EXH 454: Declaration Dr. Patrick Lucia Support ACC Motion Stay Section 401 Cert No. 1996-4-02325

This 2001 declaration from civil and environmental engineer Dr. Patrick Lucia, filed with Washington's Pollution Control Hearings Board, supports the Airport Communities Coalition's motion to halt construction of a proposed Third Runway at Seattle-Tacoma International Airport. Dr. Lucia, a principal with GeoSyntec Consultants, outlines his review of geotechnical and seismic concerns related to the runway's embankment fill and MSE retaining walls. The declaration references multiple technical letters submitted to the Washington State Department of Ecology and the U.S. Army Corps of Engineers raising safety and environmental questions about the project.

Notes

Declaration of Dr. Patrick Lucia, Ph.D., Civil and Environmental Engineer and Principal with GeoSyntec Consultants, filed in support of Airport Communities Coalition (ACC) Motion for Stay before the Pollution Control Hearings Board (PCHB), Case Nos. 01-133 and 01-160. Addresses geotechnical and seismic issues related to the embankment fill and MSE (Mechanically Stabilized Earth) walls for the Third Runway expansion at Seattle-Tacoma International Airport. References Section 401 Certification No. 1996-4-02325 (Amended-1) and CZMA concurrency statement issued August 10, 2001, reissued September 21, 2001. Reviews Pacific Groundwater Group hydrologic modeling reports, Parametrix low flow analysis, U.S. Fish and Wildlife Service Biological Opinion (May 22, 2001), and Ecology 401 Certifications. Previously co-authored GeoSyntec letters to U.S. Army Corps of Engineers and Washington State Department of Ecology dated February 16, March 15, June 22, and August 6, 2001, concerning Nisqually Earthquake implications and embankment fill design.

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