Notes
Declaration by Michael P. Witek filed in Pollution Control Hearings Board (PCHB) Case No. 01-160, Airport Communities Coalition (ACC) v. State of Washington Department of Ecology and Port of Seattle, in support of ACC’s response to motions to compel and limit entry. Document lists Exhibits A through S, including ACC’s November 26, 2001 Request for Entry upon Port Property, Port’s December 24, 2001 Objections, correspondence between ACC counsel and Port counsel dated December 12, 18, 28, 2001 and January 7, 8, 14, 16, 17, 2002, deposition transcripts of Kevin Fitzpatrick and Gordon White (January 16, 2002), emails obtained via Public Disclosure Act from Ann Kenny regarding Rod Thompson site visit and Dr. John Strand comments, Port’s Interrogatories and Requests for Production of Documents (November 9, 2001), and Port’s Answers and Objections to ACC’s Interrogatories. Related to Section 401 Certification No. 1996-4-02325 and CZMA concurrency statement issued August 10, 2001, reissued September 21, 2001. Filed by Helsell Fetterman LLP and Rachael Paschal Osborn.