TagAirport Communities Coalition(268)
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2002-03-11
EXH AR002760: Motion in Limine to Quash Subpoena of Linda Logan, PCHB 01-160
In March 2002, the Port of Seattle filed a motion asking the Pollution Control Hearings Board to quash a subpoena issued by the Airport Communities Coalition (ACC) seeking testimony from Dr. Linda Logan, an employee of consulting firm Parametrix. The Port argued two reasons for quashing: Dr. Logan did not appear on any party's final witness list as required by the Board's pre-hearing order, and the accompanying notice under Civil Rule 43(f) was improper because Dr. Logan was neither a party nor a managing agent of the Port of Seattle. -
2002-03-07
PCHB Doc 015773: ACC v. DOE/PORT — Certificate of Service, Prefiled Testimony, PCHB No. 01-160
Certificate of Service filed March 7, 2002 by Holly Simmelink, Certified PLS, of Foster Pepper & Shefelman PLLC in Airport Communities Coalition (ACC) v. State of Washington Department of Ecology and Port of Seattle, PCHB No. 01-160, Pollution Control Hearings Board for the State of Washington. Certifies service of prefiled testimony of 16 witnesses: Michael -
2002-03-07
EXH AR016335: Pre-Filed Direct Testimony of Paul S. Fendt, P.E. — PCHB 01-160, ACC and CASE v. Ecology and Port Of Seattle
Pre-filed direct testimony of Paul S. Fendt, P.E., submitted to the Pollution Control Hearings Board (PCHB), case No. PCHB 01-160, Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) v. Department of Ecology and Port Of Seattle. AR 016335. Testimony covers stormwater impacts from the MPU (Master Plan Update) improvements at Sea-Tac Airport, including -
2002-03-05
PCHB Doc 3146: Declaration of Thomas R. Luster — ACC v. Ecology and Port Of Seattle, No. 01-160
Declaration of Thomas R. Luster filed March 5, 2002 in PCHB Case No. 01-160, Airport Communities Coalition (ACC) v. State of Washington Department of Ecology and Port Of Seattle. Luster responds to Ecology’s Motion in Limine seeking to strike portions of his pre-filed testimony on grounds he is serving as an expert witness. Luster asserts -
2002-03-05
EXH AR003184: Notice of Withdrawal and Substitution of Counsel for Respondent Port Of Seattle — PCHB No. 01-160
Notice of Withdrawal and Substitution of Counsel filed March 5, 2002 in PCHB No. 01-160 before the Pollution Control Hearings Board for the State of Washington. Marten Brown Inc. withdraws as counsel for Respondent Port Of Seattle and is replaced by Brown Reavis & Manning PLLC, with Gillis E. Reavis (WSBA #21451) signing for both -
2002-03-05
EXH AR003187: Port Of Seattle Joinder in Department of Ecology’s Motion in Limine Re: WAC 371-08-475 (PCHB No. 01-160)
Port Of Seattle joinder filed March 5, 2002 in PCHB No. 01-160 supporting Department of Ecology’s motion in limine to exclude testimony of Thomas R. Luster pursuant to WAC 371-08-475(7). Argues that ER 701 prohibits lay witness opinion testimony and that WAC 371-08-475(7) precludes Luster from serving as an expert, requesting exclusion of all opinion -
2002-03-05
Exhibit 227: Port Of Seattle’s First Set of Interrogatories and Requests for Production to ACC, with Answers and Responses — PCHB No. 01-160
This document contains legal discovery materials from a Pollution Control Hearings Board case in Washington State, in which the Airport Communities Coalition (ACC) challenged the Port of Seattle and the Washington Department of Ecology over the Sea-Tac Third Runway Project. The Port of Seattle submitted interrogatories asking ACC to identify its expert witnesses and their prior testimony histories, to which ACC objected as overbroad and burdensome. Expert witnesses from Northwest Hydraulic Consultants, including Bill Rozeboom and Malcolm Leytham, are listed along with their prior cases involving stormwater and water quality issues relevant to the runway project. -
2002-02-27
PCHB Doc 3203: Certificate of Service — ACC and CASE Prefiled Testimony of Dr. Pat Lucia
Certificate of Service filed February 27, 2002 by Rachel Parks, employee of Helsell Fetterman LLP, attorneys for Airport Communities Coalition (ACC), in PCHB Case No. 01-160. Certifies hand-delivery of ACC’s and CASE’s (Citizens Against Sea-Tac Expansion) prefiled testimony with exhibits of witness Dr. Pat Lucia to respondents State of Washington Department of Ecology and Port -
2002-02-26
EXH AR003201: Erratum to Respondent Port Of Seattle’s List of Witnesses and Exhibits
Erratum filed by Port Of Seattle in PCHB case No. 01-160 (Airport Communities Coalition v. Department of Ecology and Port Of Seattle) correcting Item No. 136 in the witness and exhibit list. Corrects dates for Parametrix, Inc. draft memorandum to Port Of Seattle project files titled ‘Range-finding water-effect ratio results’ (authors L. Logan and D. -
2002-02-26
EXH 457: Second Declaration Dr. Patrick Lucia Supporting ACC Motion for Stay (PCHB Nos. 01-133, 01-160)
This legal declaration by Dr. Patrick Lucia, filed in a Washington State Pollution Control Hearings Board case, argues that the Department of Ecology lacks reasonable assurance that fill material used to construct the Sea-Tac Airport Third Runway embankment meets environmental safety standards. Dr. Lucia contends that the certification allows soil concentrations of arsenic and other metals — including cadmium, chromium, lead, mercury, and nickel — that significantly exceed Puget Sound natural background levels. He also criticizes the Port of Seattle's soil sampling approach as arbitrary and unscientific, asserting it fails to meet accepted environmental engineering standards for contaminant testing.