Notes
Declaration by Michael P. Witek of Helsell Fetterman LLP filed in Pollution Control Hearings Board Case No. 01-160, Airport Communities Coalition (ACC) v. State of Washington Department of Ecology and Port Of Seattle, in support of ACC’s Motion in Limine. Concerns Section 401 Certification No. 1996-4-02325 and CZMA concurrency statement issued August 10, 2001, reissued September 21, 2001. Attaches Exhibits A-F including: list of untimely plans and reports offered by Port and Ecology; transcript pages 9-29 from October 15, 2001 pre-hearing conference; email from Port Counsel re ‘Third Runway and Embankment Fill Water Quality and Transport Analysis’; transcript pages from February 12, 2002 deposition of Michael Riley; January 21, 2002 Technical Memorandum on wetlands by James Kelly of Parametrix submitted to Army Corps of Engineers January 25, 2002 (obtained via FOIA request March 7, 2002); and Port’s November 15, 2001 letter to PCHB re Plans and Reports Prepared Pursuant to Section 401 Certification. Third Runway Project, water quality, wetlands, CZMA, Clean Water Act.