TagACC(1524)

Declaration by Jeff Kray, submitted to the Pollution Control Hearings Board in the case of Airport Communities Coalition v. State of Washington Department of Ecology and Port of Seattle (PCHB No. 01-160). The declaration attaches two documents: the Amended Final Findings of Fact Conclusions of Law and Order in Public Utility District No. 1 of

Declaration by attorney Michael P. Witek of the Airport Communities Coalition in support of their motion for summary judgment before the Pollution Control Hearings Board. The declaration authenticates several exhibits including the Section 401 Water Quality Certification, deposition transcripts, and other documents related to the construction of a third runway at Seattle-Tacoma International Airport. The

The Pollution Control Hearings Board issued a discovery order resolving four pending motions in Airport Communities Coalition v. State of Washington Department of Ecology and Port of Seattle. The order addresses ACC’s motion to compel inspection of Port property, ACC’s motion to extend the discovery schedule, and the Port’s motions to compel depositions and document

A memorandum from Beth Clark to Paul Agid dated January 22, 2002, summarizing the sequence of events related to petroleum-impacted soil from the Summit Ridge fill source in Bellevue, Washington that was placed in the Third Runway embankment. The memo details how approximately 1540 tons of soil were removed from the Third Runway after petroleum

A memo from Beth Clark to Paul Agid regarding the Black River Quarry, attaching the April 30, 2001 memorandum submitted to the Department of Ecology. The memo clarifies that June 9, 2000 sample results from an existing stockpile were not representative of approved fill material for the Third Runway, as the stockpile contained asphaltic material

This document is a table of cases cited in discovery motions and responses for Airport Communities Coalition v. Department of Ecology et al., PCHB No. 01-160. It lists 17 legal cases from various federal and state courts, including Washington state cases and federal district court cases. The document was received by the Environmental Hearings Office

The Port of Seattle filed this reply memorandum in PCHB No. 01-160 responding to the Airport Communities Coalition’s (ACC) opposition to the Port’s motion to compel depositions and limit site visit access. The Port argues ACC has stalled discovery by refusing to produce documents, make witnesses available for deposition, or agree to site visit dates.

The Airport Communities Coalition (ACC) filed this reply brief in support of its motion to compel inspection of Port of Seattle property, including wetlands, surface waters, and soils. ACC argues that the Port has improperly restricted site access despite providing unrestricted access to Ecology staff and Port consultants, and that CR 34 expressly permits such

The Airport Communities Coalition (ACC) replies to the Port of Seattle’s opposition to ACC’s motion to extend the discovery schedule in PCHB No. 01-160. ACC argues that the Port controls site access and has withheld data and expert reports, only agreeing to propose site visit dates on January 16, 2002, just days before the February

The Washington Department of Ecology responds to the Airport Communities Coalition’s motion to extend the discovery schedule in PCHB No. 01-160. Ecology agrees to extend the discovery cutoff to February 15, 2002, but opposes extending deadlines for the ACC’s final exhibit list and prefiled direct testimony. Ecology argues the ACC has refused to make experts