PCHB228006459

PCHBPollution Control Hearings Board of the State of Washington

v. ) WILLING IN SUPPORT OF ACC'S ) SUR-REPLY ON MOTION FOR STAY STATE OF WASHINGTON, ) DEPARTMENT OF ECOLOGY; and ) (Section 401 Certification No.9 THE PORT OF SEATTLE, ) 1996-4-02325 and CZMA concurrency ) statement, Issued August 10, 2001, Respondents. ) Reissued September 21,2001, under No. ) 1996-4-02325 (Amended-I)) Dr. Peter Willing declares as follows: 1. I declare the following from personal knowledge and am competent to testify thereto before the Board if necessary. 2. My qualifications and previous review of the issues in this matter are set out in the two declarations which I have already submitted in support of ACC's Motion for Stay in this matter. 3. Paul Fendt's Sur-reply Declaration (at 5) claims that the Port has committed to retrofitting the existing stormwater system at SeaTac for water quality best management practices "to the extent practicable." The Port has not defined this standard, which leaves it up for future definition at the Port's convenience..The word "maximum" is left out in this instance, but DECLARATION OF DR. PETER WILLING IN HELSELL FETTERMAN LLP RachaelPaschalOsborn SUPPORT OF ACC'S SUR-REPLY ON MOTION 1500pugetSound Plaza Attorneyat Law FOR STAY - 1 1325 Fourth Avenue 2421 West Mission Avenue ORIGINAL Seattle, WA 98101-2509 Spokane, WA 99201 AN 006459 1_-_9-2e) 1 9:13AM FROM WATER RESOURCES CONS 368676184@ P. 2 10-1_-Z091 1O:O0_ Fr_-_L_LL FETI_.+.J/ ZSZ4T'-15| P.OO3/OH F-OZS included ctsewher_ (Comprehensive Smn'nwater Planpp. 7-9, included as FendtExhibit'B). z "Exten: pracdcab£e"is not mc same rhmg as AKART, nor doe, it go beyond the bare…
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