TagCASE(191)

Letter dated February 19, 2002 from attorney Rachael Paschal Osborn (Spokane) to Kaleen Cottingham, Presiding Officer of the Pollution Control Hearings Board (PCHB), in ACC & CASE v. Ecology & Port of Seattle, PCHB No. 01-160. Osborn disputes timely service of Port of Seattle’s Motion for Partial Summary Judgment on SEPA Issue filed February 8,

Fax cover sheet and analytical lab reports sent by Rick Poulin of Smith & Lowney, P.L.L.C. (Seattle, WA) to Peter Eglick and Kevin Stock at Helsell Fetterman LLP on February 14, 2002, transmitting water sample lab results for Case 2, Site Visit Day 2. Enclosed letter from Analytical Resources, Incorporated (ARI), dated February 11, 2002,

A February 2002 letter from Analytical Resources, Inc. to attorney Richard Poulin of Smith & Lowney, P.L.L.C. transmits laboratory analytical results for nine water samples accepted on January 28, 2002, under Case 1. The samples were received intact with no discrepancies noted on the chain of custody record, and analysis for requested parameters including glycols, TSS, copper, zinc, and hardness proceeded without incident. Quality control results, including a method blank showing no detected ethylene or propylene glycol above 5.0 mg/L, are included in the report.

A February 2002 laboratory report from Analytical Resources, Inc. documents the analysis of four water samples submitted by the law firm Smith & Lowney, P.L.L.C. for a project identified as Case 2. The samples were tested for metals, conventional parameters, and glycols, with results showing no ethylene or propylene glycol detected above the 5.0 mg/L detection limit. A calibration issue with the glycol analysis required re-testing outside the standard holding time, though re-analysis confirmed the original findings.

Analytical Resources, Inc. submitted water sample analysis results to attorney Richard Poulin of Smith & Lowney law firm in February 2002 for a matter identified as Case 1. Nine water samples were collected on January 28, 2002 and tested for ethylene glycol and propylene glycol, with neither compound detected above the 5.0 mg/L detection limit. The chain of custody record shows samples were collected by Greg Wingard of CASE and received by ARI laboratory staff for quality-controlled analysis.

A February 2002 analytical laboratory report from Analytical Resources, Inc. to Seattle law firm Smith & Lowney, documenting water sample testing results for a project referenced as Case 2. Four water samples were collected on January 31, 2002, and analyzed for metals, conventional parameters, and glycols, with the glycol analysis requiring re-testing due to calibration issues outside acceptable control limits. The results showed no detectable levels of ethylene glycol or propylene glycol above the 5.0 mg/L detection limit.

A February 2002 letter from Marten Brown attorneys transmits two spreadsheets listing reference documents used by expert witness John Strunk in the case ACC and CASE v. Port of Seattle and Department of Ecology (PCHB No. 01-160). The spreadsheets catalog technical reports and studies related to preferential ground water flow paths near the proposed Third Runway at Seattle-Tacoma International Airport, covering sites such as airline fuel farms, maintenance hangars, and contaminated ground water areas. Documents were produced by environmental consultants including Associated Earth Sciences and EMCON, spanning reports from the mid-1990s through 2001.

Pollution Control Hearings Board (PCHB) case 01-160 denial of summary judgment filed by Airport Communities Coalition (ACC) against Washington State Department of Ecology and Port Of Seattle. ACC sought a ruling that Ecology’s §401 certification lacked reasonable assurance that Port Of Seattle had legal means to permanently mitigate low stream flow impacts of the Third

This document contains an email exchange from January 30, 2002, between legal staff at Helsell Fetterman and Foster Pepper law firms coordinating a deposition schedule for the case ACC & CASE v. DOE & POS (PCHB No. 01-060). The emails confirm scheduling adjustments, including moving Linda Logan's deposition start time to 10:00 a.m. and removing Joe Stohr (a Washington State Department of Ecology employee) from the February 19 schedule. An attached calendar lists numerous depositions scheduled between January 28 and February 23, 2002, with witnesses deposed alternately at Foster Pepper and Helsell Fetterman offices.

Reply brief filed by Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) with the Pollution Control Hearings Board (PCHB), PCHB No. 01-160, in support of their Request for Certificate of Appealability and Application for Direct Review by the Court of Appeals. Filed January 30, 2002. Argues under RCW 34.05.518(3)(b) that detrimental delay, fundamental