TagAirport Communities Coalition(279)

This 2002 legal declaration by wetland scientist Dyanne Sheldon challenges the adequacy of environmental protections attached to a Washington State Department of Ecology water quality certification related to Sea-Tac Airport expansion. Sheldon argues that the groundwater and wetland performance standards required under the 401 Certification are too vague and scientifically flawed to reliably measure success or failure, citing problems such as undefined 'normal rainfall' baselines and an over-reliance on qualitative wetland plant ratings from the 1980s. The declaration was submitted in support of the Airport Communities Coalition's motion for a stay of the certification before the Washington Pollution Control Hearings Board.

This legal document is part of a Pollution Control Hearings Board case in which the Airport Communities Coalition (ACC) challenged the Port of Seattle and the Washington State Department of Ecology over environmental concerns related to Seattle-Tacoma International Airport. The document 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, toxicity to aquatic life including salmon and trout, and fluoride impacts on fish. The referenced research was used to support ACC's claims about the environmental impact of airport operations on surrounding waterways and ecosystems.

This 2002 legal document is a supplemental response filed by the Airport Communities Coalition (ACC) in a Pollution Control Hearings Board case against the Washington State Department of Ecology and the Port of Seattle, related to the expansion of Seattle-Tacoma International Airport. It lists technical documents and expert references relied upon by ACC's witnesses, covering topics such as hydraulics, biology, and geotechnical engineering related to the proposed third runway project. The filing also summarizes the prior trial testimony experience of expert witnesses retained by the ACC.

Deposition upon oral examination of Thomas Luster, taken February 1, 2002, in PCHB No. 01-160, Airport Communities Coalition (ACC) v. Department of Ecology and Port Of Seattle. Luster, represented by Richard A. Smith of Smith & Lowney, was deposed by Gillis E. Reavis (Marten Brown) for Port Of Seattle and Thomas J. Young (Assistant Attorney

Certificate of Record filed January 31, 2002 by Tracey L. Johnson, Clerk of the Pollution Control Hearings Board (PCHB), transmitting the complete administrative record for PCHB No. 01-160, Cause No. 01-2-02386-9, in the Superior Court of Washington, Thurston County. Airport Communities Coalition (ACC) is appellant against State of Washington Department of Ecology and Port Of

Airport Communities Coalition (ACC) reply brief filed January 29, 2002 in PCHB No. 01-160 before the Pollution Control Hearings Board (PCHB), State of Washington, supporting ACC’s Motion for Summary Judgment on the absence of a water right for the Third Runway Section 401 Water Quality Certification (#1996-4-02325). ACC argues the Port Of Seattle’s Low Flow

Second Declaration of Michael P. Witek, attorney for Airport Communities Coalition (ACC), filed January 22, 2002, before the Pollution Control Hearings Board (PCHB), Case No. 01-160. Supports ACC’s Motion for Summary Judgment challenging Section 401 Water Quality Certification No. 1996-4-02325 and CZMA concurrency statement issued August 10, 2001, by Washington State Department of Ecology related

Airport Communities Coalition (ACC) v. Department of Ecology et al., PCHB No. 01-160. Table of 17 cases cited in discovery motions and responses, received by the Environmental Hearings Office on January 18, 2002. Cases include: American Medical Systems v. National Union Fire Insurance (E.D. La. 1999), Belcher v. Bassett Furniture Industries (4th Cir. 1978), Boring

Airport Communities Coalition (ACC) reply brief filed January 18, 2002, in PCHB No. 01-160 before the Washington Pollution Control Hearings Board, opposing Port of Seattle’s resistance to extending the February 1, 2002 discovery deadline. ACC argues Port of Seattle refused site visit access until January 16, 2002, withheld expert data and reports, and failed to

ACC’s response filed with the Pollution Control Hearings Board (PCHB No. 01-160) opposing Port Of Seattle motions to compel depositions of ACC experts and limit site entry. ACC argues that Port Of Seattle has refused to grant CR 34(a)(2) site access requested November 26, 2001, despite ACC serving a routine request for entry to Port