TagThird Runway(1067)

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

This memo from Port of Seattle environmental staff describes chemical testing of rock aggregate imported from Black River Quarry for use in the Third Runway embankment at Sea-Tac Airport. Testing revealed petroleum hydrocarbons (TPH) and elevated copper levels in some samples, traced to contamination from on-site asphalt recycling operations. As a result, the Port restricted material acceptance to newly blasted rock only and halted imports from the quarry in mid-October 2000 pending operational changes and additional testing.

A wetlands scientist named Amanda Azous filed a legal declaration opposing the Port of Seattle's airport expansion project, arguing that filling approximately 2.8 acres of wetlands near Miller Creek would cause serious and irreversible environmental harm. She contends that the Port's mitigation plan—relying on stormwater management, embankment walls, and upland planting—cannot adequately replace the lost wetland functions, particularly the critical water and nutrient flows these wetlands provide to the broader Miller Creek watershed. The declaration was submitted in support of the Airport Communities Coalition's motion to halt the project before the Washington Pollution Control Hearings Board in 2001.

ACC (Airport Communities Coalition) response filed with the Pollution Control Hearings Board (PCHB No. 01-160) opposing Port Of Seattle’s motion to compel production of documents and challenging subpoenas duces tecum served December 10, 2001. ACC argues Port’s discovery requests under CR 26 are overbroad and unduly burdensome, including Request for Production No. 3 demanding ‘all

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

Fourth Declaration of Steven G. Jones, attorney for Respondent Port Of Seattle, filed January 17, 2002 in PCHB No. 01-160 (Airport Communities Coalition v. State of Washington Department of Ecology and Port Of Seattle). Jones describes ACC’s January 10, 2002 Notice of Deposition noting 31 depositions from January 17–31, 2002; Port’s preparation to produce Paul

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

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,

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.

A January 2002 letter from law firm Helsell Fetterman, on behalf of the Airport Communities Coalition, raises concerns with the U.S. Army Corps of Engineers about the Port of Seattle's revised construction plans for the Sea-Tac Third Runway. The Port switched from an in-place ground improvement approach to excavating up to three million cubic yards of material beneath the proposed retaining wall, a major change that critics argue could significantly harm Miller Creek and adjacent wetlands. Attached technical comments from GeoSyntec Consultants also identify deficiencies in the Port's geotechnical report and argue the changes undermine the Port's Clean Water Act Section 404 permit application.