PCHB267007302

PCHBPollution Control Hearings Board of the State of Washington

v. ) IN SUPPORT OF ACC'S REPLY ON ) MOTION FOR STAY STATE OF WASHINGTON, ) DEPARTMENT OF ECOLOGY; and ) (Section 401 Certification No. THE PORT OF SEATTLE, ) 1996-4-02325 and CZMA concurrency ) statement, issued August 10, 2001, Reissued Respondents. ) September 21, 2001, under No. 1996-4- ) 02325 (Amended-l)) ) Dr. Peter Willing 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 have reviewed the Port of Seattle and Department of Ecology declarations,16 briefs, and exhibits submitted in opposition to ACC's motion for stay. I have also reviewed additional documents, including but not limited to the Stormwater Management Manual for Western Washington, and scientific literature related to the scope of my review. 3. I have reviewed the Department of Ecology' s Water Quality Certification No. 1996-4-02325 for construction of a third runway at SeaTac Airport, issued on August 10, 2001 and then amended and re-issued on September 26, 2001. The certification contains a number of defects that cause it to fall considerably short of reasonable assurance that the construction will HELSELL FETTERMAN LLP Rachael Paschal Osborn 1500 Puget Sound Plaza Attorney at Law 1325 Fourth Avenue 2421 West Mission Avenue DECLARATION OF DR. PETER WILLING IN Seattle,WA98101-2509 Spokane,WA99201 SUPPORT OF ACC'S MOTION FOR STAY-1 ORIGINAL , .oorao protect water quality standards. The two particulars to which I will address my statement are the augmentation of stream flow in SeaTac area…
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