EXH0339021073

PCHBPollution Control Hearings Board of the State of Washington

v. ) IN SUPPORT OF ACC'S MOTION FOR ) STAY STATE OF WASHINGTON, ) DEPARTMENT OF ECOLOGY;and ) (Section 401 CertificationNo. THE PORT OF SEATTLE, ) 1996-4-02325 and CZMA concurrency ) statement, issued August 10, 2001, Respondents. ) Reissued September 21, 2001, under _lo. ) 1996-4-02325 (Amended-l)) GregWingard declares as follows: 1. The following is based on personal knowledge to which I am competent to testifybefore the Board. 2. I haveworked extensively on issues relatedto the SeaTacIuternationalAirport's NPDES permitsince 1994in my capacityas a consultant,atvarious times, to'CASE, the Cityof D_s Moine,, theAirportCommunitiesCoalition, and individual arearesidents,and in my capacityas the19 Executive Directorof Waste Action Project. This workhas includedreviewing NPDES pmmit zl applications,workingon NPDES permitappeals, reviewing of discharge monitoringreportsfi'om1994 to present,participatingin site inspections, including inspection of the airport'slistedNPDES z_ permittedoutfalls,site sampling activities, andphotographingof the site. My review of documents DECLARATIONOFGREGWINGARDIN HO.Sn,L_.-rt_ LLP XachaelPaschalOsbom SUPPORT OF ACC'S MOTION FOR STA'Y - 1 zs00 Pnset Sound Haza AttorneyatLmv ¢ 0 F_25 Fourth Avenue 2421 W_t Mission Aven_e fie, WA 98101-Z509 Spokane. WA 99201 AR 021073 included the Portof Seattle's 1996 Sec_on 404 application,which was laterwithdrawnin 1998, as well is the existing Section 401 c_n-tification-relatedmaterials. 3. As an environmentalconsultant for the past 18 yearsandin my capacityas Executive Directorof Waste Action Project since 1994, Ihave thoroughlyreviewed well over three hundred s e Departmentof Ecology NPDES permit files andbecome very familiarwith Ecology's administrationof 7: the NPDES program,includingpublic comment processes. 4. I have also become veryfamiliarwith the PublicDisclosure Act, and Ecology'sprocedures forrespondingto public recordrequests. I have submittedmanyrequeststo Ecology under…
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