TagThird Runway(1084)

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.

A January 2002 technical letter from Northwest Hydraulic Consultants challenges the Port of Seattle's December 2001 Low Streamflow Analysis for SeaTac Airport, identifying serious modeling errors that led to underestimated impacts on Miller, Walker, and Des Moines Creeks. Key flaws include double-counting of groundwater discharges in the Miller Creek model, inconsistent methodology for assessing embankment seepage, and failure to account for updated construction methods. The letter was submitted to the U.S. Army Corps of Engineers on behalf of the Airport Communities Coalition.

Airport Communities Coalition (ACC) reply brief filed January 29, 2002 in PCHB No. 01-160 before the Pollution Control Hearings Board (PCHB), State of Washington, supporting ACC’s Motion for Summary Judgment on the absence of a water right for the Third Runway Section 401 Water Quality Certification (#1996-4-02325). ACC argues the Port Of Seattle’s Low Flow

Two photographs taken by P. Willing on January 28, 2002, document an absorbent boom placed in a stream below the SDS1 outfall, a pollution-control measure used to contain contaminants. The second photo highlights turbid (murky) effluent visible in the stream, indicating water quality concerns at the site. These images appear to be part of an environmental monitoring or spill-response record associated with drainage infrastructure near Sea-Tac Airport.

This exhibit, part of K.M. Leytham's pre-filed testimony in PCHB No. 01-160, shows photographs taken on January 28, 2002, documenting standing water on top of a fill embankment near South 160th Street. The images provide visual evidence of water pooling conditions on the embankment surface, likely related to construction or environmental concerns associated with Sea-Tac Airport development. This material was submitted as part of a formal hearing record before the Pollution Control Hearings Board.

This exhibit, part of K.M. Leytham's pre-filed testimony (PCHB No. 01-160), shows a photograph taken on January 28, 2002, of an exposed fill embankment face near South 160th Street where a slope failure occurred. The image, approximately 4 feet high by 3 feet wide, reveals distinct layering and a lack of uniformity in the fill material. This evidence was submitted in connection with proceedings related to Sea-Tac Airport development and its surrounding infrastructure impacts.

Letter dated January 23, 2002 from attorney Michael P. Witek of Helsell Fetterman to Presiding Officer Kaleen Cottingham of the Pollution Control Hearings Board (PCHB) in Airport Communities Coalition v. Department of Ecology and Port of Seattle, No. 01-160. Transmits two enclosures inadvertently omitted from Exhibit D to the Second Declaration of Michael P. Witek

Washington State Department of Ecology memorandum opposing Airport Communities Coalition (ACC) application for Certificate of Appealability of the Pollution Control Hearings Board (PCHB) Stay Order in PCHB No. 01-160. Ecology argues the Board’s stay of the § 401 Certification for the Third Runway Project (Port of Seattle) is not a ‘final decision’ under RCW 34.05.518

Internal memo from Ching-Pi Wang to Ann Kenny (cc: Jeannie Summerhays, Steve Alexander), dated January 23, 2002, reviewing the Port of Seattle’s Embankment Fill Monitoring Plan (EFMP) for the Third Runway, 401 Certification Condition E.3. Comments cover requirements for logic tree flow diagrams for tiered sampling and staged screening (groundwater, seepage), statistical methods for baseline

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