TagACC(1524)
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2001-10-09
Certificate of service
Certificate of service filed by Wendy S. Clement on October 9, 2001, in the matter of Airport Communities Coalition v. Department of Ecology and Port of Seattle before the Pollution Control Hearings Board for the State of Washington. The document lists ten items served, including reply memoranda, motions, proposed orders, and declarations. Service was made -
2001-10-09
Certificate of service – Port Of Seattle’s sur-reply memorandum and related documents
A Certificate of Service filed in PCHB No. 01-133, documenting that the Port of Seattle served multiple legal documents including a Sur-Reply Memorandum, Motion to Shorten Time, declarations, and proposed orders on October 9, 2001. The documents were personally hand-delivered to the Pollution Control Hearings Board and the Washington State Attorney General’s Office, Ecology Division. -
2001-10-09
Department of Ecology’s response to ACC’s request to file an overlength reply brief
The Washington State Department of Ecology opposes the Airport Communities Coalition’s (ACC) request to file an overlength reply brief before the Pollution Control Hearings Board. Ecology argues that the ACC itself created the cramped briefing schedule and was explicitly ordered by the Board to limit its reply brief to 30 pages. Ecology joins the Port -
2001-10-09
Motion to shorten time
The Port of Seattle requests the Pollution Control Hearings Board shorten the time to consider its Motion to Strike Overlength Brief filed by Airport Communities Coalition. The motion is needed because ACC filed an overlength response memorandum in violation of prior orders and the parties’ agreement, and the hearing on the motion for stay is -
2001-10-09
Department of Ecology’s sur-reply to the ACC’s motion for a stay
The Washington Department of Ecology submits a sur-reply brief responding to new issues raised by the Airport Communities Coalition (ACC) in their motion for a stay of the Amended 401 Certification for the Sea-Tac Airport Third Runway project. Ecology argues that the ACC misrepresents the record regarding Condition E’s fill material criteria and the Synthetic -
2001-10-09
Order shortening time
A proposed order from the Pollution Control Hearings Board for the State of Washington granting the Port of Seattle’s Motion to Shorten Time in case No. 01-160. The order allows expedited consideration of the Port of Seattle’s Motion to Strike Overlength Brief filed by appellant Airport Communities Coalition. The document was received by the Environmental -
2001-10-09
Second declaration of Erik Stockdale
Erik Stockdale, responding on behalf of the Washington Department of Ecology, addresses claims made by the Airport Communities Coalition (ACC) in a Pollution Control Hearings Board proceeding. He disputes the ACC’s assertion that hydrologic monitoring has not commenced downgradient of the embankment, citing data collected by Hart Crowser at wetlands 18 and 38 across seven -
2001-10-09
Port Of Seattle’s motion to strike overlength brief
The Port of Seattle filed a motion requesting the Pollution Control Hearings Board to strike pages exceeding the 30-page limit in the Airport Communities Coalition’s reply brief. The ACC filed a 46-page reply memorandum despite board orders limiting each brief to 30 pages, which all parties had agreed to. The Port argues the ACC failed -
2001-10-09
Declaration of Ray Hellwig in support of motion to strike
Ray Hellwig, Regional Director at the Department of Ecology Northwest Regional Office, declares that he inadvertently disclosed an attorney-client privileged briefing paper to the Airport Communities Coalition (ACC) in response to a public disclosure request. The document, a briefing paper prepared for a senior management team meeting in April 2001, was logged as withheld from -
2001-10-09
Second declaration of James C. Kelley, Ph.D.
James C. Kelley, Ph.D., a professional ecologist with Parametrix, Inc., provides a declaration in the Pollution Control Hearings Board case regarding the Third Runway project at Seattle-Tacoma International Airport. The declaration addresses Ecology’s revised §401 Certification, specifically the deletion of the pre-construction requirement for bi-monthly wetland monitoring downslope of the embankment fill. Kelley argues that