PCHB187005845

ECOLOGY and THE PORT OF SEATTLE, ) ) Respondents. ) ) MEMORANDUM SUPPORTING CASE'S SMITH & L(3WNEY, P.L.L.C,za 1v EAsTJoH_m-_T MOTION TO INTERVENE s=A_-=,W_H,NGTON9a 11z (zoalB_o-zaaa ORIGINAL A.o I. RELIEF REQUESTED Pursuant to Civil Rule 24 and WAC 371-08-420(1), Citizens Against SeaTac Expansion -_ ("CASE") moves the Pollution Control Hearings Board for status as an intervenor in this case. II. STATEMENT OF-FACTS On August 10, 2001, the Washington Department of Ecology issued Clean Water Act Certification No. 1996-4-02325, and a Coastal Zone Management Act Section 307(c)(3) concurrence statement to the Port of Seattle for Sea-Tac Airport Master Plan Update projects including the proposed third runway. Both the Airport Communities Coalition and the Port of Seattle appealed the Certification, in PCHB Nos. 01-133 and 01-150, respectively. The latter appeal resulted in the issuance of an Amended Certification ("Certification Order No. 1996-4- 02325 (Amended- 1)") on September 21,2001. The Airport Communities Coalition subsequently14 appealed the Amended Certification in PCHB No. 01-160. Petitioner/intervenor CASE is a non-profit corporation organized and in good standing under Washington law. See, Declaration of Brett Fish ("Fish Dec.") at 1 ¶1. CASE is a broad- based, local citizen's group which, among other things, acts to protect the local environment and communities from the impacts of Sea-tac Airport. Id. CASE and its members have consistently fought for clean water, including fighting for better enforcement of the Port of Seattle's NPDES pernait for discharges from Sea-tac into local streams. Id. CASE's efforts to safeguard its members, local communities, and local…

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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 [...]