Notes
Declaration of Dyanne Sheldon (wetland ecologist) filed in PCHB Case No. 01-133, Airport Communities Coalition v. State of Washington Department of Ecology and Port Of Seattle, in support of ACC’s sur-reply on motion for stay of Section 401 Certification No. 1996-4-02325 and CZMA concurrency statement (issued August 10, 2001, reissued September 21, 2001 as Amended-1). Sheldon critiques the NRMP (Natural Resource Management Plan) Performance Standards and 401 Certification conditions as lacking quantifiable groundwater monitoring benchmarks — specifically the vague ‘soils saturated in the upper part’ standard for organic and mineral soil wetlands tied to undefined ‘normal rainfall’ years. Sheldon also challenges the Port of Seattle’s reliance on statistical analysis of WIS (wetland indicator status) ratings as scientifically unjustified, citing her personal participation in the original mid-1980s Pacific Northwest WIS rating exercise and her three-year review of a 500+ acre Puget Sound lowlands wetland monitoring program using the same methodology. References Kelley and Stockdale second declarations, 1987 Corps of Engineers Delineation Manual, facultative plant indicator status, and the Helsell Fetterman LLP legal team.