PCHB229006461

v. ) STRAND 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- 1)) Dr. John Strand 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. GeneralComments: 3. The Port's Sur-Reply and the Declaration ofC. Linn Gould ignore the evidence that contamination already exists on site. There are no adequate safeguards in the Amended 401 Certification to stop the Port from again accepting contaminated soils. The Declaration of DECLARATION OF DR. JOHN STRAND IN HELSELL FETTERMAN LLP RachaelPaschalOsborn SUPPORT OF ACC'S SUR-REPLY ON MOTION 150oPugetSoundPlaza Attorneyat Law FOR STAY - 1 1325 Fourth Avenue 2421 West Mission Avenue ORIGINAL Seattle, WA 98101-2509 Spokane, WA 99201 AN 006461 Elizabeth Clark submitted with the Port's response materials also unjustifiably downplays the contamination in soils the Port has already accepted, e.g., from the Hamm Creek and First Avenue Bridge sites. See First Strand Decl. at ¶¶ 6, 31 ; Second Strand Decl. at ¶¶ 23-25, 28; Ms. Clark does not even begin to address the point we make…

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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 [...]