EXH 355: Decl. Dr. Peter Willing Support ACC Motion for Stay (PCHB Nos. 01-133, 01-160)

This document is a legal declaration by Dr. Peter Willing submitted in support of the Airport Communities Coalition's motion for a stay against the Port of Seattle's water quality certification for construction of a third runway at Sea-Tac Airport. Dr. Willing, a water treatment and water quality expert, argues that the Port's plan to augment low summer stream flows using stored stormwater is an unproven concept lacking necessary design details, manufacturer specifications, or documented precedent. He contends that neither the Department of Ecology nor the Pollution Control Hearings Board had sufficient information to evaluate the plan, leaving serious unresolved concerns about potential violations of Washington State water quality standards.

Notes

Declaration of Dr. Peter Willing (AR 021243–021245) filed in support of Airport Communities Coalition (ACC) reply motion for stay before the Pollution Control Hearings Board (PCHB), Case Nos. 01-133 and 01-160, opposing respondents State of Washington Department of Ecology, and Port Of Seattle. Willing, holding a Class 3 Water Treatment Operator certification from Washington State, addresses two water quality issues arising from the SeaTac Airport Master Plan Update third-runway construction: (1) flow augmentation of SeaTac-area streams using stored stormwater from underground vaults with floating orifices, and (2) stormwater management under Ecology Section 401 Water Quality Certification No. 1996-4-02325. Willing argues the Low Streamflow Analysis Summer Low Flow Impact Offset Facility Proposal lacks design details, manufacturer specifications, and precedent, and that King County identified ‘unresolved design challenges’ (Whiting at 2). The CSMP omits vault dimensions. Certification was issued August 10, 2001 and amended September 26, 2001 under CZMA concurrency. Prepared by Helsell Fetterman LLP; Rachael Paschal Osborn, Attorney at Law, Spokane, WA.

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