TagACC(1524)

In this 2001 declaration filed before Washington State's Pollution Control Hearings Board, Dr. Peter Willing challenges the Port of Seattle's commitment to improving stormwater management at Sea-Tac Airport. He argues that the Port's pledge to retrofit its stormwater system 'to the extent practicable' is vague, undefined, and falls short of required water quality standards. Dr. Willing also contends that the four best management practices listed in the Port's Stormwater Master Plan are largely inadequate, as most do not go beyond basic King County water quality requirements.

The Washington State Department of Ecology filed a motion before the Pollution Control Hearings Board seeking to strike attorney-client privileged documents inadvertently disclosed to the Airport Communities Coalition (ACC) in response to a public disclosure request. Ecology argued that because the privileged information was disclosed unintentionally, the attorney-client privilege was not waived and ACC should

Andrea Grad, a paralegal with Helsell Fetterman LLP representing the Airport Communities Coalition, declares that she submitted public disclosure requests to the Washington Department of Ecology regarding the Port of Seattle’s third runway applications. She describes how, after Ecology issued its Section 401 certification decision on August 10, 2001, she requested previously withheld deliberative documents

The Washington State Department of Ecology submits its statement of issues, preliminary witness list, and exhibit list before the Pollution Control Hearings Board in a case brought by Airport Communities Coalition against the Department of Ecology and Port of Seattle. The central issue is whether Ecology had reasonable assurance that water quality standards would be

Paul S. Fendt, a stormwater engineer with Parametrix Inc., provides a second declaration in the Pollution Control Hearings Board case between Airport Communities Coalition and the Department of Ecology and Port of Seattle. The declaration addresses claims about the Port’s control over retrofitting the stormwater system at Seattle-Tacoma International Airport, detailing the Comprehensive Stormwater Management

Declaration by Roger Pearce, attorney for the Port of Seattle, submitted to the Pollution Control Hearings Board for the State of Washington in case No. 01-160 (Airport Communities Coalition v. Department of Ecology and Port of Seattle). The declaration authenticates Exhibit A, a copy of the §401 Water Quality Certification issued by the Washington Department

C. Linn Gould, a Risk Assessor and soil scientist, submits a second declaration opposing the Airport Communities Coalition’s motion for stay in PCHB No. 01-133. The declaration responds to ACC’s allegations of errors in the Port of Seattle’s fill criteria for the Third Runway embankment, defending the numeric and narrative requirements of the 401 Certification

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

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.

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