PCHB061002212

and inaccurate reading of the Board's prehearing order and of the transcript from the preheating conference that preceded issuance of that order. As is clear from a close review of the prehearing order and the transcript from the conference, the Board has already specifically rejected the position taken in Appellants' motion. None of the exfiibits they seek to exclude are ] "untimely" under the Board's order. Appellant's motion should be denied. In its October 30, 2001 prehearing order, the Board required Ecology and the Port to identify certain plans and reports by November 15, 2001, and to complete those plans and reports by February 1, 2002. These deadlines do not apply to all plans and reports, as Appellants _'] contend, but to a very specific subset: those plans and reports prepared or expected to be PORT'S RESPONSE TO APPELLANT'S MOTION IN LIMINE FOSTER PEPPER _d SHEFELMAN PLLC TOEXCLUDE"LATE-PRODUCED"PLANSANDREPORTS- 1 1111 TulsaAVENUE,SUITE3400 SEATTLE, WASHINGTON 98101-3299 206-447-4400 AR 002212 prepared "pursuant to the §401 Certification." None of the 17 documents that Appellants seek to exclude were prepared "pursuant to the §401 Certification," and consequently none should be excluded. In fact, many of the 17 documents that Appellants seek to exclude are neither "plans" nor "reports." Several of them are figures (documents 1-13) or compilations of analytical data (documents 8 and 9). Others include a memorandum containing comments (document 14) and an interlocal agreement between the Portand Ecology (document 17).7 Appellants quote the relevant provision from the Board's preheating order, but they ignore…

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PSCAA Advisory Council Meeting Agenda
Add to CalendarMWednesday Mar 11, 9:00am - 11:35am
1904 3rd Avenue, Suite 105, Seattle, WA 98101
Call to order – Roll Call – Quorum Established – Land Acknowledgement We would like to acknowledge that our Agency operates in four present-day counties, which are the traditional lands of the Coast Salish people, past and present. This acknowledgement does not take the place of authentic relationships with indigenous communities in our jurisdiction and [...]