EXH 452: ACC First Supplemental Response to RFP No. 2 and Interrogatory No. 5

This 2002 legal document is a supplemental response filed by the Airport Communities Coalition (ACC) in a Pollution Control Hearings Board case against the Washington State Department of Ecology and the Port of Seattle, related to the expansion of Seattle-Tacoma International Airport. It lists technical documents and expert references relied upon by ACC's witnesses, covering topics such as hydraulics, biology, and geotechnical engineering related to the proposed third runway project. The filing also summarizes the prior trial testimony experience of expert witnesses retained by the ACC.

Notes

Airport Communities Coalition (ACC) first supplemental response filed in PCHB No. 01-160 before the Pollution Control Hearings Board of the State of Washington, directed to respondent Port Of Seattle’s Request for Production No. 2 and Interrogatory No. 5. Lists documents relied upon by ACC expert witnesses including Northwest Hydraulic Consultants (Bill Rozeboom and Dr. Malcolm Leytham), Dr. John Strand of Columbia Biological Assessments, and Dr. Pat Lucia of GeoSyntec Consultants. References geotechnical, seismic, and groundwater-related literature including Hart Crowser Geotechnical Summary Report for Third Runway Embankment and MSE Retaining Walls at Seattle-Tacoma International Airport (Report No. 4978-06, November 2001). Dr. Lucia’s prior trial testimony listed includes Park County Montana v. BNSF, Catellus Development Company v. NL Industries, State of Illinois v. Kerr McGee, Rancho Solano Homeowners Association v. Peter Kiewit Construction, Davest Construction Company v. Klienfelder Engineers, and Ferraris v. BART. Received by Marten Brown Inc. February 4, 2002; filed by Helsell Fetterman.

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