TagPollution Control Hearings Board(1532)

Draft memorandum dated January 17, 2002 from Hart Crowser engineers Doug Lindquist, Reda Mikhail, and Michael Bailey to Jim Thomson (HNTB Corporation), project number 4978-40, regarding FLAC (finite difference model) seismic analysis of three proposed mechanically stabilized earth (MSE) retaining walls for the Third Runway project at Seattle-Tacoma International Airport. Analyses cover four wall sections

Declaration by Michael P. Witek filed in Pollution Control Hearings Board (PCHB) Case No. 01-160, Airport Communities Coalition (ACC) v. State of Washington Department of Ecology and Port of Seattle, in support of ACC’s response to motions to compel and limit entry. Document lists Exhibits A through S, including ACC’s November 26, 2001 Request for

Port Of Seattle legal brief filed with the Pollution Control Hearings Board (PCHB No. 01-160) opposing Airport Communities Coalition (ACC) motion to compel inspection of Port property. Filed by Foster Pepper & Shefelman PLLC, received January 18, 2002. Argues ACC’s demand for unlimited site visit under CR 34(a) constitutes impermissible fishing expedition, citing Belcher v.

Summary statement for deposition publication submitted pursuant to Order Granting Appellant’s Motion to Publish Depositions of Ecology Managers and CR 30(b)(6) Designated Witnesses, dated March 19, 2002, in ACC & CASE v. Dept. of Ecology & Port of Seattle, PCHB No. 01-160. Deponent Gordon White, who signed the 401 certifications for the Department of Ecology,

ACC (Airport Communities Coalition) and CASE (Citizens Against Sea-Tac Expansion) application filed in Thurston County Superior Court (Case No. 01-2-02386-9) for direct review by Washington Court of Appeals, Division II, of the Pollution Control Hearings Board (PCHB No. 01-160) ‘Order Granting Motion to Stay the Effectiveness of Section 401 Certification’ issued December 17, 2001. Also

Port Of Seattle motion to dismiss under Civil Rule 12(b)(6) filed in Thurston County Superior Court (Case No. 02-2-00029-8) against petitioners Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE). Seeks dismissal of ACC/CASE petition for review of Pollution Control Hearings Board (PCHB) orders related to the Section 401 Water Quality Certification issued by

Summary Statement for Deposition Publication submitted by ACC and CASE in ACC & CASE v. Dept. of Ecology & Port of Seattle, PCHB No. 01-160, pursuant to Order Granting Appellant’s Motion to Publish Depositions of Ecology Managers and CR 30(b)(6) Designated Witnesses dated March 19, 2002. Deponent Kevin Fitzpatrick, Section Manager of the Water Quality

CASE (Citizens Against Sea-Tac Expansion) response brief filed January 16, 2002 in PCHB No. 01-160, concurring with ACC’s (Airport Communities Coalition) Motion for Summary Judgment regarding the absence of a water right for the Third Runway Section 401 Certification. The brief argues Port Of Seattle must obtain a water right to implement low streamflow conditions,

Letter dated January 15, 2002 from Peter J. Eglick of Helsell Fetterman LLP to Hon. Kaleen Cottingham, Presiding Officer of the Pollution Control Hearings Board, in PCHB No. 01-160, ACC v. Dept. of Ecology and Port Of Seattle. ACC opposes Port Of Seattle’s emergency request for status conference, arguing it is premature pending ACC’s response

This document contains interrogatories and responses from a Pollution Control Hearings Board case (PCHB No. 01-160) in which the Airport Communities Coalition (representing cities near Sea-Tac Airport, including Burien) appealed against the State of Washington Department of Ecology and the Port of Seattle regarding a 401 Water Quality Certification for the Third Runway Project. It includes lists of expert witnesses and their prior testimony histories covering topics such as hydrology, stormwater, and environmental impact, as well as objections to broad document production requests related to the Third Runway Project.