TagACC(1534)

Pre-filed testimony of W. A. Rozeboom, M.B.A., P.E. submitted to the Environmental Hearings Office (PCHB), received March 18, 2002, consisting of an index to exhibits A through P. Exhibits include Northwest Hydraulic Consultants letters to U.S. Army Corps of Engineers (November 1999, February 2001, June 2001, December 2001) commenting on stormwater, hydrology, and hydraulics of

ACC’s reply brief in PCHB No. 01-160 supporting motion in limine to exclude plans and reports produced after February 1, 2002, cutoff date set in the October 30, 2001 Pre-Hearing Order. Arguments center on the plain language of the Pre-Hearing Order prohibiting Ecology and Port Of Seattle from relying on any plan or report prepared

Appellants’ reply brief filed by Airport Communities Coalition (ACC) in PCHB No. 01-160 supporting motion in limine to exclude testimony of Washington State Department of Ecology witness Dave Garland regarding the Port of Seattle’s December 17, 2001 Low Flow Plan. ACC argues Ecology violated CR 26(e)(1)(B) duty to supplement interrogatory responses and the Board’s Pre-Hearing

Airport Communities Coalition (ACC) reply brief in PCHB No. 01-160 supporting motion to publish depositions of Ecology managers and CR 30(b)(6) designated witnesses at hearing. Filed March 18, 2002 before the Pollution Control Hearings Board, State of Washington. Argues CR 32 allows depositions of officers, directors, or managing agents of governmental agencies to be used

Appellants’ reply brief filed March 17, 2002 in PCHB No. 01-160 by Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) via Helsell Fetterman LLP and Smith & Lowney PLLC, supporting their motion to strike the Port of Seattle’s pre-hearing brief. ACC argues the Port manipulated double-spacing in Microsoft Word to stuff additional lines

Respondent Washington State Department of Ecology concurs with and joins Port Of Seattle’s response to Appellants’ Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) Motion in Limine to Exclude “Late-Produced” Plans and Reports, filed March 15, 2002 in PCHB No. 01-160. Signed by Assistant Attorneys General Jeff B. Kray (WSBA #22174), Joan M.

State of Washington Department of Ecology’s response opposing Airport Communities Coalition (ACC) motion under CR 32(a)(2) to publish over 1,424 pages of deposition transcripts in lieu of direct testimony in PCHB No. 01-160. Ecology argues depositions of Fitzsimmons, White, Hellwig, Kenny, Stockdale, Drabek, Fitzpatrick, and Kmet are inadmissible, that ACC failed to timely file the

Prefiled direct testimony of James C. Kelley, Ph.D. (Parametrix, Inc.) submitted to the Pollution Control Hearings Board (PCHB) for the State of Washington, Case No. PCHB 01-160, on behalf of respondents Department of Ecology and Port Of Seattle, against appellants Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE). Kelley testifies as principal consulting

Port Of Seattle’s response brief filed in PCHB case 01-160 opposing ACC and CASE motion in limine to exclude 17 exhibits as ‘late-produced.’ Port argues the Board’s October 30, 2001 prehearing order deadlines (November 15, 2001 identification, February 1, 2002 completion) apply only to plans and reports prepared ‘pursuant to the §401 Certification,’ not all

Prefiled testimony (with errata corrections) of Joseph Brascher of AQUA TERRA Consultants submitted to the Pollution Control Hearings Board (PCHB No. 01-160) in the matter of Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) v. State of Washington Department of Ecology and Port Of Seattle. Brascher testifies regarding low streamflow hydrologic modeling at