TagPollution Control Hearings Board(1532)

Pre-filed testimony of Dr. Patrick C. Lucia, Ph.D., submitted on behalf of appellant Airport Communities Coalition (ACC) in PCHB No. 01-160, ACC & CASE v. Dept. of Ecology & Port of Seattle, dated February 27, 2002. Filed with the Environmental Hearings Office as Supplemental Binder #1 of 1, AR 015511-015513. Case involves Sea-Tac Airport expansion

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.

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

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

This February 2002 draft document from King County Department of Natural Resources presents technical review comments on the Port of Seattle's December 2001 Low Streamflow Analysis and Summer Low Flow Impact Offset Facility Proposal. The review identifies several deficiencies in the hydrologic modeling for Walker Creek and Miller Creek, including inconsistencies in impervious area calculations, questionable vault-filling timelines, and concerns about the accuracy of observed streamflow data used for calibration. King County recommends additional refinements before approving the revised impact numbers, and suggests that Ecology and the Port establish a formal compliance oversight process.

King County Department of Natural Resources draft review comments (AR034844-034846) on the Port Of Seattle / Parametrix Inc. December 2001 Low Streamflow Analysis – Summer Low Flow Impact Offset Facility Proposal. Review evaluates HSPF hydrologic modeling, impact assessment, and conceptual design of low-flow offset facilities for Miller Creek and Walker Creek against Washington State Department

Pre-filed testimony of Dyanne Sheldon, environmental scientist and wetland ecologist, submitted on behalf of appellant Airport Communities Coalition (ACC) in PCHB No. 01-160, ACC & CASE v. Dept. of Ecology & Port of Seattle, dated February 22, 2002. Testimony addresses discrepancies in Ecology’s regulatory authority over wetlands, restoration/creation credits, wetland function assessment, 401 permit conditions,

Pre-filed written testimony of Dr. John Strand, Ph.D. (Principal Biologist, Columbia Biological Assessments; Adjunct Professor, Washington State University Tri-Cities), submitted on behalf of Appellant Airport Communities Coalition (ACC) in PCHB No. 01-160, ACC & CASE v. Dept. of Ecology & Port of Seattle, dated February 22, 2002. Strand’s testimony covers ecological risk assessment of stormwater