Notes
Exhibit 354 (AR 021222). Declaration of Dr. Peter Willing, Principal at Water Resources Consulting LLC (Bellingham, WA), filed on behalf of Airport Communities Coalition (ACC) in PCHB Case No. 01-133 in support of ACC’s Motion for Stay of Department of Ecology Water Quality Certification No. 1996-4-02325 and CZMA concurrency statement issued August 10, 2001, for construction of a third runway at Sea-Tac Airport. Willing holds MS and PhD from Cornell University, Department of Natural Resources. Declaration identifies two core deficiencies: (1) Port Of Seattle’s flawed low streamflow analysis and changing plans to augment flows in Class AA streams including Des Moines Creek via the Des Moines Creek Flow Augmentation Facility; (2) inadequate stormwater management plans under the Sea-Tac Stormwater Master Plan failing to provide reasonable assurance of compliance with water quality standards. References Section 404 permit application, NPDES permit major modification, Best Management Practices, Clean Water Act Section 401, Applied Fluvial Geomorphology, and Western Washington University adjunct faculty credentials. Argues Ecology’s 401 certification relies on last-minute stop-gap rather than technically sound mitigation plan.