TagACC(1534)

Certificate of Record filed January 31, 2002 by Tracey L. Johnson, Clerk of the Pollution Control Hearings Board (PCHB), transmitting the complete administrative record for PCHB No. 01-160, Cause No. 01-2-02386-9, in the Superior Court of Washington, Thurston County. Airport Communities Coalition (ACC) is appellant against State of Washington Department of Ecology and Port Of

Handwritten field observation notes by R. Azous (Azous Exhibit 387, dated 2-19-02) transmitted via fax from Helsell Fetterman LLP on 02-19-2002, documenting site visits to Vacca Farm and West Side areas adjacent to Miller Creek and STIA. Notes cover wetland conditions, plant communities (cattail, alder, Juncus, Phalaris, Sparganium, sedge), upland buffer zones, NRM planting plan

A January 2002 technical letter from Northwest Hydraulic Consultants challenges the Port of Seattle's December 2001 Low Streamflow Analysis for SeaTac Airport, identifying serious modeling errors that led to underestimated impacts on Miller, Walker, and Des Moines Creeks. Key flaws include double-counting of groundwater discharges in the Miller Creek model, inconsistent methodology for assessing embankment seepage, and failure to account for updated construction methods. The letter was submitted to the U.S. Army Corps of Engineers on behalf of the Airport Communities Coalition.

This document contains an email exchange from January 30, 2002, between legal staff at Helsell Fetterman and Foster Pepper law firms coordinating a deposition schedule for the case ACC & CASE v. DOE & POS (PCHB No. 01-060). The emails confirm scheduling adjustments, including moving Linda Logan's deposition start time to 10:00 a.m. and removing Joe Stohr (a Washington State Department of Ecology employee) from the February 19 schedule. An attached calendar lists numerous depositions scheduled between January 28 and February 23, 2002, with witnesses deposed alternately at Foster Pepper and Helsell Fetterman offices.

A January 2002 letter from Northwest Hydraulic Consultants to the U.S. Army Corps of Engineers challenges the Port of Seattle's December 2001 Low Streamflow Analysis related to Sea-Tac Airport's third runway development. The letter identifies critical flaws in hydrologic modeling of Miller, Walker, and Des Moines Creeks, including double-counting of groundwater discharges, flawed seepage modeling methodology, and failure to account for construction impacts on stream low flows. The consultants argue these errors cause the Port to substantially underestimate the project's negative impacts on local stream flows.

Reply brief filed by Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) with the Pollution Control Hearings Board (PCHB), PCHB No. 01-160, in support of their Request for Certificate of Appealability and Application for Direct Review by the Court of Appeals. Filed January 30, 2002. Argues under RCW 34.05.518(3)(b) that detrimental delay, fundamental

SSA Study Baseflow Sample Results data tables (mg/l) from 2/19/02 Preliminary Draft, dated 1/30/02, covering water quality sampling at stations including DMEssa, NPool, DMKCwelr, MCssa, MC8h, WCjcN, WCcpS, WC171tst, Reba, and others. Parameters include pH, alk, hard, TSS, DOC, Ca2+, Mg2+, d-Cu, TR-Cu, d-Zn, TR-Zn, d-Cd, TR-Cd, TR-Cr, TR-Pb, TR-Ni across baseflow events (BF1-1 through

Airport Communities Coalition (ACC) reply brief filed January 29, 2002 in PCHB No. 01-160 before the Pollution Control Hearings Board (PCHB), State of Washington, supporting ACC’s Motion for Summary Judgment on the absence of a water right for the Third Runway Section 401 Water Quality Certification (#1996-4-02325). ACC argues the Port Of Seattle’s Low Flow

Two photographs taken by P. Willing on January 28, 2002, document an absorbent boom placed in a stream below the SDS1 outfall, a pollution-control measure used to contain contaminants. The second photo highlights turbid (murky) effluent visible in the stream, indicating water quality concerns at the site. These images appear to be part of an environmental monitoring or spill-response record associated with drainage infrastructure near Sea-Tac Airport.

This exhibit, part of K.M. Leytham's pre-filed testimony in PCHB No. 01-160, shows photographs taken on January 28, 2002, documenting standing water on top of a fill embankment near South 160th Street. The images provide visual evidence of water pooling conditions on the embankment surface, likely related to construction or environmental concerns associated with Sea-Tac Airport development. This material was submitted as part of a formal hearing record before the Pollution Control Hearings Board.