EXH 346: First Interrogatories & Requests for Production to ACC — Answers & Responses (PCHB No. 01-160)

This document contains interrogatories and responses from a Pollution Control Hearings Board case (PCHB No. 01-160) in which the Airport Communities Coalition (representing cities near Sea-Tac Airport, including Burien) appealed against the State of Washington Department of Ecology and the Port of Seattle regarding a 401 Water Quality Certification for the Third Runway Project. It includes lists of expert witnesses and their prior testimony histories covering topics such as hydrology, stormwater, and environmental impact, as well as objections to broad document production requests related to the Third Runway Project.

Notes

Port Of Seattle’s First Set of Interrogatories and Requests for Production directed to Airport Communities Coalition (ACC), PCHB No. 01-160, with ACC’s answers and responses thereto. Document includes expert witness testimony histories for Dr. Peter Willing (Water Resources Consulting, Inc.) covering cases including Watershed Defense Fund v. Whatcom County Water Dist. No. 10, San Juan County Hearing Examiner proceedings (1997-1999), and PCHB Nos. 93-320, 94-7, 94-11; and Dr. Patrick Lucia (approximately 40 expert witness appearances in 15 years). Also covers ACC response to Request for Production No. 3 regarding all documents relating to the 401 Certification and Third Runway Project, with objections citing attorney-client privilege, work product doctrine, and CR 26(b) scope. Additional experts referenced: Dr. Ed Kavazanjian (GeoSyntec Consultants), Amanda Azous (Azous Environmental Sciences), Dyanne Sheldon (Sheldon & Associates), Greg Wingard (Waste Action Project). Exhibit 346, AR 021141.

V V