ¶3,6,7,8). However, the Performance Standards of the NRMP, HEI.SEI.L_ L[_ RachaelPaschalOd_m ZSO0Puget Sound Plaza Attorneyat I-=w 1325 Fourth Avenue 2421 Wast Mission Avenue DECLARATION OF DYANNE S_.DON IN Seattle,WA 98101-2509 Spokane,WA99201 SUPPORT OF ACC'S SUR-REPLY-_ _ _V AR 019189 as summarized by Kelley (110) provide virtually no quantifiable standard by which to measure whether groundwater parameters have been met. The Performance standard states, "Wetland areas with organic soils...wi/] hove soils saturated in the upper part (emphasis added) to mid-June in years of normal (emphasis added, see ¶ 3, below) rainfall." For the wetlands that have mineral soils, the Performance standard is stated as, "...soils saturated in the upperparl to mid-April in years…

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PSCAA Advisory Council Meeting Agenda
Add to CalendarMWednesday Mar 11, 9:00am - 11:35am
1904 3rd Avenue, Suite 105, Seattle, WA 98101
Call to order – Roll Call – Quorum Established – Land Acknowledgement We would like to acknowledge that our Agency operates in four present-day counties, which are the traditional lands of the Coast Salish people, past and present. This acknowledgement does not take the place of authentic relationships with indigenous communities in our jurisdiction and [...]