PCHB225006437

PCHBPollution Control Hearings Board of the State of Washington

v. ) SUR-REPLY ON MOTION FOR STAY ) STATE OF WASHINGTON, ) (Section 401 Certification No. DEPARTMENT OF ECOLOGY; and ) 1996-4-02325 and CZMA THE PORT OF SEATTLE, ) concurrency statement, issued August ) 10, 2001, Reissued September 21, Respondents. ) 2001, under No. 1996-4-02325 (Amended-i)) Amanda Azous declares as follows: 1. I am over the age of 18, am competent to testify, and have personal knowledge of the facts stated herein. 2. I am responding to the sur-replies submitted by the Department of17 Ecology and the Port of Seattle and the second declarations of Erik Stockdale and Dr. James Kelley. 3. The Port and Ecology do not address the underlying reasons why the Port's hydrologic monitoring of wetlands is inadequate and ignore the importance of properly evaluating what is accepted by most wetland scientists as the major driver of wetland ecosystem processes, hydrology. The result is flawed performance24 DECLARATION OF AMANDA AZOUS IN HELSELL FETTERMAN LLP Rachael Paschal Osborn SUPPORT OF SUR-REPLYON ACC'S MOTION 1500PugetSoundPlaza Attorneyat Law FOR STAY - 1 1325 Fourth Avenue 2421 West Mission Avenue O_2#_#_JAL.,. _ , Seattle, WA98101-2509 Spokane, WA99201 AR 006437 standards for ensuring adequate seepage flows to remaining wetlands that will result in reduced functioning of remaining wetland areas. 4. Two wetlands, 18 and 37, are in immediate danger of irrevocable alteration from filling of their tributary wetlands and streams due to the Port's near4 term fill plans. Wetlands to be filled in the near term include part of Wetland 18, and…
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