TagAirport Communities Coalition(272)

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.

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

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.

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.

Port Of Seattle’s reply memorandum supporting its motion for partial summary judgment on Issue No. 14 (‘Did Ecology and the Port comply with SEPA?’) in PCHB Case No. 01-160, Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) v. Department of Ecology and Port Of Seattle. Argues the Pollution Control Hearings Board (PCHB) lacks

Declaration by Roger A. Pearce, attorney for Port Of Seattle, filed February 25, 2002 in PCHB No. 01-160, Airport Communities Coalition v. Department of Ecology and Port Of Seattle. Supports Port Of Seattle’s Motion for Partial Summary Judgment on SEPA Issue. Identifies and authenticates three exhibits from the Final Environmental Impact Statement (FEIS) for the

Respondent State of Washington Department of Ecology’s final list of witnesses and exhibits filed before the Pollution Control Hearings Board in PCHB No. 01-160, Airport Communities Coalition and Citizens Against Sea-Tac Expansion v. State of Washington Department of Ecology and Port Of Seattle. Lists 11 witnesses including Ann Kenny, Erik Stockdale, Kevin Fitzpatrick, Katie Walter

Washington State Department of Ecology memorandum supporting Port Of Seattle’s Motion for Partial Summary Judgment on SEPA compliance issue in PCHB No. 01-160. Filed before the Pollution Control Hearings Board by Assistant Attorneys General Joan M. Marchioro, Thomas J. Young, and Jeff B. Kray. Ecology argues ACC (Airport Communities Coalition) and Citizens Against Sea-Tac Expansion

This legal document is a supplemental response filed by the Airport Communities Coalition (ACC) in a Washington State Pollution Control Hearings Board case (No. 01-160) against the State Department of Ecology and the Port of Seattle. It lists scientific references and studies relied upon by ACC's expert witnesses, covering topics such as the effects of airport deicing chemicals on water quality, dissolved oxygen levels in receiving streams, fluoride impacts on salmon, and toxicity of stormwater runoff to aquatic life near Seattle-Tacoma International Airport.

This declaration by Paul Fendt, a licensed civil engineer with over 18 years of stormwater experience, was submitted in support of the Port of Seattle's opposition to the Airport Communities Coalition's motion in a 2001 Washington Pollution Control Hearings Board case. Fendt explains how new airport development and impervious surfaces can impact local waterways by increasing runoff and reducing groundwater recharge, and describes the stormwater management systems required by the Washington Department of Ecology for the Port of Seattle's Master Plan Update projects. The document provides technical background on stormwater best management practices (BMPs) and regulatory requirements under Washington State and federal Clean Water Act permits.