TagACC(1524)

The Airport Communities Coalition (ACC) opposes the Washington Department of Ecology’s motion to strike documents related to a public disclosure request concerning the Port of Seattle’s third runway application. ACC argues the documents were not inadvertently disclosed, that attorney-client privilege was waived by the client’s own disclosure, and that the Board lacks jurisdiction to order

The Airport Communities Coalition filed this preliminary list of legal issues with the Pollution Control Hearings Board for the State of Washington, challenging the Department of Ecology’s Section 401 water quality certification for the Sea-Tac Airport Third Runway project. The document raises numerous legal questions about whether the certification provides reasonable assurance of compliance with

The Airport Communities Coalition (ACC) filed this sur-rebuttal before the Pollution Control Hearings Board challenging the Department of Ecology’s Section 401 Certification and CZMA concurrency statement issued for the Port of Seattle. ACC argues that the amended certification conditions fail to provide reasonable assurance of water quality standards compliance, citing inadequate fill contaminant criteria (including

Amanda Azous, a wetland scientist, declares that the Port of Seattle’s hydrologic monitoring of wetlands is inadequate to protect remaining wetlands or restore conditions if the Section 401 Certification is rescinded. She identifies Wetlands 18 and 37 as being in immediate danger of irrevocable alteration due to the Port’s near-term fill plans, and argues that

Dyanne Sheldon, a wetland specialist, submits a declaration challenging the adequacy of pre-construction groundwater monitoring standards in the Port of Seattle’s 401 Certification. She argues that the Performance Standards in the NRMP are imprecise and unmeasurable, that reliance on ‘normal rainfall’ as a baseline is contradictory, and that using wetland indicator status (WIS) ratings as

Dr. Patrick Lucia provides a second declaration supporting the Airport Communities Coalition’s motion for a stay of the Section 401 Certification issued to the Port of Seattle for the Third Runway embankment project at Sea-Tac Airport. The declaration argues that the Department of Ecology lacks reasonable assurance that fill material used in the embankment meets

Dr. John Strand submits a declaration in support of the Airport Communities Coalition’s sur-reply on a motion for stay regarding Washington Department of Ecology’s Section 401 Certification and CZMA concurrency statement for the Port of Seattle. The declaration addresses contamination concerns with soils already accepted by the Port, critiques the Declaration of C. Linn Gould,

The Port of Seattle submits its preliminary list of issues, witnesses, and exhibits to the Pollution Control Hearings Board in response to an appeal by the Airport Communities Coalition. The document outlines 17 potential issues related to the §401 Water Quality Certification for projects at Seattle-Tacoma International Airport, covering topics such as wetland impacts, stream

The Airport Communities Coalition (ACC) replies to objections from the Washington Department of Ecology and the Port of Seattle regarding ACC’s motion to file an overlength reply brief. ACC argues that Ecology and the Port embedded extensive legal arguments within declarations to circumvent page limits, and that ACC requires additional pages to respond to 56

This document is a reply memorandum filed by the Airport Communities Coalition (ACC) in support of its motion for a stay, arguing that the Amended Certification sets acceptable soil contamination levels too high to protect water quality. The brief highlights that DOE’s own expert calculations show contaminants like Antimony and Arsenic are permitted at levels