PCHB246006616

1. I am over the age of 18, am competent to testify, and have personal knowledge of the facts stated herein. 2. I am a Risk Assessor and soil scientist by training, having received my BA in geology and an MS in soil science. A description of my expertise and qualifications is included in my prior declaration supporting the Port of Seattle's Motion Opposing ACe's Motion for Stay and in Exhibit A to that declaration. AR 006616 3. In its reply memorandum, Ace alleges that the Port has made a number of "errors" in deriving or setting its fill criteria. Neither ACe's brief nor the declarations supporting it, however, link these alleged "errors" to any evidence, scientific or otherwise, that would tend to show that the MARTENBROWNINC. DECLARATION OF C. LINN GOULD NAL 1191 SECONDAWNt_, SUITE22000RI61 SEATTLE,WASHrNGTON98101PAGE 1 (206) 292-6300 criteria and other requirements are not protective of aquatic life and water quality. Moreover, the ACC's allegations either miss the point or are simply wrong, as discussed herein. 4. First, despite ACC's implications to the contrary, both the numeric and the narrative requirements of the 401 Certification are protective of water quality. The narrative criteria prohibit acceptance of fill from contaminated sources and fill that was previously contaminated but has been remediated. See 401 Certification, Condition E(1)(b). The numeric criteria are more stringent than is necessary to ensure that water quality standards are not violated. See Declaration of L. Gould in Support of the Port of Seattle's Response Opposing ACC's…

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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 [...]