TagThird Runway(1084)

Second declaration of Dr. Patrick Lucia filed by Airport Communities Coalition (ACC) in support of motion for stay before the Pollution Control Hearings Board (PCHB), case nos. 01-133 and 01-160, opposing Section 401 Certification No. 1996-4-02325 (Amended-1) and CZMA concurrency statement issued by Washington Department of Ecology for Port Of Seattle Third Runway embankment at

Declaration by Andrea Grad, paralegal at Helsell Fetterman LLP, filed in PCHB Case Nos. 01-133 and 01-160 before the Pollution Control Hearings Board for the State of Washington. Grad attests to her role submitting public disclosure requests to the Washington State Department of Ecology (Northwest Regional Office, Ann Kenny, Sally Perkins) regarding Port of Seattle’s

In this 2001 declaration filed before Washington State's Pollution Control Hearings Board, Dr. Peter Willing challenges the Port of Seattle's commitment to improving stormwater management at Sea-Tac Airport. He argues that the Port's pledge to retrofit its stormwater system 'to the extent practicable' is vague, undefined, and falls short of required water quality standards. Dr. Willing also contends that the four best management practices listed in the Port's Stormwater Master Plan are largely inadequate, as most do not go beyond basic King County water quality requirements.

Second Declaration of James C. Kelley, Ph.D., professional ecologist with Parametrix, Inc., filed in Pollution Control Hearings Board (PCHB) cases No. 01-133 and No. 01-160, Airport Communities Coalition (ACC) v. Department of Ecology and Port Of Seattle. Kelley addresses §401 Certification Condition D1g requiring bi-monthly wetland monitoring downslope of the Third Runway embankment fill at

Declaration by Roger Pearce, attorney at Foster Pepper & Shefelman PLLC representing Port Of Seattle, filed in Pollution Control Hearings Board case No. 01-160, Airport Communities Coalition v. Department of Ecology and Port Of Seattle. Attaches Exhibit A: Washington Department of Ecology §401 Water Quality Certification (Order No. 1996-4-02325 Amended-1) issued September 21, 2001, for

Second Declaration of C. Linn Gould (Risk Assessor, soil scientist, BA geology, MS soil science) filed on behalf of Port Of Seattle opposing Airport Communities Coalition (ACC) Motion for Stay in PCHB No. 01-133. Gould rebuts ACC’s alleged ‘errors’ in the 401 Certification fill criteria for the Third Runway embankment, addressing MTCA Method A cleanup

Department of Ecology sur-reply brief filed before the Pollution Control Hearings Board (PCHB No. 01-133, PCHB No. 01-160) opposing ACC’s motion for a stay of the Amended 401 Certification for the Third Runway embankment project at Sea-Tac Airport. Ecology argues the Amended 401 Certification does not lessen water quality protections under Condition E (acceptable fill

In a 2001 declaration filed with Washington State's Pollution Control Hearings Board, environmental reviewer Tom Luster argues that the state Department of Ecology's water quality certification for the Sea-Tac Airport expansion was based on speculation rather than the legally required 'reasonable assurance' that water quality standards would be met. Luster contends the certification lacks sufficient evidentiary support and that the approved stormwater and low-flow mitigation plans fall far short of adequately protecting state waters. He warns that accepting this certification approach could set a damaging precedent for future water quality reviews of major projects across Washington State.

This 2001 declaration from civil and environmental engineer Dr. Patrick Lucia, filed with Washington's Pollution Control Hearings Board, supports the Airport Communities Coalition's motion to halt construction of a proposed Third Runway at Seattle-Tacoma International Airport. Dr. Lucia, a principal with GeoSyntec Consultants, outlines his review of geotechnical and seismic concerns related to the runway's embankment fill and MSE retaining walls. The declaration references multiple technical letters submitted to the Washington State Department of Ecology and the U.S. Army Corps of Engineers raising safety and environmental questions about the project.

Declaration by Stephen L. M. Hockaday, Professor of Civil and Environmental Engineering at Cal Poly San Luis Obispo and expert in airport/airspace planning, filed in support of Airport Communities Coalition (ACC) Motion for Stay in PCHB Case Nos. 01-133 and 01-160. Opposes Port Of Seattle construction of Third Runway at Sea-Tac Airport pending resolution of