TagAirport Communities Coalition(279)

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

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

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

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

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.

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

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