TagThird Runway(1098)

This 2002 legal document is a supplemental response filed by the Airport Communities Coalition (ACC) in a Pollution Control Hearings Board case against the Washington State Department of Ecology and the Port of Seattle, related to the expansion of Seattle-Tacoma International Airport. It lists technical documents and expert references relied upon by ACC's witnesses, covering topics such as hydraulics, biology, and geotechnical engineering related to the proposed third runway project. The filing also summarizes the prior trial testimony experience of expert witnesses retained by the ACC.

A February 2002 letter from Marten Brown attorneys transmits a CD-ROM of data files and related emails from Pacific Groundwater Group (PGG) to opposing counsel in the case ACC v. Port of Seattle. The materials include technical data and correspondence relied upon by expert Charles Ellingson and PGG in forming their opinions and conclusions. Supporting emails from October 2001 detail groundwater inflow and surface runoff modeling data exchanged between consultants Joe Brascher and PGG.

This document, labeled Exhibit E, contains photographs taken on January 31, 2002 of the Vacca Farm site, showing various land features including areas designated as Prior Converted Cropland, farmed wetlands, and Wetland A1. The photos document the site's vegetation and water features, including a close-up of wetland plants and a view of Miller Creek looking west across Wetland A1. The images appear to be part of an environmental or land-use assessment record related to the Vacca Farm property near Des Moines Way.

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 letter from Northwest Hydraulic Consultants to the U.S. Army Corps of Engineers challenges the Port of Seattle's December 2001 Low Streamflow Analysis related to Sea-Tac Airport's third runway development. The letter identifies critical flaws in hydrologic modeling of Miller, Walker, and Des Moines Creeks, including double-counting of groundwater discharges, flawed seepage modeling methodology, and failure to account for construction impacts on stream low flows. The consultants argue these errors cause the Port to substantially underestimate the project's negative impacts on local stream flows.

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.