TagPollution Control Hearings Board(1532)

This document contains the Port of Seattle’s first set of interrogatories and requests for production directed to the Airport Communities Coalition (ACC) in PCHB No. 01-160, along with ACC’s answers and objections. The document includes ACC’s responses regarding expert witnesses, including Bill Rozeboom and Malcolm Leytham of Northwest Hydraulic Consultants, and their prior testimony in

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

Draft figure (AR 037219) prepared by Parametrix, Inc. on March 5, 2002, mapping wetlands near Seattle-Tacoma International Airport (northern section) at scale 1:2400. Shows surveyed wetland boundaries, estimated wetland boundaries, other estimated or unverified wetlands outside project area, parcel boundaries, temporary impacts, and permanent impacts. Elevation points marked at 335.5, 335.3, 324.4. Administrative Record number

AR037220 draft wetland map (Figure 2, Southern Map) prepared by Parametrix, Inc., dated March 05, 2002, depicting wetlands near Seattle-Tacoma International Airport. Map shows surveyed wetland boundaries, estimated wetland boundaries, SASA boundaries, temporary and permanent impact boundaries, and wetlands outside project area at scale 1:2400. Includes elevation data points and wetland delineation markers across the

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

Letter dated March 4, 2002 from Peter Eglick of Helsell Fetterman LLP to Presiding Officer Kaleen Cottingham of the Pollution Control Hearings Board (PCHB No. 01-160, ACC v. Dept. of Ecology and Port of Seattle) regarding use of a chess clock format during hearing proceedings. Letter argues for a per-side rather than per-party chess clock

Pollution Control Hearings Board (PCHB) Order Denying Motion in Limine in case PCHB 01-160, filed March 4, 2002. Department of Ecology moved to strike pre-filed written direct testimony of Thomas R. Luster submitted by Airport Communities Coalition (ACC), citing WAC 371-08-475(7) prohibiting former department employees from appearing as expert witnesses in proceedings where they took

Motion in limine filed March 4, 2002 by State of Washington Department of Ecology (Ecology) before the Pollution Control Hearings Board (PCHB No. 01-160) seeking to strike pre-filed expert witness testimony of Thomas R. Luster, a former Ecology employee, submitted by Airport Communities Coalition (ACC). Ecology argues WAC 371-08-475(7) prohibits former Ecology employees from appearing

Erratum filed by Washington State Department of Ecology (Ecology) in PCHB No. 01-160, Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) v. State of Washington Department of Ecology and Port Of Seattle. Adds omitted Exhibit No. 240 — Photographs of Vacca Farm and Tyee Golf Course — to Ecology’s Final Witness and Exhibit

Joint Status Report filed February 28, 2002 in PCHB Case No. 01-160, Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) v. Washington Department of Ecology and Port Of Seattle. Appeal of Clean Water Act Section 401 Certifications #1996-4-02325 and #1996-4-02325 (Amended-I) for Third Runway and Related Master Plan Updates. Parties report settlement is